Privacy Policy

EFFECTIVE DATE: DECEMBER 10, 2024

LAST UPDATED: DECEMBER 10, 2024

INTRODUCTION

This Privacy Notice sets out how Suntory RTD North America LCC ("Suntory RTD"; "we"; "us"; "our") uses your information while operating our business and sets out your legal rights in relation to the information we process about you, including through our websites, applications, and other services. We may use personal data provided to us either by you or other parties for any of the purposes described in this Privacy Notice or as otherwise stated at the point of collection.

We may modify this Privacy Notice from time to time. We will notify you of any material changes to this Privacy Notice as required by law. We will also post an updated copy on our website. You should check periodically for changes.

LEGAL DRINKING AGE AND DATA OF CHILDREN

This website is not intended for individuals under the legal drinking age and we perform age checks upon visiting the website (without storing your date of birth). We do not knowingly collect, solicit personal information from anyone under the legal drinking age. If we later learn that an individual under the legal drinking age has provided us with personal information, we will delete that information as quickly as possible. Please do not share or forward this website or its contents to anyone underage. If you believe that a child under the legal drinking age may have provided us personal information, please contact us by emailing maruhi@suntory.com (this email address will become active from Jan 1st 2025) or using our contact form here.

LINKS TO OTHER WEBSITES

This Privacy Notice does not apply to the privacy practices of third-party websites linked within this site. If you click on a third-party link, you will be taken to a website that we do not control. We encourage you to read the privacy statements on the other websites you visit. We are not responsible for the practices of these other parties.

WHAT DO WE MEAN BY PERSONAL DATA?

Personal data, sometimes referred to as “personal information,” is any information relating to an identified or identifiable natural person and includes all information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. When “you” or “your” are used in this Privacy Notice, we are referring to the relevant individual who is the subject of the personal data.

THE INFORMATION WE COLLECT ABOUT YOU

We may collect a number of different categories of personal data from and about you:

• Identity Data including name, title, marital status, date of birth or age range, and gender.
• Contact Data including billing address, delivery address, email address and phone numbers.
• Device and Usage Data including information about how you use our website, products, digital assets, apps and services, such as cookie information, internet protocol (IP) address, unique personal identifiers (including those affiliated with your digital wallet address), browser type and version, time zone setting and geolocation, browser plug-in types and versions, mobile device IDs and MAID (Mobile Advertising IDs), operating system and platform and other technology used by the devices you use to access this website.
• Marketing and Communications Data including your preferences in receiving marketing materials, promotions and/or newsletters from us and your communication preferences, responses to customer satisfaction surveys or market research, feedback or complaints which you have communicated to us.
• Photographic and Video Data including photos and video taken at our events, photos or videos you upload on our website or social media sites.
• Social Media Data including social media interactions, usage, handles, profile photo and other social media profile information (such as number of followers).
• User Generated Content including text, pictures, audios, videos, testimonials, tweets, blog posts and reviews posted by you on online platforms such as social media and e-commerce sites.
• Business-to-Business (“B2B”) Data including information related to our business-to-business and vendor relationships, such as business contact information provided to us online or offline to consummate the relationship and carry out business functions. Examples include your name, title, company you work for, address, email address and phone number.

In addition, other specific types of information may be collected in connection with contests, sweepstakes, promotional offers or other marketing efforts. This could include your dietary and taste preferences. We may also collect aggregated or de-identified information that cannot reasonably be used to identify you.

WHEN DO WE COLLECT YOUR PERSONAL DATA?

We will mainly collect personal data about you through interactions with you and your use of our website and digital platforms. In addition, this Privacy Notice applies to our use of any information about you, which we may collect from you via face-to-face communication, mail, phone, email, social media, event registration/attendance, or any other means of communication (including any form of electronic communication).

We may collect information you provide to us online or offline when we enter into a B2B relationship, in order to consummate the relationship and carry out business functions.

We also collect technical data derived from your browsing.

We may also collect information about you from other entities in our corporate group, our business partners and various other third-party service providers.

HOW DO WE USE YOUR PERSONAL DATA?

Your personal data may be used for the following purposes:

• To provide you with products and services.
• To market and promote our products and services.
• To deliver interest-based advertising.
• To improve and develop our business and products.
• To provide and administer our loyalty programs.
• To monitor and analyze trends, usage, and activities in connection with our products and services.
• Consumer support.
• Website administration.
• Enhanced user experience.
• To carry out B2B functions.
• To comply with law or regulation.

HOW LONG DO WE KEEP YOUR DATA?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected, including as required by applicable law or regulation and to satisfy any legal, accounting, or reporting requirements. When the data is no longer necessary for the purpose for which it was collected, we securely delete it or, in some cases, anonymize it.

WITH WHOM DO WE SHARE YOUR DATA?

We may share your personal information with members of our corporate group whose parent company is Suntory Holdings Limited where we have a legal basis for doing so. You can visit our corporate site to find out more.

We also may share your information with select other parties that provide services to us or act on our behalf in connection with the operation of our business, as well as with certain third parties. We require such other parties to respect the privacy and security of your personal information and to treat it in accordance with the law.

In particular, your information may be disclosed to the following categories of recipients:

• Professional advisers (e.g. IT, legal and financial advisers) and auditors.
• IT and system providers; website development and data storage providers; web and data analytic companies; Web3 developers and digital wallet providers.
• Ecommerce platform and service providers operating and managing online stores on our behalf; card and online payment processing service providers.
• Digital, mobile and social media marketing agencies; mail and email deployment agencies; customer fulfilment agencies; event and competition organizers and photographers.
• Identity resolution service & data onboarding service providers; online and social media retargeting and remarketing advertisers.
• Logistics, distribution and delivery service providers; manufacturing plants for personalized products.
• Trade associates, business partners and other parties with whom we may enter into negotiations with in respect of a commercial agreement, e.g. joint business venture.
• Other parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
• Law enforcement agencies; financial regulators and other relevant regulatory authorities; government bodies; tax authorities; courts tribunals and complaints/dispute resolution bodies in circumstances where we are required to disclose personal information by law.
• We may also share your personal information with other parties with your consent or at your direction.

YOUR PRIVACY RIGHTS

The law in some jurisdictions may provide you with additional rights regarding our use of personal information. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the following privacy addenda that are attached to this Privacy Notice below.

ADDITIONAL DISCLOSURE FOR CALIFORNIA RESIDENTS

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us by emailing maruhi@suntory.com (this email address will become active from Jan 1st 2025) or using our contact form here.

DO NOT TRACK

Your browser or device may include “Do Not Track” functionality. Our information collection and disclosure practices and the choices that we provide to you will continue to operate as described in this privacy policy regardless of whether a Do Not Track signal is received.

HOW TO CONTACT US

Please get in touch if you have any questions about how we use your information, or if you wish to contact us about your legal rights or if you have any complaints or feedback about our use of your information. Please contact us at any time by emailing maruhi@suntory.com (this email address will become active from Jan 1st 2025) or using our contact form here.