LAST UPDATED: July 1, 2024

Whenever you access our products or services or interact with us in other ways, both online and offline, Brown-Forman Corporation and its affiliated companies (“Brown-Forman”, “we”, “us”) collect, use, and otherwise process information about you (referred to as your “personal information”). “Personal information” is information that identifies you as an individual or relates to an identifiable individual. For example, we process your personal information when you engage with us as an existing or prospective customer, visit one of our websites or social media pages, attend one of our in-person events, or in your capacity as an employee of one of our suppliers or vendors.

This notice describes how we collect personal information and how we use, share and protect it. It also explains your rights regarding your personal information and how you can contact us. Please use the links to access detailed information. If anything is not clear, please contact us via email at [email protected].

In this privacy notice we describe:

• Who collects your personal information
• Information that we collect
• How we use your personal information
• How we share your personal information
• Other information we collect
• Your rights in respect of your information
• Other important information

WHO COLLECTS YOUR PERSONAL INFORMATION

Brown-Forman is a group of companies, headed by Brown-Forman Corporation in the United States and with local entities throughout the world. Which of the Brown-Forman companies is responsible for collecting and processing your personal information depends on various factors, including how you interact with us and where processing of your personal information takes place.

Please review the Country Specific Information for the name and contact information of the Brown-Forman entity responsible for processing activities relating to each country as well as certain additional information. Whenever we refer to “Brown-Forman”, “we” or “us” in this notice we mean the relevant Brown-Forman entity.

INFORMATION THAT WE COLLECT

In order to make our products and services available to you, or to meet a legal obligation, we need to collect and use certain personal information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Some of this information we collect directly from you either in person or via a website, social media or other online service. We also collect personal information about you from other sources.

If you disclose any personal information relating to other people to us or to our service providers in connection with our products and services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Please click on the links to learn more:

• How we collect personal information
• Personal information we collect

How we collect personal information

We collect personal information when you engage with our products and services, for example, when you:

1. visit one of our websites or use our mobile apps
2. create an online account with one of our stores
3. sign-up for our newsletter or other marketing communications
4. participate in a prize promotion, contest or event
5. make a purchase or return something to us through an online store, order form, by e-mail or over the phone
6. submit a review or participate in a survey
7. communicate with us via social media
8. contact us for assistance
9. interact with us on social media
10. attend one of our in-person events
11. visit one of our locations
12. hold shares of Brown-Forman stock

We also collect personal information from other sources:

• Information received as part of routine card verification (fraud) checks.
• Social network information. When you use a social network login to access our services, you will share certain personal information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your services account. The specific information transferred depends on your security settings and the privacy policy of your social media network.
• Partners, when they share information with us.
• Publicly available databases.

Personal information we collect

Personal information we may collect includes:

1. Contact Information, such as name, email address, telephone number, address, and country of residence
2. Age, such as date of birth and age
3. Identification, such as driver’s license or other government-issued identification information
4. Account Information, such as user name, password, user, and device or other associated online identifiers
5. Organization Information, such as role, title, office location, employment history, organizational identifier, and other information relevant to your relationship with one of our vendors, suppliers, customers, partners or other third party organization with whom we work
6. Billing Information, such as debit or credit card details, bank account details, and billing address
7. User Content, such as Your reviews about our products and services, and other content you may create, such as posts on our social media pages, along with any related name, username, alias or other account information
8. Preferences and Interests, such as preferences (including language, marketing and cookie preferences), interests, purchasing patterns and trends, and engagement with marketing or promotional communications, our websites, apps and social media pages
9. Relationship History, including details of your contact with us, and order history and details
10. Visitor and Event Information, such as dietary restrictions, travel and accommodation details, government-issued identification to access one of our physical premises, and other details specific to a particular event or conference
11. Photographs and Videos, such as photos and videos submitted by you or taken at one of our events
12. Biometric Information, such as through the use of third-party facial recognition software, which we use for verify your identity as part of our security and fraud prevention activities
13. Social Media Profile, such as profile pictures and other social media profile information
14. Shareholder Information, such as brokerage account information, details of shares held and elections and date of death

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for legitimate business purposes as described in the chart below, which explains how we use personal information and the legal basis for such use (if applicable).

HOW WE SHARE PERSONAL INFORMATION

We share your personal information in order to provide our products and services and for the other legitimate business purposes described in this Privacy Notice. The following are categories of recipients with whom we might share your data. Please click the links to learn more.

• Other companies within the Brown-Forman Group
• Third party service providers
• When you share information
• Business transactions, legal reasons and law enforcement

Other companies within the Brown-Forman Group:

We share your information with other companies within the Brown-Forman Group of companies for the purposes described in this Privacy Notice. You can consult the list below to see the location of companies within the Brown-Forman Group. Brown-Forman Corporation is the party responsible for the management of the jointly used personal information. We will use this information to help provide you with the products and services you request.

Third party service providers:

We use third party service providers to process personal information on our behalf. These may include the provision of customer support, web hosting providers, customer data management and list enhancement companies, agencies that run our prize promotions, companies that fill product orders or coordinate mailings, delivery companies, payment processors, data analysis firms, marketing firms and email service providers. We seek to use service providers who are able to provide appropriate data privacy and security standards.

When you share personal information:

• On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our social media pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
• Through your social sharing activity. When you connect to the services with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

Business transactions, legal reasons and law enforcement:

We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

We may also disclose personal information to comply with legal obligations (such as paying taxes); to respond to requests from government or other public authorities; to protect the rights, privacy, safety or property of Brown-Forman, you or others; and to permit us to pursue available remedies or limit the damages that we may sustain. These legal obligations and government requests can include laws and authorities outside your country of residence.

OTHER INFORMATION WE COLLECT

We and our service providers also may collect other information that does not reveal your specific identity or does not directly relate to an identifiable individual (referred to as “other information”). This may include:

• Server log files and environmental variables
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

If we are required to treat other information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information detailed in this Policy.

Other information may be collected in a variety of ways, including:

• Through your browser or device
  • Server Log Files. We use W3C* compliant extended log files, or equivalent, when recording web-server activity on our web servers including, for example, the IP address (a number automatically assigned to the computer that you are using by your Internet Service Provider), device identifier, time and date of request, page requested, user agent, referrer and cookie values sent or received. The server log files are collected and analyzed to provide information about user activity in the aggregate and identify potential errors or problems with website performance. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. *W3C is an international consortium that develops web standards and guidelines. Further information is available at www.w3c.org.
  • Environmental Variables. We and our service providers may also collect certain environmental variables, such as your computer type (Windows or Macintosh), screen resolution, OS version, device manufacturer and model, Internet browser, and Internet browser version. These environmental variables are collected by most browsers and can be used to optimize your experience on the Website.

• Through your use of one of our mobile apps; When you download and use one of our mobile applications, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number.
• Using cookies; Please read our Cookie Policy [link]

• Using pixel tags and other similar technologies

We and our service providers may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Website pages and HTML-formatted e-mail messages to, among other things, compile aggregate statistics about Website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1) that is ordinarily not visible to Website visitors and may be associated with Cookies on the visitors’ hard drives. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when the e-mail has been opened.

Our websites may also provide us with information including details of the content you access and interact with. This is done through Brown-Forman websites and through cross-website tracking. We use cookies and other technologies to collect information about your device browser and operating system, IP address, links you click and pages you open, which we then use to tailor marketing messages. For more information, please refer to our Cookie Policy. We will provide personalized services either with your consent or because we have a legitimate interest.

Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of our services and report on activities and trends. Google Analytics may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

• Physical location

We may collect the physical location of your device if you use a location-based service. Before this information is collected, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

• Do Not Track Signals: We currently respond to browser GPC and do-not-track signals.

Uses and Disclosure of Other Information

We may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine other information with personal information. In those instances we will treat the combined information as personal information while it is combined.

YOUR RIGHTS TO YOUR PERSONAL INFORMATION

You may request to access, correct, update, suppress, restrict or remove (or anonymize) your personal information, or object to or opt out of the processing of personal information, to the extent these rights are provided by applicable law. You also may request to receive an electronic copy of your personal information to transmit it to another company (to the extent this right to data portability is provided by applicable law). In each case, we may require you to prove your identity and/or provide further information in order to identify your information. We will respond to your requests consistent with applicable law. Please click the links to learn more.

In addition, if you would like to opt-out from marketing messages, you may opt-out by clicking here. We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing communications from us, we may still send you important administrative messages, from which you cannot opt-out.

• Accessing your personal information
• Correcting or updating your personal information
• Removing your personal information
• Restricting, objecting to or opting out of processing your personal information
• Requests for portability

Accessing your personal information

You may ask to see what information we hold about you and to receive an explanation about how we process your data by using the “contact us” form.

Correcting or updating your personal information

If we hold personal information about you that is incorrect or out of date, you have the right to tell us that it is incorrect or out of date and ask us to amend it. We will do this consistent with applicable law. If you would like to correct your personal information, please send an email to [email protected].

Removing your personal information

You may ask us to remove, anonymize or delete your personal information from our database. If you do not want to receive promotional emails, please click here. If you wish to have your personal information removed from our database, please send an email to [email protected].

Restricting, objecting to or opting out of processing your personal information

You may ask us to restrict, cease or otherwise limit our processing of your personal information under certain circumstances. Please send an email to [email protected].

Portability Requests

You may ask us to port your personal information from our database, please send an email to [email protected].

For more information on requests you may make under California or other applicable state laws, please see the end of this notice.

OTHER IMPORTANT INFORMATION

We take the security of your information very seriously. This section outlines our technology practices to keep your information protected. Please click the links to learn more.

• How we protect your information
• How we retain your information
• International transfers of your information
• Underage access to services
• Third-party services
• Third-party advertising

How we protect your information

We use various security measures and tools, such as firewalls, to help protect against the loss, misuse and alteration of the personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive personal information.

How we retain your personal information

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

· The length of time we have an ongoing relationship with you and provide the services to you (for example, for as long as you have an account with us or keep using the services);

· Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

· Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

International transfers of your personal information

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In these circumstances we take measures to ensure that your information is protected, which includes putting in place contracts with the recipients of your information to ensure that they provide adequate protection for your information. You may obtain a copy of these measures by contacting us at [email protected].

• EU/EEA: Some of these countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards (the full list of these countries is available here. With regard to transfers from the EEA to other countries, we have put in place adequate measures, such as Standard Contractual Clauses adopted by the European Commission. You may obtain a copy of these measures by contacting us at [email protected].
• UK: Some of these countries are recognized by the UK as providing an adequate level of protection according to UK standards. With regard to transfers from the UK to other countries, we have put in place adequate measures, such as Standard Contractual Clauses. You may obtain a copy of these measures by contacting us at [email protected].

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

Access to services by individuals who are underage.

Our services are not directed to individuals who are under the legal age to purchase alcohol, and we do not knowingly collect personal information from such individuals.

Third-party services

This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which our services link. The inclusion of a link on the services does not imply Brown-Forman’s endorsement of the linked site or service. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Meta, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with our apps or our social media pages.

Third-party advertising

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use Brown-Forman services and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit https://optout.aboutads.info/?c=2&lang=EN and https://optout.networkadvertising.org/?c=1. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.

Sensitive personal information

We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise to us.

UPDATES TO THIS PRIVACY NOTICE

We may change this Privacy Notice. The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the services. 

CONTACTING US

Brown-Forman Corporation is located at 850 Dixie Highway, Louisville, KY 40210, USA.

If you have any questions about this Privacy Policy, please contact us at [email protected], the address listed in the country-specific information below or

Brown-Forman Corporation

850 Dixie Highway

Louisville, KY, USA 40210.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us. 

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA AND UK

You may also lodge a complaint with a data protection authority for your country or region, or the location of an alleged infringement of applicable data protection law. If you have any difficulty locating this data protection authority, please do not hesitate to reach out to us so that we can assist you.

• For the EU/EEA you can find this information at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
• For the UK, you can find this information here https://ico.org.uk/make-a-complaint/

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