1. What type of Personal Information does the …

1 Personal Information Protection and Privacy JT International , Inc. ( JTI USA ), the owner of the JTI EVOLVE website ( the owner , we , our , us ) is committed to protecting your privacy and maintaining the integrity of any identifiable Information it collects ( Personal Information ). The purpose of this statement of policy is to outline the steps we take to keep your Personal Information confidential, to inform you about how and why we collect Personal Information , how we intend to use your Personal Information and to provide you with contact Information should you have questions or concerns about our Personal Information protection practices.

2 This policy is accessible at the bottom of every web page of this site. The Collection of Personal Information at (collectively, the Website ) 1. What type of Personal Information does the owner collect? At times, the owner may request that you supply it with various types of Personal Information . Some examples of Personal Information collected may include your name, postal address, telephone number, Personal e-mail address, date of birth and Personal preferences. 2. Why does the owner collect your Personal Information ?

3 The owner collects Personal Information in various contexts for the following purposes: To administer the Website including the Trade Loyalty Rewards Program and Contests sections; To ensure that participants to the Trade Loyalty Rewards Program and Contests displayed on our Website are 21 years of age or older; To fulfill legal requirements; To protect the owner and Website users against fraud; To contact you and to send you Information about our products, our activities, trade programs and events; To cross-reference with the Personal Information you provided to our Trade Marketers earlier on to ensure the accuracy thereof; To develop and analyze statistics that help us better understand your interests and improve the Website s performance; To respond to product inquiries; To send users online or postal surveys.

4 And To provide Personal users interaction with the Website. Each time you will receive a message from the owner, you will have the option to decline to receive further Information related to the Website Content. If you choose not to provide the requested Personal Information , you may not be able to access the Trade Loyalty Rewards Program or Contest sections of the Website. 3. How does the owner collect Personal Information ? The owner may obtain and collect your Personal Information by asking you to voluntarily respond to certain questions on its Website.

5 Specifically, Personal Information may be collected when you: register to the Website, access the Website, redeem points for rewards under our Trade Loyalty Rewards Program, subscribe to our mailing list, participate in a survey or enter a contest. Information Automatically Collected Non-Identifiable Information Like many other websites, the Website automatically collects certain non-identifiable Information regarding Website users, such as the Internet protocol (IP) address of your computer, the IP address of your Internet service provider, the date and time you access the Website, the Internet address of the website from which you linked directly to the Website, the operating system you are using, the sections of the Website you visit, the Website pages read and images viewed, and the materials you post to or download from the Website.

6 This non-identifiable Information is used for website and system administration purposes and to improve the Website. The owner may also use non-identifiable Information to initiate interactive real-time discussions with users. Your non-identifiable Information may be disclosed to others and permanently archived for future use. Cookies The Website uses cookies , a technology that installs Information on a website user s computer to permit the Website to recognize future visits using that computer.

7 Cookies enhance the convenience and use of the Website. For example, the Information provided through cookies is used to recognize you as a previous user of the Website, to track your activity at the Website in order to respond to your needs, to offer personalized web page content and Information for your use, to automatically populate online forms with your Personal Information for your convenience, and to otherwise facilitate your Website experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website.

8 The Disclosure of Personal Information The owner does not sell, rent, or lease to third parties any Personal Information it collects from you. The owner may disclose or share this Information with its authorized employees, agents, service providers and legal representatives for the purposes described above and who are duly bound by the same obligations. The owner will not otherwise share your Personal Information with third parties without your consent, unless authorized or required by law or as disclosed when the Information is collected.

9 The owner may disclose your Personal Information to a government institution or agency that has asserted its lawful authority to obtain the Information or where the owner has reasonable grounds to believe the Information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of Information , or to comply with court rules regarding the production of records and Information , or to protect the owner s rights and property.

10 The owner may be involved in the sale or transfer of some or all of its business. As part of that sale or transfer, the owner may disclose your Personal Information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of your Personal Information in a manner that is consistent with this Policy. 4. How the Owner Protects Your Privacy The owner keeps the Personal Information it collects about you confidential and has adopted reasonable physical, electronic and managerial procedures to safeguard your Personal Information .