PRIVACY NOTICE

When communicating with us and our customer service

BAT processes your personal data for the purpose of providing customer service to you and to handle any questions, inquiries, claims etc. that you might have about our products, services and BAT in general, e.g. as a workplace or for recruitment purposes. BAT communicates with you through email, phone and website communication such as contact formulas and chats depending on how you choose to contact us.

We may process the following categories of personal data about you:

Ordinary personal data:

Name, email, telephone number, job title and any information that you give us in your inquiry when you contact, e.g. the questions you might have and the information related to these as well as further information that we might need to handle your inquiry.

Information related to any claims or complaints that you might have about our products, e.g. your experience with our products.

When you call our customer service we might record our conversation for internal training purposes if you give us your consent to do so.

If you communicate with us and our customer service for recruitment purposes, e.g. for the purpose of knowing more about life at BAT, the recruitment process etc. we will also process the information about you that you give us, i.e. your contact information, your inquiry, our correspondence and any attachments such as application, CV, etc.

We will however always guide you to our official recruitment channel (careers.bat.com) for job applications or our HR department and we will then delete the material you might have sent.

Sources:

We collect your personal data directly from you when you contact us.

We process your personal data on the following legal bases:

• Article 6.1.a (consent) with respect to recordings

• Article 6.1.b (necessary for the performance of a contract)

• Article 6.1.c (necessary to comply with our legal obligations), including

- regulation that we are subject to for the purpose of handling any claims or complaints that you might have about our products, including regulation that set out our obligations towards you

• Article 6.1.f (necessary for the pursuit of our legitimate interest in operating and developing our business, including

  - providing customer services to you,
  - optimizing our products and our customer service
  - to handle claims and complaints
  - brand our company as a workplace, find the right candidates and help you with any questions you might have about life at BAT and recruitment)

We may share your personal data with:

• Business partners and third parties, including suppliers and vendors, that we work with to assist our company (e.g. suppliers, call centres, service providers, technical and IT and digital support)

• Group entities

• (Potential) purchasers, sellers and advisors in case of a sale or purchase

We will retain personal data processed for this purpose for:

We will retain your personal data for as long as it is necessary in order for us to find a solution on your inquiry, i.e. to answer your questions and/or handle your complaints and claims. As a main rule this is up to 6 months from the end of the communication or the end of the case your inquiry is about.

If your inquiry is or might develop into a potential dispute we may retain your personal data for a longer period of time. The retention period is hereafter depending on the circumstances around your inquiry, including what your inquiry is about, if it involves any damages etc., and we will only retain the personal data in order to be able to document the case and handle a potential (legal) dispute arising from or involving your inquiry and only for the period of time we might be met with a dispute etc. in accordance with the limitation regulation.

Any recordings of conversations that you are a part of based on your consent will be deleted after 30 days.

When you are a customer, supplier, business partner or other third-party representative

BAT processes your personal data for business operations purposes when you represent your employer or have a relation to a company when your employer or such company is a customer, supplier or other third-party to BAT, e.g. if you communicate with BAT as a part of you working for one of BAT’s business partners or other parties that BAT is communicating and co-operating with.

Examples of such communication could be as a part of marketing of our products, sale and distribution of BAT’s products, contact with public authorities, contact with journalists, use of third-party suppliers and agencies to support our business, organisations, retailers, external consultants, BAT ambassadors, cleaning firms, food suppliers, on site guards, etc.

Categories of personal data and sources

Legal basis for the processing

Recipients

Data retention

We may process the following categories of personal data about you:

Ordinary personal data:

Name, job title, workplace, signature and contact information such as your email and telephone number as well as other information that you choose to give us.

Information about the task/job/case etc. that our relationship concern, including all communication in this regard.

If you are visiting or working at our locations, we will also process information about you through our use of CCTV surveillance and logging of the use of access cards.

For this purpose, we will only process your personal data in the case that you are employed with or have a relation to one of BAT’s customer, suppliers or other third-parties that BAT is communicating with as part of our business operations.

Sources:

We collect your personal data either directly from you or from the company that you work for a have a relation to: BAT’s customer, supplier or other third-party that we work with or have a relation to.

We process your personal data on the following legal bases:

Article 6.1.f (necessary for the pursuit of BAT’s legitimate interest in business operations and development), including:

• Communication and co-operations with customers, suppliers and other third parties and business partners that we work with or have a relation to,
• Production of products,
• Sale and distribution of products,
• Marketing of our products
• Security measures, such as the use of surveillance and access cards
• As well as other business-related matters.

We may share your personal data with:

• Business partners and third parties, including suppliers and vendors, that we work with to assist our company (e.g. suppliers, service providers, technical and IT and digital support)
• Social media depending on the character of our agreement
• Group entities
• The company that you work with or have a relation to; BAT’s customer, supplier or other third parties and business partners
• (Potential) purchasers, sellers and advisors in case of a sale or purchase

We will retain personal data processed for this purpose for:

As a main rule we will retain your personal data for up to five years as from the end of the year in which the last purchase or delivery was made, or as from the end of our relationship/collaboration or the relationship/collaboration with the party that you represent or have a relation to.

However, we may store the personal data for an extended period if deemed necessary in a specific case, e.g. for establishing legal claims or in order for BAT to be able to document the relationship and/or certain circumstances with respect to the customer, supplier or other third-party.

Some inquiries follow the retention periods as mentioned under “When communicating with us or our customer service” – please refer to this purpose for more information.