PJ Carroll (BAT Ireland) - Conditions of use

Introduction

This website is operated by P. J. Carroll & Company. Please read these terms and conditions of use ("conditions of use") carefully. By accessing this website you agree to be bound by them. If you do not agree to be bound by these conditions of use you should not access or view this website.

To make these conditions of use easier to read, we use a few definitions. The terms
“P. J. Carroll & Company “ we”, “us” and “our” are used to refer to P. J. Carroll & Company.

The terms “British American Tobacco”, “the Group” and “The British American Tobacco Group” are used to refer to British American Tobacco p.l.c. and the group of companies constituting its direct and indirect subsidiaries worldwide, including P. J. Carroll & Company.

These conditions of use contain six sections, including this introduction. Other sections below provide our privacy policy, our cookie policy, information about the external links that appear on this website, general provisions and company information. These conditions of use are accessible from every page of this website.

Any enquiries or complaints which you have in relation to this website should be made either by using the Contact us facility or be addressed to the Corporate and Regulatory Affairs Department of P. J. Carroll & Company, The Greenhouse, Block E, Mountainview, Leopardstown, Dublin 18.

Privacy Notice

We respect your privacy. We are committed to safeguarding the privacy of our website visitors. Please read this document carefully as it sets out our 'Privacy Policy' which informs you what we do with your personal data, whether we are providing you with news alerts or using your personal data as part of the research that we conduct for or statistical purposes.

This Privacy Notice applies to the personal data of visitors to this website.

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the " GDPR "), the data controller and the company responsible for your personal data is P.J. Carroll and Company Limited, The Greenhouse, 6th Floor, Block E Mountain View, Leopardstown, Dublin 18 (“ PJC ”)
We may amend this Privacy Notice from time to time. Please visit this page if you want to stay up-to-date as we will post any changes here.
If you are dissatisfied with any aspect of our Privacy Notice, you may have legal rights which we have described below where relevant.

1) Information we collect about you

Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to help us with this:

Name;
Contact details;
Country of residence;
Background i.e. vocation/profession; and
Extra information that you choose to tell us.

The above list details the personal details that may we collect from you.

Some of the personal data we collect from you are required to enable us to fulfil our duties to you or to others. For example, when you sign up to email alerts, we need to collect your email address, name and country to be able to process your request. Other items may simply be needed to ensure that our relationship can run smoothly.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil the request
For details of the legal bases that we rely on to be able to use and process your personal data, please see the below section entitled "Legal bases for us processing your data".

2) How do we collect your personal data?

We collect your personal data in three primary ways:

Personal data that you give to us;
Personal data that we receive from other sources; and
Personal data we collect automatically.

Personal data you give to us:
There are numerous ways that you can share your information with us. These include:

Where you register with our website (for example email alerts);
Where you contact us proactively, usually by phone, email or via social media; and/or
Where we contact you, either by phone or email.

Personal data we collect automatically
When you visit our website, we collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We use the information for statistical reporting and do not link it to any named individuals.

PJC will not intentionally collect any information about visitors to this website who are under eighteen years of age. If PJC becomes aware that a child has provided any information this will immediately be deleted from PJC’s records.

3) Why do we collect your personal data?

We collect, use and disclose your personal data for a number of reasons, including:

to ensure that we can respond to any queries and contact you if you request us to do so
for storing your details (and updating them when necessary) on our database, so that we can contact you in relation to email news alerts or respond to any query you have asked us to answer
as part of the research that we conduct for statistical purposes
to administer our website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
to ensure the effective operation of software and IT services procured by us (including disaster recovery)
for other reasons with your consent.

4) Who do we share your information with?

We will share your personal data primarily to ensure we provide you with the most relevant and up to date news, content and events, or to ensure we can respond to any query quickly and expeditiously. Unless you specify otherwise, we may share your information with any of the following groups:

British American Tobacco plc or any of its subsidiaries (including PJC) or other companies within its group of companies, where this is necessary, and in accordance with laws on data transfers;
Tax, audit, or other authorities, when we believe that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation) or in order to help prevent fraud or to enforce or protect the rights and properties of British American Tobacco or its subsidiaries; or protect the personal safety of British American Tobacco employees, third party agents or members of the public.
Third party service providers who perform functions on our behalf (including external consultants, investor relations service providers and professional advisers (such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems));
Third party outsourced IT providers where we have an appropriate data processing agreements (or similar protections) in place;
If a BAT Entity merges with or is acquired by another business or company in the future, we may share your personal data with the new owners of the business or company (and provide you with notice of this disclosure); and
Circumstances may arise where, whether for strategic or other business reasons, British American Tobacco plc decides to sell, buy, merge or otherwise reorganise businesses in some countries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it from sellers. It is British American Tobacco plc’s practice to seek appropriate protection for personal information in these types of transactions.

We do not share, rent or trade your information with third parties for marketing or promotional purposes.

5) How long do we keep your personal data for?

We will not keep your personal data for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated or ongoing litigation).

When it is no longer necessary to retain your data for the above purposes, we will delete the personal data that we hold about you from our systems.

6) How do we keep your personal data secure?

We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.

We are committed to taking all reasonable and appropriate steps to protect the personal data that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Please raise your concern by contacting us (using the details below) or by using the Contact us section of the website, in the first instance, and we will investigate the matter and update you as soon as possible on next steps.

7) Your rights

You have various rights in relation to the data which we hold about you. We have set these out below.

Right to object

This right enables you to object to us processing your personal data where we do so for one of the following reasons:

because it is in our legitimate interests to do so (for further information please see section 10 below);
to enable us to perform a task in the public interest or exercise official authority; or
for research, or statistical purposes.

We will stop such processing unless we can demonstrate compelling legitimate grounds for the processing which overrides your interests or if the processing is necessary for the establishment, exercise or defence of legal claims. You will always have the right to object to us processing your personal data for direct marketing purposes.

Right to withdraw consent

Where we have obtained your consent to process your personal data for certain activities, you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

Data Subject Access Requests

You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We may request proof of identification to verify your request. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

Right to erasure

You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:

The data are no longer necessary;
You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue (where the processing is based on consent);
The data has been processed unlawfully;
It is necessary for the data to be erased in order for us to comply with our obligations under law; or
You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so.

Right to restrict processing

You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification

You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability

If you wish, you have the right to transfer your personal data between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party, without hindrance. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.

Right to complain

You also have the right to lodge a complaint with a local supervisory authority, in particular in the Member State of your residence, place of work or place of an alleged infringement if you consider that the processing of your personal data infringes the GDPR. The relevant supervisory authority in Ireland is the Data Protection Commission. You can contact them in the following ways:

Phone: +353 57 8684800
Email: info@dataprotection.ie
Post: Data Protection Commission, Canal House, Station Road, Portarlington, County Laois

If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us using the Contact Us form on the website. We will respond to your request within one month. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

8) How do we store and transfer your data internationally?

Your personal data may be transferred outside of the European Economic Area to the types of entities described in section 4 above.

We want to make sure that your personal data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

By way of an intra-group agreement between BAT Entities, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws;
By way of a data transfer agreement with a third party, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws; or
By transferring your data to an entity which has signed up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
By transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer your data to a benefits provider based outside the EEA); or
Where you have consented to the data transfer.

Where we transfer your personal data outside the EEA and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Please contact us if you wish to obtain information concerning such safeguards (Contact Us below).

9) Legal bases for us processing your data

There are a number of different ways that we are lawfully able to process your personal data. We have set these out below.

Where using your data is in our legitimate interests

We are allowed to use your personal data where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you.

We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:

To help us understand our website visitors better and provide more relevant information and services to them;
To ensure that our website runs smoothly; and
To help us keep our systems secure and prevent unauthorized access or cyber-attacks.

We don't think that any of the activities set out in this Privacy Notice will prejudice you in any way. However, you do have the right to object to us processing your personal data on this basis. We have set out details regarding how you can go about doing this in section 7 above.

Where you give us your consent to use your personal data

We are allowed to use your data where you have specifically consented. In order for your consent to be valid:

It has to be given freely, without us putting you under any type of pressure;
You have to know what you are consenting to - so we'll make sure we give you enough information;
You should only be asked to consent to one thing at a time - we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to; and
You need to take positive and affirmative action in giving us your consent - we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

When you register on our website, we ask you for specific consents to allow us to use your data in certain ways. If we require your consent for anything else in the future we will provide you with sufficient information so that you can decide whether or not you wish to consent.

You have the right to withdraw your consent at any time. We have set out details regarding how you can go about this in section 7 above.

Where using your personal data is necessary for us to carry out our obligations under our contract with you

We are allowed to use your personal data when it is necessary to do so for the performance of our contract with you.

For example, we need to collect your email address in order to be able to provide you with any email alerts that you have requested.

Where processing is necessary for us to carry out our legal obligations

As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with and we are allowed to use your personal data when we need to in order to comply with those other legal obligations.

10) Contact Us

If you have any comments or suggestions concerning this Privacy Notice please contact us using the Contact Us form on the website, by e-mail to info@pjcarroll.ieor by post to P.J. Carroll and Company Limited, The Greenhouse, Block E, 6th Floor, Mountainview, Leopardstown, Dublin 18. We take privacy seriously and will get back to you as soon as possible.

Cookie Policy

'Cookies' are small data files that are sent to your browser from a web server and stored on your device's hard drive. References in these conditions of use to ‘cookies’ also include other means of automatically accessing or storing information on your device.

When you accessed the website, you were presented with a message that notified you of the use of cookies on this website. We had to use a cookie to present you with that notice. If you continue to use this website, further cookies will be placed on your device as described in the table below. By continuing to use this website after we present that notice to you, you are agreeing to the use of the cookies described in this Cookie Policy.

We may use web beacons, which are transparent image files on web pages and are used to monitor your journey around British American Tobacco Group websites.

Otherwise, we do not ourselves use cookies on this website. However, some of the tools and content in the ‘Media’ and ‘Investors’ sections of our website are delivered by (and in some cases also hosted by) third party content providers. When you access this content, these third party providers may set cookies on your computer or mobile device.

We allow third parties to set the following cookies on this website:

Cookie / technology	Google Analytics
Purpose	These cookies are used to collect information about how you and other visitors use our website, which we use to help improve it. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the website from and the pages they have visited.
How to disable / enable this cookie	To opt out of being tracked by Google Analytics across all websites, please visit: Google Analytics Opt-out Browser Add-on
Name	Expiry
_ga	Persistent cookie: 2 years from set/update
_gat	Persistent cookie: 10 minutes from set/update
_gid	Persistent cookie: 10 minutes from set/update
Cookie / technology	This website
Purpose	This cookie is used to store if a user has seen the cookie notification message on this website.
How to disable / enable this cookie	Disable cookies coming from the ‘www.pjcarroll.ie’ domain in browser.
Name	Expiry
cookieMessage	Persistent cookie: 180 days from set/update

For more information about cookies, including how to set your internet browser to reject cookies, please visit www.allaboutcookies.org.

Google Analytics

This website uses Google Analytics, a Web Analytics service from Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files which are stored on users' computers and which allow an analysis of the use of the website by them. The information generated by the cookie about the use of this website by the users is usually transferred to a server of Google in the USA where it is stored. IP anonymization has been activated on this website, so that the IP address of the users of Google is shortened in advance for those Member States of the European Union or European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the United States and shortened there. On behalf of the operator of this website, Google will use this information to evaluate the use of the website by the users, to compile reports on the website activities and for further purposes related to the use of the website and Internet use to provide services to the website operator.

The IP address submitted by your browser as part of Google Analytics will not be merged with other Google data. Information that BAT collects through Google Analytics are: Number of visitors, URLs from which visitors come and reputable sites.

You can also prevent Google from collecting the data generated by these cookies by setting a so-called "opt-out cookie" on your computer – here you can find out how to implement it. Find out more about Google Analytics privacy policy here .

Links to external websites

This website includes links to external websites which are subject to their own terms and conditions and privacy policies. We are not responsible for the content of these external websites and we recommend that you familiarise yourself with the terms and conditions of such sites before you submit any information about yourself. These links are provided solely for convenience to you. No endorsement of any party, products or services is expressed or implied and accordingly P. J. Carroll & Company cannot accept any liability for the accuracy of, or otherwise in relation to, any content or the security of any activity carried out on such other websites. You acknowledge and agree that we are not responsible or liable, directly or indirectly, for any damage, loss or cost caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on such linked websites. Your use of such websites is at your sole risk.

If you choose to access external websites using links provided on this website, these websites may set a cookie. British American Tobacco does not have any control over the use of such cookies and you should refer to the terms and conditions of use and cookie policy of the particular third party website for further information.

General provisions

This website is provided to you free of charge, without any warranties or guarantees unless specifically stated. The information contained in this website is intended for general information purposes only.
Except as expressly provided for on this website, P. J. Carroll & Company is not responsible for the content or use of any web pages or any messages sent or received by you.
All copyright, trade marks, and other intellectual property rights used as part of this website are vested in P. J. Carroll & Company and / or its licensors. You acquire no rights in the website other than the limited right to use the website in accordance with these conditions of use. You may not offer for sale or sell or distribute over any medium, any part of this website or its content. However, you are permitted to print out or download information and content from this website for your own personal, non-commercial use only. Other than as stated in these conditions of use, you may not make any part of the website available as part of another website, whether by scraping, crawling, hyperlink framing on the Internet or otherwise unless you have been authorised to do so in writing by P. J. Carroll & Company.
You shall not use this website for any illegal purposes and in particular agree that you shall not send, use, copy, post or allow any posting which is defamatory or obscene or which is abusive, indecent or in breach of the privacy of any person. You agree not to send any unsolicited promotional or advertising material, spam or similar materials or any volume messages which may interfere with the operation of this website or with the enjoyment of this website by other visitors.
P. J. Carroll & Company reserves the right at any time and without notice to enhance, modify, alter, suspend or permanently discontinue all or any part of this website and to restrict or prohibit access to it.
You hereby agree to indemnify P. J. Carroll & Company against any costs, claims, losses and damages (including legal fees) incurred by or awarded against P. J. Carroll & Company as a result of your misuse of this website or your breach of these conditions of use.
If you are in breach of these conditions of P. J. Carroll & Company may suspend or block your access to this website and refuse to provide you with any further access to it.
P. J. CARROLL & COMPANY PUBLISHES THIS WEBSITE “AS IS” AND “AS AVAILABLE” WITHOUT ANY WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, AS TO THE OPERATION OF THE WEBSITE, THE ACCURACY OF THE INFORMATION OR THE PRODUCTS OR SERVICES REFERRED TO ON THE WEBSITE (IN SO FAR AS SUCH WARRANTIES MAY BE EXCLUDED UNDER ANY RELEVANT LAW). EXCEPT IN THE CASE OF PERSONAL INJURY OR DEATH CAUSED BY ITS NEGLIGENCE OR FOR FRAUD, TO THE EXTENT PERMITTED BY LAW, NEITHER P. J. CARROLL & COMPANY NOR ANY OTHER COMPANY IN THE BRITISH AMERICAN TOBACCO GROUP SHALL BE LIABLE FOR ANY LOSSES OR DAMAGE WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE) OR OTHERWISE AND WHETHER DIRECT OR INDIRECT (INCLUDING, WITHOUT LIMITATION DIRECT OR INDIRECT LOSS OF PROFITS), CONSEQUENTIAL, INCIDENTAL OR SPECIAL THAT MAY RESULT FROM ACCESS OR USE OF THIS WEBSITE, HOWSOEVER ARISING. YOUR SOLE REMEDY IS TO DISCONTINUE USING THIS WEBSITE.
If any part of these conditions of use is found to be unenforceable as a matter of law, all other parts of these conditions of use shall not be affected.
These conditions of use govern our relationship with you and represent our entire agreement with you.
The conditions of use and the content of this website are governed Irish law whose courts shall have exclusive jurisdiction.