JUNE 2024

What does this notice cover?

This notice describes how Moët Hennessy U.K. Limited (also referred to as “Moët Hennessy“, “we“, “us” or “data controller”) processes the personal data of guests at the Ascot Moet Photobooth Activation (the “activation”) captured via photography or filming at the activation. Each data subject is referred to in this notice as “you” or “your”.

It also describes your data protection rights, including a right to object to some of the processing which Moët Hennessy carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

What information do we collect?

 

We collect and process personal data:

• from photography or filming carried out during the activation;
• when you complete forms relating to attending or participating in the activation; and
• when you attend and participate in the activation.

The personal data that we collect includes:

• activation data including when you interact with our employees during the activation (for example when you sign up to a mailing list), complete any of our surveys and feedback forms; and
• any photographs, videos or other recordings taken of you during your attendance at the activation.

How do we use this information, and what is the legal basis for this use?

We process this personal data for the following purposes:

• As required by Moët Hennessy to conduct our business and pursue our legitimate interests. In particular we use your information:
  • to market and promote LVMH Group products and brands; and
  • for internal planning and administration purposes, including maintaining records of the activation;

• Where you give us consent, we use your information:
  • to market and promote LVMH Group products and brands.

On other occasions where we ask you for consent, we will use your information for the purpose which we explain at that time.

Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You withdraw your consent by informing the staff during the activation or by contacting us using the details set out below.

Who will we share this data with, where and when?

We may share your personal data with other companies in the LVMH Group (including the Group entities outside the EEA, such as the US, Australia, China, Argentina and New Zealand) for marketing purposes; a list of the LVMH Group Companies is available from the investors section of the Group website www.lvmh.com.

Personal data will also be shared with third party photographers and third party service providers (including suppliers located outside the EEA, US, Australia, China, Argentina and New Zealand) who will process it on behalf of Moët Hennessy for the purposes identified above. In particular, we use third party providers of: IT systems, hosting and maintenance (for example, relating to our email system), and marketing providers.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Where information is transferred outside the EEA and UK, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses for use between controller and controller (module one) and/or, for use between controller and processor (module two) and associated UK Addendum (meaning the template addendum issued by the UK Information Commissioner’s Office in accordance with s119A of the Data Protection Act 2018, as updated and/or replaced from time to time, available here: international-data-transfer-addendum.pdf (ico.org.uk)), an Adequacy Decision, including but not limited to the EU-US Data Privacy Framework and/or the UK Extension to the EU-US Data Privacy Framework or Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to Privacy-UK@moethennessy.com.

Sharing data with us

If any personal data which you provide to us relates to any third party, then by providing us with their personal data you confirm that you have obtained any necessary permissions from those persons to the reasonable use of their personal data in the way set out in this notice, or you are otherwise permitted to give us this personal data. You should share a copy of this notice with those other individuals when disclosing any personal data about them to us.

What rights do I have?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to move, copy or transfer this data to another data controller where technically feasible.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can contact us – or our data protection officer – using the details set out below. If you have unresolved concerns, You have the right to complain to the data protection authority where you live, work or where you believe a breach may have occurred. The relevant supervisory authority for the UK is the ICO (Information Commissioner’s Office (ICO)). If you are located outside the UK, you can identify the relevant supervisory authority of your respective country at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

How long will you retain my data?

We will only keep the personal data that we collect on our systems or with third parties for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject but in any event for no longer than two years from the date of the end of the activation. We will regularly review our files to check that information is accurate and up-to-date and still required.

How do I get in contact you?

We hope that we can satisfy any queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can contact us at Privacy-UK@moethennessy.com or by writing to CFO, Moët Hennessy U.K. Limited, 18 Grosvenor Gardens, London, SW1W 0DH.

Moët Hennessy Data Protection Officer

You can also contact our Data Protection Officer at Moët Hennessy UK Limited:

Address: Bird & Bird DPO Services SRL, Avenue Louise 235 box 1, 1050 Brussels

Email: DPO.MHUK@twobirds.com