PRIVACY POLICY - ENGAGETRADEPARTNERS.COM

Effective date: February 23, 2017

This website (the "Site") is operated by RAI Trade Marketing Services Company ("RAI TMS”) for use by authorized employees of wholesalers and retailers (collectively "customers") of the products of R.J. Reynolds Tobacco Company ("RJRT"), American Snuff Company, LLC ("ASC"), R.J. Reynolds Vapor Company ("RJRV"), Santa Fe Natural Tobacco Company ("SFNTC"), and/or Niconovum USA, Inc. ("Niconovum”). Hereafter, this Privacy Policy will refer collectively to RAI TMS, RJRT, ASC, RJRV, SFNTC, and/or Niconovum as "we" or "us."

This Privacy Policy describes the types of personal and non-personal information we collect on the Site, how we use such information, to whom and under what circumstances we may disclose it, and how we protect the information. This Privacy Policy also describes your responsibilities to keep information you access on this Site confidential. By using the Site, you fully and unconditionally agree to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, do not use the Site.

Information Collection and Use

If you are your company's designated administrator ("Designated Site Administrator"), you will submit certain personal information in order to set up an account including but not necessarily limited to your name and position in your company, company name, and contact information for you and your company. The Designated Site Administrator is responsible for ensuring that all contact information remains up-to-date

If you use the Site through your company's account but you are not the Designated Site Administrator, your Designated Site Administrator will submit your name and position in the company.

Each time a person accesses the Site, he or she must submit a user name and password to access the Site. RAI TMS will assign a user name and password to the Designated Site Administrator (which he or she may then change). The Designated Site Administrator may, if he or she chooses, assign additional user names and passwords to other employees of the company. These user names and passwords constitute your "Account Information."

We may also collect information from you when you contact us or when you otherwise voluntarily submit it to us. We may combine the information we collect from you online with information we collect from and about you and your company offline and from other sources.

When you use the Site, we or our third party service providers may automatically collect certain non-personally-identifiable information from you including but not necessarily limited to your IP address, browser type and language, and the date and time of your visit. We or our third party service providers may also use cookies to collect information about your browsing behavior such as the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, and the number of times you return. A cookie is a small text file that is stored on the hard drive of your computer when you access the Site. We may combine all of this non-personally identifiable information with your personal information.

In addition, we use a third party service provider to place a cookie on your system to collect anonymous traffic data when you use the Site. This information provides us with insight into how the Site is used.

We may use the information we or our third party service providers collect from and about you: (1) to administer the Site; (2) to respond to your inquiries; (3) to contact you when necessary such as to inform you of Site issues or updates; (4) to monitor and review Site usage and operations; (5) to address problems with, update, or improve the Site, our business, or our services; and (6) to protect the security or integrity of the Site and our business.

Your Responsibility for Your Account Information

You understand and agree that it is your responsibility to maintain the confidentiality of your Account Information. You also understand and agree that you are solely responsible for maintaining the security, confidentiality, and integrity of any information you access using this Site. You agree to immediately notify us of any unauthorized use of your account or Account Information or any other actual or suspected breach of Site security.

Information Disclosure

If you are your company's Designated Site Administrator, the other authorized users from your company will be able to see your contact information when they are logged into the Site.

We may disclose information collected from and about all Site users as follows: (1) to our service providers to perform a business, professional or technical support function for us; (2) to our affiliated companies; (3) if we believe that there has been a violation of the Site Terms of Use; (4) if we have reason to believe that such disclosure is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interfering with the business of RAI TMS, RJRT, ASC, RJRV, SFNTC, Niconovum, other users of the Site, or any other third party; (5) to respond to judicial process, to provide information to law enforcement agencies, or otherwise as required by law; (6) in the event that our company(ies) or substantially all of its(their) assets are acquired, your personal information may be one of the transferred assets; and (7) otherwise with your express consent.

We may share aggregate, non-personally identifiable information about Site users with third parties.

Security

We have taken certain physical, electronic, contractual, and managerial steps to safeguard and secure the information we collect from Site visitors. Nevertheless, by your use of this Site, you understand and agree that no information transmitted over the Internet can be perfectly secure and that it is possible that certain information, including but not necessarily limited to your company's financial and business information, could be accessed by a third party without authorization, notwithstanding our security procedures.

Links to Other Sites

The Site may contain links to our other sites and/or sites operated by third parties. These sites may have privacy policies that differ from this policy. Accordingly, we recommend that you review the privacy policy posted on any site that you access through the Site.

Changes to This Privacy Policy

We reserve the right to change this privacy policy. We will update this page and the effective date when we do so.

Contact Us

If you have questions about this Privacy Policy, contact us at Engage@RJRT.com.