The Privacy Policy of Pernod Ricard (Ningxia)Winemakers Co., Ltd.

Pernod Ricard (Ningxia)Winemakers Co., Ltd. (hereinafter referred to as the “Company” or “we/us”) respects the privacy of each customer. This Privacy Policy (hereinafter referred to as the “Policy”) will enumerate the type of information collected by us, the scope and purpose of our use of the information, the information process and transfer and our protection of the information. The Policy shall apply to all the persons who visit, scan the website or other platform of the Company, or to all the persons who access or use the website or other platform in any manner. The “website of the Company” and “other platform of the Company” referred in this Policy include but not limited to the official website and any other page under the same top level domain, as well as the contents and services provided, communication platform of any public (subscription) number authorized by the Company and all the contents duly authorized by the Company thereof, the Company’s app and services provided and all the contents published thereof, e-commerce operator authorized by the Company and all the services provided and all the contents directly by the Company or duly authorized by the Company thereof, hereinafter collectively referred to as “Any and All Platform of the Company”.

The Policy is based on the relevant industrial guiding principle and standard of China, as well as the relevant local, national and international laws and customs. Relevant industrial guiding principles include principle of responsibility in accord with authority, principle of specific purpose, principle of selective consent, principle of minimum use, principle of openness and transparency, principle of safety assurance and principle of participation.

Using or scanning Any and All Platform of the Company and relevant services provided via computer, cellphone, laptop, console or other equipment (hereinafter referred to as “equipment”), means you have fully and sufficiently read, understood and accepted the Policy and agreed to be binding. If you have any disagreement on any part of the Policy, please do NOT use or scan Any and All Platform of the Company.

We may, from time to time, update the Policy in accordance with the applicable laws, regulations and other requirements. It’s suggested to check the Policy regularly to ensure you have understand the latest binding version of the Policy.

The Policy aims to illustrate the general privacy policy of the Company. Our target is to provide more details to you at the most influential moment to you. Please note such notice during our service.

• 1. Age and Capacity

Any and All Platform of the Company shall be used by the customers on or above the legitimate age of alcohol purchase locally. If you fail to reach the legitimate age of alcohol purchase locally, please do NOT provide your personal information (defined as below). The Company does neither intend to collect any personal information from any person under the legitimate age of alcohol purchase locally, nor promote our products to such person. None of the customer under the legitimate age of alcohol purchase locally is allowed to use Any and All Platform of the Company, yet the relevant services provided thereof. We may collect your date of birth anonymously, in order to ensure our customer above the legitimate age of alcohol purchase locally. Such information will be used to ensure whether you have reached the legitimate age of alcohol purchase locally. After the age check, we will delete the information immediately.

If you have reached the legitimate age of alcohol purchase locally, but without the full capacity of your residence or place where you surf the internet, you have to read the Policy carefully with accompany of your parents or guardian, and use the relevant product or service after their consent. Completion of the register or use the relevant product or service means you have acquired the consent from your parents or guardian.

• 2. Information may be collected by us

We may collect your following information when you visit, scan and use Any and All Platform of the Company,

1. The information you provided, includes your personal information and the shared information provided by you.
2. Personal information. Personal information means any relevant data regarding specific natural person, which will be used independently or collectively with other information to identify certain personnel. We can only collect those information that are permitted and provided by you. We will collect and retain certain personal information, including but not limited to the name, phone number, address and email that you provided when you register, log in or use Any and All Platform of the Company, as well as your purchase and preference information of our products, you GPS data, and the information of your credit card and payment platform.
3. Shared information refers to any information or material you have uploaded through your social media platform, no matter of name, personal introduction, photos, videos, stories, thoughts, comments, creative concept, information or other released materials.

• The information we collected from other parties (including but not limited to your authorized third party, our affiliated company, parent company or business partner). We may use the information that you provided or we collected together with the other information from company channel, transaction or communication, which may including but not limited to interaction information from our online or offline store, direct express, product catalogue, event, or products and applications. We also might use this information collectively with public information or data from third party. We also collect information from gift sender or information of you or gift receiver from your authorized third party. If we combine the information you provided with the information from interaction or third party, such combined information will also be deemed as personal information as long as it remained in a combined condition. To prevent fraud and ensure the security, our affiliated company, parent company and business partner will share with us your information subject to applicable law or your consent.
  • The information collected automatically from you. Through the collection of such information, we may know how to improve our website, E-commerce and relevant service for your need. You hereby agree explicitly, that when you visit, browse or use all the Platform of the Company, we may collect the equipment information, operating information and location information automatically thorough cookies (the detailed description of cookies please refer to Art 4 ) or other methods.
• Equipment Information
  • Equipment or software information, like configuration information of your portable devices, webpage browser or other procedure you use to access our service, IP address (IP address is a number that located to your computer when you are using the Internet, which will not contain any of your personal information. Your IP address will be used to help identify you in certain dialogue and collect macro statistic data) and the version and equipment heading code of the portable equipment.
• Operating Information
  • The information searched or browsed when using our service, for example the search topic you used, the url address of the social media page that you visited, and other information or detail that are visited or required;
    • The information of the APP or other software you have used, or the information showing you have used such APP and software;
    • The information you transacted through our service, like the account you have communicated with, as well as the time, data and period of the communication;
    • The operation of you when you are visiting all Platforms of the Company or using any of our services, as well as relevant information regarding you transaction on the Platforms;
• Location Information
  • The geographic information collected through GPS or WiFi when you using our service through portable devices with orientation function;
    • The real time information which contains your geographic locations, like the district information contained in the account information you provided, shared information uploaded by you or other people which contains the geographic information of your current or previous locations, or the geographic marks contained in the photos shared by you or others;
    • Most portable devices would allow you to turn off the orientation service, we suggest that you consult with relevant distributor or supplier of the portable devices.

If you are unwilling to provide us with the aforementioned information, you may still visit some of the contents of our website, however, you may not be able to enjoy a full benefit of registered member or may be prevented from certain promotional activities or marketing information.

• 3. About Cookies

Cookie is a regular method to record the preference of customers when they use the website, in order to acquire better and more personalization. Such preference information will be stored in the document of your computer hard disk drive. For example, a cookie may record your residential country so that it will not be necessary to request for the same at your each visit.

We also use “Analysis” cookie, it will help us to check and calculate the number of visitors, checking the visitor’s movement on Any and All Platform of the Company, which will help us to improve the work method of Any and All Platform of the Company, such as ensuring the customers to find the contents requested easily.

Our website will use two types of cookies——permanent cookie and session cookie. Permanent cookie will remain into your computer until being deleted by you “manually”, while session cookie will be automatically deleted when you turn to the next website or close the browser.

www.allaboutcookies.org。

More information about cookies, including how to activate the cookie, how to change the setting of the browser and how to find and delete the cookie on hard disk drive, please refer to the Help menu of your browser or visit www.allaboutcookies.org.

• 4. Use of information

We will use your information collected for the following aspects,

1. Providing all the services you used and other services you may be interested into

We will use the personal information provided by you for your requested services and other services you may be interested into.

With your specific consent, we will use the information provided by you to contact you and send information regarding us, our associated companies, parent companies and products, services and promotion of relevant business. Such service is selectable, you may at any time unsubscribe at your own discretion.

• Improvement of the service and product provided

We will use your personal information, also, to improve our promotion, analyzing the use of the website in statistical method, to improve our contents and products provided and, to create the contents, layout of website and items of services in accordance with the customer’s requirements. We believe that such use will improve our website and provide better service to visitors.

• Sending message to third party at your request

If you use our social media, we may send your customized information, material or service of Any and All Platform of the Company to third party in accordance with the information you provided regarding such third party. Kind reminder that we will simply send the information in accordance with your needs, rather than we encourage any third party to drink alcohol. Without specific consent from such third party, we will not send other relevant information to him/her. Please make sure that such third party has reached legitimate age of alcohol purchase locally.

• Use for relevant e-commerce service

If you use the e-commerce service on Any and All Platform of the Company, we may use your personal information to reply to your question on product purchase, record your purchase information to contact you when necessary and other use for completion of your order.

• 5. Use of Integration and Statistic

The Company use record information of the website (including your website browser, operating system, website scanned, etc.) to help us design website, identify the popular special products and other management. We will use the information anonymously to, for example, calculate how many customers have visited Any and All Platform of the Company, how many websites have been visited, etc. We will not use the information to identify the person pointed to. However, if necessary, we will use the website record to help recognize whether there is anyone trying to trespass or break our website. If we are convinced that it’s proved to break the computer safety or violate relevant laws, we will share the website record information with executive departments.

• 6. information sharing

In the absence of your consent, we will not share the personal information of the visitors with any enterprise or individual that is not related to your service. However, you fully understand and agree that, in the following cases, we will share your personal information with the third parties on the premise that the three parties should understand and abide by this policy clearly and protect your personal information to the extent of the policy.

• a. As a member of the Pernod Ricard group, we may use the resources of our affiliated company or parent company when providing services of Any and All Platform of the Company Therefore, we may disclose your personal information to our affiliated company or parent company in the case of local law.
  • b. Any third party that you agree to share information
  • c. When you use some specific services (including but not limited to subscribing our WeChat public account, become a user of our social platform), you agree to provide or share some of the basic information to us, possibly including your username, the city and the picture of your head.
  • d. You can choose to share specific information. In order to use specific functions, you may need to adjust your privacy settings and share more information. You can also choose to share your activities on other platforms, such as Weibo and WeChat. Please read the privacy policies of these platforms, because the activities you publish on these platforms will no longer apply to our privacy policies.
  • e. Publicly shared information may be used for advertising purposes.
  • f. In order to provide a better service to you, we may provide your information to our agents, suppliers, subcontractors, or partners to serve us on behalf of our Any and All Platform of the Company (for example: suppliers that provide services in social media) or to provide you with the services on Any and All Platform of the Company or other in your request, including but not limited to your order information provided to warehousing or logistics companies for the completion of your order, to provide your credit card and payment information to the parties concerned to complete the transaction, to provide your information to our advertising and market suppliers for sending you related information, to share our data with analysts to analyze the usage of websites. and share your personal information with the third party for the purpose of service. However, the above-mentioned persons shall not use the information for other purposes or share or resell such data with any third party that does not co-provide services. At the same time, the range of personal information they could use will be limited to the services related to our company’s service to you.
  • g. In the case of sale, merger, reorganization, conversion of control, transfer of major assets, financing or liquidation, we may transfer, sell or designated transfer to third party the business that includes your personal information.
  • h. Under the requirements of enforcement, the government or the legal department or other third parties that comply with the mandatory provisions of the law, we may share your information with the third party under the premise that we believe it is necessary to comply with the mandatory provisions of the law, or if we are to investigate, protect, or defend our company.

• 7. Third party tracking

We also corporate with companies that represent us putting advertisements on the whole internet with tracking technics.  Those companies may collect interaction information between us, including advertisements. If you want to opt out of the ad technology that is related to the third-party tracking technology related to this website, please click here. Attention, if you do opt out of these third-party tracking techniques, you may still expose to our advertisements on other websites, however, such advertisements are not advertising related to the third party produced by tracking technology.  

• 8. The storage and transfer of information

By providing us with information, you are fully aware, understanding and clearly agreed that, on the premise of complying with local laws and regulations, we may transfer such personal information to other countries or regions, or to deal with personal information in these countries or regions. Our personal information storage, transfer and processing will comply with the relevant provisions of this policy.; you aware, understand, and clearly agree that your personal information will normally be stored in the company’s database, which is distributed all over the world, including the United States and the European Union, and will be transferred according to the business needs of the company. The storage period of the information shall be from the date of collection to the date of receipt and deletion of your request (request under Article 10 of this Policy). No matter where your personal information is stored, the company will take the same data protection standards and use your personal information in the manner and purpose specified in this statement.   

• 9. Information security, risk disclosure and responsibility

Our company promise to protect the safety of your personal information and taking reasonable precautions to prevent your personal information from being lost, misused or changed. We promise to use appropriate physical, electronic and other means and procedures to protect the personal information we collect.

In view of our agency, supplier, subcontractor, or partner, they can see your personal information when providing services to our company. We require them to keep the information confidential and not to use the information in any other way except providing services to our company.

The content of the personal information provided by you will not be evaluated, changed or confirmed. The company’s collection, use and disclosure of your personal information all are the automatic screening of the relevant websites of our company. The company does not review and modify the content of your personal information. Therefore, for the company could provide you with accurate and effective services., we strongly recommend that you ensure the accuracy and authenticity of personal information that you provide.

You need to be clear that, like other companies, we do not fully protect the personal information contained in the communication you have with us. And any information you publish on social media is usually open and unprotected, which may be collected and used by others, leading to involuntary receipt of information from other people. Therefore, we recommend that you do not include any confidential, proprietary or other sensitive personal information in the above exchanges and social media.

Notwithstanding the above agreement, the company does not guarantee that your information is not infringed upon by force majeure or malicious computer programs.

• 10. Request

You have the right to access, correct and delete your data, and you have the right to withdraw your consent and obtain a copy of your personal information. As requested, we will make the best effort to correct and delete your identifiable information from the company and the backstage files of third parties that share your personal information according to the policy terms.

After you requested that our company passively stops providing products or services, we will stop collecting personal information, but we have the right to keep the personal information that has been collected before the stop service and have the right to continue to use information that is treated anonymously.

If you are currently receiving direct marketing of Pernod Ricard, but you do not want it continue to use or provide your information to others for direct marketing, you can exercise your exit option by [issuing a written request / click back link] without paying the cost. To unsubscribe or stop receiving messages, change your settings or follow instructions for e-mail, SMS, notification, or other message types. If you cancel subscribing to any communications about our company, you may still receive communications already in production due to the communication production cycle.

• 11. Third Party Link

Any and All Platform of the Company may contain some links, ads and contents from third party, which fall beyond our control. Please note that we may not have any or have little control or management on such website. Therefore the Policy shall not apply on such website. You are highly suggested to read their privacy policy and terms and conditions when visiting, scanning and using such website.

• 12. Contact

If you have any request for our help (including the request in accordance with the Section 10 hereabove and other inquiry, complain), please contact us via,

Company Name: Pernod Ricard (Ningxia)Winemakers Co., Ltd.

Registered Address: Suit 1501, 168 Hu Bin Road, Huangpu District, Shanghai

Contact Address: Suit 1501, 168 Hu Bin Road, Huangpu District, Shanghai

Zip Code: 750104

Atten: QSE Department

Complained Hotline: 4001171919

Sales Hotline: 40000161619

Email: HLM Servicedesk @pernod-ricard.com

Under most circumstance your request will be replied within 30 days.

• 13. External Dispute Settlement Institution and Contact

Any disputes arising under or connected with this Agreement shall firstly be settled amicably. In case, no amicable settlement can be reached, either party may submit the dispute to the Shanghai International Economic and Trade Arbitration Commission for arbitration in Shanghai pursuant to its arbitration rules. The venue of the arbitration will be held in Shanghai and the award shall be final and binding to both parties.

The contact of Shanghai International Economic and Trade Arbitration Commission please refer to the official website http://www.cietac-sh.org/SHIAC/index.aspx.