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Swedish Match applies the prevailing regulatory framework pertaining to the processing of personal data and continuously strives to provide you with optimal integrity protection. We, in particular, comply with the statutory requirements of the Swiss Federal Law on Data Protection (DSG), the Ordinance to the Federal Law on Data Protection (VDSG), the Telecommunications Law (FMG) as well as the General Data Protection Regulation of the European Union (GDPR) and other applicable provisions of Swiss and European Data Protection Law.

This Privacy Notice is intended to help you understand how we collect, process and use your personal data, for example, whenever you create an account or purchase products from the website www.swedishmatch.ch (“The Website”). 

Who is the controller of your personal data?

Swedish Match North Europe AB, SE- 118 85 Stockholm, Sweden; corp. reg. no. 556571-6924, tel: +46 (0)200-113 114 (“Swedish Match”) operates the Website. Accordingly, Swedish Match is the controller for processing the personal data.

For what purposes does Swedish Match process your personal data?

We mainly use your personal data to fulfill our obligations to you – for example, to create an account and process, save, update and deliver your orders. Below you find information about each category of personal data concerned, and the purpose and legal basis for our processing. 

Information submitted by you directly

For customers

If you order a product on the Website, we ask you to provide the following information about yourself:

  • First name*
  • Last name*
  • Street address*
  • C/O
  • Zip code*
  • City*
  • Country
  • E-mail address*
  • Telephone number*
  • Payment information*

Fields marked with an * are mandatory fields.

We require this information in order to process (save, update and deliver) your orders and administer potential returns. If you do not provide the above information, we will not be able to process your orders. We solely process your telephone number in order to send you text messages with information about the delivery of your purchase orders and other important information in connection with your purchase. The telephone number will not be used for marketing purposes. The legal basis of processing of such data for these purposes is the performance of a contract (order and purchase agreement; see art. 6 para. 1 lit. b GDPR) as well as our legitimate interest in being able to administer possible returns (see art. 6 para. 1 lit. f GDPR).

We further ask you to provide your birth date when first entering the Website. We require this information in order to verify your age. The legal basis of processing of this data is our legal obligation to comply with age limit limitations for the sale of tobacco products. 

Furthermore, we process your orders and payment details based on our legal bookkeeping obligations. 

Finally, we maintain and process your order history, i.e. information about what items you ordered, such as number of items, date of order and item price. We maintain such data in order to provide you with post-order services, as well as to handle any potential complaints. The legal basis for this processing is our legitimate interest in providing the best service possible, in contributing to the safe use of our goods, and in safeguarding our rights in connection with any potential complaints (see art. 6 para. 1 lit. f GDPR). We further process the above data to comply with our legal obligations relating to product safety requirements, as applicable. 

For account holders

When you create an account on the Website, we ask you to provide the following information about yourself: 

  • First name*
  • Last name*
  • Telephone number
  • E-mail address*
  • Password*
  • Confirm password* 

Fields marked with an * are mandatory fields.

We require this information for the purpose of account creation and administration. The legal basis of processing of such data for this purpose is our legitimate interest in administering your account (art. 6 para. 1 lit. f GDPR). You can reject this data processing at any time. However, we are then not able to further administer your account and will close the account. 

For you who contact customer service

When you contact our customer service, we potentially collect the following information:

  • First name
  • Last name
  • E-mail address (if you contact us by email at customerservice@swedishmatch.com)
  • IP-address (if you use our Live Chat)
  • Telephone number and address
  • Content of your query

We process this information in order to administer the customer service matter. The legal basis of processing of this data for the above purposes is our legitimate interest in administering the customer service matter and in providing you with good service (see art. 6 para. 1 lit. f GDPR), as well as our potential legal obligations e.g. product safety requirements.

We further process your IP-address when you use the chat function to provide improved service. Swedish Match uses Zendesk Live Chat to provide customer service and live chat functions. Zendesk Live Chat is provided by Zendesk, Inc., 1019 Market Street, San Francisco, CA 94103, USA. The data is stored in the EU. Zendesk uses cookies to ensure that customer service can see how a visitor moves on the site and that customer service can provide support between sessions. For this purpose we rely on our legitimate interest to continually improve our services (see art. 6 para. 1 lit. f GDPR).

 

For visitors to the Website

When you visit the Website, Swedish Match collects the following information (see also Swedish Match’s Information about cookies). Note that certain other companies than Swedish Match also collect your IP address when you visit the Website, in connection with the use of third-party cookies. How this occurs, and how you can go about limiting or turning off cookies in your Web browser, are described in Swedish Match’s Information about cookies.

  • Device information: your MAC or IP address and settings on the device you use to access our services, the operating system of your computer and the browser used (type, version and language)
  • Name of the owner of the IP address range (usually your Internet access provider)
  • Date and time of access, name and URL of the data retrieved
  • The website from which our domain was accessed (referrer URL)
  • The transmission protocol used (e.g. HTTP/1.1)
  • Login information: when and how long you use our services, search words you enter when using our services and all information stored in the cookies we install on your device
  • Location information: the GPS signal from your device or information concerning nearby Wi-Fi access points and mobile towers that may be sent to us when you use our services.

We use your IP address to direct you to your country´s website, to prevent infringements, incidents and other misuse of our services on the Website, to run statistics on visitors to the Website and to update and improve the Website. It may further be used for identification purposes in criminal proceedings and in the context of civil and criminal proceedings against the concerned individual, as necessary and required.

We further process the above data for the purpose of allowing the use of our Website (establishing a connection), ensuring system security and stability in the long term and allowing our Internet offering to be optimized, as well as for internal statistical purposes

The legal basis for this processing is our legitimate interest in ensuring system security and stability in the long term, preventing misuse and in having a properly functioning Website (see art. 6 para. 1 lit. f GDPR).

Who do we share your personal data with?

Swedish Match may share your personal data with other companies within the Swedish Match Group, as well as with collaborating partners, for example when providing IT and payment services., to the extent required for the use of the Website and contract performance, namely for the processing of your orders, for facilitating the delivery of your orders, for processing your payments, for the provision of our services, and to analyze your user, order, and payment patterns. The use of the disclosed data by third parties is strictly limited to the mentioned purposes.

These recipients only process your personal data on our behalf and in accordance with our instructions. Swedish Match takes all appropriate legal, technological and organizational measures to ensure that your personal data is processed securely, and with an adequate level of security when transferring to or sharing with selected recipients of this kind.

Swedish Match may also share your personal data with other companies who do not process your personal data on behalf of Swedish Match, but rather under their own control and in their own interest, for example companies providing shipping and payment services. We only share your information with these companies in order to fulfill our commitments towards you. When your personal data is shared with these companies, which are independent controllers, your personal data is processed in accordance with what is outlined in these companies’ privacy notices.

Swedish Match may also share your personal data with governmental agencies if we are obligated under the law to do so, or on suspicion of criminal activity.

Where do we process your personal data?

We are entitled to forward your personal data to third-party companies abroad and in particular to other companies in the Swedish Match Group, insofar as this is necessary in connection with the purposes described above. These third-party companies are obliged to respect the privacy of users to the same extent as we are.

Your personal data will primarily be processed within the EU/EEA, but may also be transferred to a country outside the EU/EEA,– for example, if we share your information with other companies in the Swedish Match Group.

Swedish Match will only transfer your personal data to a country outside the EU/EEA if there are legal grounds to do so and sufficient guarantees that your personal data will be handled in a lawful manner. In such cases, Swedish Match takes all appropriate legal, technological and organizational measures to ensure that your personal data is at all times processed securely, and with an adequate level of protection comparable to the level of protection offered in Switzerland and/or within the EU/EEA.

How long do we store your personal data?

Once you have created an account on the Website, your personal data is stored until your account is deactivated. Otherwise, we store your personal data only as long as is necessary for the purpose for which the data was collected. See more information under each purpose above.

We may also save your personal data for a longer time if it is necessary to fulfill a legal obligation that requires processing in accordance with applicable laws, such as legal retention obligations, or so that we can establish, enforce, or defend legal claims.

What are your rights?

You have certain specific legal rights that you can enforce against us. A summary of these rights follows below.

Right to access/extracts from the register. You have the right to know what personal data about you we are processing. Upon request from you, we will provide you with information in writing about our processing of your personal data, free of charge. 

Right to data portability. You have the right to request a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format. Provided that it is technologically possible – which is determined by Swedish Match – you also have the right to request that we transfer this personal data to another controller. The right to data portability applies to personal data that is processed via automated means, and that is based on the performance of a contract.

Correction of erroneous information. You have the right to request that we correct erroneous or incomplete information about yourself. If you have an account you may also correct certain information by logging in. 

Deletion of certain data. You have the right to request that we delete your personal data under certain conditions, for example if your personal data is no longer necessary for the purpose for which we collected the data, if you object to a weighing of legitimate interests we have carried out and support for our legitimate interest is lacking, if your personal data was processed in an unlawful manner or if your personal data has to be deleted in order to fulfill a legal obligation.

In certain cases, we must retain your personal data despite your request, owing to legal requirements such as accounting and tax legislation, or for example if we need to retain certain data in order to establish, enforce or defend a legal claim.

Right to restrict processing of your personal data. You have the right to demand a restriction on our processing of your personal data in certain cases. If, for example, you claim that your personal data is incorrect, you can request a restriction on processing for a period of time that will give us the opportunity to check if your personal data is correct.

Right to object to our processing of personal data. You have the right, under certain conditions, to object to our processing of your personal data,.

You have the right to object to processing that is based on the legal grounds of our legitimate interest. However, we may continue processing your data despite your objection to the processing if we have compelling legitimate reasons for the processing that outweigh your privacy interests.

Cookies

We use cookies when you visit the Website. Read more about how we use cookies in our Information on cookies.

Questions and complaints

If you have any questions regarding our processing of your personal data, or if you would like to present a request about an excerpt from the registry, data portability, correction or deletion – or present an objection or a restriction – please contact us at 

Swedish Match North Europe AB
118 85 Stockholm
+46 0200-113 114 
customerservice@swedishmatch.com 

If you have a complaint regarding Swedish Match’s processing of your personal data, you have the right to submit such complaints to the competent data protection authority.

How do we protect your personal data?

We use suitable technical and organizational security measures to protect your personal data stored by us against tampering, partial or complete loss and unauthorized access by third parties. Our security measures are subject to continuous improvements in line with technological developments. 

For instance, Swedish Match takes the security measures needed to protect your personal data, for example, Secure Socket Layer (SSL) is a protocol for the secure transfer of data developed by Netscape Communications. 

If you create an account, the access to your account will only be permitted with your personal password. You should always keep your account details and your payment information confidential and close the browser window as soon as you terminate the communication with our Website, in particular if you do not access our Website with your own personal computer or if you share access to the computer with another person.

Links to other websites

The Website may contain links to other websites. This Privacy Notice applies only to the Website. Swedish Match is not responsible for the processing of personal data by other websites and you are therefore encouraged to check the privacy policy for any such third party websites.

Changes to this Privacy Notice

Swedish Match reserves the right to make changes to this Privacy Notice. Any such changes are published on the Website. We therefore encourage you to periodically review this Privacy Notice for any changes.


Latest update to this Privacy Notice: July 13, 2018 (Version 1.0)

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