We take the protection of your privacy very seriously, and when you use our websites, mobile applications, social media pages, online forms, or in any other way connect electronically with us (collectively, “our Digital Services”), we respect your right to privacy. In order to better inform you about how we gather, keep, use, and process the Personal Data you share with us through our Digital Services, we have prepared this Privacy Policy.

Please take the time to carefully read this privacy statement as it contains critical information about who we are, what we do, how we use your Personal Data, and why. It also outlines your rights regarding your personal data and how to get in touch with us or the appropriate regulatory authorities if you have complaints.

We gather, utilise, and are accountable for some of your personal data. When we do so, we are held accountable as the “controller” of the Personal Data for the purposes of the General Data Protection Regulation, which is enforced across the European Union (including in the United Kingdom).

Please review this privacy statement before using our digital services. Please refrain from using our digital services if you disagree with either our cookies policy or our privacy statement.

When processing your Personal Data under the circumstances outlined in this Privacy Policy, including when you submit Personal Data to this website or another website that links to this privacy policy, like a microsite we use to run a contest or competition, we are the data controller (the “Website”).

1. What Personal Data do we collect about you and how?

Personal Data means any information that can be used to personally identify you or contact you online or elsewhere.

We may collect and use the following Personal Data about you:

• your name and contact information, including postal address, email address and telephone numbers and, if applicable, company details
• information to enable us to check and verify your identity, e.g. your date of birth
• your gender information, if you choose to give this to us
• location data
• your professional online presence, e.g. LinkedIn profile
• your contact history, purchase history and saved items
• information from accounts you link to us, e.g. Facebook
• information about how you use our website, IT, communication and other systems
• your responses to surveys, competitions and promotions
• your IP address and your mobile/tablet/device ID
• information provided to us for your attendance at Heritage Centres and distilleries, meetings and events, including which Heritage Centres and distilleries, meetings and events you attend as well as information about access or dietary requirements

This Personal Data is required to provide products and Digital Services to you. If you do not provide Personal Data we ask for, it may delay or prevent us from providing products or services to you.

2. How your Personal Data is collected

Personal Data we collect from you:

We collect most of this Personal Data directly from you—in person, by telephone, text or email and/or via our website and apps. This usually occurs when you take part in one of our promotional activities or subscribe to one of our Digital Services, for example:

• Registration or sign-up online: e.g. mobile app, websites, social media or subscribing to a newsletter specific to our Digital Services or creating an account to be a member of a club;
• ‘Send to a friend’ marketing communications;
• Sweepstake and contest;
• Joining a loyalty program or subscribing to a newsletter;
• Buying products or services online;
• When doing e-commerce on certain of our websites;
• Using a QR Code displayed on products;
• Events (invitation form or online forms on tablets filled out by our representatives with your input);
• Booking a tour or attending a distillery or Heritage Centre;
• Brand websites;
• Training;
• Tastings;
• Feedback, questions, enquiries, surveys or comments through ‘Contact us’;
• Any other request that requires the submission of Personal Data.

The type and amount of information we collect for the features listed above will vary and depends on the activity.

Personal Data we collect from other sources

We may also collect information:

• from publicly accessible sources, e.g. the Electoral Roll or the Post Office’s National Change of Address Database;
• directly from a third party, e.g.: “Send to a friend” marketing communications or a third party sign-up form from one of our partners;
• from credit reference agencies;
• from customer due diligence providers;
• from a third party with your consent, e.g. your bank or building society
• from cookies on our website (see below – How and why do we use tracking technologies?)

The purpose of our use of tracking technology

These tracking technologies help us tailor our Digital Services to your personal needs:

• Where required by relevant legislation, our Digital Services may use cookies and other similar technologies, subject to your consent (“cookies”).
• Every time you connect to the Internet, a network uses your computer’s IP address to identify it. Internet Protocol (IP) addresses may be recorded by us in order to, among other things: I troubleshoot technical problems; (ii) maintain website safety and security; (iii) restrict access to our digital services to certain users; (iv) track location and behaviour; analyse, segment, and target advertising to customers; and (v) better understand how our digital services are used, for example using Google Analytics;
• Your mobile/tablet device ID may be gathered and used by us (or a third party acting on our behalf) to give you a more specialised browsing experience, to notify you of nearby events or promotions, and for reporting and analysis;
• In order to record activity and compile statistics regarding surfing patterns, we (or a third party acting on our behalf) may gather information in the form of log files. These entries are generated anonymously and assist us in gathering information such as I your operating system and web browser type, (ii) details about your session (such as the URL you came from, the date and time you visited our Digital Services, and which pages you have viewed and for how long), and (iii) other comparable navigational or click-stream data. In order to continually enhance and personalise the online services we provide you, we also use log file data for internal marketing and demographic research.
• Log files are not linked to any personally identifying information and are solely used internally.

3.  How long do we keep your Personal Data?

We might keep the Personal Data in our databases that you give to us via our Digital Services. Your Personal Data won’t be kept by us any longer than is required for the goals outlined in this policy. For various forms of personal data, different retention times are required.

We keep your Personal Data for as long as your account is active, as long as we have a contract with you, or for however long is necessary to give you the products or services you’ve requested, to respond to your questions or problems, to demonstrate that we treated you fairly, to maintain records as required by law, to improve our services, or to introduce new ones.

We might also need to keep your Personal Data in order to fulfil our legal and regulatory requirements, settle disputes, uphold agreements, and serve similar records-keeping functions.
After you cease using our services or our digital services, we might continue to keep your personal data for a reasonable amount of time. Your Personal Data will be removed from all Pernod Ricard Group systems after this time frame.
According to your rights outlined in Article 9 below, if you request that we erase your information, we will keep the bare minimum of information on you on a suppression list as a record of your request and to prevent sending you unsolicited materials in the future.

4. How do we keep your Personal Data secure?

We take the necessary security precautions to guard against unauthorised access, use, or loss of your Personal Data. These include I storing your Personal Data in secure operating environments that are not accessible to the general public and that are only available to authorised employees, our agents, and contractors; and (ii) requiring registration before allowing access to any Personal Data we store about registered users.

Additionally, we have protocols in place to handle any suspected breach of data security. If we are required by law to do so, we shall alert you and any relevant regulator of a suspected data security breach.

5. Rights you have

You have the following rights, which you can exercise free of charge:

You can ask us to:

• provide a copy of your personal data (the right of access)
• correct any mistakes in your personal data
• delete your personal data—in certain situations
• restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
• provide you with a copy of the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

You can object:

• at any time to your personal data being processed for direct marketing including profiling;
• in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests

If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time. We hope that we can resolve any query or concern you may raise about our use of your information. You also have the right to complain to the supervisory authority in the European Union where you work, normally live or where any alleged infringement of data protection laws occurred.

If you would like to exercise your right to object to direct marketing please email us on Info@blackshortindia.com  

If you would like to exercise any of your other rights, please email us on Blackshortindia@gmail.com Your objection (or withdrawal of consent) may mean we cannot provide the products or services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your Personal Data if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.

If you participated in a program that involved a third party and you agreed to receive communications from that third party, you will need to contact them directly to opt-out. This process should be outlined in the third party’s privacy policy.

6. How do we handle the information on children?

We do not intentionally collect Personal Data from Minors since our Digital Services are not designed for minors (“Minor”). To register for an account and take part in activities and transactions on our Digital Services, you must be at least eighteen years old (or, if the legal drinking age in your country is higher, you must be at least that age).

You certify that you are at least eighteen years old (or, if the legal drinking age in your jurisdiction is higher, that you are at least of legal drinking age) and that you are fully able to enter into, comply with, and be legally bound by our any terms of use made available to you, including this Privacy Policy, by creating an account or by participating in activities or transactions. We will remove a Minor’s Personal Data if we are informed or find out that they have provided it to us through our Digital Services.

7. How can you contact us?

 If you have any questions, complaints, or comments about this Privacy Policy or our how we collect and manage your Personal Data, please contact us either:

• By writing to: Data Privacy Champion, Black Short India Limited, Unit no. 406, MGF metropolis mall Gurgaon-122002, Haryana. or sending an email to: Info@blackshortindia.com 
• With our Toll Free Number: 1800 419 6567. 

– For Software Data:

Location:  For employee/partner – This permission enables us to verify your exact location information and locate your present location to align you at the preferred region when you begin or engage in a delivery and track the progress and completion of your work.

 This feature/permission helps in computing the right distance pay.