PRIVACY POLICY

DEFINITIONS

Personal Data: has the meaning given to it or a conceptually similar term under Applicable Regulations, and means any information relating to a Data Subject, it being understood that a Data Subject is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological,genetic, mental, economic, cultural or social identity of that person.

Data Subject: has the meaning given to it or a conceptuallysimilar term under Applicable Regulations, and means an identified oridentifiable living natural person or existing juristic person as applicable,and for the purposes of this Privacy Notice is referred to as “you” or “your”.

Data Controller: has the meaning given to it or a conceptually similar term underApplicable Regulations, and means the natural orlegal person, public authority, agency, or other body which, alone or jointlywith others, determines the purposes and means of the processing of Personal Data.

Joint Controller: has the meaning given to it or a conceptually similar term underApplicable Regulations, and means a Data Controller whodetermines the purposes and means of the Processing jointly with one or severalother Data Controller(s).

Processing: has the meaning given to it or aconceptually similar term under Applicable Regulations, and means any operationor set of operations which is performed on Personal Data or on sets of PersonalData, whether or not by automated means, such as collection, recording,organization, structuring, storage, adaptation or alteration, retrieval,consultation, use, disclosure by transmission, dissemination or otherwisemaking available, alignment or combination, restriction, erasure, ordestruction.

1. WHO IS PROCESSING YOUR PERSONAL DATA?

EDWARDSNELL & CO PTY LTD, a company incorporated under the laws of South Africa, registered at the Trade and Companies Register under the n° 1923/001266/07, having its registered office at 8 Power Drive, Prospecton, Durban, South Africa and E. REMYMARTIN & C°, a company incorporated under the laws of France, registered at the Trade and Companies Register of Angouleme (France)under the n° 775 563 323, having its registered office at 20 rue de la Société Vinicole, 16100 Cognac, France (hereafter together referred to as “We”, “ or “Our”), acting as Joint Controllers, would like to inform you about the Processing of your Personal Data, in accordance with applicable laws and regulations on the protection of Personal Data, in particular: (i) Regulation (EU) 2016/679 dated April 27, 2016 (hereinafter "GDPR"), (ii) South African Law Protection of Personal Information Act, 2013, (iii) French Law No 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties and (iv) any other text or provision that may be enacted by a competent authority on the protection of Personal Data at national or European level - (hereinaftercollectively referred to as the "ApplicableRegulations").

2. WHAT DATA SUBJECTS ARE CONCERNED BY THE PERSONAL DATA WE PROCESS?

We Process Personal Data of end customers and trade partners.

3. WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?

We collect and otherwiseProcess the following Personal Data that is strictly necessary for the purposefor which it is to be used: Personal Data about end customers and tradepartners such as: name, last name, email address, transactions and “qualitativedata” (hobbies, wedding anniversary, participation to LOUIS XIII events).

4. HOW DO WE COLLECT YOUR PERSONAL DATA?

The Personal Data Processed by us as Joint Controllers is provided by you to EDWARD SNELL & CO PTY LTD directly or indirectly, whether in writing, through our website, over the telephone or any other means.

5. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

As Joint Controllers, We process your Personal Data for our respective direct marketing purposes in order to expand the Louis XIII brand in the territory of South Africa.

Upon request, We undertake to provide you with the essence of our arrangement between each other (the Joint Controllers) regarding our respective roles and responsibilities.

6. ON WHAT LEGAL BASES DO WE PROCESS YOUR PERSONAL DATA?

Personal Data is processed on the followinggrounds (legal bases):

Purposes	Legal bases
Direct marketing by email to: End customers (“BtoB” and “BtoC” if they already bought Louis XIII products) (i.e. existing customers); Trade partners (“BtoB”)	Legitimate interest of E. REMY MARTIN & C° and of Edward Snell to carry out direct marketing operations
Direct marketing by email to: End customers (“BtoC”) that haven’t already bought Louis XIII products; Trade partners (“BtoC”)	Consent

Purposes

Legal bases

Direct marketing by email to:

End customers (“BtoB” and “BtoC” if they already bought Louis XIII products) (i.e. existing customers);
Trade partners (“BtoB”)

Legitimate interest of E. REMY MARTIN & C° and of Edward Snell to carry out direct marketing operations

Direct marketing by email to:

End customers (“BtoC”) that haven’t already bought Louis XIII products;
Trade partners (“BtoC”)

Consent

Providing your Personal Data to us is voluntary. If you fail to provide certain information when requested, we may not be able to perform the services you requested from us or we may be prevented from complying with our legal obligations.

7. FOR HOW LONG IS YOUR PERSONAL DATA RETAINED?

We retain your Personal Data for as longas necessary for the fulfilment of the Purposes as described in section 3 above, and for a maximum of 3 years from the date of our last contact with you or, where applicable, until the withdrawal of your consent.

8. HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement all appropriate technical and organisational measures to ensure a level of security of your Personal Data appropriate to the risk, considering the state of the art, the costs of implementation and the nature, scope, context, and purposes of the Processing as well as the risks and their likelihood.

9. WHO HAS ACCESS TO YOUR PERSONAL DATA?

For the purposes of the Processing described in section 3 above, your Personal Data will be communicated to the following parties:

internally within EDWARD SNELL & CO PTY LTD and E. REMY MARTIN & C° to customer services and sales administration departments.

We may also communicate your Personal Data to third party service providers, data processors (i.e., IT service providers).

10. IS YOUR PERSONAL DATA TRANSFERRED ABROAD?

Your Personal Data is shared between EDWARD SNELL & CO PTY LTD and E. REMY MARTIN & C°, as Joint Controllers, for the purpose mentioned in section 3 above, namely direct marketing purposes to expand the Louis XIII brand in the territory of South Africa.

As EDWARD SNELL & CO PTY LTD is located in South Africa, your Personal Data is transmitted to the European Union and then transferred back to South Africa, whose level of protection has not been deemed adequate by the European Commission. Therefore, such transfers take place lawfully, under an agreement which covers the EU requirements for the transfer of Personal Data outside the EU.

We may transfer your information to recipients in other countries, for example entities in our respective company groups, an agent, sub-contractor or third party who carries on business in another country, including one which may not have data privacy laws similar to those in the country where it was collected.

If this happens, we will ensure that anyone to whom we pass your information agrees to treat your information with the same level of protection as if we were dealing with it. Further, your Personal Data will only be transferred to and stored in country that has equivalent, or better, data protection legislation than the country in which the data is collected, or with a service provider which is subject to an agreement requiring it to comply with data protection requirements equivalent or better than those applicable in the country in which the Personal Data was collected.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

To obtain a copy of the relevant adequate safeguards, you can send us your request using the details in section 10“Contact us” below.

11. WHAT ARE YOUR RIGHTS WITH REGARD TO PERSONAL DATA?

In accordance with Applicable Regulations,you have a right of access, right to rectification, right to erasure, right torestriction of processing, right to data portability, and right to objectregarding your Personal Data, as well as the right to withdraw your consent atany time. You can also send us your instructions in order to organize the fateof your Personal Data after your death.

You can exercise these rights by writingto the following e-mail address: privacy@remy-cointreau.com.

You also have the right to lodge acomplaint before a supervisory authority such as:

the French data protection law is applicable: the CommissionNationale de l'Informatique et des Libertés (CNIL) in the event of a breach ofthe Applicable Regulations.
South African data protection law is applicable: the Information Regulator of South Africa; POPIAComplaints@inforegulator.org.za; JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001.

12. CONTACT US

You can contact us if you have any questions about the Processing of your Personal Data or if you wish to exercise your rights at the following address:

Email address: privacy@remy-cointreau.com.