INTRODUCTION

Our Privacy Policy explains how we collect, use and protect information in relation to WESTLAND Distillery’s website and digital services (collectively, the “Services”). This Privacy Policy applies to all visitors and users who access the Services.

This website is operated by WESTLAND Distillery, 2931 First Avenue South, Suite B, Seattle, Washington 98134.

1. INFORMATION WE COLLECT

Depending on the Services provided by the website and used by you, on your choices and configuration of your terminal (with respect in particular to cookies), personal data concerning you (your “Personal Data”) collected and processed by WESTLAND Distillery mainly includes: your name, date of birth, e-mail address, postal address, telephone number, your preferences and interests, as well as the information that you may disclose when you contact us. To the extent permitted by applicable law, we may combine the information collected, including information about the organization for which you work, with other information in our possession or information that you provide to us.

The Personal Data that is mandatory for WESTLAND Distillery to fulfill the purposes that are described below is marked with an asterisk on the various pages of the website. Should you not fill in these mandatory fields, WESTLAND Distillery may not be able to take care of your demands and/or to provide you the requested services. Other Personal Data is purely optional and allows us to know you better and to improve our communications and services accordingly.

When you visit the website, we may use cookies, tracers and similar tracking technologies to collect information about how you use our Services and provide features to you. Cookies are used to automatically collect your device identifiers and other information about you, such as the following: Internet Protocol (IP) address, logs, webpages clicked. We may also ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

2. PURPOSES OF PROCESSING

We collect and process your Personal Data with your consent and/or as necessary to perform a contract (e.g. to provide products ordered), meet our legal obligations, or fulfill our legitimate interests (notably for marketing purposes, to prevent fraud or to protect the security of our IT systems).

We use and process Personal Data about you for purposes described below:

• to provide the products or services requested;

• to personalize the content of the website, to send you information about our products, services, offers, news and events (newsletters, invitations and other publications) either by e-mail, telephone, contact forms, or post;

• to understand your preferences and interests;

• to make statistics;

• to prevent fraud and ensure compliance;

• to reply to your questions, complaints or orders of documents or services;

• to improve our website and provide technical support.[TT1]

We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing, we will ask your separate consent. To the extent necessary, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only the categories of Personal Data that are strictly required for the purposes mentioned above.

3. YOUR RIGHTS

In accordance with applicable data protection laws and regulations, you have a right to request access to, rectification or erasure of your Personal Data, or restriction of processing, and to object to said processing, as well as the right to data portability to the extent applicable, subject to any overriding legitimate grounds that WESTLAND Distillery might invoke to retain your Personal Data.

You may request at any time that we stop sending you information about our offers, news and events by using the opt-out link inserted in each e-mail that we send you.

You may also give us specific instructions regarding your Personal Data after your death.

Moreover, you have the right to lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with the law.

You can exercise your rights by using your account settings or by simply writing us at the following address: privacy@remy-cointreau.com. Please keep in mind that in case of a vague request we may engage a discussion to better understand the motivation for the request and require you to prove your identity (for example, by requesting an ID). This is made to ensure that no right of third parties is violated by your request.

4. DATA RECIPIENTS

Your Personal Data shall be processed by WESTLAND Distillery. It shall not be transferred or made accessible to any third party apart from:

• i. our service providers (such as providers of hosting and maintenance services or advertising partners);

• ii. the other entities of the Remy Cointreau group;

• iii. in case of a change of control, if we sell or otherwise transfer part or the whole of WESTLAND Distillery or our assets to another company (e.g., in the course of a transaction like a merger, acquisition, liquidation) and;

• iv. to third parties if such disclosure is required by law, by a regulatory provision or by a court ruling, or if this disclosure is necessary to ensure the protection and defense of rights or to prevent harm.

5. TRANSFER OF PERSONAL DATA & SECURITY MEASURES

WESTLAND Distillery uses reasonable and appropriate information security safeguards to help keep the information collected through the Services secure and take reasonable steps to verify your identity before granting you access to your account. Among others, we utilize the following security measures:

• Pseudonymization of certain categories of your Personal Data;

• Encryption of your Personal Data in transit and in rest;

• Regular vulnerability scanning and penetration testing;

• Organizational measures (access control, restriction of access);

• Conducting periodical data protection impact assessments and privacy audit.

6. DATA RETENTION

We will retain your Personal Data as long as your account is active or needed to provide you services, and only for as long as necessary in relation to purposes of processing identified in this Privacy Policy. Information we receive about you may be retained for an extended period of time when it is the subject of a legal obligation, an investigation or otherwise to prevent harm.

The Personal Data that is used for the purpose of sending you information concerning the offers, news and events of WESTLAND Distillery shall be kept for a period of three (3) years as of the date on which it was collected or as of your last contact with WESTLAND Distillery. Your Personal Data shall be destroyed within a maximum of 30 days following any request on your part to unsubscribe.

The Personal Data that is collected and processed under the “Contact us” and/or or similar section shall only be kept throughout the duration of the processing of your request. It shall be deleted thereafter.

Finally, the connection logs that are collected, subject to your consent, using the cookies, tracers and other similar tracking technologies implemented on our website, shall be kept in accordance with applicable laws and regulations for a period of time that does not exceed thirteen (13) months.

7. CHILDREN’S PRIVACY

WESTLAND Distillery website is not directed to users under the legal age of drinking. If you are younger this legal age, depending on your country, you may not use our Services. If you are a parent or guardian and believe we may have collected information about a child, please contact us.

8. CONTACT US

If you have any questions about this Privacy Policy and if you wish to exercise your rights, please contact our Data Protection Officer through the email privacy@remy-cointreau.com or to our mailing address:

Remy Cointreau DPO

21 Boulevard Haussmann

75009 – Paris – France

Phone: +33 (0) 1 44 13 44 13

9. CHANGES TO OUR PRIVACY POLICY

WESTLAND Distillery may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances.

Last update: October 2019