NOTE ON THE PROCESSING OF PERSONAL DATA AND COOKIES ON SOCIAL NETWORKS

We are committed to taking care of your privacy. This Note on the processing of personal data and cookies on social networks (the "Note") sets out what information is collected and how your personal data is processed when you follow or subscribe to our Page on this social network.

 

1. Identity and contact details of the data controllers 

The page dedicated to Hennessy (the "Page") on the Facebook and/or Instagram and/or Twitter and/or YouTube website/application is operated by:

• Jas Hennessy & Co a French company having its registered address at Rue de la Richonne, 16100 Cognac with company number905 620 035 RCS Angoulême (“we”), and
• Meta Platforms Ireland Limited, an Irish company having its registered address at Merrion Road Dublin 4, Ireland, and/or
• Twitter International Unlimited Company, an Irish Company having its registered address at One Cumberland Place, Fenian Street Dublin 2, Ireland, and/or
• Google Ireland Limited, an Irish company having its regitered address at Gordon House, Barrow Street, Dublin 4, Ireland.
  
  (the "Social Network(s)"),

[both of which are independent] data controller(s) for certain processing and joint data controllers for others, under the General Data Protection Regulation ("GDPR") of 27 April 2016.

With regard to the processing of your personal data by the Social Network, we invite you to read the Privacy Policy of the Social Network(s) (here for Facebook, here for Instagram, here for Twitter*, here for YouTube) on its website/application.

     

     2. How is your personal data collected and used?

We collect your personal data directly from you or from the Social Network when you browse the Page and use the services offered or automatically when you access the Page.

We also collect information you provide about other people, for example when you play a game on our Page and wish to invite friends to play as well. We only use this information to respond to your requests and will not send marketing communications to your contacts unless they opt-in to receive communications from us.

 

     3. Basis and purpose of processing your personal data

Why do we process your personal data?	What personal data is processed?	On what legal ground is this data processed?	How long is personal data kept?
To respond to your information request or question on our service via the chat/IM of the Social Network or by comments under a publication on our Page	Username and any other optional information that you choose to share.	Our legitimate interest	Duration of processing then three (3) years after processing.
For customer and prospect relations via social networks and management of our brand image Your data is processed for the purposes of (i) the animation and moderation of our social network pages; and (ii) managing customer relations via social networks, including our brand image (Social listening)	Username and any other optional information that you choose to share via the social networks	Our legitimate interest	(i) Until the removal of your publication, or the deletion of your account on the social network (if this deletion deletes your comments and messages).   (ii) As long as you remain a customer and for a maximum of three (3) years from the last contact with us
To engage you in marketing activities: based on your preference, we may send you information about our offers, news and events (newsletters, invitations and other publications) as well as offers, news and events related to other entities of the Moët Hennessy group.	Username, e-mail address, name, surname, country, age, and any other optional information that you choose to share.	Your consent	Three (3) years or until you unsubscribe from our mailing list
To show you targeted advertisements       To find other people like you within the social media networks	Using the email address you provided us in an encrypted format with information you have supplied to the Social Network   We may use profiling for this purpose however, you will never be subject to a decision based solely on automated processing which produces legal effects or similarly significantly affects you.	Our legitimate interest Your Consent	As long as you have not withdrawn your consent, and for a maximum period of 13 months from the last contact with us
To manage your participation in a competition/game on the Page (participation, draw, sending of the prize)	Username, name, e-mail address, address, and any other optional information that you choose to share.	(i) Performance of a contract (ii) Your Consent	Duration of the competition and one (1) year after the results of the competition
To respond to the exercise of your rights	Any information necessary to respond (including information necessary to verify your identity in case of reasonable doubt) and that you have voluntarily provided to us.	Our compliance with a legal obligation	For the duration necessary to respond in the active database and then for five (5) years (prescription periods) in intermediate storage. Any identification documents provided will be deleted immediately after your identity has been verified.
To compile statistics and get feedback on our brand image and marketing campaigns to improve our products and services	Information provided by the Social Networks: identification data when you create your account on the Social Networks such as, but not limited to, gender, country of residence, age, Socio-biographic data such as professional, education information, your preferences and interests.	Based on our legitimate interest	Duration necessary to achieve the purpose of the profiling or until you exercise your right to object to the processing.
To initiate legal claims and preparing our defense in litigation procedures	Any Information or commercial and/or identification necessary to Initiating legal claims and preparing our defense in litigation procedures	Our legitimate interest	Five (5) years from our last business relationship with you
To comply with applicable laws, subpoenas, court orders, other judicial process, or the requirements of any applicable regulatory authorities	Any information necessary to comply with applicable laws, subpoenas, court orders, other judicial process, or the requirements of any applicable regulatory authorities	Processing is necessary for compliance with our legal obligation	Five (5) years from our last business relationship with you

 

     4. Recipients of your personal data

In accordance with the regulations in force, your personal data may be accessed by our company’s staff and our subcontractors within the strict framework of the purposes that we have presented in this Note.

1. 4.1. Accessibility within our company

In this respect, your personal data is processed by the following departments:

• Our Communication Department to manage your requests and queries;
• Our Marketing Department to all processing related to marketing (customer service, statistical analysis service, Social listening);
• Our DPO if you exercise you rights or ask questions about the processing of your personal data;
• Our Security, Quality, Brand protection and Legal teams to manage fraudulent acts or legal claims if any.
  
  4.2. Accessibility by third party

Certain third parties may have access to your personal data, specifically:

• Our affiliates. Other Moët Hennessy affiliates, for a limited and defined number of internal recipients to provide you with relevant content and services;
• Our marketing providers Our support and marketing providers (customer service, statistical analysis service, Social listening);
• Our subcontractors, processors and service providers acting for technical and logistical reasons (website hosting, technical service providers responsible for sending e-mails and newsletters, anti-spam and anti-bot services, etc.).
• Authorities. Any authorities, courts or other authorised third parties, where the disclosure of personal data is required by law, regulation or court order, or where such disclosure is necessary for the protection and defense of our rights.
• Investors. We may share some of your personal data if another company acquires our company, business, or assets. That company will process the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Note.

We have signed strict contracts with our subcontractors, in compliance with Article 28 of the GDPR, notably specifying the security objectives to be achieved, to protect your data from unlawful disclosure, use, modification and destruction.

 

     5. Data transfers

For certain data processing, we transfer personal data to countries outside the European Economic Area ("EEA"), including countries that have different data protection standards to those that apply in the EEA. When personal data is transferred outside the EEA, we take all necessary precautions, alternately or cumulatively: (i) ensure that the European Commission has taken an adequacy decision regarding the country of destination (ii) that standard contractual clauses adopted by the European Commission, or the supervisory authority have been signed with the recipient.

 A copy of extracts of these applicable safeguards can be obtained on request (by contacting us as set out below -Section “Your rights”). If you have any questions about transfers of personal data outside the European Economic Area, you can contact us at the address set out below (section "Data Protection Officer (DPO) contact details").

 

     6. Data retention

Your personal data is kept for as long as necessary for the purpose for which it was collected and will be destroyed at the end of this period. The retention periods are listed in the table above.

 

     7. Minors

Access to the Social Network is governed by the Social Network’s Terms and Conditions and subject to users’ age. Users must be legally entitled to drink and/or purchase in their place of residence to access the Page. As such, we do not intentionally collect any personal data from persons under the legal drinking and/or purchasing age according to the legislation in force in their place of residence, unless it is legally required or authorized.

You must be of legal drinking and/or purchasing age according to applicable legislation in your place of residence to make purchase on the Page and by doing so, you warrant that you are of the required age and are fully capable of entering into and being legally bound by such transactions.

However, if you believe that we may process personal data of persons under the legal drinking and/or purchasing age, please let us know. 

 

     8. Your rights

               8.1. Access, rectification, and portability (art. 15, 16 and 20 of the GPDR)

You have the right to access your personal data. You may also request correction of your personal data should it be inaccurate. Depending on the purpose of processing, you also have the right to have incomplete personal data completed.

In some cases, and to the extent provided for by the GDPR, you may exercise your right to data portability which allows you to retrieve the personal data that you provided to us in a structured and machine-readable form.

1.  8.2. Right to request erasure of your data and to restrict processing of your data (art. 17 of the GDPR)

You may request erasure of your personal data if:

• You believe that our processing of your personal data is no longer needed for the purposes described in this Note,
• You believe that the processing is unlawful, or you contest the accuracy of the data we process about you,
• You withdraw your consent to the processing of your data.

Alternatively, to the extent provided for by law, you may request restriction of the processing of your data.

Please note that despite the exercise of your right to erasure, or processing restriction, we will retain some of your personal data when the law requires us to do so, or if such retention is necessary to protect and defend our rights.

1. 8.3. Right to withdraw your consent

When the processing of your personal data is based on your consent, you may withdraw your consent at any time without justification. Withdrawing your consent will not affect the lawfulness of any processing already carried out.

1. 8.4. Right to object to processing based on legitimate interests (art. 21 of the GDPR)

You have a right to object to the processing of your personal data when such processing is based on our legitimate interest.

Please note that despite the exercise of your right to object to processing, we may reject your request:

• if such processing is required by law;
• if such processing is necessary to protect and defend our rights;
•  if our legitimate interests override your interests;
• if your request is manifestly unfounded or excessive.

1. 8.5. Right to establish instructions for the management of your Personal Data after your death (Art. 85 of the French Law n° 78-17 of January 6, 1978)

You may also establish instructions regarding the retention, erasure and disclosure of your personal data upon your death and modify these directives at any point in time.

1. 8.6. Procedure to exercise your Data protection rights

In order to respond to your request, we may ask you to provide proof of identity. We may also ask you to provide additional information or proof. We will endeavour to respond to your request as soon as possible.

These rights can be exercised at any time by sending a letter or email to the following addresses

"Data Protection Officer (DPO)", 38 rue de Sèvres, 75007 PARIS or by email : contactdpo@moethennessy.com.

You also have to the right to complain about the way we collect and process your Data to :

• the French Data Protection Authority (“CNIL”), 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, or
• any other data protection authority. The list of authorities is available by clicking here.

For any request for rights concerning your data processed by the Social Network and for which we are not the Data Controller, please contact the Social Network directly.

 

     9. United States Residents

If you reside in the United States and have questions about your data, please refer to the Privacy Policy located on the U.S. portion of the brand website.

 

     10. Amendments

Our commitment to preserving your privacy will not change but our processing may evolve. We may update this Note from time-to-time by posting a new version on our Page. The effective date of each version is identified at the top of this document.