This privacy policy sets out how Swedish Match North America LLC (“Swedish Match”) uses and protects any information that you provide Swedish Match through its website. 

Swedish Match is committed to ensuring that our consumers’ privacy is protected and you can be assured that such information will only be used in accordance with this privacy statement. 

Swedish Match has a policy of protecting the confidentiality and security of information we collect from consumers and does not share your non-public personal information with unaffiliated third parties. Information is only shared with your consent except for the specific purposes below, in accordance with all applicable laws. 

This privacy policy was last updated on January 14, 2019. Please review it carefully and check this page periodically, as Swedish Match may modify its privacy policy from time to time and use customer information for new, unanticipated uses not previously disclosed. 

INFORMATION WE COLLECT
Swedish Match is committed to responsible marketing practices of quality tobacco products and restricts access to our web site and marketing communications to adult tobacco consumers who are 21 years of age or older. 


For each visitor, our web server automatically recognizes only the consumer's domain name. We collect the domain name, personal and contact information (including name, address, date of birth, email address and telephone number, where possible) of visitors to our web site, aggregate information on what pages consumers access or visit, and information volunteered by the consumer, such as survey information and/or site registrations. 

This site uses Google Analytics, which places a cookie on your computer to track site usage when you visit this site. Additionally, Swedish Match has implemented Google Analytics Advertising Features for tracking demographic information. Google Analytics Advertising Features may place a cookie on your computer when you are shown ads through the Google Advertising network, such as on Google.com or elsewhere. All information provided to us through these networks is provided in aggregate — or in totals or sums of numbers — rather than on an individual user basis. Aggregate information provided to us through these networks is never tied to a specific user, if provided to us through registration or other channels. 

You may opt-out of having your information used in aggregate for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/

USE AND SHARING OF INFORMATION
The information we collect is used to help Swedish Match contact consumers for marketing purposes. For example, Swedish Match may use your personal information to provide advertising, promotions, and content. We may also share your personal information with Swedish Match affiliates. We will not, however, sell, rent, trade or otherwise transfer the personally identifiable information you provide to any third party for marketing purposes and Swedish Match does not partner with any ad server companies. 


TRACKING TECHNOLOGIES
Swedish Match uses cookies and similar technologies to analyze trends, administer the website, and track users’ movements around the website. Cookies are small text files containing information that is sent to us from your computer or mobile device. They are unique to your account or browser and store non-personally identifiable information related to your navigation on our website. Our website also uses web beacons, which are embedded invisibly on Web pages and help us better manage content on our site by informing us what content is effective. Swedish Match uses these technologies to customize web page content based on information that the visitor sends and to record past activity at a site in order to provide better service when visitors return to our site. You can control the use of cookies and other technologies in your browser settings, but if you choose to disable them, it may limit your use of certain features or functions on our website. 


SECURITY
Swedish Match is committed to ensuring that your information is secure. In order to prevent unauthorized access, use, or disclosure, we always use the industry-standard encryption technologies when transferring and receiving consumer data. Swedish Match has also put in place suitable physical and managerial procedures to safeguard information we collect. 


OPTING OUT
If you no longer wish to receive e-mail from Swedish Match, you may opt out by letting us know using any of the following options: visiting the My Account section of this website, via email to info.us@zyn.com; calling us at 1-855-YOUR ZYN; or, writing us at ZYN, PO Box 986, Owensboro, KY, 42302. 


If you supplied us with your postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. You can request to have your name removed from our mailing list by any of the methods above. Please make sure to provide us with your proper name and address when doing so. 

YOUR CALIFORNIA PRIVACY RIGHTS
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please email or write to us at ZYN, PO Box 986, Owensboro, KY, 42302. Indicate in your letter that you are a California resident making a "Shine the Light" inquiry. 


PRIVACY POLICY FOR CALIFORNIA RESIDENTS

Effective Date: 1/1/2020
Last Reviewed on: 12/05/2019


This Privacy Notice for California Residents supplements the information contained in the ZYN.com Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”).  We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and terms defined in the CCPA have the same meaning when used in this notice.

INFORMATION WE COLLECT
Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably by linked, directly or indirectly, with a particular consumer or device (“personal information”).  In particular, ZYN.COM has collected the following categories of personal information from its consumers within the last twelve (12) months:

CATEGORY

EXAMPLES

COLLECTED

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

YES

B. Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment or employment history.   Some personal information in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familiar genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

 

Personal information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like:

    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you.  For example, the personal and contact information provided by visitors to our web site and information volunteered by the consumer, such as survey information and/or site registrations.

  • Directly and indirectly from activity on our website (www.zyn.com).  For example, from submissions through our website portal or website usage details collected automatically

USE OF PERSONAL INFORMATION
We may use, or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information.  For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry.  If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.  We may also save your information to facilitate new product orders or process returns. 

  • To provide, support, personalize, and develop our Website, products, and services.

  • To create, maintain, customize, and secure your account with us.

  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • To personalize your Website experience and to deliver the content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep both that personal information confidential and not use it for any purpose except performing the contract. 


We share your information with the following categories of third parties:

  • Service providers

  • Data aggregators.

  • Our affiliates.

  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with the products or services we provide to you.

YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information.  This section describes your CCPA rights and explains how to exercise those rights.


Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling the personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  •  If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • sales, identifying the personal information categories that each category of recipient purchase; and

    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected form you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.


We may deny your deletion request if retaining the information is necessary to us or our service provider(s) to:

1.     Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2.     Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.     Debug product to identify and repair errors that impair existing intended functionality.

4.     Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5.     Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).

6.     Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7.     Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8.     Comply with a legal obligation.

9.     Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.  You may also make a verifiable request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period.  The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

Making a verifiable consumer request does not require you to create an account with us.  However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. 

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.


If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless its excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties.

  • Provide you a different level of quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or service or a different level or quality of goods or services.

OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  To make such a request, please send an email to info.us@zyn.com or write us at ZYN, P.O. Box 986, Owensboro, KY 42302.


CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion at any time.  When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.


CONTACT INFORMATION
If you have any questions or comments about this privacy policy for California residents, the ways in which we collect and use your personal information, your choices and rights regarding such use, or with to exercise your rights under California law, please do not hesitate to contact us at:


Phone: 1-855-YOUR ZYN

Website: http://www.zyn.com

Email: info.us@zyn.com

Postal Address:

ZYN
P.O. Box 986
Owensboro, KY 42302





CONTACTING US
If you have any questions or concerns about Swedish Match’s Privacy Policy, please contact us at info.us@zyn.com or call us at 1-855-YOUR ZYN. 

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