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Privacy Notice

This Privacy Notice explains how British American Tobacco Finland Oy ("we", "us" or “BAT”) processes your personal information as a data controller depending on your relation to BAT.

We are always committed to protecting and respecting your privacy and to process your personal data in accordance with relevant data protection legislation, i.e. the General Data Protection Regulation (the “GDPR”) and the national data protection legislation.

If you have any concerns or questions regarding BAT’s
processing of your personal data, please do not hesitate to contact us using the below listed contact information.

1. DATA CONTROLLER

The entity responsible for the processing of your personal information is:
British American Tobacco Finland Oy
Itämerentori 2
00180 Helsinki
Company registration number: 516403-6575
Email: gdpr_emails@bat.com
Phone: (+358) 9 731 311

2. DESCRIPTION OF THE PROCESSING

In the following schedules you will find information about how BAT processes your personal data depending on your relation to BAT and the purposes of which we process your personal data. 

In the schedules you will find information on how we process your personal data, including information on our purposes with processing, the categories of personal data we process about you, how we collect your personal data, the legal basis on which we rely on when processing your personal data, information on the parties that we may share your personal data with and information on how long we retain your personal data.

You can choose between information on how we process your personal data, when:

  • you communicate with us and our customer service
  • you are a customer, supplier or other third-party representative

Please choose the schedule that is relevant for you.

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.

Categories of personal data and sources

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.

Legal basis for the processing

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)
Recipients

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
Data retention

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
Purpose

BAT processes your personal data for business operations purposes when you represent your employer or have a relation to a third party when your employer or such third party 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

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.

Legal basis for the processing

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..
Recipients

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
Data retention

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.

3. TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA

In some cases, we will be transferring personal data to countries outside the EU/EEA.

Such transfers will take place on the basis of the following legal basis:

a) The country/countries has/have been deemed by the Commission of the European Union to have an adequate level of protection of personal data, i.e. the country is a “secure/adequate third country”

b) The country/countries has/have not been deemed by the Commission of the European Union to have an adequate level of protection of personal data. We will provide appropriate safeguards for the transfer:

  • through the use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities. You may obtain a copy of the contract/agreement by contacting us at gdpr_emails@bat.com.
  • through the use of binding corporate rules between BAT entities. You may obtain a copy of these by contacting us at gdpr_emails@bat.com.

c) In the absence of a decision that the country is secure/adequate and appropriate safeguards as mentioned above the transfer might in some, however limited cases take place if i) you have given your consent to the transfer, ii) the transfer is necessary for the performance of a contract between you as a data subject and BAT as data controller or the implementation of pre-contractual measures taken at your request, or iii) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of you as a data subject between BAT as the controller and another third party.

4. AUTOMATED DECISIONS

We will not use automated decision-making pursuant to GDPR article 22.

5. MANDATORY INFORMATION

Some of the information we process about you might be mandatory for us to collect in order to provide you the service that you request, e.g. when buying or receiving our products it is mandatory for us to collect certain information about you to sell you the products as well as it is mandatory for you to provide us with certain information with respect to customer service. The consequence of not providing us any mandatory information is however alone that we will not be able to provide you the requested service.

6. YOUR RIGHTS

You have the following rights:

  • You have the right to:
    - request access to your personal data (GDPR article 15)
    - request rectification of your personal data (GDPR article 16)
    - request erasure of your personal data (GDPR article 17)
    - have the processing of your personal data restricted (GDPR article 18)
    - receive your personal information in a structured, commonly used and machine-readable format (data portability) (GDPR article 20)

If processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent. You may withdraw your consent by contacting us at gdpr_emails@bat.com and (+358) 9 731 311. If you wish to withdraw your consent with respect to cookies, please also see our cookie overview and policy.

Furthermore, you have the right to object to processing of your personal data as follows.

  • If processing of your personal data is based on article 6(1)(e) or article 6(1)(f), see above regarding legal basis, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data.
  • Where your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data about you for such marketing.

You can take steps to exercise your rights by contacting us at gdpr_emails@bat.com and (+358) 9 731 311.

There may be conditions or limitations on these rights. It is therefore not certain that for example you have the right of data portability in the specific case - this depends on the specific circumstances of the processing activity.

You may also always lodge a complaint with the local data protection supervisory authority:

Office of the Data Protection Ombudsman
P.O. Box 800
00531 Helsinki
Email: tietosuoja@om.fi
Phone: +358 (0)29 566 6777

Last updated: 20 December 2020

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