INTRODUCTION

The tobaccoharmreduction.net (“THR“) website is supported by individual donors and Health Diplomats (‘’HD’’). The THR website is a repository of information to support tobacco harm reduction as a means to prevent tobacco-related disease and premature death.

The THR website www.tobaccoharmreduction.net is maintained by Health Diplomats Pte Ltd (“HD“), which is registered in Switzerland and Singapore (registered office at #29-11 South Beach Tower, Singapore. For the purposes of this website’s Privacy Policy, Health Diplomats is the controller of “personal data”, and its contact details are set out in the CONTACT section of this website.

Both tobaccoharmreduction.net and Health Diplomats take the privacy of the users of the THR website seriously. The Privacy Policy is meant to inform what information the managers and data controllers of this website might collect.

It specifies why we collect it, what we do with it, and how viewers can update and manage their information.

The purposes of the information described in this Privacy Policy that you provide to us, or which we collect via www.tobaccoharmreduction.net and other activities we carry out include:

• Conducting online and in-person surveys;
• Collecting information from individuals or organisations that want to know more about tobacco harm reduction or are interested in supporting THR’s cause;
• Having written correspondence (including e-mail); and
• Engaging in relevant activities on social media platforms.

INFORMATION WE COLLECT

Through your use of the tobaccoharmreduction.net website, we may collect personal and non - personal information from you, including:

• Your name, email and country;
• Your browser type, operating system, IP address, and device information(“Analytical Information”).

We shall apply the terms of our Privacy Policy to any personal information received from a third party, unless we have disclosed to you otherwise.Health Diplomats is not responsible for these third parties’ use, processing and dissemination of your personal information.

Staff operating outside the EEA that work for us or one of our third - party service providers may also process your personal information. By submitting your personal information, you agree to this transfer, storing, and processing.We take all steps reasonably necessary to ensure your data are treated securely and in accordance with this Privacy Policy.

We shall retain your information for as long as your information is needed to provide you with our services(including information on your confirmed areas of interest), as required to fulfil our legal obligations, or until you tell us to delete your personal information.

If you would like us to delete your personal information or request that we no longer use it to provide you with information, contact us at [email protected].

PURPOSES FOR WHICH WE COLLECT AND PROCESS INFORMATION

The information we collect about you, including any personal data, will only be used in connection with issues relating to THR, as well as to provide you with information on requested topics, and to comply with our legal obligations. We use your information to assist you, supply information you have requested, and to note your preferences in order to provide the best possible user experience.

We may use your information, including personal data relating to you, for these specific, legitimate purposes:

• If you have signed up and given consent to receive information from us, we may contact you via written communication (including electronic communications such as email) with relevant content and information.
• You may unsubscribe from such issues-based lists at any time by contacting us at [email protected] or by simply clicking “UNSUBSCRIBE” at the bottom of any of our emails.
• We may use your contact information to respond to your questions about THR’s content.
• When you use our website, we automatically collect and use analytical Information, described above. This helps us to continually improve your experience with our website and to target appropriate marketing communications and advertising to you.

WHOM WE SHARE YOUR INFORMATION WITH

We only share your information (including your Email details) or relevant questions you ask with THR content developers. We also use personal information for tasks such as storing and maintaining the personal information we provide on a database to our content developers, analysing website or mobile application usage data, electronic and postal mail services, marketing services, social media services as well as calculating, managing, and reporting sales tax.

Third-party service providers may receive your personal information as necessary to perform their role. (These include designated data processors, IT infrastructure providers, telephone service providers, external auditors and offsite data storage providers etc.).

We shall ensure that approved safeguards such as the approved standard contractual clauses or the EU-US Privacy Shield are in place if any personal information is provided to third parties outside the EEA or those who will access the information from outside the EEA.

We shall disclose your personal information if required by law, regulation, or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if permitted under the General Data Protection Regulation “GDPR” and other laws, we may disclose certain personal information to such bodies or agencies.

INFORMATION SECURITY

We work hard to protect our users from unauthorised access to or unauthorised alteration, disclosure, or destruction of information we hold. In particular:

• We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorised access to our systems.
• We restrict access to personal information to Health Diplomats employees, contractors and agents that need to know that information to process it on our behalf.

Such persons are subject to strict contractual confidentiality obligations and may be disciplined or their contracts terminated if they fail to meet these obligations.

While no method of transmission over the Internet or method of electronic storage is 100% secure, we strive to protect the information submitted to us. We consider the sensitivity of the personal information we collect, process, and store and use the appropriate technology to protect your personal information. However, we cannot guarantee its absolute security.

YOUR PRIVACY RIGHTS

Individuals in certain countries including the EEA, have certain rights in relation to their personal data. For example, you have the right to request access to your personal information, the right to have a machine-readable copy of your data transferred to another organisation, the right to correct or update your personal information, and the right to have all your personal information deleted.

You also have the right to object to our processing activities (as summarised below).

If you have any questions or wish to exercise your rights as described above, you may contact us at [email protected].

COMPLIANCE AND COOPERATION WITH REGULATORS

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data transfers

As we use servers around the world, your information may be processed on servers located outside of the country where you live. Regardless of where your information is processed, we apply the same protections described in this Privacy Policy.

European requirements

If GDPR applies to the processing of your information, we provide the controls described in this Privacy Policy so you can exercise your right to request access to, update, remove and restrict the processing of your information. You may also object to the processing of your information at any time for: (1) marketing purposes; or, (2) where we rely on our legitimate interests (unless we have compelling grounds to continue processing).

We process your information for the purposes described in this policy, based on these legal grounds:

With your consent─ we ask for your agreement to process your information for specific purposes and you may withdraw your consent at any time.

When pursuing legitimate interests. We process your information for our legitimate interests while applying safeguards that protect your privacy. This means we process your information for functions such as:

• Communicating with you, with your prior consent, on issues of concern to THR;
• Providing, maintaining, and improving our websites to meet the needs of our users;
• Developing new features;
• Understanding how people use our websites to improve the performance of our websites;
• Marketing to inform users about our work;
• Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our websites, and
• Protecting against harm to the rights, property, or safety of THR, our users, or the public as required or permitted by law.
• When complying with legal obligations, we shall process your data when we have a legal obligation to do so, for example, if we are responding to legal process or an enforceable governmental request.

If you have questions about our legal basis for processing information, you may contact us at [email protected]. You can contact your local data protection authority if you have concerns regarding your rights under local law or would like to make a complaint against us.

LINKS TO THIRD-PARTY WEBSITES

Our websites contain links to other harm reduction-relevant websites, social networking and mobile applications that are operated and controlled by third parties. Unless otherwise stated,

any personal information you provide to any third-party website will be collected by that party and not by us and will be subject to that party’s privacy policy rather than this Privacy Policy.

COOKIES

We use “cookies” and other similar technologies to help provide you with a better, more personalised user experience. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the

visitor returns. We use these technologies to help us understand and improve how visitors use our websites, including which pages and products are viewed most frequently.

AGE LIMIT

We do not intend to solicit or collect personal information from anyone that is either under the permitted age for using tobacco harm reduction products, science or any related subject to other legal restrictions in their country of residence that prohibits them from viewing or submitting personal information to this site.

Your continued use of our website following any changes to this Privacy Policy indicates your consent to the practices described in the revised Privacy Policy. Unless stated otherwise, our Privacy Policy applies to all information we have about you and your account.

CONSENT

By using our website, you hereby consent to our Privacy Policy and agree to its terms.

CONTACTING US

If you have questions about this Privacy Notice, please email us at [email protected]