Johnnie Walker

1. Introduction

All references to ”our,” “us,” “we” or “company” within this policy and within the opt-in notice are deemed to refer to Diageo plc, its subsidiaries, affiliates and associates.

We endeavor to protect your personal privacy. We provide this Privacy Statement to help you to understand what we may do with any personal information that we obtain from you. By providing your personal information to us, you signify your acceptance of our Privacy Statement and agree that we may collect, use and disclose your personal information as described in this Privacy Statement. If you do not agree to this statement, please do not provide your personal details to us. This Privacy Statement is incorporated into, and part of, the Terms & Conditions, which govern your use of the Site in general. We will use your information only for the purposes set out below.

We may need to update this Privacy Statement from time to time. We recommend that you regularly check this page to ensure that you have read the most recent version.

Changes to the Privacy Statement are noted here: Date last revised: 22.08.06

2. Legal Purchase Age

You must not provide us with your personal information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are accessing the Site. We do not intend to collect personal information from any individuals under the legal purchase age or market alcoholic beverages to anyone under the legal purchase age. If we receive notice or believe that someone under the legal purchase age has provided us with personal information we will make every reasonable effort to remove such personal information from our files or flag such personal information and retain it for the sole purpose of ensuring that it is not used any further.

3. What is personal information?

Personal information is information about an identifiable individual, as defined by applicable law. It does not include aggregated information that does not allow you to be identified, nor does it include business contact information such as your name, title, business address and business phone number.

4. Collecting personal information

You can decide what personal information you provide to us. We will only collect personal information that you choose to provide. Where possible, we will enable you to select how we will use this information (for example, by choosing to opt in or opt out of receiving special promotional offers).

You may choose to provide us with personal information if, for example, you: contact us with an enquiry; register on the Site, fill out a survey or other form with your personal information included; request us to provide you with information; enter a competition; post information to public areas of the Site or take advantage of a promotion.

You have the opportunity to decide whether or not to receive communications from us, except communications required by law or to administer any transaction requested by you, at any point where we request information about you.

By providing any personal information to us, you fully understand and clearly consent to the transfer of such personal information to, and the collection and processing of such information in, other countries or territories. Any such transfer and processing by us will be in accordance with this Privacy Statement.

5. Use of cookies on our websites

In common with many websites, we use "cookies" to help us gather and store information about visitors to our websites.

A cookie is a small data file that our server sends to your browser when you visit the Site. The use of cookies helps us to assist your use of certain aspects of the Site.

You can delete cookies at any time or you can set your browser to reject or disable cookies.

You can obtain information about how to manage cookies at www.aboutcookies.org.

We may use information from cookies for the following purposes:

1. Traffic monitoring, e.g.:
   • the IP address from which you access the Site
   • the type of browser and operating system used to access the Site
   • the date and time of your access to the Site
   • the pages you visit
   • the internet address of the website from which you accessed the Site
2. To recognize repeat visitors for statistical / analytical purposes.
3. Anonymous tracking of interaction with online advertising, e.g., to monitor the number of times that a banner ad is displayed and the number of times it is clicked.

We may connect the information that we collect through cookies with other personally identifiable information that you provide to us. Such purposes are:

1. To customize or personalize your experience of the site; for example, so that we can greet you on the site by name.
2. For transactional purposes, such as credit card sales.
3. To monitor your use of our website(s) in order to make our communications to you as relevant as possible; for example, by sending you email communications relevant to the parts of the Site that you visit most often or by letting you know about features of the Site that you have not accessed previously.

We may compile and report to third parties (such as advertisers) aggregate statistics about our users in terms of numbers, traffic patterns and related Site information.

6. Use of personal information

We may use and/or disclose personal information collected from you in one or more the following ways:

1. Marketing Communications.

   We may use your personal information in order to communicate with you about our products and services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses. However, you will be able to choose whether or not to receive such communications when you first provide personal information to us. You will also have an opportunity to unsubscribe whenever we communicate with you. You may also unsubscribe from such communications at any time (see “Unsubscribe, access, questions and further information” below).

2. Marketing analysis.

   We may use information for internal marketing analysis, for example, to assess trends among our consumers or to measure the amount of traffic to our websites. We may also share non-personal information with others, such as advertisers, in aggregate anonymous form, which means that the information will not contain any personally identifiable information about you. We will only share identifiable personal information with third parties for marketing analysis with your consent.

3. Transactional purposes.

   We may use your personal information in order to respond to your queries and requests and to manage transactions such as credit card payments for any goods that you order from us or any of our agents, or for the fulfillment of such transactions (e.g., delivery). The personal information you provide may be used by an authorized vendor to fulfill that order.

4. Third-party offers.

   We may arrange for carefully selected organizations to send you marketing and promotional information that may be of interest to you. In such circumstances your personal information may be disclosed to these organizations who will be bound by confidentiality obligations and restrictions on use of personal information. We will obtain your permission before we allow a third party to send you any such communications.

5. Public (or Interactive) areas of our websites.

   Information that you post on or through the public areas of the Site (e.g., chat rooms, bulletin boards and discussion groups) is generally accessible to, and may be collected and used by, others and may result in unsolicited messages or other contact from others. Users of our websites are encouraged to exercise caution when providing personal information about themselves in public (or interactive) areas of this site.

6. Sale or Transfer.

   In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, financing, reorganization or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including without limitation, personally identifiable information that you provide and other information concerning your relationship with us.

7. Legal purposes.

   We may collect, use and/or disclose your personal information if permitted by law or required to do so by law or where we believe such action is necessary in order to detect, protect or defend us and/or other third parties against error, negligence, breach of contract, theft, fraud and other illegal or harmful activity, to comply with our audit and security requirements, and to audit compliance with or corporate policies, procedures, legal and contractual obligations.

7. Disclosure of personal information

In addition to disclosures identified in the purposes above, from time to time we may disclose personal information to:

1. our service providers and sub-contractors, including our affiliates, retained to perform functions on our behalf or to provide services to us, such as warehousing and delivery; marketing and advertising; data processing; software development; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers; and further provided such service provider does not collect, use or disclose the personal information for any purpose other than to perform such functions or to provide services to us or as otherwise required by law;
2. a person or entity, including our affiliates, to whom disclosure is required in order to fulfill one or more of the purposes described above under “Purposes for Collecting Personal Information”;
3. a person who, in our reasonable judgment, is providing or seeking the information as the authorized or appointed legal agent of the subject individual; or
4. any third party with your consent or where disclosure is required or permitted by law.

Your acceptance of the Terms & Conditions of use of this Site, which include this Privacy Statement, constitute the granting of consent to the use and disclosure of your personal information for the purposes set out above.

8. Security

We take security seriously and we take precautions to keep your personal information secure. We have put in place appropriate physical, electronic and managerial procedures to safeguard the information we collect. We have no control over the privacy of any email communications while in transit to us. We recommend that you not include confidential, proprietary or sensitive information in emails.

In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email.

9. Unsubscribe, access, questions and further information

At your request, where the law requires us to do so, we will confirm what personal information we hold about you, update your information, remove your information and/or correct any inaccuracies in such personal information if you contact us using the unsubscribe details provided below.

10. Portfolio permissions

If you have given permission for communications about Diageo brands generally (for example, by opting to receive news and special offers by email about Diageo’s other great alcohol brands) you may from time to time receive communications about brands to which you have not opted in specifically. Information about many of Diageo’s brands can be found at www.diageobrands.com

We may occasionally send you communications about brands not featured on www.diageobrands.com (e.g. new brands). We recommend that you refer to www.diageobrands.com from time to time as the list of brands featured will be updated periodically.

Providing general permission for us to communicate with you about our brands does not mean that you will receive communications about all Diageo’s brands. We will only communicate with you about those brands that we think may be of particular interest to you. Any such communications will provide you with an opportunity to unsubscribe from the brand in question and/or from all communications about Diageo brands.

If you have any privacy-related questions, concerns or complaints, please contact: Digital Governance Director, Diageo plc, 8 Henrietta Place, London, W1G 0NB.

Only use the next paragraph in market-specific sites where specific contact details can be published in the localized version of this statement If you would like to unsubscribe from Johnnie Walker communications or from all communications about Diageo brands, or if you have any privacy-related questions, concerns or complaints, please contact: [INSERT CONTACT NAME AND EMAIL ADDRESS APPROPRIATE FOR THE BRAND].

11. Links

This Site may contain links or references to other websites outside of our control. Please be aware that we have no control over these sites and our privacy statement does not apply to these sites. We encourage you to read the privacy statements and terms and conditions of linked or referenced sites you enter.

As required, this Privacy Statement will be supplemented by additional legal requirements in jurisdictions where we conduct business. Nothing in this Privacy Statement or otherwise will create, or add to, any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against the company or any third party or any of their respective directors, officers, employees, agents or representatives (collectively the “Diageo Group”); nor will the existence of this Privacy Statement or its application impose or add to any obligations or liability upon the Diageo Group that the Diageo Group does not already otherwise have under law.