(Effective Date: January 1, 2024)

This Privacy Policy applies to the information that you provide to Reynoldsamerican.com which is operated by RAI Services Company, a subsidiary of Reynolds American Inc. (“RAI”, “we”, “our” or “us”) in connection with your interactions with us via the Website or via one of our communication channels such as mail, email, telephone, text message, mobile app or the Internet. The references in this Privacy Policy to “Website” refers to the website that links to this Privacy Policy. By interacting with us and sharing personal information about yourself or others, you agree that the personal information you share will be handled in accordance with this Privacy Policy, as amended. When we refer to “personal information” in this Privacy Policy, we mean information that directly or indirectly identifies you or can be used to identify you as an individual.  This Privacy Policy does not apply to aggregated, de-identified or anonymous data.

 

Geographic Restrictions. The Website is operated, in whole or in part, from the United States. Personal information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. By using the Website, or transmitting information to us, regardless of where you live in the world, you consent to have any personal information you provide to us transferred to, processed, and stored in the United States or elsewhere in the world, and you authorize us to use and collect your personal information in accordance with this Privacy Policy. We will undertake reasonable steps to protect the privacy and security of personal information according to this Privacy Policy regardless of where it is processed or stored, although we cannot guarantee against illegal access to it and we disclaim liability for such illegal access.

 

The Website is operated for the purpose of distributing information and educating people about our organization and purpose. We may use personal information to communicate with you if you provide us with contact information, to provide the Website, to improve the Website and your experience on the Website, to prevent fraud, to protect the security of our systems, to comply with applicable laws, to protect RAI, its affiliates and Website users.

 

INFORMATION WE COLLECT AND HOW WE COLLECT IT

We may collect contact information from you if you request information from us or ask us a question.

 

When you use or interact with the Website, we will collect certain information automatically, subject to your browser and other usage settings.

 

In general, we automatically gather certain technical information from our Website visitors through our automatic data collection tools, including cookies or server logs. Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit.  To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.  These tools may collect certain standard information that your browser sends to the Website such as the number and frequency of your visits and may include the URL of the last and next website you visit, your browser and operating system, your Internet Protocol (“IP”) address, how long you spend on the Website, and what pages you view here. We may use this information to provide the Website; to understand better how our visitors use the Website; to troubleshoot the Website; to improve the Website; to provide visitors with relevant services and information; and for other similar purposes.

 

Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies, and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the Website.

 

We use Google Analytics to collect information about your use of the Website. Google Analytics collects information such as how often visitors visit the Website, what pages visitors visit, and what other sites they visited prior to or after coming to the Website. We use this information to improve the Website.  You can find more information on how Google collects and processes your data at www.google.com/policies/privacy/partners. To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout.

 

WHO WE MAY SHARE INFORMATION WITH

We may share your personal information with the following parties:

• Our Affiliates and Service Providers. We may share and disclose information among our businesses, including employees, agents and affiliates of our businesses. In addition, we may share your information with non-affiliated businesses that perform services for us. For example, among other things, we may use a service provider to correct technical problems and malfunctions on the Website and to help us provide, improve, protect, and promote the Website and services. When we contract with such service providers to help us conduct our business, we do not permit them to use or store your personal information for any purpose other than the work they are doing on our behalf or as required by law.
• Other Third Parties. We may also share your information with non-affiliated third-parties, including, for example: (1) if we believe that there has been a violation of our policies regarding the Website; (2) if we believe that someone may be causing injury to our rights or property, or those of anyone else; (3) to respond to judicial process or to provide information to law enforcement or other governmental agencies; (4) otherwise as required by law; or (5) in the event of a liquidation, reorganization, merger, consolidation, change of control, asset or stock acquisition/disposition or other corporate combination.

 

HOW WE PROTECT YOUR PRIVACY

We use reasonable precautions, including, but not limited to, technical, administrative, and physical procedures, to protect personal information from loss, misuse, or alteration. Although guaranteed security does not exist on the Internet or offline, we make commercially reasonable efforts to handle such information consistent with this Privacy Policy and applicable laws. Due to the design of the Internet and other factors outside our control, we cannot guarantee that communications between you and our servers will be free from unauthorized access by third parties. Therefore, your use of the Website and sharing of your personal information with us is at your own risk.

 

HOW YOU CAN MANAGE YOUR PRIVACY

Do Not Track Requests & Third-Party Tracking. Unless your browser settings are configured to make your online activities and publicly available information about your online activities (such as traffic data described above) invisible to usage analytics tools, your online activities within a website are not omitted from usage analytics to the extent your browser only sends us a “do not track” message and does not otherwise screen you from tracking without any action on our part. Third-parties, other than our service providers (such as our website analytics providers), do not have authorization from us to track which websites you visited prior to and after visiting the Website. That said, we cannot control all third-party tracking and there may be some third-party tracking over time and across third-party websites that occurs without our knowledge or consent.

How You Can Protect Yourself Against Identity Theft. If you would like to learn more about protecting against identity theft, you can visit the FTC’s website for more information on how to avoid identity theft at: https://www.consumer.ftc.gov/features/feature-0014-identity-theft.

Opting Out of Cookies and Tracking Technologies. The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Without cookies, you may not have access to certain features on the Website.

 

LINKS TO THIRD-PARTY WEBSITES

From time to time, this Website may provide information about or links to unaffiliated third-party websites. Those websites operate independently from us (and our affiliates) and may have their own privacy statements in place which we recommend you review if you visit any linked websites. To the extent any such third-party websites you visit are not owned and operated by us or our affiliates, RAI or our affiliates are not responsible for their content or any use of those websites. The ability to access information of third-parties from the Website, or links to other websites or locations, is for your convenience and does not signify our endorsement of such third-parties, their services, other websites, products, services, locations or other content.

 

NOTICE TO CALIFORNIA, VIRGINIA, UTAH, CONNECTICUT, TEXAS, AND MONTANA RESIDENTS – YOUR STATE LAW PRIVACY RIGHTS

If you are a California, Virginia, Colorado, Utah, Connecticut, Texas, or Montana resident (each, an “eligible resident”), you have certain rights, pursuant to the consumer privacy laws of your state of residence. These state law privacy rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise these rights using the contact details below.

 

Your State Privacy Rights

Right to Know or Access	As an eligible resident, you have the right to request that we disclose what categories of personal information we collect, use, disclose and/or sell; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom we disclose, share or sell information; and specific pieces of personal information we have collected about you; and you have the right to confirm if we are processing your personal information and access your personal information. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, then that service provider will not retain such information provided for verification purposes.
Right to Data Portability	As an eligible resident, you have the right obtain the personal information you request in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, then that service provider will not retain such information provided for verification purposes.
Right to Correct	As an eligible resident, you have the right to request that we correct your inaccurate personal information collected or maintained by us. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, then that service provider will not retain such information provided for verification purposes.
Right to Request Deletion	As an eligible resident, you have the right to request the deletion of your personal information collected or maintained by us. To enable us to fulfill that request, we will need to verify your identity. We may ask for certain information to verify the request in accordance with applicable law. If we use a service provider for such verification, then that service provider will not retain such information provided for verification purposes.
Right to Non-Discrimination	As an eligible resident, you have the right not to receive discriminatory treatment by us for the exercise of any of your privacy rights.
How to Exercise Your State Privacy Rights; Authorized Agents	If you are an eligible resident and would like to submit a verifiable consumer request, you can do so by emailing info@reynoldsamerican.com with the subject line “Privacy Request.” We may ask for certain information to verify a request in accordance with applicable law.   As an eligible resident, you can designate an authorized agent to make a request on your behalf; such authorized agent should use the same method to exercise rights on your behalf. We may require that you provide the authorized agent written permission to submit a request on your behalf and that the authorized agent verifies their own identity directly with us.
Contact Us for More Information	If you have questions about this Privacy Policy, including anything in this section about Your State Law Privacy Rights, please contact via email at info@reynoldsamerican.com.

 

In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us.

 

Sources of Personal Information

As described in the “Information We Collect and How We Collect It” section of this Privacy Policy, we collect personal information automatically from you using cookies and other technologies.

 

Purposes for Collecting Personal Information

We collect, use, and disclose personal information about you for the business and commercial purposes further described in the “HOW WE USE YOUR INFORMATION” section of this Privacy Policy.

 

Collection, Disclosure, and Sale or Share of Personal Information

As described further in the “HOW WE USE YOUR INFORMATION” and “WHEN DO WE DISCLOSE YOUR INFORMATION” section of the Privacy Policy, we disclose personal information listed below internally among the RAI group of companies and with our service providers and contractors that help us operate the Website and business. We may also disclose personal information with a variety of third parties.  If we are subject to certain corporate transactions or reorganizations; with third parties to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented.

For purposes of this Privacy Policy, when we use the term “third party” we mean entities that are not service providers or contractors providing services on our behalf and that are not entities with whom you interact with directly.

In the last 12 months, we have collected each of the categories of personal information noted in the table below and disclosed it, for a business purpose, to the categories of recipients listed below. We did not “share” any of your personal information for cross-context behavioral advertising, profiling, or targeted advertising or “sell” any of your personal information to third parties during the last 12 months.

 

Category of personal information	Categories of Recipients to Whom Personal Information is Disclosed for Business Purposes
Identifiers (such as name, email address, online identifiers or IP address)	Service Providers and Contractors, such as Analytics Vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
Internet or other electronic network activity (such as browsing history, browser type and version, search history, and other information regarding a user’s interaction with the Website, including screen resolution, monitor color depth, operating system, JavaScript version, connection speed, device type used to access the Website (i.e., computer or mobile device), application version, click path taken through the Website, and other publicly available information)	Service Providers and Contractors, such as Analytics Vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
Geolocation data	Service Providers and Contractors, such as Analytics Vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies

 

We do not knowingly collect any personal information of minors under 16 years of age.

We do not collect “Sensitive Personal Information” as defined in applicable privacy laws.

If you would like to print a copy of this Privacy Policy, please select the “Print” button on your web browser.

The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.

 

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy without prior notice to you. We will update this page when we do so. You should check this Privacy Policy frequently on this Website to see recent changes. Use of the Website following such changes constitutes your acceptance of the revised Privacy Policy then in effect.