We take privacy seriously. This notice tells you who we are, what information about you we collect, and what we do with it.
We are Rothmans, Benson and Hedges Inc, an affiliate of Philip Morris International. Our details (name, address, etc.) will have been given to you separately at the time of (or to confirm) the collection of information about you, for example, in a notice on an app or a website, or in an e-mail or SMS, containing a link to this notice.
We may collect information about you in various ways.
We may collect information that you provide directly. Typically this will happen when you:
We may collect information about you automatically. Typically this will happen when you:
We may also collect information in other contexts made apparent to you at the time.
We may collect various types of information about you:
Information that we collect from you directly will be apparent from the context in which you provide it. For example:
Information that we collect automatically will generally concern:
Information that we collect from third parties will generally consist of publicly-available profile information (such as your preferences and interests), for example from public social media posts.
In this section, we describe the purposes for which we use personal information. However, this is a global notice, and where the laws of a country restrict or prohibit certain activities described in this notice, we will not use information about you for those purposes in that country.
Subject to the above, we use information about you for the following purposes:
The legal basis for our use of information about you is one of the following (which we explain in more detail below):
The purposes for which we use information about you, with corresponding methods of collection and legal basis for use, are:
|Purpose||Method of collection and legal basis for processing|
Comply with regulatory obligations
This information is generally provided to us by you directly.
We use it because it is necessary for us to comply with legal obligations, in certain areas of our business, to deal only with adults, or, in countries where there is no such legal obligation, because we have a legitimate business interest to deal only with adults, that is not overridden by your interests, rights and freedoms to protect information about you.
Deliver RBH touchpoints, press releases and mail alerts
This will typically be a combination of information that you provide to us (for example, your name and contact and social media details); and information that we collect automatically (for example, using technology to monitor use of RBH touchpoints).
We use it on the grounds that we have a legitimate business interest to operate RBH touchpoints, and to customize your experiences, in these ways that is not overridden by your interests, rights and freedoms to protect information about you.
Administer our contract for user generated content with you (where applicable)
This information is generally provided to us by you directly. We use it because it is necessary for us to fulfil our contract with you and because we have a legitimate business interest to administer our relationship, market our products (including by using any content you submit to a digital RBH touchpoint), and to operate RBH touchpoints that is not overridden by your interests, rights and freedoms to protect information about you.
We will generally either receive the information from you directly. We use it because we have a legitimate business interest to run our business, manage our relationship with you and maintain the security and integrity of our IT systems that is not overridden by your interests, rights and freedoms to restrict use of information about you.
Business analytics and improvements
This will typically be a combination of information that you provide to us; information that we collect automatically; and (where permitted by law) information that we acquire from third parties.
We use it on the grounds that we have a legitimate business interest to analyze and to improve our business performance, our products, RBH touchpoints, outlets and events, and to invite others to get involved in promoting Products, that is not overridden by interests, rights and freedoms to protect information about you.
Where we do not base our use of information about you on one of the above legal bases, we will ask for your consent before we process the information (these cases will be clear from the context).
In some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.
We may share information about you with:
As with any multinational organisation, PMI affiliates transfer information globally. Accordingly, information about you may be transferred globally (if your information is collected within the European Economic Area, this means that your information may be transferred outside it).
When using information as described in this notice, information about you may be transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards.
For example, PMI affiliates within the European Economic Area (“EEA”) may transfer personal information to PMI affiliates outside the EEA. In all cases, the transfer will be:
In all cases, appropriate security measures for the protection of personal information will be applied in those countries or territories, in accordance with applicable data protection laws.
We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy and security requirements.
We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes.
Typically, we retain data based on the criteria described in the table below:
|Database records||If you have signed up to receive e-mail alerts (and similar) or to use an RBH digital touchpoint, most of the information in your profile is kept for the duration of the period you continue to receive the alerts, use the digital touchpoint, or respond to our communications. However, some elements of your profile, such as your history of use of the RBH digital touchpoint, naturally go out of date after a period of time, so we delete them automatically after defined periods as appropriate for the purpose for which we collected them.|
|System audit logs||System audit logs are retained typically for a period of only a few months.|
|Business analytics||Business analytics data is typically collected automatically when you use RBH touchpoints and anonymised/aggregated shortly afterwards.|
You may have some or all of the following rights in respect of information about you that we hold:
We offer you easy ways to exercise these rights, such as “unsubscribe” links, or giving you a contact address, in messages you receive.
Some mobile applications we offer might also send you push messages, for instance about new products or services. You can disable these messages through the settings in your phone or the application.
The rights you have depend on the laws of your country. If you are in the European Economic Area, you will have the rights set out in the table below. If you are elsewhere, you can contact us (see the paragraph “who should you contact with questions?” at the end of this notice) to find out more.
|Right in respect of the information about you that we hold||Further detail (note: certain legal limits to all these rights apply)|
|To request us to give you access to it||
This is confirmation of:
|To request us to rectify or update it||
This applies if the information we hold is inaccurate or incomplete.
|To request us to erase it||
This applies if:
|To request us to restrict our processing of it||
This right applies, temporarily while we look into your case, if you:
This right applies also if:
|To object to our processing it||
You have two rights here:
|To withdraw your consent to our using it||
This applies if the legal basis on which we use the information about you is consent. These cases will be clear from the context.
|To data portability||
then you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible for us to do so.
|To lodge a complaint with the supervisory authority in your country||
Each European Economic Area country must provide for one or more public authorities for this purpose. You can find their contact details here. For other countries please consult the website of your country’s authority.
According to which country you are in, you may have some additional rights.
If you have any questions, or wish to exercise any of your rights, you can contact us at DataPrivacy.RBH@rbhinc.ca.
If your country has a data protection authority, you have a right to contact it with any questions or concerns. If RBH cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.
We may update this notice (and any supplemental privacy notice), from time to time. We will notify you of the changes where required by law to do so.
Last modified 27 June 2018.