Privacy policy

Information pursuant to Art 13, 14 General Data Protection Regulation
Status: 16.12.2022

1. Who is responsible for data processing activities and whom can I contact?
   • Swedish Match North Europe AB, 118 85 Stockholm, Sverige, (“Swedish Match”, “we”, “us”), is the controller within the meaning of Art 4 Z 7 of the General Data Protection Regulation (“GDPR”) with regard to the processing of your personal data on the website [Please include link of the main page] (in the following “the website”).
   • This Privacy Policy applies to the processing of your personal data for which we are responsible, i.e. where we decide for what purposes and by what means your personal data will be processed.
   • You can reach us as follows:

Mail: Swedish Match North Europe AB, 118 85 Stockholm, Sweden

Phone:+46 08 6580200

E-mail: customerservice@swedishmatch.com

Website: www.thundernp.com

• You can reach our contact person for data protection or our data protection officer at: customerservice@swedishmatch.com
• Swedish Match takes the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the applicable data protection regulations, in particular the GDPR and the Austrian Data Protection Act(“ADPA”).
• In this Privacy Policy, you will find information on the data processing activities carried out by us. We use the terms set out in the GDPR. For a better understanding, we would like to explain to you below the most important terms according to their legal definition:

• Personal data: Any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• Data subject: The person whose personal data are processed (in this case you).
• Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processor: The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
• Consent (of the data subject): Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
  2. For what purposes do we process YOUR personal data?
     • Enquiry by e-mail, mail or telephone (Customer service and support)
       • If you send us an enquiry, complaint, etc. by mail, e-mail or if you call us (telephone), we collect personal data such as your name, e-mail address, address and other information that you provide to us voluntarily.
       • The legal basis for the processing of the above-mentioned data is our legitimate interest according to Art 6 (1)(f) GDPR to be able to process your enquiry, complaint etc.
       • The provision of your personal data is voluntary. However, if you do not provide certain data (such as e-mail address), we may not be able to process your enquiry.
     • Electronic Advertising
       • We will send you electronic mailings (via email, SMS, messenger etc.) to promote our products or services (“promotional messages”).
       • You can object to receiving promotional messages at any time by sending us an e-mail stating your objection. We will also provide you with the opportunity to opt-out of receiving further promotional messages with each promotional message.
       • The legal basis for sending advertising messages is Section 174 (3) Austrian Telecommunications Act 2021.
     • Newsletter
       • You can subscribe to our newsletter (online) on our website. In doing so, we collect personal data such as name, e-mail address and other information that you provide to us voluntarily.
       • The legal basis for sending the newsletter is Section 174 (3) Austrian Telecommunications Act 2021 in conjunction with Art 6 (1)(a) GDPR (your consent).
       • You can withdraw your consent in relation to the newsletter at any time by contacting us at [please include e-mail address]. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
     • Legal Prosecution
       • In the event of a dispute with the administrative authorities or in court, the personal data necessary for the appropriate prosecution will be transferred to legal representatives and courts.
       • In this context, we process in particular your contact details (e.g. first and last name, academic title, address, e-mail address) as well as other personal data related to the litigation in question (e.g. your behaviour in relation to the use of the website).
       • We process the aforementioned personal data on the basis of our legitimate legal interests in establishing, exercising or defending legal claims (Art 6 (1)(f) in conjunction with Art 9 (2)(f) GDPR).

3. Storage period
   • Swedish Match only stores personal data for as long as is necessary to fulfil the above-mentioned purposes. The personal data of the data subject will be stored longer despite the fulfilment of the purpose (e.g. processing of your enquiry), provided that this is necessary for the fulfilment of a legal obligation of the controller (e.g. according to Section 132 Abs 1 BAO and Sections 190, 212 UGB: 7 years) or for exercising or defending legal claims (as a rule for a maximum period of 3 years), whereby a longer processing of your personal data may be necessary in the case of an emerging or concrete proceeding.
4. To which recipients will your personal data be transferred?
   • We transfer your personal data as necessary for the respective purpose to the following recipients: service partners (including processors, see below), legal representatives, courts and administrative authorities. We may also transfer your personal data to processors who process the personal data exclusively on our behalf in accordance with our instructions (cf. Art 28 GDPR). Such processors may only process the data provided to them in accordance with our instructions and for the performance of services for us pursuant to Art 28 GDPR. In the case of data transfers outside the EEA, we contractually oblige these processors to ensure the confidentiality and security of the personal data processed under the contract. We are happy to provide a complete list of all processors currently engaged by us upon request.
5. What rights do you have?
   • You have the right to information under Article 15 of the GDPR, the right to rectification under Article 16 of the GDPR, the right to erasure under Article 17 of the GDPR, the right to restriction of processing under Article 18 of the GDPR, the right to object under Article 21 of the GDPR, the right not to be subject to automated individual decision-making, including profiling, and the right to data portability under Article 20 of the GDPR. Furthermore, you have the right to lodge a complaint with a competent data protection supervisory authority pursuant to Art 77 GDPR.
   • The competent data protection supervisory authority is the Austrian Data Protection Authority, Barichgasse 40-42, 1030 Vienna (https://www.dsb.gv.at/).
   • If you have any questions in connection with the processing of your personal data or wish to exercise any rights under the GDPR, such as your right to erasure or your right to information, please feel free to contact us as described in point 1.3 above.

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