PRIVACY POLICY OF THE My e/LOUIS
Last update: May 2024
INTRODUCTION
Our Privacy Policy describes how we collect, use and protect personal data (i.e. any information relating to an identified or identifiable person, referred to as a "Data Subject") on the website and in the context of the digital services provided by E. REMY MARTIN & C° (collectively, the "Services"). This Policy and the Cookies Policy (Section 6) cover all users, including those who use the website and the Services without being registered or subscribing to a specific service (hereinafter collectively, the "Users").
This website is operated by the company E. REMY MARTIN & C°, located at 20 rue de la Société Vinicole, 16100 Cognac, France, hereinafter designated by its trademark LOUIS XIII, which is an entity of the Rémy Cointreau Group.
LOUIS XIII acts as a data controller with regard to the applicable legislation and regulations on data protection, in particular: (i) the UK General Data Protection Regulation and the Data Protection Act 2018; (ii) the Privacy and Electronic Communications Regulations 2003 (which are derived from the Privacy and Electronic Communications Directive 2002/58/EC); (iii) the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, hereinafter the "GDPR"), which entered into force on 25 May 2018 ; and (iv) all applicable laws, statutes, statutory instruments, orders, regulations and codes of practice (whether or not having the force of law) in force from time to time and which apply to the processing of your personal data- hereinafter collectively referred to as the "Applicable Laws". However, when you make a purchase on our website, the entity located in the country of delivery of your product or indicated in the General Terms and Conditions of Sale, acts as the data controller for the purposes of managing, tracking and shipping your order.
1. INFORMATION WE COLLECT
Depending on the Services offered by the website you are using, and the choices and settings you have made on your device (in particular with respect to cookies), the personal data concerning you (your "Personal Data") that we collect and process mainly includes:
Third Party Services: The Services may be associated with websites published by third party companies not affiliated with LOUIS XIII, including:
The personal data we necessarily need for the purposes described below are indicated by an asterisk on the various pages of the website. Without this mandatory data, we will not be able to respond to your requests and/or provide you with the requested services. The other personal data are purely optional and are intended to get to know you better and to offer you better services.
2. PURPOSES OF PROCESSING
We use and process Personal Data about you for the purposes described below:
a) Checking you meet the minimum legal age requirements for the products or services requested;
b) To supply the products or services requested; to manage and process your order (including the commercial transaction, its follow-up and after-sales service);
c) To respond to your requests, comments and complaints;
d) To understand your interests and how you use our products and services, to personalize your experience and to tailor our marketing activities to your needs and preferences;
e) To carry out analysis of statistics concerning our marketing campaigns and the activity of the website;
f) To send commercial communications about products and services that may be of interest to you, provided that you have given your prior consent or ordered a similar product or service from the website;
g) To manage the security of the website and protect from fraud, theft or any other illegal activity that may affect our services;
h) To improve our website and provide you with technical support;
i) To comply with legal obligations (e.g. keeping transaction records and other business records is necessary to meet legal and administrative requirements, the needs of our insurers or for audit purposes).
The purposes of processing mentioned above at (a) and (i) are based on LOUIS XIII’s compliance with the applicable legal and regulatory obligations to which it is subject;
The processing purposes mentioned above from (b) to (h) are based on the legitimate interest of the Data Controller and are necessary to operate the website and respond to User requests.
For some of the cookies that may be used (see Section 6), the processing is based on the consent of the Data Subjects;
We undertake not to process your Personal Data in a way that would defeat the purpose for which it was collected and to collect only the Personal Data that is necessary for the purposes stated above. We will seek your specific consent before we process your Personal Data for any new purpose.
3. YOUR RIGHTS
In accordance with the Applicable Law, you have the rights of access, rectification, erasure, restriction of processing, objection, portability of your personal data we hold about you to the extent applicable, unless we can demonstrate a compelling legitimate reason for retaining your Personal Data.
Right of access – You have the right to ask us for copies of your personal information.
Right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.
Right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
When the Processing is based on your consent, you have the right to withdraw your consent at any time.
You can ask us to stop sending you information regarding our offers, news and events at any time by using the unsubscribe link in every email we send you.
In addition, you have the right to lodge a complaint with your local data protection authority.
You can exercise your rights by using your account settings or by writing to us at: privacy@remy-cointreau.com.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
4. RECIPIENTS OF THE DATA
Your Personal Data will not be transferred to or made accessible by third parties, except in the following cases:
5. DATA TRANSFER AND SECURITY MEASURES
We may transfer your personal data to another country outside of the UK and European Union. Where we transfer your data to such third countries (e.g. for transaction processing and fraud prevention purposes), we ensure an adequate level of protection for the transferred personal data by entering into data transfer agreements with the recipients of your personal data based on the European Commission's standard contractual clauses (“SCCs”) or other valid transfer mechanisms and we carry out, in accordance with the European Court of Justice's decision of 16 July 2020 "Schrems II" (Case C 311-18) and with the guidance of the European Data Protection Board, a risk assessment of the transferred data. Please contact us if you would like to receive a copy of the safeguards in place to secure data transfers outside the European Economic Area.
Data is processed both manually and electronically and is protected by appropriate security measures. We will provide an adequate level of protection for your data and ensure that appropriate technical and organisational security measures are in place to protect your data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and against all other forms of unlawful processing.
The same level of protection is contractually imposed by LOUIS XIII on all its subcontractors. Any employee of LOUIS XIII who, in the course of his or her duties, may have access to your personal data undertakes to hold it in strict confidence. However, as the Internet is not completely secure, we cannot guarantee that your personal information stored or sent will be completely safe. We encourage you to exercise caution when using the Internet to access our website.
6. COOKIES
This section on cookies explains how we use cookies to provide, protect and improve our website.Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Strictly Necessary Cookies
We use essential cookies to ensure our website functions as intended for users and to keep it secure. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended. These cookies do not store any personally identifiable information.
7. DATA RETENTION
Your Data will be retained, in a form that allows you to be identified, only for as long as is necessary for the purposes described in this Privacy Policy, or for as long as is necessary to comply with any legal obligation. Please note that the length of time required by law to retain data may vary from country to country.
For example:
8. PROTECTION OF CHILDREN
The LOUIS XIII website is not intended for Internet users under the legal drinking age and LOUIS XIII does not collects personal data from individuals under the legal drinking age. If you are under the legal drinking age, which varies by country, you are prohibited from using our Services. If you are the parent or guardian of a child about whom you believe we have collected information, please contact us.
9. CONTACT US
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact our Data Protection Officer by sending an email to privacy@remy-cointreau.com.
LOUIS XIII may change or update this Privacy Policy at any time, so please review it regularly. We will provide further notice of changes or updates as appropriate.
If you are a US resident you can contact either by e-mail at Privacy@remy-cointreau.com, by mail at RC USA – DPO – 3 Times Square, #20 Fl, 10036 – NYC – NY – USA, or by using the web form available at this address.
10. U.S. STATE PRIVACY RIGHTS
You may have certain rights with respect to Personal Information under U.S. State Privacy Laws. Under the California Privacy Rights Act (CPRA) and/or the Virginia Consumer Data Protection Act (VCDPA), these rights have been extended to Personal Information collected, used, and shared between businesses (B2B); however, these rights have not been extended in any other state. As a result, these rights are limited to consumers, not applicable to individuals in their capacity as employees of businesses that are exchanging personal information between one another. For purposes of this subsection, the terms “consumer”, “Personal Information”, “categories of Personal Information”, “business purpose”, “third party”, “sell”, and “share” have the meanings ascribed to them respectively in the applicable state law. To the extent provided under applicable laws, you have the right to:
Access and Disclosure. You have the right to send us a request, up to two times every 12 months, that we disclose to you the categories of Personal Information we collected about you, the categories of sources from which we collected your Personal Information, the business or commercial purposes for collecting, selling, or sharing your Personal Information, the categories of third parties to whom we have shared your Personal Information, and the specific pieces of Personal Information we have collected about you, the categories of Personal Information we sold or disclosed. You also have the right to request a portable copy of your Personal Information.
Correction and Deletion. You have the right to send us a request to correct or delete Personal Information we have about you, subject to certain exceptions allowed under applicable law.
Do Not Sell or Share My Personal Information (Opt-out of Targeted Advertising). Under certain U.S. State Privacy Laws, you may be able to request that we not sell, or share for targeted behavioural advertising, your Personal Information. We may sell, share, and use for targeted advertising the following categories of Personal Information to companies that provide marketing and advertising services to us, as well as advertisers that place advertisements on our Services: Device, Internet, and Network Activity Information, IP Address, cookie IDs and Device ID, and General Location Information. This information is shared to help us understand who our users are, so that we can sell ads on the Services and advertise and market the Services to new users. You can request that we not sell or share your Personal Information by sending an email with your request.
Opt-out Preference Signals; Global Privacy Control. You have the right to send us a request to opt-out of the selling and sharing of Personal Information through an opt-out preference signal. If you use an opt-out preference signal, we will apply the opt-out to the device or browser which sends the opt-out preference signal and to any consumer profile associated with that browser or device, including pseudonymous profiles. You can use an opt-out preference signal by downloading a supported browser or extension. If known, we will also treat the opt-out preference signal as a valid request to opt-out of sale/sharing for the user. Some browsers allow you to send a Do Not Track signal, an older request to block tracking of users by third parties. We may not honor these older signals.
Sensitive Personal Information. You have the right to send us a request to limit the use of your Sensitive Personal Information to those uses that are necessary to perform the services reasonably expected by an average person and to certain other permitted business purposes. These business purposes include helping to perform services reasonably expected by users of this Services who have requested such services, ensuring security and integrity (to the extent the use of the information is reasonably necessary and proportionate for these purposes), ensuring physical safety of natural persons (to the extent the use of the information is reasonably necessary and proportionate for these purposes), short-term, transient use (subject to certain conditions), performing certain services, and engaging in certain activities related to quality or safety of our services or products. We do not collect or process Sensitive Personal Information for the purpose of inferring characteristics about you.
No Financial Incentives. We do not offer any programs that would be considered a “financial incentive” for sharing your Personal Information under U.S. state privacy laws.