EU / EEA Privacy Statement

Data privacy

Subsidiaries of Alliance One International, Inc. that are organized in the EU / EEA including Alliance One International Services Ltd, Alliance One Tobacco Bulgaria EOOD, Alliance One Rotag AG, Alliance One Bulgaria Greek Branch, Trans-Continental Leaf Tobacco Corp. Limited, Intabex Netherlands B.V., Alliance One International Tabak B.V., Standard Commercial Tobacco (UK) Company Limited, Standard Commercial Tobacco (UK) Services Limited, Standard Commercial SA and International Tobacco Funding, S.L (collectively “AOI EU,” “us” or “we”) have a legal obligation to comply with the General Data Protection Regulation (GDPR)

This privacy statement is applicable to AOI EU operations and sets out the basis on which we will process any personal information that we may collect about you as a visitor to our website or premises or a contact at one of our customers, suppliers (including growers) or other business partners.

The information that we collect about you

We may collect and process the following information about you:

• Information that you give us: This is information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete), giving us a business card (or similar) or communicating with us by telephone, post, email, directly or otherwise. It may include, for example, your name, address, email address, telephone number and other personal details; information about your business relationship with AOI and other business details; and information about your professional role, background and interests.
  
  
• Information that our website and other systems collect about you:
  
  
  • If you visit our website it will automatically connect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as your browser type and version and the pages on our site that you visit. Our website may also download "cookies" to your device – this is described in our separate Cookie Policy.
    
    
  • If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content.
    
    
  • Some of our premises have closed circuit TV systems which may record you if you visit our premises, for security and safety purposes.
    
    
• Other information: We may also collect some information from other sources. For example:
  
  
  • If we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship.
    
    
  • We sometimes collect information from third party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
    
    

The uses that we make of your information

We may use your information for the following purposes:

• to operate, manage, develop and promote our business and, in particular, our relationship with the organisation you represent (if any) and related transactions – this includes, for example, marketing and billing / payment purposes;
  
  
• to operate, administer and improve our website and premises and other aspects of the way in which we conduct our operations;
  
  
• to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes; and
  
  
• to comply with our legal and regulatory obligations and bring and defend legal claims. 

We may from time to time review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as described below. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left AOI).

We will only process your personal information as necessary so that we can pursue the purposes described above, and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. In exceptional circumstances we may also be required by law to disclose or otherwise process your personal information. We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information. Otherwise you should assume that we need the information for our business or compliance purposes (as described above). If you are uncertain as to AOI EU's need for information that we request from you, please contact the AOI EU representative asking for the information, or contact us (see below), with your query.

Disclosure and international transfer of your information

We may disclose personal information about you, where reasonably necessary for the various purposes set out above:

• to the other members of the Alliance One International group of companies;
  
  
• to your colleagues within the organization that you represent;
  
  
• to service providers, such as those who host our website or other information technology systems or
  otherwise hold or process your information on our behalf in the course of supporting our business operations;
  
  
• to a person who takes over our business and assets, or relevant parts of them; or
  
  
• in certain circumstances:
  
  
  • to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory;  or
    
    
  • where we are required by law to disclose.

These disclosures may involve transferring your personal information overseas. You should be aware that this may include transfers to countries outside the European Economic Area / UK, which do not have similarly strict data privacy laws. In those cases, where we transfer personal data to other members of the Alliance One International group or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission. Please contact us if you would like to know whether any such agreements are in place or, if so, to see a copy.

Retention and deletion of your information

We will delete the information that we hold about you when we no longer need it.

Your rights

You may have a right of access to the personal information that we hold about you, and to some related information, under data protection law. You can also require any inaccurate personal information to be corrected or deleted. You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.

If you wish to exercise any of these rights, please contact us.

You can also lodge a complaint about our processing of your personal information with the relevant Data Protection Authority:

Bulgaria

Commission for Personal Data Protection2, Prof. Tsvetan Lazarov blvd. Sofia 1592 Tel. +359 2 915 3580 Fax +359 2 915 3525 e-mail: [email protected] Website: http://www.cpdp.bg/

Germany

The State Data Protection Officer of Baden-Württemberg,Königstraße, 10a, 70173 Stuttgart, phone 0711/615541-0, fax 0711/615541-15, email: [email protected]

Greece

Hellenic Data Protection Authority Kifisias, Av. 1-3, PC 11523 Ampelokipi Athens Tel. +30 210 6475 600 Fax +30 210 6475 628 e-mail: [email protected] Website: http://www.dpa.gr/

Netherlands

Autoriteit Persoonsgegevens Prins Clauslaan, 60 P.O. Box 93374 2509 AJ Den Haag/The Hague Tel. +31 70 888 8500 Fax +31 70 888 8501 e-mail: [email protected] Website: https://autoriteitpersoonsgegevens.nl/nl

Spain

Agencia de Protección de Datos,C/Jorge Juan, 6 28001 Madrid Tel. +34 91399 6200 Fax +34 91455 5699 e-mail: [email protected] Website: https://www.agpd.es/

United Kingdom

The Information Commissioner’s Office,Water Lane, Wycliffe House Wilmslow - Cheshire SK9 5AF Tel. +44 1625 545 745 e-mail: [email protected] Website: https://ico.org.uk

Liechtenstein

Data Protection Office Kirchstrasse 8, P.O. Box 684 9490 Vaduz Principality of Liechtenstein Tel. +423 236 6090 e-mail: [email protected]

Contact us

We welcome questions, comments and requests regarding this privacy statement and our processing of personal information. Please send them to Alliance One International, Inc., Attn: Compliance 8001 Aerial Center Parkway, P.O. Box 2009, Morrisville, NC 27560, United States of America or email us on [email protected].

Alternatively you can contact us at:

• Alliance One Rotag, Hardeckstrasse 2a, 76185 Karlsruhe, Germany
• Alliance One International Services Limited, Building A, Riverside Way, Camberley, Surrey, GU15 3YL, England
• Alliance One Tobacco Bulgaria EOOD, 62 Saedinenie Blvd, BG-6300, Haskovo, Bulgaria
  
  

Changes to this policy

Any changes we make to this privacy statement in the future will be posted to our website at www.aointl.com and also available if you contact us. Please check back frequently to see any changes.

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