Privacy & cookies

PRIVACY NOTICE

Thank you for visiting the Imperial Brands PLC website. Imperial Brands and its affiliated companies welcome your interest in this website (www.zhil8.com).

We are committed to protecting your privacy online and off. This notice, our “Privacy Notice”, explains what personal information we collect about you either directly or indirectly and how we use, share and look after that information. We encourage you to review our Privacy Notice carefully.

This Privacy Notice applies from 27 June 2019. It applies when we collect personal information about:

  • visitors to our website
  • visitors to our premises
  • people making general enquiries, whether online or by contacting us offline
  • people making complaints about us or our products, online or not
  • shareholders visiting our website
  • others connected to our Imperial Brands businesses or employees

This website includes links to different sub-sites for Imperial Brands businesses, products and services, and careers, which may have their own privacy notice and may be operated by other Imperial companies. These privacy notices should be read in conjunction with this Privacy Notice. Please read these if you visit our sub-sites. For example, if you click on our Next Generation Products page, you can be directed to a sub-site operated by our subsidiary Fontem Ventures B.V. displaying a privacy notice relevant to that business. Alternatively, if you apply for a job with an Imperial company through the careers area of this website, you will be directed to the Global Careers or the Intern, Graduate and MBA Opportunities sub-sites, which are operated by Imperial Tobacco Limited. You will find relevant privacy notices there.

There is a privacy statement addressed to shareholders in our Shareholder Centre.

In addition to the commitments set out in this Privacy Notice, we live by a set of data privacy rules which apply to the processing of all personal information by our organisation. These privacy rules can be found in our Code of Conduct, which can be downloaded from our website here

If you have any questions about how we handle or protect your personal information, please contact us using the contact details below.

Who we are

We are Imperial Brands PLC, 121 Winterstoke Road, Bristol, BS3 2LL in the United Kingdom. We are responsible for operating this website for the Imperial Brands group of companies.

Personal information

Personal information is any information that tells us something about you. This could include information such as your name and contact details. Some personal information is categorised as "special" under data protection legislation. This includes information relating to health, racial or ethnic origin, religious or philosophical beliefs, political opinions, genetic and biometric data, sex life, sexual orientation and trade union membership. This personal information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data. We may process special categories of personal information and criminal conviction information in limited circumstances with your explicit consent unless we have a legal reason to do so without your consent. Where we ask for your consent, we will explain at the time the purpose for which the personal information will be used. Otherwise, this Privacy Notice applies.

Types of personal information we collect

We collect personal information to manage our business, maintain communications with analysts and investors, engage with people who want to stay in touch with us or who have questions or complaints about us or our products, and to comply with our regulatory obligations.

Information you provide to us

We collect information you voluntarily provide to us, such as your name and contact details, for instance, when you make a general enquiry or sign up for our email alert service, or when you do business with us. We may also ask you to provide information to us so that we can respond to your enquiry or complaint.

Information we collect automatically

We collect information about you automatically, such as information collected by cookies and similar technologies when you use, access or interact with us via our website. For more information about our use of cookies, see our Cookies Policy below.

Information we collect from other sources

In some circumstances, we collect personal information from employees, our subsidiaries, other business partners and, in the case of the investigatory work we need to do to comply with our regulatory obligations, law enforcement and other public bodies. Where possible and as long as we are not prevented by law from doing so, we will tell you when we collect your personal information from third-parties.

Information we collect and the purposes for which we collect it

Visitors to our website

If you are a visitor to our website, you should read this Privacy Notice in conjunction with our Cookies Policy below.

We use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out the number of visitors to the various parts of our website and how they interact with the content on the site. This information does not identify any individuals.

We use this information to maintain and monitor the performance of our website, and to look for ways of improving our website and the services it offers to users.

Visitors to our premises

We take care to secure our premises appropriately. We collect personal information so that we know who is on our premises. You will be asked to comply with our security requirements, which will include verifying your identity. We use CCTV to monitor our premises. We collect ID and CCTV information for security and safety purposes.

If you use the Wi-Fi on our premises, we will provide you with the address and a password. We record the device address and will automatically allocate you an IP address while you are on our premises. We log traffic information in the form of the websites visited, the duration and date sent/received. We use the information to provide you with access to the internet while you are on our premises. We monitor and from time to time test the security of our networks, which may occur while you are using the Wi-Fi. Imperial has no responsibility or control over your use of the internet while you are on our premises.

People who sign up to our newsletters and email alert service

If you ask us to send you newsletters, other communications or our email alerts, we collect your contact details and keep a record of your communications preferences so that we can send you just what you want.

People making general enquiries

When you contact us to make an enquiry, we collect the information we need, including your personal information, so that we can respond to it. If you contact us by email or post, we will collect a return address for response. We use the information to deal with the enquiry and any subsequent issues that arise, and to check the level of service we provide.

People making complaints about us or our products

When you contact us to make a complaint about us or our products, we collect the information we need, including your personal information, so that we can investigate and respond to your complaint. If you contact us by email or post, we will collect a return address for response. We use the information to deal with the complaint and any subsequent issues that arise, and to check our processes for handling complaints. We compile internal reports and statistics on the number of complaints we receive and how quickly they are handled, but not in a form that identifies anyone.

Others connected to our Imperial Brands’ businesses or employees

We are a global organisation offering goods and services across many jurisdictions. You may be one of the many people we or our employees have a connection to (for instance, you may be a contact at our business partners or an emergency contact for our employees). When we collect your personal information, we do so in line with our privacy rules and this Privacy Notice. We ensure we have a legitimate purpose for collecting your personal information and only collect what is necessary for the purpose.

We operate in a regulated industry. In support of our anti-illicit trade and anti-money laundering objectives, we collect personal information when we conduct our “Know Your Customer and Contractor” procedures and to verify the integrity of our supply chain. For more information, please contact us using the details below. We also collect personal information when we investigate illicit trade, money laundering and fraud.

Children

We do not intentionally collect any information about visitors to this website who are under eighteen years of age. If we become aware that a child has provided any information, this will immediately be deleted from our records.

Legal basis that permits us to use your personal information

If you are based in a European country where the EU rules on data protection apply, we need to tell you the legal basis on which we process your personal information. We rely on the following legal bases to use your personal information:

  • with your permission where you ask us to send you newsletters, other communications or our email alerts;
  • where we need your personal information to enter into a contract with you;
  • where we perform tasks in the public interest or to comply with a legal obligation (for example, where we need to take action as an organisation in a regulated industry or to comply with health and safety legislation); and/or
  • 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.

The table below provides more detail about the personal information we use and the legal basis that we rely on in each case.

Communications, newsletters and email alerts

Name, contact details, communication preferences

Consent

Website analytics.

Device, IP address, general geographic location indicated by your IP address, the web pages you view and whether you interact with the content on the website.

Consent where necessary or legitimate interests. It is in our legitimate interest to evaluate our website and its services to ensure its effectiveness.

Administering and protecting our businesses.

Name, contact details, device, IP address, other information collected for the purpose.

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

To deal with enquiries and complaints.

Contact details, information submitted as part of the enquiry.

Legitimate interests.  It is in our legitimate interests to collect appropriate information to handle enquiries and complaints thoroughly.

Verifying identity at our premises and monitoring our premises for safety and security reasons.

Identification information, vehicle registration details and contact details.

Legal obligation and legitimate interests. It is in our interests as well as the interests of our employees and visitors to ensure that our premises are safe and secure.

Fraud and crime prevention.

Information about criminal convictions and offences committed by you. Identity verification information. CCTV images.

Public interest, legal obligation and legitimate interests. It is in our interests as well as the interests of our stakeholders and of tax and law enforcement organisations to ensure the prevention of fraud and crime. This helps create a safe workplace for all and helps us to comply with our anti-illicit trade and anti-money laundering obligations.

To deal with legal disputes.

Name, contact details, other information required for the purposes.

Legitimate interests. It is in our legitimate interest to process personal information to bring and defend legal claims and ensure our legal rights and those of our employees are protected.

What happens if you do not provide the personal information that we request?

We need some of your personal information to respond to your enquiries, to confirm you as a customer/contractor or your status in our supply chain, to register you as a shareholder or to handle your complaint. If you do not provide the necessary information personal information, we may not be able to continue with the process that you want us to. We explain when this is the case at the point where we collect personal information from you if it is not clear why we need it.

Who we share your personal information with

We treat all personal information as confidential and in accordance with applicable data protection laws. However, sometimes we need to share your personal information with others for specific purposes.

For example, we share your personal information where necessary with other Imperial Brands companies worldwide for the purposes outlined above.

We share your personal information with our third-party service-providers. For instance, to provide website hosting services, and system maintenance and support.

We may also disclose your personal information to public authorities, other businesses, financial organisations or law enforcement agencies for the prevention or detection of fraud, to comply with tax obligations, or if we are required or permitted to do so by law, or if we consider disclosure necessary to protect and defend the rights, property or personal safety of Imperial, our people, our brands or other visitors to our website.

We may decide, for strategic or other business reasons, to sell, buy, merge or re-organise our business. In doing so, we may share information we hold about you with third-parties or receive it from third-parties as part of the transaction.

Cross-border transfers

Your personal information will only be transferred to countries in the European Economic Area (the “EEA”) or where the recipient has confirmed an adequate level of protection for it, for instance, by contractual agreement. You can ask us about the arrangements we have in place.

How we look after your personal information

Transmission of information via the internet is not always secure. We cannot guarantee the security of the information while it is being transmitted to our website; any transmission is at your own risk. However, once we have received your information, we take appropriate security measures to prevent unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss of your personal information once it is under our control. We monitor compliance with our policies and take disciplinary action where appropriate. Where we use service providers, we require them to take appropriate security measures to protect your personal information.

Cookies

This website uses cookies. A cookie is a small file of numbers and letters that we put on your device if you agree. These cookies allow us to distinguish you from other users of the website and tells us how you are using the website. Some cookies help us to provide you with a good experience as you browse our website; others enable us to gather information that informs how we improve our website.

For further information on the cookies we use on this website, please refer to our Cookies Policy below.

How long we hold personal information for

We keep your personal information for as long as is necessary to fulfil the purposes for which it was collected. After that we will delete or de-identify your personal information unless we hold it to comply with our legal obligations, resolve disputes and enforce our agreements.

Third-party websites we link to

Our website may contain links to other sites which are outside our control. These websites will have their own privacy policies. We are not responsible for the content of such websites or the protection and privacy of any information you provide on those websites.

Your information rights

You have the right, within certain legal parameters, to ask us:

  • for details about how we use your personal information;
  • to see what personal information we hold about you;
  • to correct your personal information;
  • to erase your personal information in certain circumstances;
  • not to use your personal information in a particular way;
  • to port your personal information in a commonly used electronic format;
  • to restrict how we use your personal information; and
  • not be subject to automated decisions about you and to request human intervention.

If we have asked you and you have given us permission to use your personal information in any particular way, you have the right to withdraw that permission at any time.

For more information and to exercise your rights or if you have a query or complaint about how we handle your personal information, please contact us using the details below.

Lodging a complaint

If you have made a complaint to us about how we handle your personal information that we have not been able to resolve, you have the right to complain to the UK’s Information Commissioner’s Office at https://ico.org.uk.

Changes to this Privacy Notice

We may make changes to this Privacy Notice at any time. We will do this by posting an updated version of the Privacy Notice on our website. You can find the date when this Privacy Notice was last updated at the top of the page. We recommend that you check this page from time to time to ensure that you are aware of any changes.

Contact

By post:

Group Privacy Counsel
Imperial Brands plc
121 Winterstoke Road
Bristol
BS3 2LL

By email: 
data.protection@uk.imptob.com

COOKIES

Cookies are small text files that are saved on your device to help the website perform a number of functions. On your first visit to our website, a popup banner asked you to accept our use of cookies and similar technologies. The information these cookies collect is based on your browsing device's IP-address (hardware identifier).

What do the cookies do?

The cookies we use:


DO NOT:

store personally identifiable information about you

 

store information such as passwords

 

(and cannot) allow us to access other information stored on your device

 

store information about you others could understand

 

compromise your security

 

DO:

allow us to see how many people use our website and monitor their activities

 

allow us to see how people arrive at our site (e.g. via search engine)

 

allow us to gather geographic location and browser information

What cookies does the website use?

This website uses two types of cookies:

1. Persistent cookies, which remain on your device to capture and remember your preferences (if chosen) for any future re-visit (e.g. your location).

2. Session cookies, which are deleted when your browser is closed. These cookies are used for analytical services provided by Google Inc. in the US on our behalf. The analysis allows an insight into where and how our website is used so that we can continuously work on its improvement. Google will not associate your IP address with any other data held by Google. However, if you don't wish to be part of this analysis, feel free to download and install a browser plug-in to opt-out under https://tools.google.com/dlpage/gaoptout?hl=en-G.

The cookies we use, what they are used for and how long they remain on your device are set out below:

Website  Cookie  Cookie Name and Type  Default Expiration Type  Description
www.zhil8.com

Google Analytic s (GA) Cookies  _ga  2 years  Used to destinguish users. 
www.zhil8.com

Google Analytic s (GA) Cookies 

_gat_imperial,

 

10 minutes  Used to throttle request rate. 
www.zhil8.com

Google Analytic s (GA) Cookies  opt_out  1 year Blocks the Google Analytics code from being embedded on the page. 
www.zhil8.com

Google Analytic s (GA) Cookies  Analytical/performance cookies   External jquery.com and fonts.com services are required for the websites. These two services do set own GA cookies too.
www.zhil8.com

Service cookies 

spamshield

Functionality cookies

  For preventing spam in forms (e.g. contact form, job application form) 
www.zhil8.com

Apache Server  NA  NA  Collecting IP addresses of visitors. 
www.zhil8.com

Service cookies for website functions 

suppliertoken

SessionID

Strictly necessary cookies

 

Session  Session-related parameters which are necessary for registered website user accounts.  

Analytics cookies - our website uses Google Analytics, a web analytics service offered by Google, Inc (“Google”). The cookies used by Google Analytics are third-party cookies referred to above, and help analyse how you use the website. The information generated by the cookies about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to provide us with reports on website activity and other services relating to website activity. For more information about how Google uses your personal information, please see Google’s Privacy & Terms.

For more choice about how your personal information is collected by Google Analytics, please go to the Google Analytics Opt-out Browser Add-on here.

Using Facebook, LinkedIn or Twitter

This website uses these third-party cookies when you share information to social media via the AddThis sharing button on our website or you engage with our content on or through a social networking website such as Facebook, LinkedIn or Twitter. The social network will record that you have done this. Please note that third-party cookies used by social networks are not under our control so you should check their websites and cookie policies accordingly. The information is used for analytics purposes so we can better understand the content users are sharing.

How are cookies deleted?

To delete or stop cookies being placed on your device, please check the help menu of your internet browser. Blocking cookies may reduce the functionality of this website.

For more information

To learn more about cookies and similar technologies, we recommend you visit: http://www.allaboutcookies.org/

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