BACARDI Global Privacy Policy

February 8, 2007

INFORMATION ABOUT US

Bacardi Global Brand Limited is registered in England & Wales under company number 3651489 with a registered office and main trading address at 28 Dorset Square, London, NW1 6QG, United Kingdom (“We/us” or “BGB”). Our VAT number is GB 222 2530 16.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is BGB of 28 Dorset Square, London, NW1 6QG, United Kingdom.

We are committed to protecting and respecting your privacy. This Global Privacy Policy (together with the Bacardi Global User Terms and Conditions) and any other documents referred to in them govern our use of information gathered about you. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Although we are committed to maintaining your confidence and trust in all of our activities with you, this Global Privacy Policy does not govern our collection or use of data about you through channels other than Our Sites (as defined below).

Please exit Our Sites immediately if you do not accept this Global Privacy Policy, are not of a legal age for consuming alcoholic beverages in the country or other territory in which you are located, or are accessing Our Sites in a country or other territory where use of Our Site is not permitted.

SOCIAL RESPONSIBILITY

We are extremely proud of our high quality brands, products and marketing. That pride goes hand in hand with a deep sense of responsibility and respect for the global communities that we serve and the individual consumers who enjoy our products. As part of our commitment to responsible marketing, we comply with the social responsibility policies established by DISCUS — the Distilled Spirits Council for the United States and EFRD — European Forum for Responsible Drinking which set out the principles we maintain in all of our sales and marketing activities, including advertising and promotional programmes.

DATA WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

IP ADDRESSES AND COOKIES

We may collect information about your computer (including, where available, your IP address, operating system and browser type) for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual. Our Internet servers may also keep track of the number of visitors to Our Sites, the pages they visited and how long they stayed. None of this information includes any personal information about you.

For the same reason, We may obtain information about your general Internet usage by using a “cookie” file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. Some cookies load automatically unless otherwise disabled by the computer user, whilst others may require that you affirmatively accept them (such as a “remember me” option). Cookies help us to improve Our Sites and to deliver a better and more personalised service. They enable us:

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies, however, by doing so you may be unable to access certain parts of Our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to Our Sites.

WHERE WE STORE YOUR PERSONAL DATA

We are a global company with a long history of providing our products to responsible consumers all over the world. The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") including but not limited to the USA. Data We collect may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or service providers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Global Privacy Policy.

The information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where We have given you (or where you have chosen) a user identification code, password or any other piece of information as a part of a registration scheme or a security procedure to enable you to access certain parts of Our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. In particular, you should not share your password with anyone who is not of legal drinking age in the country or other territory in which you are located or are accessing Our Sites or to anyone in a country or other territory where use of Our Sites is not permitted.

Unfortunately, the transmission of information via the Internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to any of Our Sites; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

OUR USE OF YOUR INFORMATION

We use information held about you in the following ways:

We also reserve the right to share information with other organisations in the following situations:

If you are an existing customer, We will only contact you by appropriate electronic means with information about goods and services similar to those which were the subject of a previous sale to you. If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by electronic means only if you have consented to this.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information amongst the Group Companies. We may also disclose your personal information to the following selected third parties:

YOUR RIGHTS

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. We will inform you (before collecting your data) if We intend to use your data for marketing purposes or if We intend to disclose your information to any third party for marketing purposes. You can exercise your right to prevent such processing by ticking the relevant boxes on the forms We use to collect your data. If you at any time decide that you do not want to be contacted for any purpose or if you would like to obtain a copy of the personal information about you gathered by Our Sites or correct or delete such information from Our Sites’ databases, you can always contact us at the following e-mail address: webmaster@bacardi.com.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, creative partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

VARIATIONS

We may revise this Privacy Policy at any time by amending this page. Each time you use Our Sites, the current version of the Privacy Policy will apply. Accordingly, when you use Our Sites, you should check the date of the Privacy Policy (which appears at the top right hand corner) and review any changes since the last version.

CHILDREN

Our Sites are designed to appeal to adults. We do not knowingly solicit any information from children nor do we knowingly market or otherwise target Our Sites or its products or services to children. If we become aware that a visitor to Our Sites is under the legal drinking age in the country or other territory in which he or she is located at the relevant time and has registered without verifiable parental consent, we will remove his or her personal information from our files.

CONTACT

Questions, comments and requests regarding this Global Privacy Policy are welcomed and should be addressed to:
Bacardi Global Brands Limited
28 Dorset Square
London
NW1 6QG
United Kingdom
webmaster@bacardi.com.