PRIVACY STATEMENT – YOUR PRIVACY RIGHTS

Last Updated: April 2017

We at U.S. Smokeless Tobacco Co. respect your concerns about privacy and value the relationship we have with you. This Privacy Statement describes the types of personal information collected by U.S. Smokeless Tobacco Co. for its brands online. This statement does not apply to U.S. Smokeless Tobacco Co. websites that do not display or link to this statement or that have their own privacy statements.

Our Privacy Statement also describes how we may use the information that we collect, to whom and under what circumstances we may disclose it and the measures we take to protect the security of the information. We also tell you how you can contact us, remove your name from our brand contact list (which is used to send communications to you) or answer any questions you may have about our collection and use of information. By joining our brand contact list, you agree to the terms of this Privacy Statement.

INFORMATION WE COLLECT

Our Contact List: When you request to be added to our brand contact list, we may ask you to provide personal information, such as your name, address, date of birth, last four digits of your Social Security number, email address and telephone number. We also may work with third parties to supplement the information you provide with other data so that we may customize our offers to you.

Age and Identity Verification: If you elect to sign up to our brand contact list, for age and identity verification purposes, we may collect, and work with third parties to confirm your age and identity by using, your name, address and date of birth, or your name, the last four digits of your Social Security number and date of birth.

Nonpersonal Aggregate Data: We may collect aggregate information when you visit our website. This information tells us such things as how many users visited those websites and which pages were accessed.

Other Data: When you visit our websites, your browser may send us certain information that it sends to websites you visit, such as your Internet protocol (IP) address, geo-location, browser type and language, access times and referring website addresses. We may also collect information about you using tracking tools.

INFORMATION WE USE

We may use your personal information for any of the following purposes: (1) to provide you content, offers and advertising by direct mail, email and/or in other ways; (2) to monitor and conduct reviews of our products and offers; (3) to help us improve and develop products; (4) to send you administrative and/or legislative-related communications; and (5) to otherwise contact you related to any of these reasons or at your request.

COOKIES

Like many companies, we use cookies on many of our websites. Cookies are bits of text that are placed on your computer's hard drive when you visit certain websites. Cookies may enhance and personalize your online experience by helping you find the information you want.

For example, we may use cookies to tell us whether you've visited us before or if you're a new visitor, to enable you to use certain website features and to monitor and maintain information about your use of our websites. The Help portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie and how to delete existing cookies.

WEB BEACONS

Certain pages on our websites also contain web beacons (also known as spotlight tags, Internet tags, pixel tags and clear GIFs), which are tiny graphic images that may appear on our websites and in our emails. Web beacons help us analyze our customers' online behavior and measure the effectiveness of our websites and email communications. We work with certain service providers that help us track, collect and analyze this information. If you would like more information about this practice and to know your choices about not having your information used by our service providers, click here.

Web beacons on our websites may be used to collect information about your visit, including the pages you view, the features you use, the links you click and other actions you take in connection with the websites. This information may include your computer's IP address, your browser type, your Internet service provider (ISP), your operating system, date and time information and other technical information about your computer. Web beacons in our emails may be used to track your interactions with those messages, such as when you receive, open, forward or click a link in an email message from us.

We may also combine the information we collect from cookies and web beacons with other information that we have collected from you. This information may be used for purposes of improving our websites, personalizing your online experience, tailoring our communications with you and determining the effectiveness of our advertising.

INFORMATION WE SHARE

We may share your personal information with U.S. Smokeless Tobacco Co.'s affiliates, including ones that market tobacco products like Philip Morris USA, John Middleton and Nu Mark. Philip Morris USA, U.S. Smokeless Tobacco Company, John Middleton and Nu Mark are subsidiaries of Altria Group, Inc. To learn more about Altria Group, Inc., and its companies, visit http://www.altria.com/About-Altria/At-A-Glance/Pages/default.aspx.

We also may share personal information with third-party service providers what we have retained to perform services on our behalf. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or connection with an investigation of suspected or actual illegal activity.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided through our websites in a manner that is consistent with this Privacy Statement.

LINKS TO THIRD-PARTY WEBSITES

From time to time, we may provide links to third-party websites. These websites operate independently from U.S. Smokeless Tobacco Co., and may have their own privacy statements in place, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are unrelated to U.S. Smokeless Tobacco Co., we are not responsible for their content or any use of the websites.

HOW WE PROTECT PERSONAL INFORMATION

We use standard security measures on this website to help protect against unauthorized disclosure, use, alteration or destruction of the personal information you provide on this website. However, the Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet.

CONTROLLING SPAM OR UNSOLICITED EMAIL

U.S. Smokeless Tobacco Co. is concerned about controlling unsolicited commercial email, or spam. We are against the use of spam and will not sell, lease or rent our email lists to third parties.

YOUR CHOICES

If you would like your name removed from our brand contact list, you can click on the Remove Your Name link located on the Login Page of www.skoal.com. You will then be prompted to enter your information and confirm that you would no longer like to receive communication from Skoal.com and U.S. Smokeless Tobacco Co. tobacco brands through U.S. Mail or email. Additionally, your name can be removed from our brand contact list by calling 1-866-404-1934.

YOUR CALIFORNIA PRIVACY RIGHTS

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email or call us at the phone number provided below. Indicate in your letter that you are a California resident making a "Shine the Light" inquiry.

UPDATES TO OUR PRIVACY STATEMENT

This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our information practices. If there are material changes to our Privacy Statement, we will post a prominent notice on our websites and indicate at the top of the statement when it was most recently updated, and/or provide other appropriate notice to you.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Statement, or if you would like us to update information we have about you, please contact us by calling us at 1-866-404-1934.