Privacy Policy - Nordic Spirit Website Effective May 2022

Gallaher Limited is a company incorporated in England and Wales with company registration number 01501573 and whose registered office is at 1 Werter Road, Putney, SW15 2LL England ("JTI”, “we”, “us”, “our”) are committed to protecting and respecting your privacy.

This Privacy Policy ("Privacy Policy") (together with our Website Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the applicable data protection law, including the UK General Data Protection Regulation, and any subsequent data protection legislation, the controller of your personal data is JTI.

This Privacy Policy explains how we collect, use and share your personal data. It also explains the rights you have over your personal data under data protection law.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to consumer@nordicspirit.co.uk, call us on 0800 169 2891 or by writing to Customer Contact Centre: Freepost CUSTOMER CONTACT CENTRE, PO Box 8, Crewe, CW1 6GF.

1. YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

2. INFORMATION WE MAY COLLECT

We may collect the following data about you, in the following ways:

• Information you give us.
  You may give us information about you by filling in forms on our site www.nordicspirit.co.uk our associated micro-sites (our site) or by corresponding with us by phone, text, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, provide customer feedback, participate in our marketing and rewards schemes (such as Club 64), enter a competition, survey or other similar activities and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number.

• Information we collect about you.
  With regard to each of your visits to our site we may automatically collect the following information:

• Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit, including: the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Contact Centre;
• Information relating to your advertising and marketing preferences, including information about personalised offers and rewards;
• Information from operating system and platform and other technology on the devices you use to access our website;
• Information collected for market research;
• Notes of conversation with you made in phone calls;
• Information concerning you and your account such as your profile, purchases made, feedback you have given and other sales data; and
• Your IP address, login data, traffic data, weblogs and other communication data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

• Information we receive from other sources.
  We may receive information about you (e.g. consumer account information, including name and contact details) if you use any of the other websites we operate or the other services we provide. We need this information to identify you across our different platforms to provide you with the agreed services (e.g. rewards).
• We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Please refer to their privacy policies to learn more.

• Information we receive from you as part of the age verification process:

• No part of this website is intended to be accessible to persons under 18 and we do not knowingly collect personal data relating to children.
• We are legally required to verify your age. You will therefore be required to complete age verification process conducted on our behalf by a third party, GB Group plc, to prove to our satisfaction that you are at least 18 years old before you can order any of our products. Your personal data collected from you as part of this process is only shared with GB Group plc for the purposes of verifying your age. For more details on age verification process please visit https://nordicspirit.co.uk/age-confirmation/
• Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services) or perform our legal obligations. In this case, we may have to cancel a product or service you have with us but we will notify you at the time.

3. USES MADE OF THE INFORMATION AND PURPOSES FOR WHICH WE USE YOUR INFORMATION

We will only use your information where the law allows us to. Most commonly, we will use your information in the following circumstances:

• Where we need to perform the contract we are about to enter into, or have entered into, with you
• Where we need to comply with a legal or regulatory obligation
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we have obtained your consent to process your data.

These are known as “lawful grounds” under data protection law. Note that we may process your information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at consumer@nordicspirit.co.uk if you need details about the specific legal ground we are relying on to process your personal data.

4. USE OF YOUR INFORMATION.

We use information held about you in the following ways:

• to determine whether or not to grant you access to the site or to allow you to purchase products from the site;
• to record, process, handle and administer request(s) for information in relation to our products;
• to administer this site, our systems and for internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
• to process your order;
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to contact you regarding offers on our products;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
• to make suggestions and recommendations to you about goods or services that may interest you or them;
• we will contact you only by email, post or phone as determined by you when you select your contact preferences in your account. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please ensure your Contact Preferences, in your account, are updated, or otherwise let us know via consumer@nordicspirit.co.uk , 0800 169 2891 or by writing to Customer Contact Centre: Freepost CUSTOMER CONTACT CENTRE, PO Box 8, Crewe, CW1 6GF. Please note that it may take up to 30 days for us to process your request;
• to measure or understand the effectiveness of advertising we serve to you and others (e.g. understanding what offers and rewards are of interest to you), and to deliver relevant advertising, including personalised offers, to you where you have opted in to this;
• to allow you to participate in interactive features of our service, when you choose to do so;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to notify you about changes to our service, changes to our site or other changes which might otherwise affect you; and
• as part of our efforts to keep our site safe and secure.

5. INFORMATION WE RECEIVE FROM OTHER SOURCES.

We may combine this information with information you give to us (e.g. via our surveys) and information we collect about you (e.g. information about your purchases, transactions and interactions). We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

6. MARKETING

You have the right to ask us not to process your personal data for marketing purposes. If you do not wish to receive marketing materials from us any longer, please update your contact preferences on your account, or alternatively write to us at consumer@nordicspirit.co.uk, call us on 0800 169 2891 or by writing to Customer Contact Centre: Freepost CUSTOMER CONTACT CENTRE, PO Box 8, Crewe, CW1 6GF.

Please note that it may take up to 30 days for us to process your request.

7. LINKS TO OTHER WEBSITES

Our site may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and read the Privacy Policy applicable to the website in question before proceeding to use that website.

8. DISCLOSURE OF YOUR INFORMATION

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Policy.

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Our suppliers, reward partners, and sub-contractors that help us deliver you our marketing and rewards schemes (such as Club 64) and contact you about products that might be of interest to you.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
• Our payment provider processes your payment information in an encrypted format. This means that we do not have sight of these. We recommend you read their privacy policy here https://online.worldpay.com/terms/privacy

We may disclose your personal information to third parties in the following circumstances:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If JTI or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of sale and other agreements; or to protect the rights, property, or safety of JTI, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In the event that we need to disclose your personal data to external professional advisers such as accountants, bankers, insurers, auditors and lawyers.

9. WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the UK and European Economic Area ("EEA"). It may also be processed by staff operating outside the UK and EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

Whenever we undertake such transfers, we ensure a similar degree of protection is afforded to your personal data by ensuring at least one of the following safeguards is implemented:

• the recipient country that has been deemed by the UK to provide an adequate level of protection for personal data; or
• where an adequacy decision has not been provided with respect to a recipient country, we rely on the standard contractual clauses as approved in the UK (or equivalent clauses as adopted and approved by the European Commission, where applicable).

In some occasional circumstances, we may rely on a derogation to the data protection laws that apply to transfers of personal data to third countries. For example, if such transfers are based on your consent or necessary for the performance of a contract between us.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data to third countries.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

10. DATA SECURITY

Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access, and to prevent your information being accidentally lost. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your information on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. HOW LONG WE WILL KEEP YOUR INFORMATION

We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To decide the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your information, the purposes for which we process your information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can contact us and ask us for details of the retention periods for different aspects of your personal data in case you want to learn more.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

12. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your information which we have listed below.

• Request access to your personal data (known as a “data subject access request”).
  This right entitles you to receive a copy of the personal data we hold about you. It also entitles you to receive certain information on how we use your personal data and to check that we are lawfully processing it. We will usually provide your personal data to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal data will be provided to you by electronic means where possible.
• Request correction of your personal data where there is incomplete or inaccurate information.
  This right entitles you to have any incomplete or inaccurate data we hold about you corrected. We always take care to ensure that the information we hold about you is accurate and where necessary up to date. If you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, you may request to change your personal details anytime by contacting us.
• Request erasure of your personal data.
  This is sometimes known as the "right to be forgotten". It entitles you, in certain circumstances, to ask us to delete or remove your personal data. These circumstances include, for example: (a) where we no longer need your personal data for the original purpose we collected it for; (b) where you have exercised your right to withdraw consent; (c) where you have successfully exercised your right to object to processing (see below); and/or (d) where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.
  Note, however, that we may not always be able to comply with your request of erasure. Whilst we will assess every request, there are other factors that we will need to take into consideration. For example, we may be unable to erase your information if retention of your personal information is reasonably necessary to: (a) comply with our legal obligations; (b) meet our legal obligations; (c) resolve disputes; (d) maintain security; and/or (d) prevent fraud and abuse.
• Object to processing of your personal data
  This right entitles you to object to our processing of your personal data in certain circumstances. It applies where we process your personal data based on our legitimate business interests. In some cases, we may refuse your request to object to our processing of your personal data. This is in circumstances where we can demonstrate that we have compelling legitimate grounds to process your personal data which outweighs any prejudice to your rights and freedoms.
  With respect to direct marketing, you have control over the extent to which we market to you and you have the right to request that we stop sending you marketing messages at any time. For information about how to let us know you do not want to receive marketing messages, see section 6 of this Privacy Policy. Please note that even if you exercise this right because you do not want to receive marketing messages, we may still send you service related communications where necessary.
• Request restriction of processing your personal data
  This right entitles you to ask us to suspend the processing of your personal data in the following circumstances: (a) if you want us to establish the accuracy of your information; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your information to you or a third party.
  This right entitles you to request the transfer of your personal data to you or to a third party in certain circumstances. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to processing carried out by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent where we are relying on consent to process your data. Please refer to section 6 of the Privacy Policy above for ways in which you can update your marketing preferences.
• Right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/make-a-complaint/ for how to do this.

If you wish to exercise any of the rights set out above, please contact us at consumer@nordicspirit.co.uk, call us on 0800 169 2891 or write to us at Customer Contact Centre: Freepost CUSTOMER CONTACT CENTRE, PO Box 8, Crewe, CW1 6GF

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

13. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.