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This Privacy Policy sets out how Swedish Match North America LLC and its subsidiaries and sister companies (“Affiliates”) (collectively, “Swedish Match,” “SMNA,” “we,” and “our”) uses and protects any personal information that you provide Swedish Match through websites owned and operated by Swedish Match, including ZYN, General Snus, America’s Best Chew, Timber Wolf Snuff and all related websites, web applications, mobile apps, or other web-connected services (“Websites”). This Privacy Policy also covers our collection, use, and sharing of personal information that may be collected through other channels in connection with Swedish Match’s products and services, including via telephone, email, and other electronic communications, at events and otherwise in-person, and/or through electronic devices (together with Websites, our “Products and Services”).

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 September 27, 2023. 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 products and restricts access to our Websites and marketing communications to adult 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 website, aggregate information on what pages consumers access or visit, and information volunteered by the consumer, such as survey information and/or site registrations. 

When registering on our Websites, we collect certain personal information including your legal first name, preferred first name, last name, address (including street, city, state, and zip code), telephone number (if you choose to provide), your date of birth, email, and whether you use nicotine products.

In addition, we may collect various types of personal information about you, whether through our Websites or in other contexts in connection with our Products and Services:

  • information about your orders, including information necessary to fulfill them
  • information necessary to verify your age
  • information you give us in communications (e.g., calls, e-mails, chats) you have with contact centers
  • information you give us to participate in loyalty rewards programs
  • information about your experiences using our Products and Services
  • information about your preferences and interests (including information that we infer from other information, for example from statistical information)
  • statistical information about you (for example, statistical information about people in certain geographical areas)

 

HOW WE COLLECT INFORMATION

We may collect personal information about you in various ways:

  • You may provide us with information directly (e.g. filling in a form, making a call to us, or uploading information to us via a mobile app)
  • We may collect information automatically when you interact with our systems or we communicate with you (e.g. when you use our website or, where we use technologies to observe when you receive or open e-mails or receive SMS messages)

 

We may collect personal information that you provide directly. Typically, this will happen when you:

  • request information about our Products and Services
  • purchase Swedish Match Products and Services at a retail outlet
  • download, or use, a Swedish Match digital touchpoint (e.g. website)
  • contact us through a touchpoint, or by e-mail, social media or telephone
  • register a device with us
  • subscribe to a Swedish Match panel portal
  • register to receive Swedish Match press releases, e-mail alerts, or marketing communications
  • participate in Swedish Match surveys or (where permitted by law) Swedish Match competitions or promotions
  • attend an event that a Swedish Match affiliate has organized

 

We may collect information about you automatically. Typically, this will happen when you:

  • visit an outlet that sells our products (for example, by collecting your data at check-out, or through sensors at the outlet that connect with mobile technology)
  • attend an event that a Swedish Match affiliate has organized (for example, through purchases at the event or through sensors at the event that connect with mobile technology)
  • communicate with us (for example, through a touchpoint, or social media platforms)
  • use Swedish Match touchpoints (for example, through tracking mechanisms (such as cookies and web beacons/pixels), where we use them, that you receive when you use the PMI touchpoint or get an e-mail or SMS message from us)

 

Where permitted by law, we may acquire information about you from third parties. This may include information shared between PMI affiliates, marketing lists and supplementary information acquired from third party agencies.

Where permitted by law, we may infer information about you from information about you that we already have. For example, we may use aggregated information about people in certain geographical areas, that we acquire from third parties, to infer your preferences.

We may also collect information in other contexts made apparent to you at the time.

USE AND SHARING OF INFORMATION

The personal information we collect may be 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 may use, or disclose the personal information we collect for one or more of the following business purposes:

  • To comply with regulatory obligations, such as verifying your age and status as a user of our Products and Services
  • 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 and 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 Websites, 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 experience on our Websites and to deliver the content and Product and Service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
  • To market our Products and Services (to the extent permitted by law and consistent with this Privacy Policy), including administering loyalty programs and referral programs, product improvement, market research (and for the purposes of demonstrating fair practices in market research), developing marketing strategies, administering marketing campaigns, and customizing your experiences, for example at outlets that sell Swedish Match products and at events, and the content of messages we send you or advertisements we show you
  • 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.
  • 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 users is among the assets transferred.

 

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 may share your personal information with the following categories of third parties:

  • Service providers
  • Data aggregators.
  • Our affiliates, our parent company Philip Morris Intl. (PMI) and it’s affiliates’ carefully selected business partners and advertisers (in areas connected with our products, or consistent with their style and image) so that they can contact you with offers that they think may interest you, in accordance with your preferences and applicable law
  • 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.
  • Other third parties, where required or permitted by law

 

We share information about you with others only in accordance with applicable laws. Thus, where law requires your consent, we will first ask for it.

INTERNATIONAL DATA TRANSFER

As with any multinational organization, we transfer information globally to our affiliates and service providers.  Your data may therefore be transferred to other countries as part of our standard operations.  Whenever we transfer your data abroad, we will limit access to your data only to those who need to see it, process your data in accordance with our internal data protection standards, protect it appropriately and only transfer information in compliance with applicable data privacy laws.  When data is transferred, we will require the receiving party to keep your data confidential, delete it when it is no longer required and act in accordance with this privacy notice.  Accordingly, information about you may be transferred outside of your jurisdiction. 

COOKIES AND TRACKING TECHNOLOGIES

Swedish Match uses cookies and similar technologies to analyze trends, administer the Websites, 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 Websites also uses web beacons, which are embedded invisibly on pages and help us better manage content on our Websites 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. 

The Websites use 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. By accessing Swedish Match through the Websites, visitors consent to use of Google Analytics and the collection of certain demographic information. 

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

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.  In addition, Swedish Match conducts data protection assessments when required by law.  

OPTING OUT
If you no longer wish to receive commercial e-mails 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.

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. 

PRIVACY RIGHTS

How to Exercise Your U.S. Privacy Rights

If you are a U.S. resident and any of the notices below apply to you, please use the following information to exercise your rights. Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable state privacy laws, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to certain exceptions under applicable state privacy laws, which may vary from state to state.

Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some states an authorized agent may submit a request to exercise your rights on your behalf.

How to submit a request. If you are a U.S. resident and wish to seek to exercise these rights, please submit a request 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 are a visually-impaired customer, a customer who has another disability or a customer who seek support in other language, you may access your state-specific privacy rights by emailing us at info.us@zyn.com.

We do not charge a fee to process or respond to your verifiable consumer request unless its excessive, repetitive, manifestly unfounded, or in accordance with state-specific requirements.  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.

You may only make a verifiable or authenticated consumer request twice within a twelve (12) month period. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, under some state privacy laws, you may designate an authorized agent to submit a request on your behalf. The request must include:

  • 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 or authenticated 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 or authenticated consumer request to verify the requestor’s identity or authority to make the request.

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.

CALIFORNIA PRIVACY NOTICE

Effective Date: January 1, 2023
Last Updated on: September 27, 2023

This California Privacy Notice applies to any California residents about whom we have collected personal information from any source, including through your use of our Websites, Products, and Services.

The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (together, the “CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in this Privacy Policy.

The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, sale, and sharing of personal information, as well as rights to access, delete, correct, and restrict the use, disclosure, and sale of certain personal information we collect about them. Additionally, California residents have the right to opt-out of the sale/sharing of their personal information. California residents also have the right not to receive discriminatory treatment by us for the exercise of their privacy rights under the CCPA. This California Privacy Notice does not apply to certain personal information that is already subject to certain federal and state regulation.

If you are a California resident, you may submit a request to exercise these rights by emailing us using the information provided in the Your Privacy Rights section below. This section applies to you if you are a California resident about whom we have collected personal information through the Website.

 

PERSONAL INFORMATION WE COLLECT
For purposes of this California Privacy Notice, our Websites collect 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”). Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified; or aggregated consumer information. For purposes of this section, “publicly available information” includes: information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

 In particular, we have collected the following categories of personal information from  consumers within the last twelve (12) months:

CATEGORY

EXAMPLES

A. Identifiers.

AA 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 or other information linked or linkable to an identifiable individual.

B. Personal information listed in states customer records, including 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.

D. Commercial information.

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

F. Internet or other similar network activity.

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

G. Geolocation data.

Physical location or movements.

K. Inferences drawn from other personal information.

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

Sensitive personal information. Certain types of personal information that we collect, as described above, may constitute “sensitive personal information” under California law, including:

 

SOURCES OF PERSONAL INFORMATION

We may collect personal information from you from the categories of sources described in SHARING OF PERSONAL INFORMATION.

USE OF PERSONAL INFORMATION
We may use the personal information we collect about you for the purposes described in USE AND SHARING OF INFORMATION section above. 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 limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal information for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal information was collected.  

We do “sell”/”share” personal information for purposes of cross-context behavioral advertising, as those terms are defined by the CCPA.  Review our “Notice of Right to Opt-Out” below for more detail about this activity and your rights to opt-out of it.

The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

 

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions: 

  • Right to Know. You have the right to request, up to twice in a 12-month period, what personal information we collect, use, disclose, and/or sell, as applicable.
  • Right to Delete. You have the right to request under certain circumstances that we as well as our service providers and contractors delete the personal information we collected from you.
  • Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale of your personal information by us as those terms are defined by the CCPA.
  • Right to Correct. You have the right to request the correction of your inaccurate personal information.
  • Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our Products and Services to you, or for certain other authorized purposes.
  • Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above. This right may be subject to the offers described in our Notice of Financial Incentives, set forth below.

 

How to submit a request. If you are a California resident and wish to seek to exercise these rights, please reach us in one of the following ways please refer to the information under How to Exercise Your U.S. Privacy Rights above.

  • Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information.  In order to verify you, you must provide us with your first and last name and email address.  These rights are also subject to various exclusions and exceptions under applicable laws. 
  • Authorized Agents. You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child. If you use an authorized agent to exercise your various rights under the CCPA, we may require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us. If your authorized agent does not submit proof that they have been authorized by you to submit verified requests, we reserve the right to deny such a request that we have received and will explain to your authorized agent why we have denied such request.

 

Household Data. We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.

Any disclosures we provide will only cover personal information we have collected on or after January 1, 2022. 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. 

YOUR RIGHTS AND CHOICES
The CCPA and VCDPA provides consumers (California and Virginia residents) with specific rights regarding their personal information.  This section describes your CCPA and VCDPA 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:

  • Whether or not we are processing personal data
  • The personal data we have processed
  • 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 / Correcting Inaccuracies Rights
You have the right to request that we delete any of your personal information and/or correct any inaccurate information that we collected from 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.) and similar state laws.
  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.

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

Direct Marketing By Third Parties


California’s “Shine the Light” law (Civil Code § 1798.83) permits users of the Websites 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.

Notice of the Right to Opt-Out

We “sell”/”share” a limited set of personal information with third parties as those terms are defined by the CCPA, including to participate in behavioral advertising networks. This includes information we collect through the Website. If you wish to opt-out of the “sale”/”sharing” of the limited personal information that is gathered when you visit the Websites for purposes of cross-context behavioral advertising, please email info.us@zyn.com.

Notice of Financial Incentives

We may offer discounts on products and services – including those offered by us, our affiliates, and third-party business partners. The availability of these promotions to you at any given time will vary. If and when we offer such programs, we may ask for your personal information as a prerequisite to your participation in the program.

  • Mailing Lists. When you subscribe to the mailing lists, we may offer you special deals in the form of free or discounted products, coupons, rewards, and announcements of sweepstakes, contests, and giveaways.  In order to participate, you must create an account on the Website.
  • ZYN Rewards. When you participate in the ZYN Rewards program, we may use the information you provided us during the registration process in order to facilitate your participation in the program.

 

VIRGINIA PRIVACY NOTICE

This Virginia Privacy Notice applies to any Virginia residents about whom we have collected personal information from any source, including through your use of our websites, by engaging us to inquire about or obtain the various products and services that we offer, or by communicating with us electronically, by telephone, in paper correspondence, or in person. The provisions contained within this section are intended to provide notices in compliance with the Virginia Consumer Data Protection Act (“VCDPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in this Privacy Policy.

The VCDPA provides Virginia residents with rights to receive certain disclosures and access regarding collection, use, sale, and sharing of personal information, as well as rights to delete, correct, and affirmatively consent to the use, disclosure, and sale of certain personal information we collect about them. Additionally, Virginia residents have the right to opt-out of targeted advertising, sale of their personal data, and profiling. Virginia residents also have the right not to receive discriminatory treatment by us for the exercise of their privacy rights. This Virginia Privacy Notice does not apply to certain personal data that is already subject to certain federal and state regulation. If you are a Virginia resident, you may submit a request to exercise these rights by emailing us using the information provided in the Your Privacy Rights section below.

This section applies to you if you are a Virginia resident about whom we have collected personal information through the websites.

PERSONAL DATA WE COLLECT

For the purposes of this Virginia Privacy Notice, except where a different definition is noted, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified data or publicly available information. For the purposes of this section, “publicly available information” includes: information that is lawfully made available through federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully made available to the general public through widely distributed media, by the consumer; and information that is made available by a person to whom the consumer has disclosed the information, unless the consumer has restricted the information to a specific audience.

We may collect the personal data from or about you as detailed under INFORMATION WE COLLECT and PERSONAL INFORMATION WE COLLECT.

Sensitive data. Certain types of personal data that we collect, as described above, may constitute “sensitive data” under Virginia law, including:

USE OF PERSONAL DATA

We may use the personal data we collect about you for the purposes described in USE AND SHARING OF INFORMATION section above. 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.

SOURCES OF PERSONAL DATA

We may collect personal data from the categories of sources described in the HOW WE COLLECT INFORMATION section above.

SHARING PERSONAL DATA

We limit our disclosure of the categories of data above to our service providers for one or more business purposes.Business purposes”  means the reasonably necessary and proportionate use of personal data, in a way that is adequate, relevant, and necessary for specific purposes described in this Privacy Policy, compatible with the nature and purpose(s) for the collection, use, and retention of the personal data.

We share personal data for targeted advertising purposes as those terms are defined under Virginia law.  You may opt-out of such sharing by following the instructions provided in the Notice of the Right to Opt-Out above.

YOUR VIRGINIA PRIVACY RIGHTS

If you are a Virginia resident, you have the following rights under applicable Virginia law in relation to your personal data, subject to certain exceptions: 

  • Right to Know. You have the right to, up to twice in a 12-month period, request what personal information we collect, use, disclose, and/or sell, as applicable;
  • Right to Delete. You have the right to request under certain circumstances that we delete your personal data.
  • Right to Opt-Out. You have the right to opt-out of targeted advertising, our sale of your personal data, and profiling decisions that could produce  legal or similarly significant effects concerning the consumer.
  • Right to Correct. You have the right to request the correction of your inaccurate personal information.
  • Right to Provide Affirmative Consent. We cannot process your sensitive data or use your personal data for certain purposes without your affirmative consent.
  • Right to Non-Discrimination. You have the right to not receive discriminatory treatment for the exercise of the privacy rights described above.

 

How to submit a request. If you are a Virginia resident and wish to seek to exercise these rights, please reach us in one of the following ways please refer to the information under How to Exercise Your U.S. Privacy Rights above.

  • If you wish to appeal our decision with regard to a request that you have previously made, please contact us using the information above or notify the Office of the Attorney General of Virginia by clicking g here.
  • Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Virginia’s Office of Attorney General by phone at (804) 786-2071, written correspondence to 202 North 9th Street, Richmond, Virginia 23219, or by accessing:   https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

 

CHANGES TO OUR PRIVACY POLICY

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 Notice for California and Virginia Residents, the ways in which we collect and use your personal information, your choices, and rights regarding such use, or wish to exercise your rights under applicable California or Virginia law, please do not hesitate to contact us at:

Phone: 1-855-YOUR ZYN

Website: http://www.zyn.com

Email: info.us@zyn.com

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