MARTELL COGNAC COGNACS MARTELL HOUSE COCKTAILS COGNAC ESSENTIALS H.O.M.E. BY MARTELL NEWSLETTER VISIT US PRIVACY POLICY P RIVACY POLICY We are committed to protecting and respecting your privacy. This Privacy Policy, together with the Terms and Conditions of use of our website www.martell.com (hereinafter referred to as the “Site”) and any other documents referred to on it, sets out the basis on which any personal data we collect from you or that you provide to us (hereinafter referred to as the “Data”) will be processed by us. Please read the following carefully to understand our treatment and use of Data. For the purpose of the French Act No. 78-17 on Information Technology, Data Files and Civil Liberties of 6 January 1978 , the data controller is MARTELL & CO (hereinafter referred to as “Martell”), a French company registered at the Trade and Company Registry of Angoulême under number 342 438 892 with its registered office located Place Edouard Martell, 16100 Cognac, France. 1 Information we collect from you We collect and process the following Data about you: • Personal data (gender, first and last name, email address, address, country of residence, date of birth) that you have voluntarily submitted to us; • Statistic and general information (the time and date of your visit; details of your visits to the Site (including traffic Data, location Data, weblogs and other communication Data, whether this is required for our own billing purposes or otherwise) and the resources that you access; • Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to a service we provide including without limitation the Newsletter subscription, requesting information from us or submitting comments. We may also ask you for information if you report a problem with our Site; if you contact us, we may keep a record of that correspondence. When you access our Site, your computer's browser provides us with information such as your IP address, browser type, access time and referring URL which is collected and used to compile statistical data on the use of our Site. This information may be used to help us to improve our Site and the services we offer. Mandatory information (principally first name, last name, address and email) must be entered in the information fields marked with an asterisk in the data collection forms. If these fields are not completed, we are unable to provide the services outlined above. 2 Purposes of the processing We use your Data that we collect, exclusively, to: • ensure that content from our Site is presented in the most effective manner for you and for your computer; • provide you with information that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes; • compile statistical data on the use of our Site; • send a newsletter, excluding any commercial solicitation; • organize visits and tours of the Martell cellars; and • notify you about changes to our service. 3 International transfers Martell may transfer for the purposes set forth in Article 3 of this Privacy Policy your Data to recipients, internal or external, which may be located in countries with different levels of protection of personal data. In this respect, Martell has implemented appropriate contractual measures, based on the model clauses of the European Commission, to establish and/or to confirm that, prior to receiving your Data, the Data recipients, internal or external located in such countries will process your Data with an adequate level of protection. 4 Data Security Martell is committed to protecting the security of your Data. We use a variety of measures and procedures to protect your Data from unauthorized access and use, accidental or unlawful destruction, or accidental loss, and alteration. To this end, we have notably implemented technical measures such as firewalls and organizational measures such as a login/efficient password system, physical protection, etc. 5 Recipients of the data The recipients of your Data are: • any member of Martell which means Martell’s Communication Department, Martell’s Marketing Department and the Service in charge of the visits of Martell, • the companies that may assist Martell in the operation and/or exploitation of the Site, • and, potentially, any member of the Pernod Ricard Group which means the Pernod Ricard S.A. company and any company directly or indirectly controlled by Pernod Ricard S.A. in the meaning of Article L.233-3 of the French Commercial Code or consolidated in the accounts of Pernod Ricard S.A. We may also disclose your Data to third parties for following purposes: • If you have given us your prior approval to share such information; • If we need to share Data to provide any product or service you have requested; • In the event that we sell or buy any business or assets, in which case we may disclose your Data to the prospective seller or buyer of such business or assets; • If Martell or substantially all of its assets are acquired by a third party, in which case your Data held by it may be one of the transferred assets; • If we are under a duty to disclose or share your Data in order to comply with any legal obligation or in order to enforce the Terms and Conditions of the Site, or to protect the rights, property, or safety of Martell, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. 6 Links to other sites Our Site may, from time to time, contain links to and from other websites. These links are provided solely as a convenience to you. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for those policies regarding collection, use and disclosure of Information collected through those websites. Please check those policies before you submit any personal data to those websites. 7 Rights concerning the collected personal data According to the French Act No. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties as amended, you have the right to access, modify, oppose to the use of your Data for legitimate reasons and ask for the deletion of your Data on the Site. All such rights shall be exercised by electronic letter, together with a copy of a piece of identity, sent to privacy@martell.com. We will respond to you within a reasonable period of time from your request, in compliance with applicable law. We store your Data only for as long as necessary for the purposes of providing access to the Site and related services to you, or as permitted by applicable law. 8 Changes to our Privacy Policy We reserve the right to change this Privacy Policy from time to time in our sole discretion. If we make any changes to the processing of your Data, we ensure that you are informed of such changes and will ask your consent to the changes. 9 Contact Us Questions, comments, requests and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed at privacy@martell.com. All requests will be dealt with promptly and efficiently. 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