Introduction
Suspect it? Report it! is a service provided by Imperial Tobacco Limited of 121 Winterstoke Road, Bristol, BS3 2LL (referred to in this notice as “ITL”, “we” or “us”). Where we refer to “our website” or “the website”, we mean the website page located at: http://suspect-it-report-it.co.uk/
You must be aged 18 or over to enter and use our website. We will ask you to confirm you are over 18 when you enter the website. The website is not intended for children and we do not knowingly collect data relating to children.
The purpose of this notice is to explain how we will collect and use your personal information when you submit information through the website or contact us via telephone, email, post or any other communications you have with us and to inform you of your rights in relation to the personal information we collect under data protection laws. We respect your privacy and we are committed to protecting your personal information. We will always treat your personal information in an appropriate manner and in accordance with the relevant data protection laws.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Important Information
Controller
ITL is the controller of the personal information you provide and is responsible for your personal information. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us by emailing dataprotection@uk.imptob.com.
Changes to our notice
We will keep this notice updated and keep you informed of any material changes to the way we process your personal information. Future changes will be posted here and we encourage you to read about the changes so that you keep up to date.
This privacy notice was last updated on 1 April 2021.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Third party links
Our website may include links to third-party websites, plug-ins and applications. We do not control these third-party websites and are not responsible for their privacy statements or for how they collect, use or share your personal information. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The information we collect about you
Personal information means any information about an individual from which that person can be identified. This includes information such as your name, email address, telephone number and address. It does not include data where the identity has been removed (anonymous data).
We collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity Data includes first name and last name.
- Contact Data includes email address and telephone numbers.
- Technical Data includes 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 this website.
- Opinion Data includes your feedback submitted to us.
- Usage Data includes information about how you use our website and services.
- Communications Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this notice.
We do not actively collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you include any special categories of personal data when you use our website or contact us, it is your responsibility to make sure you are happy for us to use that personal information in accordance with this notice. You should be aware that special categories of personal data are more sensitive and are more heavily protected by data protection legislation, so you should avoid including this kind of data if possible.
If you fail to provide personal information
Where we need to collect personal information in order to respond to your query and you fail to provide us with your personal information, we may not be able to contact you or deal with your request.
How is your personal information collected?
We use different methods to collect personal information from and about you including through:
Direct interactions – When you give us your Identity, Contact, Opinion and Communications Data when filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal information provided when you:
- submit queries or information to us through our website or by any other means, in relation to queries you have including reporting any problems with our website;;
- give us feedback;
- report anti-illicit tobacco trading and we require additional information from you to help with the AIT investigation;
- contact us by means other than the website for any other reason.
Automated technologies or interactions – As you interact with our website, we may automatically collect Usage Data about how you use our website and Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please see our Cookies section for further details.
Third parties – We may receive personal information about you from third parties such as Technical Data from analytics providers such as Google.
How we use your personal information?
Under data protection laws we are only permitted to use your personal information if we have a legal basis for doing so as set out in the data protection laws. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to comply with a legal or regulatory obligation; or
- Where it is necessary for the performance of a task carried out in the public interest; 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; or
- With your consent (for example, where you have requested communications via a particular method such as email or telephone), which you have the right to withdraw at any time by contacting us using the contact details above.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| Respond to Queries
To manage our relationship with you which will include responding to any queries you submit to us through the website, by telephone, by email, by post or any other means.
|
(a) Identity
(b) Contact (c) Opinion (d) Communications |
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how individuals use our services) (c) Consent |
| Gain Feedback
To enable you to submit feedback, including when you complete a survey and return to us. |
(a) Identity
(b) Contact (c) Opinion (d) Usage |
Necessary for our legitimate interests (to inform us of unauthorised use or sale of tobacco products and to inform our strategy) |
| AIT investigations
To request your assistance with our investigations relating to any activity you have reported to us. This includes to investigate and build intelligence on illicit tobacco activity in the UK and to report it to the relevant authorities (for example, Trading Standards). |
(a) Identity
(b) Contact (c) Opinion |
(a) Necessary to comply with a legal obligation
(b) Necessary for the performance of a task carried out in the public interest
(b) Necessary for our legitimate interests (to take appropriate measures to prevent the trading of counterfeit tobacco products) |
| Administering and protecting our business
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
| Data Analytics
To use data analytics to improve our website, services, relationships and experiences |
(a) Technical
(b) Usage |
Necessary for our legitimate interests (to define types of individuals who use our services, to keep our website updated and relevant and to develop our business) |
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details above.
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.
Marketing
We will not use your personal information for any marketing purposes and we will not share your personal information with third parties for any marketing purposes.
Disclosures of personal information
We will treat all of your personal information as private and confidential and in accordance with the data protection laws. We may however, need to share your personal information with third parties who provide services to us to enable them to provide their services to us such as IT providers and system administration services.
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 of 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.
Any third party service provider that we instruct will only process your personal information:
- for the same purposes for which we may use your personal information (as set out in this notice);
- as is strictly necessary to perform its obligations to us; and
- in the ways instructed by us.
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 will however, share your personal information with relevant authorities and law enforcement agencies in order to assist with enforcement actions against any illicit tobacco trade activities.
We will also share your personal information with other members of the group of companies to which we belong, all under the heading of the Imperial Brands PLC Group.
We will not usually disclose your personal information other than as set out above. However, there may be circumstances where we need to share personal information other than as anticipated above. These include:
- 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, law enforcement agencies and Trading Standards;
- where we need to disclose the personal information for the purpose of or in connection with any legal proceedings, or for the purpose of 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 when engaging with us, 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 with if we reorganise our business. Alternatively, we may seek to acquire other businesses or merge with them.
Transfers outside of the UK
Your personal information will only be transferred to a third party country under UK and/or EU data protection law 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
Security
Any information that you provide to us is stored on our secure servers. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Although we will do our best to protect your personal information, any information transmitted via the internet may not be completely secure and any transmission is at your own risk.
Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Generally we will keep your personal information for a period of six (6) years in order to facilitate any investigations arising from or in relation to your submission or query. However, where we have a statutory obligation to keep the personal information for a longer period or where we may need to keep your personal information for a longer period in case of a legal claim or dealing with ongoing queries or complaints, then the retention period may be longer. Your personal information will be retained in accordance with your rights under the data protection laws and in line with our regulatory obligations.
Your rights
You have a number of rights in relation to your personal information. You have the right within certain legal parameters, to:
- be informed about how we use your personal information (which we do in this privacy notice);
- obtain access to your personal information that we hold;
- request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate;
- ask us to erase your personal information in certain circumstances;
- ask us to restrict our information processing activities in certain circumstances;
- ask us for a copy of certain personal information that you have provided to us in a commonly used electronic format;
- object to our processing of your personal information;
- not be subject to automated decisions about you and to request human intervention; and
- withdraw consent where we are relying on consent to process your personal information.
If you would like to exercise any of the rights set out above, please contact us using the contact details above.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Cookies
The sections below explain how we use cookies to collect information about you and the steps that you can take to block cookies if you wish to do so.
What are cookies?
Cookies are small files of letters and numbers that we store on your browser or the hard drive of your device. Like most websites, we use cookies on our websites for our legitimate interests. There are different types of cookies that we use for different purposes; however generally speaking cookies help us to distinguish you from other users of our website, which allows us to provide you a better experience and also allows us to improve our website.
Generally, the role of cookies is beneficial, making your interaction with frequently-visited sites smoother with no extra effort on your part.
The cookies we use help to:
- make our website work as you would expect;
- improve your and other users’ experiences of our website;
- improve the speed/security of our website;
- remember your settings during and between visits;
We use the following cookies on our website:
- Strictly necessary cookies. These are cookies that are required for the operation of our website (also known as “required cookies”). They include, for example, cookies that enable you to log into secure areas of our website.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below. In particular, we use Google Analytics JavaScript libraries cookies to analyse which part of the website you have visited. Details of these cookies and how long they will be stored on your browser are set out in the table below.
| Cookie | Purpose | Expiration |
|---|---|---|
| __utma | Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics. | 2 years |
| __utmt | Used to throttle request rate. | 10 minutes |
| __utmb | Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics. | 30 minutes |
| __utmc | Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit. | End of browser session |
| __utmz | Stores the traffic source or campaign that explains how the user reached the website. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics. | 6 months |
| __utmv | Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics. | 2 years |
You can change the settings in your web browser to control how cookies are accepted or stored by your browser and computer and to block cookies if you wish. www.aboutcookies.org is a useful website that gives you information about how different browsers manage cookies. However, if you disable or restrict cookies, then you may find that some areas of our website no longer function correctly for you.
Complaints
We are registered with the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk), with registration number ZA106554. You have the right to make a compliant at any time to the ICO. We would however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details above.