Privacy Policy

LAST UPDATED: November 24, 2014

We respect the privacy of every individual who visits our websites. This Privacy Policy and Security Statement (the “Privacy Policy“) describes our practices in connection with personal data collected through this Website.

By entering this Website you agree to the terms of the Privacy Policy.

This Website is operated by Brown-Forman Beverages, Europe, Ltd., (registered in the United Kingdom) (“Company”), and any personal data collected through this Website is controlled by Company, an affiliate of the Brown-Forman Corporation (“BFC”). Company wants you to be familiar with how we collect, use and disclose personal data in compliance with applicable data protection law.

For individuals who are located in the European Union, you should be aware that BFC abides by the Safe Harbor framework agreed to by the U.S. Department of Commerce and the European Union (EU) with respect to personal information collected by entities located in the EEA and transferred to BFC in the United States. For additional information regarding the Safe Harbor Program, see the U.S. Dept. of Commerce web site at http://www.export.gov/safeharbor.

Company may revise the Privacy Policy at any time by updating this posting. You can determine when the Privacy Policy was last revised by referring to the “LAST UPDATED” legend at the top of the Privacy Policy. Your continued use of the Website will be deemed acceptance of the updated or amended Privacy Policy. If you do not agree to the changes, you should cease using this Website.

Except as stated in Section 3 of this Privacy Policy, if there is any conflict between this Privacy Policy and specific provisions appearing elsewhere on the Website, then this Privacy Policy shall prevail.

Persons under legal drinking age are not allowed.

BFC maintains this Website for the use of individuals who are of legal age to consume alcoholic beverages under applicable law. You must be of legal drinking age where you reside to access the Website or provide information to us, and you must be in a country or territory where access to this Website is permitted. We do not solicit or knowingly collect personal information from persons under such legal drinking age, and we do not knowingly market our products or services to persons under such legal drinking age.

What Types of Data Does Company Collect?

When you entered our Website you were required to provide date of birth and possibly country of residence. We do not store this information unless you voluntarily provide it to us by registering on this Website or through some other affirmative action, although this information may be placed in a temporary cookie (see “Cookies” below in this Section 2). You do not have to provide additional personal details to browse most areas of the Website. However, in order for you to take advantage of particular opportunities provided through the Website (for example, to sign up for brand information, a prize draw or contest or to request certain information from Company), we will require that you provide certain personal data, and we may request certain additional information that you provide voluntarily. Examples of such data and information are name, postal address, telephone number, e-mail address, and when associated with you: date of birth, gender, household information, consumption habits, product usage, and attitudes and preferences regarding our products. We may aggregate personal data in a manner such that the end-product does not personally identify you or any other user of this Website, for example, by using personal data to calculate the percentage of our users who have a particular postal code. Such aggregate information is not considered personal data for purposes of this Privacy Policy and because such data does not personally identify you, we may use such information for any purpose.

When you visit and interact with the Website, Company, and third parties with whom Company has contracted to provide services, may collect data such as your Internet Protocol (IP) address, operating system and browser type, or your general Internet usage. However, none of this information is stored in your specific consumer record. We collect and store this information in the aggregate only. Such information is generally collected from the following sources:

Server Log Files. We use W3C* compliant extended log files when recording web-server activity on our web servers including, for example, the IP address (a number automatically assigned to the computer that you are using by your Internet Service Provider), time and date of request, page requested, user agent, referrer and cookie values sent or received. The server log files are collected and analyzed to provide information about user activity in the aggregate and identify potential errors or problems with website performance. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites

*W3C is an international consortium that develops web standards and guidelines. Further information is available at www.w3c.org.

Environmental Variables. We and our service providers may also collect certain environmental variables, such as your computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most browsers and can be used to optimize your experience on the Website.

Cookies. Click here for the Cookie Policy.

Pixel Tags. We and our service providers may also use so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags“) in connection with some Website pages and HTML-formatted e-mail messages to, among other things, compile aggregate statistics about Website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to Website visitors and may be associated with Cookies on the visitors’ hard drives. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when the e-mail has been opened.

How Does Company Use and Share Information Collected From Me?

Personal data will be used and held by Company and may be used or held by BFC and its affiliated companies [http://brown-forman.com/10kfiling] and their agents or partners, who will provide services to Company. We will not sell, exchange or otherwise distribute your personal data to unaffiliated third parties (other than those listed above) without your consent, except to the extent required by law, or as set out below:

Fulfillment of Requests. Company may use personal data you provide for the purposes of carrying out your requests submitted through the Website, including to send you brand information or process transactions or respond to your inquiries or requests.

Administrative Communications. From time to time we may use personal data to send to you important information regarding the Website. Because this information may be important to your use of the Website, you may not opt out of receiving such communications.

Other Communications. We may use personal data to contact you by post, e-mail, telephone or SMS, to promote, to consider ways of improving, and to send you information about, [Southern Comfort] products and services. If you do not wish to receive further promotional material, you can send us an e-mail (see details in Section 9 below).

E-mails to Friends. In the event that we offer the functionality to permit you to send messages regarding Website-related content to a friend through the Website, you may provide us with your friend’s e-mail address so that we can facilitate your sending a message to your friend; provided, however, that we reserve the right to refuse to facilitate the message for any reason, including without limitation restrictions placed on this functionality by your jurisdiction or that of your friend. Company may retain your friend’s email address but will use your friend’s address only as described in this Privacy Policy and will not send additional promotional messages to your friend unless your friend registers with us (or has registered previously). Please note that any personal data you provide in connection with your request to send messages to your friend may be disclosed to your friend.

By using our send-to-a-friend functionality, you confirm that all friends you nominate to receive messages are of legal drinking age in the country where they reside and that they have consented to receiving the email(s) from this Website that you request us to send.

Promotions. We may operate prize draws, contests and similar promotions (collectively, “Promotions“) through the Website. We typically ask you for certain personal data when you enter and, if applicable, win a Promotion. We may share the personal data you provide with individuals or entities involved with the promotion or as otherwise specified in the rules applicable to the particular Promotion. You should carefully review the rules, if any, of each Promotion in which you participate through the Website, as they may contain additional important information about Company’s use or disclosure of personal data. To the extent that the terms and conditions of such rules concerning the treatment of personal data conflict with this Privacy Policy, the terms and conditions of such rules will control.

Internal Business and Statistical Analysis We may use personal data for our internal business purposes, such as quality assurance, data analysis, audits or targeted promotions. In addition, we may also use it to enhance our information and to aid us in providing our customers with targeted promotions. We use personal data to estimate our audience size and usage pattern and to recognize you when you return to our Website.

Affiliated Entities. To fulfill the purposes outlined in this Privacy Policy, we may share personal data on a need to know basis with personnel at our affiliated entities in the European Economic Area, or Switzerland or with BFC in the USA. Because BFC takes privacy seriously, BFC has certified to the Safe Harbor (see Section 1).

Service Providers. We may share personal data with third party service providers for the purpose of enabling these third parties to provide services to us (“Service Providers”). Service Providers may include customer support specialists, web hosting providers, customer data management and list enhancement companies, fulfillment companies (e.g., companies that fill product orders or coordinate mailings), data analysis firms and email service providers. Service Providers may be provided with access to personal data needed to perform their functions but only for that purpose.

Information Posted by Visitors. Company may make available through the Website services such as message boards to which you are able to post information, photos, images and other materials. Please note that any information, photos, images or materials you disclose through such services or otherwise on the Website becomes public information, and may be available to visitors to the Website all over the world and to the general public. In addition, when you choose to make a posting on such services, certain personal data will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose personal data, or any other information, on the Website. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL DATA YOU VOLUNTARILY DISCLOSE THROUGH THE WEBSITE.

Assignment. We reserve the right to transfer any and all information that we collect from Website users to another company or entity in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Company’s business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).

Law enforcement; emergencies; compliance. We reserve the right to disclose personal data to others (a) to comply with legal process; (b) to respond to requests from government or other public authorities; (c) to protect the rights, privacy, safety or property of Company, you or others; and (d) to permit us to pursue available remedies or limit the damages that we may sustain.

Third-Party Websites.

The Website may contain links to third-party Websites. These linked Websites are not under Company’s control, and we are not responsible for the privacy practices or the contents of any such linked Website or any link contained in any linked Website. We provide such links only as a convenience, and the inclusion of a link on the Website does not imply endorsement of the linked Website by Company. If you provide any personal data through any such third-party website, your transaction will occur on the third party’s website (not this Website) and the personal data you provide will be collected by and controlled by the privacy policy of that third party. We recommend that you familiarize yourself with the privacy policies and practices of any third parties. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

Information Related to Employment.

If you choose to submit your resume or apply for a position with us through this Website, we will use (and transfer, if necessary) the information you provide in order to evaluate your experience as it relates to potential employment opportunities with Company or our affiliated companies throughout the world. We will use the information to contact you regarding any positions for which we believe you may be interested in submitting an application or other opportunities at Company or our affiliates that we think may interest you.

Security.

We have security measures and tools, such as firewalls, in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive personal data in an email.

Retaining Personal Data

We retain personal data about you for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law.

Your Rights

You may request information as to the personal data we hold about you. Where appropriate, you may also object to us processing certain types of information for certain types of purposes or you may require correction and/or deletion of the personal data we hold about you. You can also exercise the right at any time by contacting us (see details in Section 9 below). We may require you to prove your identity and supply details in order to identify the data.

You may also opt-out of receiving marketing communications from us by contacting us (see details in Section 9 below). Please specify the means of communication from which you would like to opt-out. Otherwise, you may not get the communications you would otherwise expect to receive from us.

Contacting Us.

If you have any questions regarding this Privacy Policy, wish to contact us for reasons described in Section 8 or want to opt-out of receiving promotional communications, please contact us by e-mail at ElJimador@eljimadortequila.com, by postal mail at: Part Fourth Floor (west), 45 Mortimer Street, London W1W 8HJ, or by telephone at +800-753-4567, Attention: Privacy Officer. Please note that e-mail communications will not necessarily be secure; accordingly, you should not include credit or other payment card information or other sensitive information in your e-mail correspondence with us.