Effective Date: July 1, 2020
Notice to California Residents – Your California Privacy Rights
[Supplement to the Privacy Notice on U.S. Smokeless Tobacco Company corporate website]
1. Notice of Collection and Use of Personal Information
We may collect and may have collected during the 12-month period prior to the effective date of this Policy the following categories of personal information about you:
- Identifiers: identifiers such as a real name, unique personal identifiers (such as a device identifier; cookies, beacons, pixel tags, and similar technology; and other forms of persistent or probabilistic identifiers), IP address, email address, and other similar identifiers
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
We may use and may have used during the 12-month period prior to the effective date of this Policy your personal information for the purposes described on U.S. Smokeless Tobacco website and for the following business purposes specified in the California Consumer Privacy Act of 2018:
- Better understanding how visitors use the U.S. Smokeless Tobacco Company Corporate Website
- Enhancing the online experience of our visitors
- Providing you information about U.S. Smokeless Tobacco Company
- Performing services, including analytics services or other similar services
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
2. Sources of Personal Information
During the 12-month period prior to the effective date of this Policy, we may have obtained personal information about you from the following categories of sources:
- From you and your device, for example, through your use of the website, when you send us an email, when you create an account, or otherwise visit, contact or communicate with us
3. Sharing of Personal Information
During the 12-month period prior to the effective date of this Policy, we may have shared your personal information with certain categories of third parties, as described below.
We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
|Category of Third Party||Categories of Personal Information|
|Our affiliates such as those found at the following link: https://www.ussmokeless.com/||Identifiers; and Online Activity|
|Vendors, consultants and advisors who provide services on our behalf||Identifiers; and Online Activity|
|Data analytics providers||Identifiers; and Online Activity|
In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Policy, we may have shared personal information about you with the following additional categories of third parties:
|Category of Third Party||Categories of Personal Information|
|Acquiring/merging entity, in the event of a sale or transfer of all or a portion of our business or assets||Identifiers|
|Government entities and investigatory bodies, including regulatory agencies and law enforcement||Identifiers; and Online Activity|
We may share personal information for other reasons that we may describe to you from time to time or as permitted by law.
4. Sale of Personal Information
ussmokeless.com does not sell your personal information.
We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual's age.
5. California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Rights Under the California Consumer Privacy Act of 2018
Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you, subject to certain exceptions under the law. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. In the case of requests submitted online, if we are able to verify your identity (as described below), we may ask you to confirm that you would like your personal information deleted prior to deleting any of your personal information.
Opt-Out of Sale: You have the right to opt-out of sale of your personal information.
How to Submit a Request: If you would like to make a request given your relationship with a U.S. Smokeless Tobacco Company brand please visit the relevant brand website and submit your request through that process (Example: www.freshcope.com).
To submit an access, deletion, or opt-out of out sale request for U.S. Smokeless Tobacco online, please follow this link to the Privacy Contact Us Form. Indicate that you are submitting a request for U.S. Smokeless Tobacco Company.
You may also submit an access, deletion, or opt-out of sale request by sending us an email at USSTPrivacystatement@consumerconnectioncenter.com with your first name and a phone number at which we may reach you or by calling 1-800-787-6700. Indicate that you are a California resident making a "California Consumer Privacy Act" inquiry.
To submit a request as an authorized agent on behalf of a consumer, please send us an email at USSTPrivacystatement@consumerconnectioncenter.com with your first name and a phone number at which we may reach you and indicate in the subject line that you are making a CCPA Authorized Agent Request, or call 1-800-787-6700.
Verifying Access and Deletion Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.
- If you request to access or delete your personal information, we may require you to provide information such as: email, zip code and phone number.
- In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Non-Discrimination: We will not discriminate against you if you choose to exercise any of your rights under the California Consumer Privacy Act.