PRIVACY NOTICE

We believe in creating something better.  We understand you are trusting us with information that is important to you, and we want to repay your trust by being transparent about how we use and protect your information.  

The data controller of your personal information is Imperial Tobacco Limited, 121 Winterstoke Road, Bristol BS3 2LL (company registration: 01860181). If you are based in the Republic of Ireland, your personal information will be processed by John Player & Sons Limited, with its office at John Player & Sons Ltd, Park West, Dublin 12 who shall be the data controller of your personal information, and can be contacted via email: jpsCustomerServices@impbrands.com and tel: 1800 434 800.

This Privacy Notice explains how we handle your personal information when you visit our website and when you discuss our ZONE products, and services (our “ZONE Services”).  Specifically, we’ll tell you about:

⦁ The information this Privacy Notice covers

⦁ How we collect Personal Information

⦁ What Personal Information we collect

⦁ Cookies

⦁ How we use your Personal Information

⦁ Lawful basis that allows us to use your Personal Information

⦁ If you do not provide Personal Information

⦁ Who we share your Personal Information with

⦁ Cross-border transfers

⦁ How we look after your Personal Information

⦁ How long we keep your Personal Information for

⦁ Links to third-party websites

⦁ Your information rights

⦁ Changes to this Privacy Notice

⦁ Who we are and how to contact us

⦁ Lodging a complaint

⦁ Effective date

The information this Privacy Notice covers

This Privacy Notice covers personal information.  Personal information is any information that tells us something about you.

How we collect personal information

We collect your personal information to provide you with our ZONE Services, so that we can stay in touch with you, to improve and personalise our ZONE Services for you, to handle any questions or complaints you may have, and to comply with our regulatory obligations. This involves:

Information you provide to us

We collect information from you when you click through to another site, e.g PayPoint.

We collect information you voluntarily provide to us, such as your name and contact details, when you make an enquiry or complaint, sign up for information relating to ZONE products and services, and when you participate in our surveys or attend events where we are.  You volunteer information when you leave us feedback or post about yourself on our social media accounts or any public areas of our website.

Information we collect automatically or that is generated when you use ZONE Services

We collect some information about you automatically, such as information collected by cookies, web beacons and similar technologies when you use, access or interact with us via our website.

Information we collect from third-parties

Some of the information we collect about you comes from third-parties such as analytics service providers, social media providers and marketplaces. You can change how the information is shared with us by other services by changing your settings with that service.

What personal information we collect

• Identity Data is information that specifically identifies you.  It includes your first name, last name, username, social media handle, or similar identifier. We use this information to register and create your account.

• Contact Data includes email address.  We use these details to deliver our ZONE services to you.

• Communications Data includes your preferences in receiving product information from us and your communication preferences to ensure we engage with you as you wish.

• Image Data includes photographs and video footage captured by us or our representatives at festivals or events either in clearly signposted designated areas or where we obtain your consent via a consent form.

• Technical Data is the information behind the technology and the devices you use to connect to our website.  It tells us how our products and services are performing and we use this data to make our ZONE Services operate better. 

• Technical data includes your internet protocol (IP) address, your login 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.

• Usage Data is the information generated, including using cookies, as you use our ZONE Services.  We use third-party analytics providers to analyse how you are using those ZONE Services.  This data, especially when we use it as Aggregated Data, tells us how the ZONE experience could be improved and what we can do to enhance the services we offer.

We use third-party services such as Google Analytics and Hotjar, to collect standard internet log information and details of your behaviour patterns as you navigate around our website.  It does this using information from cookies.  This helps us to find out the number of users to the various parts of our website and how they interact with the content on the site.  We also 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 you.  This information does not identify any individuals.  You can see our Cookies Policy.

• Third-Party Data is the information we receive from analytics providers as mentioned above under Usage Data and, for instance, when we analyse your feedback on review sites. 

This might include information on your interests, comments and content you have posted on social media, user name, and other online activities.  You can find information on the data sharing policies and practices of the social media providers on their websites, and we encourage you to read this information and adjust your settings to your personal preferences.

• Aggregated Data is derived from your personal information but is not considered “personal data” in law as it is anonymous and the data does not directly or indirectly reveal your identity.  This data is used for statistical research and to inform business strategy.

We collect, use and share Aggregated Data, such as statistical or demographic data. Aggregated Data may be derived from personal information (for example, we may aggregate all our website visitors’ website usage to calculate the percentage of them accessing a specific website feature) but it does not identify individuals. However, if we combine or connect this Aggregated Data with your personal information in a way that directly or indirectly identifies you, we treat the combined data as “personal data” which will be used in line with this Privacy Notice.

Cookies

We collect website Usage Data and Technical Data automatically from your mobile or other device using cookies, web beacons and similar technologies. 

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

For more information about our use of cookies, please see our Cookies Policy.

How we use your personal information

Your personal information is used for the following purposes:

Providing customer service

If you contact us, we will save your contact details to respond to your query, notify you about any changes to our terms or Privacy Notice, enabling you to use promotional codes or discounts, and responding to your queries.

• Personalising your ZONE experience

We use information about your behaviour on our website to personalise your ZONE experience by tailoring our communications to your preferences.  

If you are registered to receive product information communications, we use information about your online activity to inform the updates you receive from us with news and product information. You can unsubscribe through a link in every communication we send out.

We use information about your online activity together with your response to our product information communications to personalise your online browsing and shopping experience on our website to ensure you will see content that is relevant for you.

In some instances on an adhoc basis we may send you a gift voucher as a thank you for bringing to our attention an error or improvement in our systems or communications or simply as a celebration for an important milestone in your life which you have made us aware of when you contacted our support teams.

⦁ Analysing product reviews and feedback

If you leave a review about a ZONE product on other review sites or post publicly about us or the ZONE Services on social medial, we may analyse this information to learn how we can make improvements to our products and services.

⦁ Events

We use your personal information when we invite you to events hosted by us or on our behalf. If you participate in an event, we collect information about you to better understand your preferences.

We also collect personal information about you when you attend an event that we are present at, for example, festivals. If you are in the designated area at the events where we or our authorised representatives will be taking photographs and video footage of the event, your image may be captured in those photographs and video footage. We will only collect this personal information if you are within the designated area that we are operating from, and this area will be clearly sign posted to confirm that photographs and video footage may be taken in the area.

If you do not want your image to appear in the photographs or video footage that we are collecting, please do not enter the area.

We may also approach you at events and ask you to sign a consent form where we intend to capture your image either outside of the designated area or outside the designated times or where the image clearly identifies you.

Where your image has been captured in the designated area or where you have consented for us to use your image – from an event or festival, we will use your image for internal and external promotional purposes which will appear on our website and/or other publications, including social media accounts.

The images will only be used and stored for 18 months after which they will be deleted. Where we rely on consent to use your image, you have the right to withdraw this consent at any time by getting in contact with us using the contact details below.

Withdrawing your consent means that we will thereafter not use your image in any future publications or for any further purpose, but you should be aware that your image may continue to appear in publications already in circulation or previously published for the permitted purposes.

⦁ Surveys, prize draws and competitions

Occasionally we invite you to fill out a questionnaire, enter a prize draw or a competition. You are free to choose if you would like to participate in these. The information you provide will be used to enter you into the prize draw/competition and in the case of surveys; to better understand your preferences and to serve you better.

⦁ Providing product information

Where appropriate and where you have provided your consent to receive production information from us, we may pass your information to our affiliate companies so that you receive further personalised information and services that might be of interest to you. You may ask us at any time not to use your information by contacting us using the contact details below. 

In order to provide you with a personalised experience, we will send you product information based on your preferences. These preferences can be based on your online behaviour and/or surveys or competitions that you have participated in. Based on this, personalised emails will be sent out (if you are subscribed). Based on your online behaviour and preferences, our website might also be adjusted accordingly. In certain cases, your personal information will be matched to personal information received from third parties to build up a profile. This profile will give us insight on how we can personalise your experience with us.

You can ask us to stop sending you product information messages at any time by unsubscribing using the link in one of our emails. You can also opt-out by contacting us at any time.  If you opt-out of product information messages, we will still need to send you service communications from time to time, such as information about changes to our services or product recalls.

⦁ Research and analysis

We use your personal information, (largely as Aggregated Data), including your feedback, your responses to surveys, and your online behaviour to conduct research and analysis to improve and develop our business, including to improve our ZONE Services, our marketing strategy and our customer relationships and experiences. 

⦁ Administering and protecting our business

We use your personal information to administer and protect our business, our ZONE products, our website, and our information and systems.  This includes carrying out activities like trouble-shooting, data analysis, testing, system maintenance, system security, support, reporting and hosting data.

⦁ When you purchase ZONE products in a market place

If you buy a ZONE product in a market place, we will receive information about your purchase and personal information held by the market place.

The lawful basis that allows us to use your personal information

We may use your personal information under more than one lawful basis depending on the specific reasons for using it. Please contact us if you need more details about the specific lawful basis we are relying on to process your personal information.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

The lawful bases we rely on in order to use your personal information are as follows:

⦁ with your consent (for example, where you opt-in to receiving product information from us or enter a prize draw);

⦁ to comply with a legal obligation; 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 (for example, when we use your information to help us improve and develop our ZONE Services).

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

If you do not provide the personal information

We need certain of your personal information, and without this information, we may not be able to continue with the process that you want us to.

Who we share your personal information with

We will treat all your personal information as confidential and in accordance with applicable data protection legislation. We may, however, need to share your personal information with our affiliates that are part of the Imperial Brands group and with third parties who provide us with services. 

We limit the amount of third parties that have access to your personal data to only what is needed to provide the ZONE Services.

To do so, there are certain categories of processors (i.e. those third parties who process your personal information on our behalf) that have access to your personal information, which include:

⦁ Cloud storage providers. Location: EU & US.

⦁ Tracking solutions. Location: EU.

⦁ Data collection tool. Location: EU.

⦁ Analytics solutions. Location: EU & US.

⦁ Marketing agencies and similar service providers: Location: UK & EU

Where we use third parties to process your personal information on our behalf, we will always carry out checks to ensure that there are appropriate protections for the safeguarding your personal information. We will also monitor the performance of these third parties (and their approved subcontractors) to ensure that your personal information remains secure.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We share your personal information with some of our Imperial Brands affiliates in order to provide us with sales, marketing and customer care services. Where you have opted in to receive product information from affiliates in our Imperial Brands group, we may also share your personal information with our affiliates to facilitate your request.

We also share information (usually Aggregated Data) with our relevant affiliates for business administration and reporting purposes, and for product and services development purposes.  For instance, we share statistical customer feedback and survey data with our affiliate responsible for product innovations.

We will not usually disclose your personal information other than as set out above. However, there are certain circumstances where we need to share personal information, for instance:

• where we are legally required to disclose the information, for example, because a court orders us to do so;

• where the disclosure of the personal information is required for the purposes of the prevention and detection of crime. This includes sharing the personal information with tax authorities and law enforcement agencies;

• where we need to disclose the personal information for or in connection with any legal proceedings, or for obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;

• where disclosure is necessary to protect your vital interests (for example if you are unwell at one of our events, we may need to seek medical assistance); and

• where we share your personal information with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets if we reorganise our business. Alternatively, we may seek to acquire other businesses or merge with them.

Cross-border transfers

Your personal information will only be transferred to countries outside of the UK and/or European Economic Area (the “EEA”) 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. 

In some cases, we work with third parties, including our Imperial Brands affiliates, based outside of the UK and EEA who store, host or transfer your personal information outside the UK or EEA. If we transfer your personal information out of the UK and/or EEA, we will ensure that a similar degree of protection is afforded to it.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK or EEA.

How we look after your personal information

Information sent 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’ve received it, we take appropriate security measures to keep it safe.  

We limit access to your personal information to those who have a business need to know. Where we use service providers, we require them to take appropriate security measures to protect your personal information from an accidental or unlawful destruction, loss, or alteration and unauthorised access or disclosure.  They will only process your personal information on our instructions and they are subject to a duty of confidentiality. 

We take the security of your data extremely seriously. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are required to do so.

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. 

We may need to keep your personal information for a longer period under certain limited circumstances (for example, where we have a legal reason to keep the personal information for a longer period or in case of a legal claim or dealing with on-going queries or complaints.

Links to third-party websites

Our website may include links to third-party websites, plug-ins and applications (such as Facebook and Instagram). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party links and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Your information rights

You have a number of rights in relation to your personal information. If you wish to exercise the rights set out in this section, please make your request in writing using the contact details in the Who we are and how to contact us section below. 

In summary, 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;

⦁ not to send you product information materials by withdrawing your consent (where applicable); and

⦁ not be subject to automated decisions about you and to request human intervention.

• For details about how we use your personal information. This Privacy Notice tells you this and in any further updates to it;

• To see what personal information we hold about you. You can ask us to provide you with it. 

• To correct your personal information. You can ask us to correct inaccurate information that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct it on our systems as soon as possible.

• To erase your personal information in certain circumstances. You can ask us to delete your personal information in certain circumstances (for example, if we have processed your personal information unlawfully or if we no longer need it for the purposes set out in this Privacy Notice).

• Not to use your personal information in a particular way. You can object to us processing any personal information that we process where we are relying on legitimate interests as the legal basis of our processing. If we have compelling legitimate grounds to carry on processing your personal information, we will be able to continue to do so. Otherwise, we will stop processing your personal information.

• To port your personal information in a commonly used electronic format.  You can ask us to send you a copy of the personal information that we hold about you in a commonly used electronic format.

• To restrict how we use your personal information. You can ask us to restrict the processing of your personal information in some circumstances (for example, if you think the personal information is inaccurate and we need to verify its accuracy, or if we no longer need the information but you require us to keep it so that you can exercise your own legal rights). 

• Withdrawing your consent. Where you have provided your consent to opt-in to a particular service (such as to receive product information), you can ask us not to send you direct communications by withdrawing your consent. You can do this by opting out by using the "unsubscribe" option in any of our communications with you.

• Not be subject to automated decisions about you and to request human intervention. You can object to automated decisions being made about you and to request human intervention.

• If 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.

Changes to this Privacy Notice

We will keep this Privacy Notice up to date and you can find the date it was last updated at the bottom of the page. If there are any changes to the way in which your personal information is used, we will update this Privacy Notice and, where appropriate, notify you of the changes by email. We recommend that you check this page from time to time to ensure that you are aware of any changes.

Who we are and how to contact us

If you are based in the UK, please contact us at: Imperial Tobacco Limited, 121 Winterstoke Road, Bristol BS3 2LL (company registration: 01860181).

If you have any queries about this Privacy Notice or complaints about the way we use your personal information, please contact us at dataprotection@uk.imptob.com and we will assist in resolving the issue.

If you are based in the Republic of Ireland, John Player & Sons Limited shall be the data controller of your personal information. Please contact John Player & Sons Ltd at its address: Park West, Dublin 12, via email:mailto: jpsCustomerServices@impbrands.com, or via tel: 1800 434 800.

Lodging a complaint

If we cannot resolve your complaint or you are unhappy with how we have processed your personal information, you have a right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues(www.ico.org.uk).

Effective Date

This Privacy Notice is effective from 17th November 2025.