PRIVACY POLICY AND YOUR CALIFORNIA PRIVACY RIGHTS

(Effective Date: 9/14/2020)

This Privacy Policy applies to the information that you provide to R. J. Reynolds Tobacco Company, American Snuff Company, LLC, R. J. Reynolds Vapor Company, RJR Vapor Co., LLC, Modoral Brands Inc., Santa Fe Natural Tobacco Company, Inc. and certain of their respective U.S. affiliates (collectively, “we”, “our” or “us”) in connection with your interactions with us, whether in person or via mail, email, telephone, text message, mobile app or the Internet. The references in this Privacy Policy to “websites” also refer to mobile apps if applicable in the relevant context. By interacting with us and sharing information about yourself or others, you agree that the information you share will be handled in accordance with this Privacy Policy, as amended.

Restrictions on Access and Use

Adult Tobacco or Nicotine Consumers Only. In order to interact with us, you must be 21 years of age or older and have certified that you are a tobacco or nicotine consumer who is 21 years of age or older, want to receive information and promotions concerning our products and understand that providing false information may constitute a violation of law. Before you are eligible to be added to our marketing contact list (“Marketing List”) or before making a purchase on one of our brand websites, we will verify that you are 21 years of age or older. If you are under 21 years old or have otherwise gained access to one of our brand websites by providing false information such as your date of birth, leave the website immediately.

Geographic Restrictions. Our brand websites are 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 our brand websites, 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.

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Why We Collect

We collect information for a variety of business purposes, such as to provide the services you request (e.g., to mail you requested coupons), to tailor our communications about our products and brands to you, and for consumer research and/or other business purposes.

We strive to maintain accurate information about you on our Marketing List through consumer surveys, adult tobacco or nicotine consumer-initiated contacts, and responses to our marketing programs (online and offline), as well as through address update services, among other things.

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What We Collect and How

We collect information about you in many ways, including directly from you, your devices and your interactions with us, whether in person, by mail or electronically, including on our brand websites. We may also receive information about you from service providers that provide services for us in connection with our brand websites such as address update services, as well as from service providers to whom you have provided information.

Personal Information. “Personal information” is data that can be used to uniquely identify or contact an individual, such as your name, date of birth, driver’s license number, the last four digits of your Social Security number, telephone number, mailing address, billing address or email address. There are several ways in which you may explicitly and intentionally provide us with, and consent to our collection of, personal information, including:

Examples of Information That You May Provide:

  • Registering for our Marketing List When you register for our Marketing List, we collect, and associate with your account, information like your name, date of birth, email address, phone number, mailing address, billing address and frequently the last four digits of your Social Security number. We may also rely upon third-party services to review publicly available information about you to verify your age.
  • Updating Your Account. You can update certain personal information associated with your account by logging into your account. In addition, we may periodically ask you to confirm or update your email or mailing address, or information regarding product and brand preferences, among other things.
  • Completing a “Contact Us” Form. If you complete a “contact us” request form, you must be registered for an account on our brand website and be logged into your account.
  • Initiating a “Chat with Us” Request. If you initiate a “chat with us” request, you must be registered for an account on our brand website and be logged into your account.
  • Submitting Content to Us. When you use our brand websites, or communicate with us in other ways (e.g., email, mail, telephone, text-message, social media, mobile app or in person), we may store, process and transmit content you share or review (including things like your comments on message boards and photos you upload) and information related to them (for example, location tags in photos). This will make it easy for you to do things like share items/materials, post messages, and respond to offers and other information from us.
  • Making a Purchase from Us, or Using One of Our Coupons. With respect to brand websites that permit direct e-commerce sales to adult tobacco or nicotine consumers, you may submit your credit card information if you place an order with us. The information is collected and validated by a third-party credit card processor and stored using industry standard encryption. Credit card information is used only to process your order. In addition, we may collect information regarding your use of coupons we may offer for use at retail or on one of our brand websites that permit direct e-commerce sales.

Examples of Information That May Be Collected Automatically:

  • Location Information. Your devices may transmit general location information (e.g., region, city and state) to us. This allows us to provide you with content and offers that may be relevant to you based on your location, such as special content, offers, coupons, and promotions that are available in your area.
  • Traffic Data. Whenever you visit or interact with our brand websites, we (as well as our service providers) may use assorted technologies that automatically or passively collect information about how it is accessed and used by you. We refer to this information as traffic data. Traffic data may include, but is not limited to, your IP address, device type used to access the websites (i.e., computer or mobile device), unique number assigned to identify such device, application version, click path taken through the websites and your use of features or applications on the websites. Technologies we use to collect traffic data, include, but are not limited to, cookies and beacons.
    • Cookies. Cookies are pieces of information that a website stores on your computer. We may place temporary cookies or similar files on your computer or other devices used to access our brand websites to facilitate navigation (e.g., to streamline the login process), to personalize your experience while visiting our brand websites (e.g., allowing us to select content that is most likely to appeal to you based on your preferences or location), and for security purposes (e.g., to maintain security while you browse our brand websites and help ensure that only authorized adult tobacco or nicotine consumers are on our brand websites). Please refer to your browser’s help menu for more information on how to manage your cookie settings. If you disable or opt out of receiving cookies, some features and services on our brand websites may not work as intended and you may not have access to all of the services and features we may offer.
    • Beacons. Web beacons (also known as spotlight tags, Internet tags, pixel tags and clear GIFs) are transparent images that may appear on our brand websites, in our emails, or elsewhere. Web beacons may collect information about your interactions with our brand websites and our emails, including the pages you view, the emails you open, the features you use, the links you click and other actions you take in connection with our brand websites or emails from us in order to deliver content that may be of the most interest to you and to improve our brand websites, our services, and our products.

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Who We May Share Information With

We do not sell, rent or share information about you except as described in this Privacy Policy.

  • 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’s database to confirm that you are 21 years of age or older when you register for our Marketing List, to correct technical problems and malfunctions on our brand websites and to help us provide, improve, protect, and promote our brand websites, brands, products or services, such as service providers that administer our sweepstakes, contests and other promotional events. 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.
  • Certain Mobile Carriers. If you request services via a mobile device, your request will be transmitted via your mobile carrier’s network and your carrier may have access to it. Consult your carrier’s privacy policy for additional information.
  • Other Adult Tobacco or Nicotine Consumers. When you register for our brand websites you will create a user name. Your user name, alias, avatar, location, city and state of residence may be shared with other adult tobacco or nicotine consumers that access our brand websites. Moreover, when logged into our brand websites, your on-line presence within our brand websites may be disclosed, including if you make submissions or post comments, and we or other adults on the Marketing List who access our brand websites may be able to comment on submissions or comments you choose to share. Certain features (such as message boards) may let you make additional information available to us or other adults on the Marketing List who access our brand websites. To further protect your privacy, we encourage you not to post or otherwise disclose on our brand websites your phone number, physical address, e-mail address, or other personally-identifying or sensitive information.
  • 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 our brand websites; (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.

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How We Protect Your Privacy; Use at Your Risk

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 our brand websites, social media and other platforms and sharing of your personal information with us is at your own risk.

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How You Can Manage Your Privacy

Opting-Out. If at any time you wish to be removed from our Marketing List, you can contact us by calling 1-800-665-6381 to speak with a customer service representative.

Your option not to receive promotional and marketing material will not preclude us from corresponding with you, by email or otherwise, regarding your existing or past business relationships with us (e.g., any purchase of our products or use of our services, or responses to requests for information you pose to us either through use of our brand websites or by other means), will not preclude us from accessing and viewing your personal information in the course of maintaining and improving our brand websites and our services, and may nonetheless be subject to dissemination to the entities identified above in the section of this policy entitled “Who We May Share Information With.”

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 brand 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 brand website analytics providers), do not have authorization from us to track which websites you visited prior to and after visiting our brand websites. 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.

Making Changes to Your Personal Information. You can update certain personal information associated with your account (such as mailing and email address) by logging into your account.

How You Can Protect Your Privacy When Using the Site. You understand that personal information that you post in any public areas of our brand websites or social media channels can be read, collected, or used by other users of our brand websites, and could be used to send you unsolicited messages. You are encouraged to exercise caution when posting personal information about yourself in public areas.

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.

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Links to Third-Party Websites

From time to time, we 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, neither we nor our affiliates are responsible for their content or any use of those websites. The ability to access information of third-parties from our brand websites, 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.

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Notice to California Residents - Your California Privacy Rights & Shine the Light

If you are a California resident, you have the right, pursuant to Section 1798.83 of the California Civil Code, to receive once a year, free of charge: (1) information identifying each third-party company to whom we may have disclosed, within the past year, personal information pertaining to you for that company’s direct marketing purposes; and (2) a description of the categories of personal information disclosed to that third-party company in the immediately preceding calendar year. If you are a California resident and would like to make this request, please call 1-800-665-6381. In addition, please refer to "Who We May Share Information With" above to see our practices related to our affiliates.

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Notice to California Residents - Your CCPA Rights

If you are a California resident, you have certain rights, pursuant to the California Consumer Privacy Act of 2018 (or “CCPA”). These CCPA 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.

Right to Know As a California resident, you have the right to request that we disclose what personal information we collect, use, disclose and/or sell. 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, that service provider will not retain such information provided for verification purposes.
Right to Request Deletion As a California resident, you have a 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, that service provider will not retain such information provided for verification purposes.
Right to Non-Discrimination As a California resident, you have a right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights.
Authorized Agent As a California resident, you can exercise your CCPA rights or you can designate an authorized agent to make a request 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 CCPA Rights, please contact us at 1-800-665-6381.

 

Category of personal information Sources of personal information Business or commercial purpose for which it was collected Categories of third-parties with whom the business shares personal information
Identifiers (such as name, date of birth, driver’s license number, last four digits of Social Security number, telephone number, mailing address, email address, internet protocol address, and unique number assigned to identify the device used to access the brand website) Directly from you; via our service providers For our operational purposes; performing services on behalf of the business including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, processing payments, verifying information, providing advertising or marketing services and providing analytic services; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes N/A
Categories of personal information outlined in Section 1798.80(e) (such as name, last four digits of Social Security Number, address, telephone number and driver’s license number) Directly from you; via our service providers For our operational purposes; performing services on behalf of the business including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, processing payments, verifying information, providing advertising or marketing services and providing analytic services; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes N/A
Internet or other electronic network activity (such as browsing history, browser type and version, search history, and other information regarding a consumer’s interaction with an internet website, including screen resolution, monitor color depth, operating system, JavaScript version, connection speed, device type used to access the brand website (i.e., computer or mobile device), application version, click path taken through the brand website, and other publicly available information) Directly from you; via our service providers For our operational purposes; performing services on behalf of the business including providing advertising or marketing services and providing analytic services; auditing related to a current interaction with the consumer and concurrent transactions; and auditing compliance with relevant standards; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes N/A
Characteristics of certain protected classifications under California or federal law (such as age (40 years or older) and sex (including gender)) Directly from you; via our service providers For our operational purposes; performing services on behalf of the business including maintaining or servicing accounts, verifying information, providing advertising or marketing services and providing analytic services; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity; commercial purposes N/A
Commercial information, including products or services purchases, obtained, or considered, or other purchasing or consuming histories or tendencies Directly from you; via our service providers For our operational purposes; performing services on behalf of the business including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying information, providing advertising or marketing services and providing analytic services; commercial purposes N/A
Geolocation data Directly from you; via our service providers For our operational purposes; performing services on behalf of the business including providing advertising or marketing services and providing analytic services; commercial purposes N/A
Inferences drawn from any personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior and attitudes Derived from information we received directly from you and via our service providers For our operational purposes; performing services including maintaining or servicing accounts and providing advertising or marketing services and providing analytic services; commercial purposes N/A

If you are a California resident and would like to submit a verifiable consumer request, you can do so using any of the following designated request methods:

  • To submit a request on behalf of yourself, please complete a webform using this link CCPA_Rights_Request;
  • To submit a request for a California resident as an Authorized Agent, please complete a webform using this link CCPA_Agent_Request;
  • For information regarding submitting a Household request, please visit this link.

Alternatively, you may also call our toll-free number at 1-877-881-0861 to submit a request. Please follow the voice prompts and speak slowly and clearly so we may complete your request.

We may ask for certain information to verify a request in accordance with applicable law.

We did not disclose or sell any personal information to third parties for their business or commercial purposes during the last 12 months. We do not knowingly collect any personal information from anyone under 21 years of age.

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

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Changes To This Privacy Policy

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

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Contact Us

Should you have any other questions about our Privacy Policy, please contact us at 1-800-665-6381.

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