Other individuals who interact with BAT

This section of the Privacy Notice applies to you if you fall within any of the following categories:

journalists with whom we communicate in any medium;
visitors to our physical premises;
individuals who attend or participate in conferences or events in which we are involved;
individuals who represent regulatory and law enforcement agencies or other governmental offices; and
academics and research professionals.

Here we tell you which BAT company is primarily responsible for your personal information, what we collect, why we collect it, how legally we can use it and for how long we keep it.

Which BAT company is primarily responsible for your personal information?

BAT company listed below with which you interact will be primarily responsible for your personal information. For further information please contact BAT Data Privacy Officer.

What personal data do we hold about you and where does it come from?

At BAT, we need some information about you, and will collect and hold the information listed in the table below under ‘ What Type of Information ’ so we can manage any current or future relationship we may have with you. We obtain this information either directly from you or from your employer, or from third parties who lawfully provide it to us (including publicly available materials) including the organisers of public events you attend.

How do we use your personal data, how do we legally do this and how long do we keep it for?

For a general description of all the ways we use your personal information please click back to section 3 of the Privacy Notice. However, in respect of the way we lawfully can use your personal information in the context of the relationship that you have with us, please see below.

Why do we hold your information	What type of information?	How legally can we use your information?	How long do we keep it for?
To contact you in order to manage your relationship with us.	Name, contact information (e.g. email address, telephone number, region where you are from)	In order to: (1) perform our obligations under contract (in particular: (a) for those individuals who attend, or participate in, conferences or events; or (b) in the context of our relationships with journalists) or take steps prior to entering into a contract.	7 years after the expiry of the business relationship or contract entered into by BAT.
To perform relevant due diligence into publicly available materials relating to you.	Name, contact information including the region where you are from Professional details including your work history, academic history and qualifications, job title, organization, website details (if any), contact details, and area of expertise or speciality Any publications, articles or publicly available materials you have created	We will either: (1) rely on our legitimate interest in: (a) protecting our business; or (b) in the context of a current or future business or commercial relationship; or (2) seek your consent where appropriate.	7 years after the expiry of the business relationship or contract entered into by BAT
To respond to any query that you have asked us.	Name and contact information Any information that you provide to us in submitting your query through our contact form or to us directly	It is in your interests for us to respond to your query and that any concerns you have relating to BAT are resolved.	1 year after the point in which it is no longer necessary for the purposes for which we obtained it.
To facilitate safe visits to our premises, and to contribute to COVID-19 containment measures.	Name, contact information and potentially questions surrounding your recent whereabouts or contact with those who may have been infected with the COVID-19 virus and body temperature information Any information that you provide to us relating to your visit.	It is our obligation to comply with safety measures put in place by regulatory agencies in the containment of the COVID-19 virus. Furthermore, maintaining safe premises and a safe working environment is within our legitimate interests, and is necessary to protect your vital interests (and those of others) and to comply with our legal obligations.	1 year after the point in which it is no longer necessary for the purposes for which we obtained it. Information obtained to contribute to COVID-19 containment measures will be retained for no longer than the conclusion of the situation pertaining to the COVID-19 outbreak.

If we rely on our legitimate interests (as detailed above in ‘ How legally can we use your information ’), we will always balance our legitimate interests against your rights and freedoms before using your information and will take into consideration the factors listed here.

Please note that we may need to keep your information longer than the periods stated above. This could be because of the following reasons:

to potentially establish, bring or defend legal proceedings or to comply with a legal or regulatory requirement;
to be able to deal with external or internal audits.

When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems. After that time, we would only retain aggregate data (from which you cannot be identified) for analytical purposes.

BAT entities primarily responsible for your personal information

British-American Tobacco (Holdings) Limited
British American Tobacco (Investments) Limited
B.A.T (U.K. and Export) Limited
BATLaw Limited
BATMark Limited
British American Shared Services (GSD) Limited
British American Tobacco AIT Limited
British American Tobacco Western Europe Commercial Trading Limited
British American Tobacco (Corby) Limited
Nicoventures Trading Limited
Nicovations Limited

BAT Nigeria - Other individuals who interact with BAT