PERSONAL INFORMATION PROTECTION POLICY

1. Application purpose

• Personal Information Privacy Policy (“Privacy Policy”) aims to ensure the security of information related to organizations, individuals participating in accessing and/or transacting on the Website https://direct.pernod-ricard.vn/ (hereinafter referred to as the “Website”) owned by Pernod Ricard Vietnam Co., Ltd (hereinafter referred to as “PRVN”).
• This policy describes how PRVN receives, synthesizes, stores, uses and protects information of organizations and individuals participating in accessing, transacting on the Website (hereinafter referred to as the “Customer”). The Customer's access or transaction on the Website is understood that the Customer has read, understood and agreed to comply with this policy, including the amended and supplemented version of the Policy. The amended and supplemented version of this Policy (if any) will take effect after five (5) days from the date the amendment and supplement of the Policy are announced on the Website.
• The Website is committed to protecting the privacy of customer's information. Please read the privacy policy below to better understand the commitments that PRVN makes, in order to respect and protect the rights of Website visitors.

2. General provisions on customer personal information privacy

2.1. Information gathering

• The information gathering is conducted when the Customer makes a transaction to buy Products on the Website, from time to time, the Customer must provide some necessary information for the execution of the transaction (“Customer Information”).
• The information gathering is conducted when the Consignee provides some necessary information to ensure Product delivery (“Consignee Information”).
• Customer and Consignees are responsible for to ensuring that the information provided is complete and accurate and to always update the information to ensure completeness and accuracy. PRVN is not responsible for resolving any dispute if the information provided by the Customer/Consignee is incorrect, out of date or falsified.

2.2. Storage and security of private information

• Customer information, Consignee information, as well as information exchanged between the customer and PRVN, are stored and kept confidential by PRVN’s system. Especially customer's payment card information will be secured by the Website's payment gateway partners according to PCI DSS international standards, and according to the Payment Information Security Policy (posted on the Website) .
• PRVN shall take appropriate technical and security measures to prevent unauthorized access and use of Customer Information and Consignee Information. PRVN also regularly coordinate with security experts to update the latest information on security network to ensure the security of Customer Information when Customer accesses and/or uses features on the Website. When gathering the data, PRVN stores and secures Customer Information at the server system and this Customer Information is secured by firewall systems, access control and data encryption. measures.
• The customer's payment card information is protected by the Website's payment gateway partners according to international standards. The Website does not allow third parties to track or collect Customer’s information on the component pages of the Website.
• For closed accounts, PRVN still stores the Customer's personal information and access information to serve the purposes of fraud prevention, investigation, answering questions ... The personal information will be stored by PRVN on the server system for a maximum of 12 (twelve) months from the date the Customer closes the account on the Website. After this period ends, PRVN will proceed to permanently delete the Customer’s personal information.
• The customer must not commit any act of using tools or programs to illegally interfere with the system or change the data structure of the Website, any act which enables interfering, sabotaging, or infiltrating of the Website's data, as well as other acts that are prohibited by Vietnamese laws. In the event that PRVN detects that the Customer has intentionally forged, committed fraud, or illegally distributed information, etc., PRVN has the right to transfer the Customer’s personal information to the competent authorities for handling in accordance with the laws.

2.3. Purpose and scope of collecting personal information:

• In order to access and use some services at the Website, the Customer may be required to provide PRVN with personal information (email, full name, contact phone number, ...). All declared information must ensure accuracy and legality. PRVN is not responsible before laws for any information provided by the Customer.
• PRVN will collect information about the number of visits, including the number of page view, links and other information related to the Customer’s connection to the Website. PRVN can also collect information of the web browser used by the Customer when accessing the Website, including: IP address, browser type, language, time and addresses reflected by the browser.

2.4. Scope of information use

• Website collects and uses the Customer’s personal information for the appropriate purposes and fully complies with the content of this Policy. Specifically:

When necessary, PRVN may use this information for the following purposes:

• Order processing: making phone calls/sending messages to confirm orders, notifying the order status and delivery time, confirming order cancellation (if any).
• Sending opening/thank-you letters, introducing new Products, new services or Special Programs on the Website.
• Providing services/utilities to Customer based on their needs and habits when accessing the Website.
• Sending notices, exchanging information between the Customer and the Website or vice versa.
• Detecting, preventing any act of fraud or sabotage of the Customer accounts or other acts of forging the Customer's identity on the Website.
• Receiving the Customer’s feedback and resolving the Customer’s Complaints.
• Providing information on bonus giving (of the Website or of the brands).
• Conducting surveys to improve customer services.
• Confirmation of technical information and customer information security.
• Processing at the request of competent authorities, in accordance with laws.

2.5. Cross-border transfer of the Customer’s personal information

• For the purposes of processing the Customer’s personal information set forth in this Policy, PRVN may have to provide/share such information to relevant third parties which may be located outside the territory of Vietnam;
• When conducting cross-border transfer of the Customer’s personal information, PRVN shall require the receiving party to ensure the security of such transfer. PRVN shall comply with regulations on cross-border transfer of the Customer’s personal information.
• Regulations on transferring personal data abroad will be updated by PRVN from time to time.

2.6. Information storage time

Customer's personal data will be stored until cancellation is requested. Except for such case, member’s personal information will be kept confidential on the Website’s server.

2.7. Persons or organizations that may have access to personal information.

• PRVN does not provide Customer Information, Consignee Information to any third party unless required to do so at the request of competent authorities, or as required by laws or when the provision of such information is necessary for PRVN to provide services/facilities to Customer.
• In addition, PRVN will send a specific notice to the Customer when it must disclose Customer Information to a third party. In this case, PRVN commits to do so only upon the Customer's consent.
• PRVN may share Customer Information, Consignee Information for the following purposes:
• Market research and analysis reports: PRVN can use Customer Information, Consignee Information to research the market, synthesizing and analyzing general information of Customer (for example: average age, geographic area); detailed information will be hidden and used only for statistical work. In the event that PRVN conducts a survey that requires the participation of the Customer, any answers to the survey or opinion polls that Customer provides to the Website will not be transferred to any third party.
• Exchange of Customer Information, Consignee Information with member/ companies of the Pernod Ricard Group and other partners that have signed a customer care agreement with PRVN: PRVN may share Customer Information, Consignee Information with member companies of the Pernod Ricard Group, PRVN's affiliated partners and domestic and international affiliated electronic information sites. This exchange helps PRVN to provide Customer with information about Products and services and other relevant issues that Customer may be interested in. In case of the member companies of the Pernod Ricard Group and affiliated companies of the Website are granted access to Customer Information, they shall strictly comply with requirements described in this Policy.
• Exchange of Customer Information, Consignee Information to third parties who are partners and agents of PRVN: PRVN may transfer Customer Information, Consignee Information to agents and subcontractors to conduct data analysis, marketing and support customer services. PRVN may also exchange Customer Information and Consignee Information with third parties for the purposes of anti-fraud and credit-related risk reduction.
• Exchange of Customer Information, Consignee Information with advertising partners: Customer behavior tracking system, which is used by the Website on the advertising display channel in accordance with current legal regulations (e.g. Customer remarketing, DoubleClick advertising campaign management system, demographic and interest research reports using Google Analytics tool ...), can collect information such as age, gender, interest, and number of advertisement interaction. For advertising features, the Customer can choose to exit the Customer behavior tracking feature of Google Analytics as well as how the advertising display channel appears on Google.
• Exchange of Customer Information, Consignee Information with other business units that PRVN plans to merge or acquire: In this case, PRVN shall require those units to strictly comply with this policy.

2.8. Information of the entity conducting collection and management of personal information, including contact information by which the Customer can reach out to ask for the status of personal information processing.

Pernod Ricard Vietnam Co., Ltd.

• Business registration address: 26th Floor, Vietcombank Building, No. 5 Me Linh Square, Ben Nghe Ward, District 1, Ho Chi Minh City, Vietnam
• Phone: (028) 38298829
• Fax Number: (028) 38250629

Whenever the Customer needs support, please contact PRVN with the aforementioned information.

2.9. Methods and tools for Customer to access and edit their personal information on the e-commerce system of the processing entity.

• The accessing and editing of personal information are conducted upon the Customer’s request in the following ways:

• Logging in to the Customer's account on the Website;
• Making a phone call to the Customer Care Center to verify personal information. The center staff will assist in editing personal information on behalf of the Customer.
• Providing comments or recommendation directly on the Website. After reviewing, the administrator will contact the Customer to confirm the personal information and edit such information if needed.

2.10. Connection to other Websites

• The Customer is responsible for protecting his/her account information and shall not provide any information related to the account and password for accessing to this Website on other Websites.
• PRVN is not responsible for problems arising from the Customer’s access to this Website via other Websites that are not PRVN’s official Websites.

2.11. Use of Cookies

PRVN provides cookies or similar technologies to collect information such as: access history, the Customer’s choices when accessing and using features on the Website, etc. This serves the purpose of PRVN’s improving Website security and customer service by having a better understanding of the Customer’s needs and preferences.

2.12. Commitment to protecting personal information of Customer and Consignees

• Customer have the right to request to change or cancel their personal information.
• Customer’ personal information on the Website shall be ensured the confidentiality under the Website's privacy policy. The collection and use of such information is executed only by Customer’ consent, unless otherwise provided for by laws.
• The use of Customer Information and Consignee Information shall comply with the contents of this Policy. It is prohibited to distribute or provide Customer Information, Consignee Information to third parties, except for the case as required by competent authorities.
• PRVN commits to take appropriate managerial and technical measures to protect the information it collects and stores; comply with technical standards and regulations on cyber security. If a hacker attacks the information server and causes the loss of personal information, PRVN is responsible for reporting/notifying the case to the competent authorities for timely settlement and to Customer.
• PRVN requires individuals, when purchasing goods as members, to provide all personal information such as: Full name, contact address, email, ID number, phone number, account number, payment card number, etc. and to be responsible for the legality of such information. PRVN shall not either be held accountable or handle any complaints by that Customer if the personal information provided at the time of account registration is incorrect.

This policy is adopted and applied by PRVN from 4^th March 2024.