Privacy Notice

A BAT staff member

If you are a current or former employee, contractor or another staff member of BAT (such as a trainee or secondee) then please note that this Privacy Notice does not apply to you. Please click here to access the BAT Employee Privacy Notice or contact Data_Privacy@bat.com for more information.

A visitor to this website

This section of the Privacy Notice applies to visitors of the BAT.com website and those individuals who are interested in BAT’s updates, events or make an enquiry via this website. Here we tell you which BAT company is primarily responsible for your personal information, what we collect, why we collect it, how legally we can use it and for how long.

Which BAT company is primarily responsible for your personal information?

The company responsible for your personal information collected on this site is British American Tobacco p.l.c. with its registered offices at Globe House, 4 Temple Place, London WC2R 2PG, United Kingdom.

What personal data do we hold about you and where does it come from?

We don't make any routine use of your personal information. Non-personally identifiable information is captured in statistical form, i.e. Google Analytics statistics about the online footfall to our site. Unless you fill in a form on our website, we can't identify you.

We only collect and hold the personal information you provide to us when you visit our website, such as through filling out a contact form, or if you sign up to receive communications regarding BAT updates or news on events.

How do we use your personal data, how do we legally do this and how long do we keep it for?

For a general description of all the ways we use your personal information please click back to section 4 of this Privacy Notice. However, in respect of the way we use your personal information in the context of the relationship that you have with us in visiting the BAT.com website, please see below

We may need to keep your information longer than the periods stated above. This could be because of the following reasons:

• to potentially establish, bring or defend legal proceedings or to comply with a legal or regulatory requirement;
• to be able to deal with external or internal audits.

When it is no longer necessary for us to keep your information, we will delete it from our systems. Afterwards, we only retain aggregated data from which you cannot be identified for analytical purposes.

Business relationships with BAT

Privacy for our business contacts

This section of the Privacy Notice applies to you if you or your employer is a Third Party and supplying goods or services to BAT (or proposing to do so), or purchasing goods or services from us (or proposing to do so). It also applies if you are a director or direct or indirect shareholder of a Third Party organisation  supplying or receiving goods or services to or from BAT (or where such Third Party organisation is proposing to do so).

In this section "Third Party" means the following:

• Supplier/Vendor - A person or organisation that provides goods or services to the BAT Group or any Group company and receives consideration for these goods or services.
• Customers - Any person or entity (other than a BAT operating company or a direct store distribution customer of a BAT operating company) which directly purchases tobacco leaf and/or products from a BAT operating company.
• Trade Associations - A group organised and funded by business/society participants that share common goals. Examples include: The Digital Coding & Tracking Association, Tobacco Manufacturers’ Associations, Associations of Accountants and Lawyers.
• Landlords - The owner of land or buildings used by BAT

Here we tell you which BAT company is primarily responsible for your personal information, what we collect, why we collect it, how legally we can use it and for how long we keep it.

Which BAT company is primarily responsible for your personal information?

The BAT company listed below which has a business relationship with you, your employer, or the company of which you are a shareholder or director, will be primarily responsible for your personal information. For further information please contact Data_Privacy@bat.com .

What personal data do we hold about you and where does it come from?

At BAT, we need some information about you, such as your name, job title and contact details so we can work with you to manage the contract and relationship for the goods or services you supply to us, or we supply to you. We may collect your personal data via  a Third-Party risk assessment tool  to complete due diligence and risk management processes necessary for Third Party onboarding. As part of managing the business relationship, we may be legally required to conduct ‘know your customer’ (e.g. via ‘World Check One’) or similar compliance screenings on you or your company. In doing so we will use the information listed below. We obtain this information either obtain directly from you or from your employer, or the company you are shareholder or director of. In the context of conducting compliance screenings, we will also check the personal information provided to us against public information, including official sources (such as sanctions lists), media sources and adverse media (such as news reports, journal articles,), and additional Government and official sources (such as court records, election results, company filings, official company websites and press releases).

How do we use your personal data, how do we legally do this and how long do we keep it for?

[For a general description of all the ways we use your personal information please click back to section 4 of the Privacy Notice. However, in respect of the way we lawfully can use your personal information in the context of the relationship that you have with us, please see below.

Please note that we may need to keep your information longer than the periods stated above. This could be because of the following reasons:

• to potentially establish, bring or defend legal proceedings or to comply with a legal or regulatory requirement;
• to be able to deal with external or internal audits.

When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems. After that time, we would only retain aggregate data (from which you cannot be identified) for analytical purposes.

BAT entities primarily responsible for your personal information

1. BAT Services Limited
2. BATLaw Limited
3. BATMark Limited
4. British American Tobacco (AIT) Limited
5. British American Tobacco (GLP) Limited
6. British American Tobacco (Investments) Limited
7. British American Tobacco Exports Limited
8. British American Tobacco p.l.c.
9. British-American Tobacco (Holdings) Limited
10. British American Tobacco UK Limited
11. Nicoventures Retail (UK) Limited
12. Nicoventures Trading Limited
13. British American Tobacco (Corby) Limited
14. Nicovations Limited

A candidate or job applicant

Privacy for our candidates or people applying to work for us.

Please see the Privacy Notice available here if you have registered with us on our BAT Career site if you have sent us your CV or resumé, or you’re currently in a recruitment process with one of our companies.

Emergency contacts or those named to receive benefits by a BAT employee

Privacy for our employees’ relatives or emergency contacts

This section of the Privacy Notice applies to you if one of our employees employed by a BAT legal entity established in the United Kingdom has named you as the person we should contact in an emergency or to administer any employee-based benefits. If the relevant employee is employed at a BAT entity outside of the United Kingdom, then a local Privacy Notice applies. Please contact the local office for more information or send an email to data_privacy@bat.com .

Here we tell you which BAT company is primarily responsible for your personal information, what we collect, why we collect it, how legally we can use it and for how long.

Which BAT company is primarily responsible for your personal information?

The BAT company primarily responsible for your personal information is British-American Tobacco (Holdings) Limited whose address is Globe House, 4 Temple Place, London WC2R 2PG or if the person nominating you is an employee at British American Tobacco UKI Limited (BAT UKI) then BAT UKI is primarily responsible for your personal information.

What personal data do we hold about you and where does it come from?

We only hold information about you (as detailed in the table below) which has been provided to us by a BAT employee to enable us to contact you in emergencies or to administer employee benefits such as healthcare or international assignment relocation packages.

How do we use your personal data, how do we legally do this and how long do we keep it for?

We only your personal information in the ways detailed in the table below, which also sets out the legal bases we rely on to contact your or use your information in any other way.

Please note that we may need to keep your information longer than the periods stated above because of the following reasons:

• to potentially establish, bring or defend legal proceedings or to comply with a legal or regulatory requirement; or
• to preserve records beyond the above periods to be able to deal with external or internal audits.

When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems.  After that time, we would only retain aggregate data (from which you cannot be identified) for analytical purposes.

Other individuals who interact with BAT

This section of the Privacy Notice applies to you if you fall within any of the following categories:

• journalists with whom we communicate in any medium;
• visitors to our physical premises;
• individuals who attend or participate in conferences or events in which we are involved;
• individuals who represent regulatory and law enforcement agencies or other governmental offices;
• individuals who voluntarily participate in any of our panels; and
• academics and research professionals.

Here we tell you which BAT company is primarily responsible for your personal information, what we collect, why we collect it, how legally we can use it and for how long we keep it.

If you engage in business with BAT by acting as a supplier or vendor, customer, trade association or landlord please see section ‘Business relationship with BAT’ here.

Which BAT company is primarily responsible for your personal information?

The BAT company listed below with which you interact will be primarily responsible for your personal information. For further information please contact Data_Privacy@bat.com .

What personal data do we hold about you and where does it come from?

At BAT, we need some information about you, and will collect and hold the information listed in the table below under ‘ What Type of Information ’ so we can manage any current or future relationship  we may have with you. We obtain this information either directly from you or from your employer, or from third parties who lawfully provide it to us (including publicly available materials) including the organisers of public events you attend.

How do we use your personal data, how do we legally do this and how long do we keep it for?

For a general description of all the ways we use your personal information please click back to section 4 of the Privacy Notice. However, in respect of the way we lawfully can use your personal information in the context of the relationship that you have with us, please see below.

If we rely on our legitimate interests (as detailed above in ‘ How legally can we use your information ’), we will always balance our legitimate interests against your rights and freedoms before using your information and will take into consideration the factors listed here .

Please note that we may need to keep your information longer than the periods stated above. This could be because of the following reasons:

• to potentially establish, bring or defend legal proceedings or to comply with a legal or regulatory requirement;
• to be able to deal with external or internal audits.

When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems. After that time, we would only retain aggregate data (from which you cannot be identified) for analytical purposes.

BAT entities primarily responsible for your personal information

15. BAT Services Limited
16. BATLaw Limited
17. BATMark Limited
18. British American Tobacco (AIT) Limited
19. British American Tobacco (GLP) Limited
20. British American Tobacco (Investments) Limited
21. British American Tobacco Exports Limited
22. British American Tobacco p.l.c.
23. British-American Tobacco (Holdings) Limited
24. British American Tobacco UK Limited
25. Nicoventures Retail (UK) Limited
26. Nicoventures Trading Limited
27. British American Tobacco (Corby) Limited
28. Nicovations Limited