Philip Morris Holland Holdings B.V., corporate registration number 20028955 ("PMHH", "we" or "us") need to process certain personal data about you as a shareholder ("Shareholder") in Swedish Match AB ("Swedish Match") in connection with PMHH's public cash offer to the shareholders in Swedish Match. This Data Privacy Notice (the "Notice") sets forth PMHH's obligations and responsibilities when processing personal data about you as a Shareholder, and in accordance with all applicable data protection laws, including the General Data Protection Regulation (2016/679) (the "GDPR"). This notice sets out our obligations towards you and your rights when we use your personal data.

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PMHH is the responsible data controller for the personal data processed about you as a Shareholder in connection with, and for the purpose of, PMHH's public cash offer to the shareholders in Swedish Match (the "Offer"). In order to administer the Offer and to communicate with you as a Shareholder, PMHH needs to process personal data about you. We need to process your phone number, name, address and Euroclear ID number.

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We have collected your personal data from Euroclear and Swedish Match.

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Unless we inform you otherwise, we will not use any other personal data related to you or for any purpose other than set forth herein. We consider that we have a legitimate interest to process your personal data in order to administer the Offer, by for example informing you of relevant information regarding the Offer and deadlines for accepting the Offer. We will save your personal data to enable us to fulfil our purposes stated herein, until the Offer is no longer relevant. However, depending on the status and acceptance of the Offer, we may store your personal data in order to further process the Offer and any contractual obligations in connection therewith and to fulfil legal obligations (such as bookkeeping legislation), or to safeguard our interest in the event of a dispute or legal claim associated herewith.

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You enjoy certain rights in relation to us when it comes to how we use your personal data. These rights include the right to (i) object to us processing your personal data when we base our processing on a legitimate interest; (ii) access to the personal data and have your personal data rectified if it is incorrect; (iii) restrict the processing of personal data; (iv) request us to delete your personal data; and (v) request your personal data to be provided in a structured, commonly used and machine-readable format, if you have provided the personal data to us and the personal data is processed automatically, based on our performance of the contract with you. You may also request that your personal data is transmitted to another controller, if technically feasible (data portability). If you object to the processing of your personal data, we will no longer use your personal data for such purpose unless we can show a compelling legitimate interest. You also have a right to be informed about why we consider ourselves to have a legitimate interest to process your personal data.

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If you wish to enforce your rights, please contact us on the contact details stated below at the end of this Notice.

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You have the right to lodge a complaint with the data protection authority if you are dissatisfied with how we process your personal data. The relevant authority in each EU/EEA country can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

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In order to fulfil our purposes set forth herein, we need to disclose your personal data to our professional advisors, our affiliates and their professional advisors, as well as to certain third party service providers (both in capacity as data processors and data controllers). We have e.g. engaged IT and telecommunication services providers which provides services to help us to process your personal data as part of the Offer, including for communication purposes. We have also appointed independent advisors, such as financial and legal advisors, to fulfil our purposes herein. To the extent your personal data will be disclosed to service providers in the capacity as data processors, such service providers cannot use it for any other purpose and must always comply with our instructions. Your personal data may also be disclosed based on our legitimate interest to a counterparty's advisor, such as financial and legal advisors, or a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy. We may also disclose personal data to authorities and other parties when we have a legal obligation to do so, such as financial authorities, tax authorities and courts, if applicable.

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To the extent personal data is transferred to countries outside the EU/EEA, such transfers are only conducted if it is ensured that the personal data is adequately protected by the receiving parties by security measures approved by the EU Commission, e.g., the recipient is in a country that ensures an adequate level of privacy protection (article 45 GDPR) or by using appropriate international data transfer mechanisms in accordance with European privacy law, e.g., by using the EU Commission's Standard Data Protection Clauses, (Article 46.2 GDPR), https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

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For more information about our data privacy, please visit https://pmiprivacy.com/.

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If you have any questions or wish to enforce your rights as set out above, please do not hesitate to contact us at dataprivacy.pmi@pmi.com.