Privacy Policy

In the course of its business (hereinafter, the "Website"), JTI Northern & Western Africa, a limited liability company with a share capital of 10,000 dirhams, whose registered office is located at the Continental Business Center,8th floor, Casablanca, Morocco, registered in the Casablanca Trade Register under number 243933 (hereinafter "JTI") collects and processes personal data relating to users of the Website (hereinafter "Users") and acts as data controller solely in relation to the Website.

The main purpose of this privacy policy is to provide information in a concise, transparent, understandable, and easily accessible format about the data processing operations carried out so that you can understand the conditions under which your data is processed.

JTI attaches the utmost importance and care to the protection of your personal data. Our relationship with you is based on the principle of transparency, with the aim of respecting your privacy in accordance with Moroccan legislation and regulations in force, and in particular in application of Law No. 09-08 on the protection of individuals with regard to the processing of personal data.

This policy informs you in particular about the categories of personal data we collect, the purposes for which we process it, the legal bases on which such processing is based, how we use and store it, the categories of recipients to whom we disclose it, how long we store it, and your rights.

Please note that this personal data protection policy may be modified or supplemented at any time by JTI, in particular to comply with any technological or legal developments. In such a case, the date of its update will be clearly identified at the top of this policy. We advise you to consult this page regularly to be aware of any changes or updates to our personal data protection policy.

WHAT DOES THIS PRIVACY POLICY APPLY TO?

This privacy policy applies to the Website, regardless of the device used (smartphone, computer, tablet, or equivalent).

However, this privacy policy does not apply to third-party websites, even if they are mentioned on the Website via a web link or banner.

WHEN AND WHAT DATA IS COLLECTED AND USED?

In the context of the processing of personal data for the purposes set out below, JTI may collect and process all or part of the following personal data through forms, online uploads of content or correspondence, when you:

• access the Website;
• agree to receive communications relating to the products presented on the Website;
• browse the Website;
• fill out a form (in particular the age verification form to access the Website or the newsletter subscription form);
• contact JTI using the contact form, by phone, or by email.

It also includes personal data we receive from third parties commissioned by us to provide services to us, such as email service providers, points of sale, age verification service providers, and technical service providers. These service providers, acting as authorized third parties, do not determine the origin of the data.

The categories of personal data that may be collected include, but are not limited to:

• your identification and contact information , (title, last name, first name, date of birth, email address, telephone number, postal address);
• your connection data (IP address, browsing data, cookies,);
• your requests or complaints addressed to JTI via the contact form, or by email, or incidents you have reported;
• any other information you wish to bring to our attention.

When you fill out a form, you will be notified whether the data is mandatory or optional at the time of collection. If you do not fill in these mandatory fields, JTI will not be able to respond to your requests. Certain personal data is collected automatically as a result of your browsing on the Website.

WHY AND ON WHAT BASIS DO WE USE YOUR PERSONAL DATA?

Your personal data is collected and processed in a fair, lawful, and transparent manner for specific, explicit, and legitimate purposes.

For each type of processing carried out, JTI undertakes to collect and use only data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

JTI ensures that data is kept up to date and implements procedures to enable the erasure or rectification of inaccurate data.

The purposes of processing and their legal bases are as follows:

• management of Website navigation and operation;
• verification of the legal age of users;
• management of requests via the contact form;
• management of exchanges with customer service;
• newsletter registration and management;
• sending information about the products presented;
• locating points of sale;
• statistical analysis and audience measurement;
• improvement of content and user experience;
• organization of loyalty and reward programs;
• Website security and prevention of misuse;
• compliance with legal and regulatory obligations.

Processing is based solely on your consent. This consent is obtained when you access the Website or when you choose to:

• Receive communications about JTI products and news about nicotine pouches;
• Obtain information about the nearest points of sale based on the postal address you have provided or your geolocation information that you agree to share;
• Submit information when contacting JTI, submitting a request to JTI, or filing a complaint.

HOW LONG IS YOUR DATA STORED?

JTI ensures that personal data is only kept in a form that allows the identification of the individuals concerned as long as is necessary for the purposes for which it was collected and for which it is processed.

The retention periods we apply to your personal data are proportionate to the purposes for which it was collected:

• Personal identification data: for the period necessary to manage the relationship with the user, then archived in accordance with the legal limitation periods.
• Connection and browsing data: six (6) months from the date of collection. Upon expiry of this period, only aggregated and anonymized data may be retained for statistical purposes.
• Data related to newsletter subscription: one (1) year from the date of consent, then archiving with restricted access before deletion.
• Data relating to requests for information or complaints: for the time necessary to process the request, then archived with restricted access before deletion.
• Other data voluntarily provided by the User: for the time strictly necessary to process the request concerned, then archived with restricted access before deletion.

WHO RECEIVES YOUR DATA?

Your personal data collected on the Website by JTI is accessible, processed, and analyzed by authorized JTI teams.

The processing of your personal data may be entrusted, as a whole or in part, to technical service providers involved in the operation and functioning of the Website, who act on our instructions, as subcontractors, in accordance with the purposes and means of processing that we ourselves have determined. You may ask us at any time to disclose the identity of these subcontractors.

Personal data may be hosted on servers located outside the country of collection. However, all recipient countries are recognized as providing an adequate level of protection by the CNDP.

We guarantee that your personal data will not be passed on to third parties for commercial prospecting purposes.

WHERE IS THIS PERSONAL DATA STORED?

As part of the hosting of the Website's data, the data may be transferred abroad. When personal data is transferred to foreign countries where JTI affiliates or service providers operate, JTI guarantees that these transfers ensure adequate protection of personal data.

In addition, JTI ensures that such transfers are carried out in accordance with applicable law and guarantees the security and confidentiality of personal data.

WHAT ARE YOUR RIGHTS?

In accordance with Law No. 09-08 on the protection of individuals with regard to the processing of personal data, you have the right to access and rectify your personal data, and the right to object, on legitimate grounds, to the processing of your personal data. However, the User acknowledges that opposition to the processing of certain data may make it impossible to use the Website.

You may exercise any of the rights described above by contacting JTI by email: [email protected]

Access

You have the right to access the personal data that JTI holds about you (subject to certain restrictions).

Requests that are manifestly unfounded, excessive, or repetitive may not be answered.

Rectification

You have the right to request that your personal data be rectified if it is inaccurate or out of date and/or completed if it is incomplete.

Object

You have the right to object, on legitimate grounds, to the processing of your personal data.

How to exercise these rights

To exercise any of these rights, simply send us a request to the following address: [email protected]

PROCEDURES

This procedure is under declaration process to the National Commission for the Control of Personal Data Protection (hereinafter the "CNDP") In addition, to the transfer of data abroad.

USER CONSENT

The User expressly consents, on the basis of the information detailed above, freely and in an informed manner, to the processing of personal data concerning him/her by the data controller, to the involvement of the data controller's affiliated companies and subcontractors in the processing of data, and to the transfer of data abroad, as detailed above.