CAMPARI PRIVACY POLICY

This Privacy Policy applies in Singapore and governs the collection, use, and disclosure of personal data (as defined below), which is subject to the Personal Data Protection Act 2012 in Singapore (the “PDPA”) and its regulation(s). This Privacy Policy shall be governed and construed in all respects by the laws of Singapore.

We, Campari Singapore Pte Ltd (“Campari”), is bound by and complies with the applicable data protection laws (“Privacy Laws”). Campari’s policy for collecting, using, disclosing, and storing personal information and data that we collect is outlined below.

Collection of Personal Data.
In this Privacy Policy, “personal data” refers to data, whether true or not, about an individual who can be identified (a) from the data; or (b) from that data and other information to which the organisation has or is likely to have access. Please note that the data protection provisions of the PDPA do not apply to business contact information (“BCI”). BCI is defined in the PDPA as an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes.
Campari may collect any personal data you provide to us. This may occur when you enter a promotion, if you fill in a form, if you send us an email, in connection with your use of one of our websites, indirectly from third parties that provide services to us such as our advertising agencies and other business partners, through business dealings with Campari, information obtained through credit checks that you authorize us to conduct and from our related bodies corporate.
Personal data which we may collect includes:

(a) contact information such as your name, date of birth, telephone number, postal address and e-mail address;

(b) other information which will assist Campari in conducting its business and to provide its products and services; and

(c) information about your use of any Campari websites and social media pages such as Facebook and Instagram.

Your personal data is collected and used for the purpose you provided it for, any other purpose you consented to, plus any reasonably related secondary purposes or other purposes permitted under Privacy Laws. This may include:

(a) to provide products or services to you or inform you about products or services on offer;

(b) to accept entries into promotions and competitions run by our company;

(c) to inform you about events that we have invited you to attend, or which you have indicated you would like to attend;

(d) to assess credit and/or employment applications;

(e) for complaints handling;

(f) for contractual obligations;

(g) to comply with various legislative or regulatory requirements; and
to conduct and develop Campari’s business and to provide and market its products and services.

(h) If you do not provide information when requested to do so, we may be unable to provide services to you.

We may use any of the media available through the personal data you provided to us in order to contact you, such as by SMS, email, and direct mail if you have provided a postal address, mobile phone no. and email address.

Campari may also collect the following information in connection with your use of our websites for marketing purposes to identify the most useful and popular sections of those sites and to generally improve those sites and tailor content. It may also use the following information to make offers and promote Campari’s products, events and, other marketing activities to you:

(a) your server address;

(b) domain name;

(c) the date and time of your visit to our site;

(d) the pages viewed and information downloaded;

(e) the previous site visited;

(f) the social media and other subscription or member-based sites you belong to; and

(g) the type of browser used.

No attempt will be made to identify users by their browsing activities.

We do not sell any personally identifiable information to any third parties.

Indirect Collection of Personal Data

Where possible, we attempt to collect personal data about an individual solely from that individual; however, at times, we may be supplied with personal data by a third party. If you supply us with personal data in relation to another person, we require that you advise the person that you have done so and ensure that they agree to the use and disclosure of their personal data in accordance with this Privacy Policy.

Sometimes we use third party providers such as Eventbrite who provide the personal data to us that you supply in connection with our marketing, events and promotional activities. We use and store this personal data in accordance with this Privacy Policy.

Disclosure of Personal Information

When you provide us with your personal data you agree to Campari’s use and disclosure of that data in accordance with the principles set out in this Privacy Policy.

Please be aware that, subject to and as permitted by Privacy Laws, Campari may disclose or transfer your personal data to the following entities or parties, whether they are located overseas or in Singapore:

(a) Campari Group affiliates;

(b) agents, contractors, other companies, individuals or third-party service providers who assist us in providing products or provide services to Campari or perform functions on our behalf, such as IT providers, marketing companies, mailing houses, consultants, credit providers and service providers, or who are affiliates of Campari;

(c) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving of Campari;

(d) external banks and their respective service providers;

(e) share registrars;

(f) companies which provide corporate secretarial services;

(g) our professional advisers such as consultants, auditors and lawyers; relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or

(h) any other party to whom you authorise us to disclose your personal data to.

Data Transfer and Data Retention

In some circumstances, our use or disclosure of information may involve its transfer to entities or servers located outside of Singapore, such as in Australia, Italy, the United States of America, the Netherlands, or other foreign locations. This will usually be for the primary purpose, or a related secondary purpose to that, for which the information was collected.

Where your personal data is transferred to foreign locations outside of Singapore, we will implement reasonable security arrangements (as required under the PDPA) to provide a standard of protection as required under applicable Privacy Laws (including the PDPA) and we will only transfer your personal data through secure servers to mitigate the risk of unauthorised access to or use of information.

All personal data is retained for as long as it is necessary for the purposes it has been collected for, or as required or permitted by applicable laws. When determining the retention period, we take into account various criteria, such as the nature and length of our relationship with you, possible re-enrolment with our services or products, the impact on our ability to provide you with certain features of our services and products if we delete some information from or about you, mandatory retention periods provided by law and the applicable statute of limitations.

Any third party who manages our personal data is also required to ensure that the personal data is disposed of in accordance with the retention period as may be agreed in their respective engagement contract(s). We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serve the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.

Security and Accuracy of Personal Information

We take all appropriate administrative, physical, and technical measures to secure your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, and the loss of any storage medium or device on which personal data is stored, and to keep this personal data accurate and up-to-date. Personal data is stored electronically or in hard copy and appropriate information security measures are in place to protect this information.

Access to any personal data held about you is restricted to those persons who need to know that information in order to carry out the permitted purposes.

Although we will take all reasonable steps to secure our websites, the internet is not a completely secure medium, and we are unable to guarantee that any information that you post on or transmit through our websites will be safe from unauthorised access or use. We urge you to take every precaution to protect your personal data.

We take all reasonable steps to ensure that we hold and use your personal data only for the period it is reasonably required for the purposes referred to in this Privacy Policy or as required of us by Privacy Laws. On the expiry of that period, we will take such steps as are reasonable in the circumstances to destroy or de-identify your personal data.

Cookies

Cookies are uniquely numbered identification numbers like tags which are placed on your browser. By themselves cookies do not identify you personally, but they may link back to a database record about you. If you register on any of our websites, we may then link your cookie back to your personal identification details.

Changes to this Privacy Policy

Campari may amend this Privacy Policy from time to time, and the amended policy will be published at https://rarespirits.asia/pages/privacy. Please review https://rarespirits.asia/pages/privacy periodically for changes to this Privacy Policy. Your continued use of Campari’s websites or services, or provision of further personal data to Campari, once this policy has been amended constitutes your acceptance of the amended policy.

Third party sites and other channels

Campari is not responsible for the privacy policy of any third-party site or other channel via which you disclose information, whether that site or channel is facilitated by Campari (for example, by a link on one of our websites) or otherwise.

Your Singapore Privacy Rights

For users who access our websites, mobile applications, and services from Singapore, you may withdraw your consent at any time where we are relying on consent to process your personal data. However, please note that we may not be able to provide certain products or services to you. We will inform you promptly if such a situation arises upon the withdrawal of your consent.

You may request to access and/or correct the personal data currently in our possession by writing to the Data Protection Officer ("DPO”) using the contact details provided below. This allows you to obtain a copy of your personal data we possess concerning you and verify that we are processing it in a lawful manner, with exceptions specified in the PDPA. Additionally, you have a right to request the rectification of any incomplete or inaccurate information we may hold about you.

If you have a complaint or a question

In most cases, you have a right to access and correct the personal data that we hold about you. You may have other rights under applicable Privacy Laws, including (in some cases) a right to require information we hold about you to be deleted if you believe our use of your personal data is not consistent with this Privacy Policy or the Privacy Laws. Requests for access, correction or deletion should be directed to the DPO, whose contact details are set out below. If you would like further information about how we manage your personal data, or if you have any other queries or concerns relating to our Privacy Policy or privacy practices, or have a problem or wish to lodge a complaint in relation to an alleged breach of Privacy Laws, please contact us via the following channels:

Attention: Data Protection Officer
(a) Email: apac.privacy@campari.com
(b) Write to our DPO at:

Data Protection Officer
152 Beach Road
#28-05 Gateway East
Singapore 189721

If you wish to make a complaint, you will need to provide sufficient details regarding your complaint as well as any supporting evidence and information. Our DPO will investigate the issue and determine any steps that Campari will undertake to resolve your complaint. Campari will contact you if it requires any further information from you and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns or contact the privacy regulator in your country.