Privacy Policy

PMG Personal Data Privacy Policy” (“Privacy Policy”)

“We” take the issue of privacy seriously. This message will tell “You” who “We” are, what information “We” collect about “You” and how “We” will use that information. “We” will only process information about “You” in accordance with applicable data protection legislation.

Please also read the terms of use regarding the service “You” are interested in. This includes more information about the way “We” carry out our activities, as “We”ll as information on all possible cases of restriction of statutory rights.

Who are “We”?

“We” are an affiliated member of the Philip Morris International Group of Companies. All affiliated members of the Group are listed here, together with the contact details of the Data Protection Officer, where applicable. Please use this information if “You” wish to contact us.

Our data (name, address, etc. etc.) It will be provided to “You” separately, after “We” have collected (or confirmed) information about “You”, for example, in an app or “We”bsite message, an email, or in an agreement bet”We”en us that contains an electronic link to that message.

“Philip Morris International” or “PMI” stands for “Philip Morris International,” an international leading tobacco group. It is made up of many companies or affiliates.

“PMI Affiliates” means the “PMI Affiliate” of each member of the Philip Morris International Group of Companies. ““We”” (or “our” or “our”) means the PMI affiliate who first collected information about “You”.

“PMI Product”: means the product of our or “PMI Affiliate”.

How do “We” collect information about “You”?

“We” may collect information about “You” in a variety of ways.

  • “You” may provide this information directly to us (e.g. By filling out a form, making a phone call, or uploading information to us via the mobile app).
  • “We” may collect information from PMI's electronic device if “You” choose to send the information to us.
  • “We” may automatically collect information when “You” interact with our systems or “We” contact “You” (e.g. When “You” use a PMI app or “Website, or when “We” use technology to track the receipt or opening of emails and SMS messages by “You”).
  • “We” may also obtain information from third parties (e.g. Publicly available information from social media platforms such as Facebook or X, or statistical information about populations in certain geographic areas).
  • For example, where permitted by law, “We” may extract information about “You” from the aggregate information “We” receive from third parties. This may include, for example, statistical information about people in certain geographical areas.

In this policy, “We” list all the methods by which “You” can contact us as “Points of Interconnection with PMI”. The “interconnection points of the PMI” include both the physical (e.g. Retail sales and events, customer contact centers), as “We”ll as digital (such as apps and “We”bsites).

 

PMG Customer Personal Data Processing Policy

“We” may collect information that “You” provide directly to us. Usually, this happens when:

  • Register to be a member of our databases (including loyalty programs) that include age verification (for example, in person, via an app or online);
  • request information about our products, which may include age recognition
  • Shop PMI's products and services at our retail outlets;
  • “You” download, or use the PMI's digital interconnection points (e.g. app or “Website”);
  • Contact us via point of contact, email, social media or phone;
  • register the device with us;
  • “You” will become a subscriber of the PMI panel portal;
  • Sign up to receive PMI press releases, email alerts or different communications;
  • within the framework of the contractual relationship;
  • Participate in PMI surveys or (where permitted by law) PMI contests or advertising campaigns; or
  • “You” will attend an event organized by a PMI affiliate.

“We” may collect information from an electronic device if “You” choose to send the information to us. This can be shared online, via a direct connection or through one of our apps that “You” can download.

“We” may automatically collect information about “You”. Usually, this happens when “You”:

  • Visit our sales facility that sells “PMI products”, e.g. collection of data provided by “You” at the time of purchase,;
  • “You” will attend an event organized by a PMI affiliate (e.g. at the time of purchase at the event);
  • “You” communicate with us (for example, using a point of contact; or using social media platforms);
  • When using PMI interconnection points (e.g. Using existing recording mechanisms (such as cookies and “We”b beacons/pixels), where “We” use those that “You” receive when “You” use PMI interconnection points or when “You” receive emails or SMS from us);
  • When using third-party “Websites”); or
  • When making public statements on the social media platforms “We” subscribe to (for example, in such a way that public opinion is understandable to us or when responding to requests related to PMI products).

“We” may also automatically collect information about “You” using cookies and other similar tracking technologies (such as Web beacons/pixels) that “You” receive when “You” visit or receive digital “PMI Interconnection Points” Email from us. The specific cookies and other technologies used will depend on the respective PMI Interconnection Point. For more information about other similar technologies used at the PMI Interconnection Points, including information on how “You” can accept or reject cookies, please see the information that will be available at the Interconnection Point or when using it. These technologies may include Google Analytics cookies (see www.google.com/policies/privacy/partners/).

“We” may obtain information about “You” from third parties. This may include information shared between PMI Affiliates, publicly available profile information (such as “Your” preferences and interests) on third-party social media sites (such as Facebook and X), marketing lists, and third-party agencies Additional information purchased.

Where permitted by law, “We” may obtain information about “You” from information “We” already have. For example, “We” may use aggregated information about people in a certain geographic area that “We” receive from third parties to determine “Your” preferences.

“We” may also collect information in other contexts that will be visible to “You” when “We” do so.

What information do “We” collect about “You”?

“We” may collect various types of information about “You”:

  • Necessary information in order to fulfill “Your“ orders;
  • Necessary information in order to provide warranty service for a period of 2 years and diagnostic service of the device for the entire period of its ownership;
  • Information about the appeals “You” have made;
  • Information that “You” provide to us by filling out forms and surveys and similar information that “You” provide to third parties to provide to us;
  • Information about “Your“ location where “You” choose to share it (e.g. on “Your“ mobile phone)
  • Information about “Your” visits to our Points of Sales and events (or about the visits to Points of Sales and events to whom we collaborate);
  • Information “You” provide when communicating with contact centers (e.g. through phone calls, conversations, sent emails and messages);
  • Information about “Your” preferences and interests (including information “We” receive from other information, such as statistical information);
  • Information that is necessary to verify “Your” age;
  • Information generated by “Your” electronic device (such as IQOS), if “You” choose to share it with us;
  • Information about “Your” experience using our products and services;
  • statistical information about “You” (for example, statistical information about people in a certain geographical area);

 

Information that “We” collect directly from “You” will be visible depending on the context in which “You” provide that information. For example:

  • If “You” purchase a product from us through a point of contact, “You” provide us with “Your” name, contact information, billing data, payment methods and the products “You” have chosen to fulfill “Your” order;
  • “You” may provide us with information about “Your” interests and product preferences so that “We” can further propose products and services of interest to “You” in order to improve our products and services;
  • If “You” schedule an appointment with us (or someone who provides support for our products and services), “We” may gain access to “Your” name and contact information;
  • “We” may collect information that allows us to verify “Your” age, such as a copy of an identity document or a picture of “Your” face (in the form of a photo or video);
  • If “You” download one of our applications “We” will collect the following information:
    • “We” may require the information of “Your” location (even when the app is closed or not in use) for certain functions. For example, the “Find my IQOS” function helps “You” find  your device if it is lost, and it will not work properly if “You” do not share the location. “We” do not store location data. It will only be used to allow these functions and only if “You” agree to the sharing of this data in the respective app and consent to the disclosure;
    • Information about “Your” mobile or computer (including operating system version, device brand, model and mobile advertising identifier (MAID) or Android ID (SSAID));
    • How “You” use the App (including when “You” open it, how long “You” use it and how “You” interact with the messages “We” send “You”);
    • Data obtained as a result of the use of the application (“Your” age range, gender, interests and location obtained from the IP address - “We” will be able to view this data only on the basis of unification); and “Your” profile registration information (name, email, etc. Mailing address, date of birth, mobile number, postal address, etc.)
    • IQOS personalization and device glitches, to perform business analytics and send notifications.
    • If “You” contact one of our contact centers, “You” can provide us with information, for example, about “Your” experience in using our products and services in order to enable us to process “Your” requests.

Information “We” collect from an electronic device if “You” choose to send the information to us. This may include information for the PMI electronic device: (i) about the device itself (such as owner serial number, charger serial number, firmware version, device errors); and (ii) use of the device (such as the number of consumable units (e.g. For IQOS device), number of cleanings, battery usage, number of phases, and device lifetime data (including cumulative values and time prints for each of the above).

 

The information “We” collect automatically mainly includes:

  • Data about “Your” visit or call (such as time, date and duration);
  • Records of “Your” calls or visits (on the basis of your consent) at PMI interconnection points, which “We” can decode in text format;
  • How often, in which territory and for what time “You” visit sales facilities or events and about “Your” purchases;
  • Data relating to “Your” use of digital PMI interconnection points (for example, information about the  websites “You” have accessed, information about the “Websites” from which “You”  were redirected and the “Webpages “You” went to when “You” left the page, the words “You” entered the search box and the links “You” click while using the Interconnection Point, how long “You” use it and how “You” interact with the messages “We” send “You” or the advertisements “We” show “You”); for this purpose “We” may use cookies and similar recording technologies (such as pixels/ web beacons);
  • “Your” use of third party  websites where the information collected will be similar to that described in the section above (“We” may use cookies and similar recording technologies (such as pixels/Web beacons) for this purpose);
  • “Your” mobile or stationary device and software (such as “Your” IP address or unique device identifier (for example, Mobile Advertising Identifier (MAID) or Android ID (SSAID)), location data (or “Your” general location (based on “Your” IP address, in which case information “We” process, will be general, e.g. The city “You” are in), or  your exact location (if “You” decide to share it for specified purposes, e.g. Store Locator)), device brand and model, screen settings for “Your” monitor, web browser type, operating system, (some may be used for digital fingerprinting (see for what purposes “We” use information about “You” below)) and any cookies (or similar technologies) details that may be stored on “Your” device); and
  • If “You” return “Your” PMI electronic device to us, or bring it to one of our stores because it is faulty and “You” decide to share the data in it with us (as above), “We” may remove that data from the device.

The information “We” collect from third parties generally includes publicly available information (such as interests and experiences), such as public announcements “You” post on social media.

For what purposes and on what legal grounds do “We” use information about “You”?

In this section, “We” explain the purposes for which “We” use personal information. Please note that  in the event that any of the activities referred to in this Policy are prohibited in any country, “We” will not use the information for the appropriate purpose in that particular country.

In view of the above, “We” use information about “You” for the following purposes:

  • For purposes of complying with statutory requirements, such as verifying “Your“ age and status as a customer of our products;
  • Rent or sell our products to “You”, which makes it easier to fulfill “Your“ orders and process payments;
  • To provide “You” with sales related services, which include meeting “Your“ questions and requirements and providing warranty support, diagnostic services;
  • Providing information about our products and services by phone, mail, email or other electronic means including administering loyalty programs, improving products, conducting market research (and demonstrating fair practices in market research), developing strategies, customer demand Administering relevant campaigns and tailoring sales facilities and events to “Your“ personal needs,
  • To understand whether “You” are still involved in our activities and whether “You” want to continue receiving it;
  • So that “We” or our business partners can inform “You” about PMI products and services available;
  • Enable “You” to use and improve “Your“ experience with PMI interconnection points and PMI electronic devices
  • To support all of the above, including administering “Your“ accounts, ensuring “Your“ use of PMI touchpoints, agreeing with “You” to schedule “Your“ meetings with us or the person who provides support related to our products and services (for example, regarding new products Providing information or after-sales services and offering it), to tailor “Your” experience and requirements to the PMI interconnection points; to prevent fraud (for example, our promotions , in the context of contests and surveys, to ensure that they are not received more than once by the same person, or to protect the cardholder's information in the context of e-commerce), for the training of personnel and quality control, administration and elimination of the incident;
  • For business analytics, archiving, statistical and scientific purposes, including to improve PMI's products (for data collected from PMI electronic devices this applies only if “You” choose to send information to us for these purposes) and services, businesses, events and information “We” (or Our Affiliates) provide to our users;
  • For other purposes about which “You” will be notified or which will be clear from the context in which the initial collection of information about “You” occurs.

The legal basis for the use of information about “You” is one of the following

  • to comply with legal obligations that apply to us;
  • compliance to the terms of the contract to which “You” is a party;
  • Legitimate business interest that does not override “You” interest in protecting information;
  • If none of the above applies, then “Your” consent (which will be required before “We” process the information).

The purposes for which “We” use information about “You”, the relevant methods of obtaining the information and the legal basis are as follows:

Purpose

Information collection method and legal basis for processing

 Compliance with regulatory obligations

 

Verification of “Your” status and age as a user of our products (depending on the country and PMI point of contact, this may be a manual or automated process;

The mentioned information is mainly provided by “You” personally.

“We” use this information because it is necessary for us to comply with our legal obligation to sell products only to adults.

 Rent or sell our products;

 

Fulfill “Your” orders (including sending “You”receipts);

To process “Your” payments;

Providing warranty and support services;

This information is usually provided to us personally by “You” (usually, first name, last name, phone number, address, e-mail address, payment information).

“We” use this information to fulfill our contractual obligations to “You” as a purchaser of our products.

Providing sales and product support services;

 

To answer “Your” questions and fulfill “Your” requests and provide us with information about “Your” experience with our products and services;

Correspondence with “You”;

General administration and system troubleshooting;

Administration of loyalty programs;

This information is primarily provided directly to us by “You”, but may be combined with information “We” collect automatically (for example, through the use of technologies (such as cookies and web beacons/pixels) through “Your” use of PMI touchpoints and information sent by us for monitoring emails) and using similar technology to monitor the use of third-party connection points; and (where permitted by law) information “We” receive from third parties (such as public social media posts).

“We” use said information because “We” have a legitimate business interest in providing sales-related services

Providing information about  our products and related services

 

Understanding your preferences (for example, which products or events may be of interest to “You”, or which are more relevant to “Your” needs) and provide information that refers to “You” personally;

 

Understand whether “You” are engaged in our activities and whether “You” wish to receive information about it;

 

Administer loyalty and referral programs;

Invite “You” to participate in and administer surveys and market research campaigns;

For market research and demonstrating fair market research practices;

Develop marketing strategies;

Manage marketing campaigns

To tailor your experience with "PMI touchpoints" to “Your” personal requirements (for example, to personalize “Your” visits, such as greetings or offers that may be of interest to “You”);

This is typically a combination of information “You” provide (for example, “Your” first name, last name, PMI Contact Points) using PMI Contact Points monitoring technologies (such as cookies and web beacons/pixels) from us to PMI Contact Points and electronic to monitor the use of messages (e.g. email and SMS) and to monitor the use of third-party contact points using similar technology; and information “We” obtain from third parties (e.g. “Your” public postings on social media).

“We” use said information on the basis that:

“We” have obtained “Your” consent to process on the relevant basis;
   

Use of "PMI Interconnection Points" and PMI Electronic Devices

 

 

To enable “You” to use and improve “Your” experience with PMI connection points and PMI electronic devices;

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

This information, if “You” choose to send it to us, will be sent directly from “Your” device's Internet connection, or through one of our apps that “You” can download.

 

 

 

This may include information about: (i) the device itself (e.g. holder serial number, charger serial number, software version, device errors); and (ii) device usage (such as number of puffs (for IQOS devices), number of wipes, battery consumption, number of puffs and device lifetime data (for each of the above, including cumulative values and time points)).

 

“We” use this information based on “Your” consent and to fulfill our contractual obligations to “You”;

Ensuring all the above objectives

 

administer “Your” accounts;

 

To enable “You” to use the PMI Contact Points (e.g. to allow “You” to remain logged in to areas of the Contact Point system reserved for authorized members only, to manage  your language preference, to provide “You” with a shopping cart, to enable certain features of the PMI Contact Point, e.g. .Find My IQOS feature (where “You” choose to share  your location));

to correspond with “You”;

to arrange meetings for “You” with us or with someone who provides support for our products and services (for example, in relation to new products or after-sales service);

improve “Your” experience;

fraud prevention (for example, in the context of our promotions, contests and surveys, to ensure that they are not entered more than once by the same person, or in the context of e-commerce to protect cardholder information);

staff training and quality control (including the use of call recording transcriptions to aggregate information in contact centers) and administration and troubleshooting;

This is usually a combination of information “You” provide (typically a name and password (or equivalent)) and information “We” collect automatically (for example, information about  your device, cookies and similar tracking technologies as described above). and  recordings (and transcriptions of those recordings) of  your calls or visits to PMI contact points).

“We” use said information on a basis that is consistent with the purposes of its use and the activities “We” carry out; For example, when “We” manage  your account to facilitate a purchase or provide after-sales service, “We” use the information to fulfill our contractual obligations to “You” as a purchaser of our products;

Business Analytics and Improvements

 

“We” or our business partners may notify “You” of opportunities to participate in PMI product promotions;

 

For business analytics, statistical or scientific purposes (including to improve PMI products (for data collected from electronic devices, this only applies if “You” have chosen to send the information to us for these purposes), as  well as services, sales outlets that sell PMI products, (to improve events, PMI's digital touchpoints and the information “We” (or our affiliates) provide to our customers)

This will typically be a combination of information “You” provide (such as information from your correspondence with PMI points of contact; or demographic information, such as  your age, gender and city of residence); Information “We” collect from “Your” electronic device (which, for PMI electronic devices, includes information about “Your” electronic device and its use, but where “We” ask for “Your” consent to use certain data, “We” will not use that data for those purposes unless “You” consent have “You” given); Information “We” collect automatically; and (where permitted by law) information “We” obtain from third parties. Where “We” have more than one type of information from these categories, “We” will combine them to improve our analysis.

“We” use said information on the basis that:

·       “We” have  your consent to process the data for the stated purpose;

·       “We” have a legitimate business interest to analyze and improve business performance, our products, PMI touchpoints, sales facilities and events;

 

If “We” use information about “You” on a basis other than the legal grounds listed above, before processing the information, “We” will ask “You” in advance for consent to the processing of said information (these cases will be understood from the context).

In addition to the purposes listed above, in some cases, “We” may also use information about “You” for other purposes. In the event of such circumstances, “We” will provide “You” with an additional personal data Privacy Policy explaining the said use. Any additional notice should be considered in conjunction with said ”Policy”.

Who do “We” share information about “You” with and for what purposes?

“We” may share information about “You” with the following parties:

  • PMI affiliated parties;
  • Third parties who provide PMI affiliates or “You” with products and services;
  • Business partners and advertisers carefully selected by PMI affiliates (in areas related to our products or in relation to their image and style), so that they can contact “You” to make offers that they think will be of interest to “You”, taking into account the nuances.

 

“We” share information about “You” with other persons only in accordance with applicable law. Thus, where “We” are required by law to obtain “Your” consent, “We” will require it first.

Sharing information with other PMI affiliates

  • Information about “You” will be shared with Philip Morris Products S.A. (based in Nevsestadt, Switzerland), which is the central place of personal data administration for PMI affiliates. Philip Morris Products S.A. “We” will process “You”r information for the purposes set out above in this ”Policy”.
  • Information about “You” may be shared with the PMI affiliate responsible for the country in which “You” reside (if the PMI affiliate is not the person who first collected the information about “You”); information about “You” may be processed in the above Policy for the intended purpose.
  • Information about “You” may be shared with all PMI affiliates “You” have contact with (for example, when “You” travel and wonder where PMI products can be purchased in a new country, or where services or support for PMI products can be found) in order to improve Service to “You”.
  • Detailed information on PMI affiliates and their countries of establishment is available on our “Website”.

 

Where can information about “You” be sent?

As with any other multinational organization, “We” pass on information to our affiliates and service providers around the world. Accordingly, information about “You” may be transferred to other countries as part of our standard operations. When “We” transfer “Your” data abroad, “We” restrict access to the data only to those who need to see it, process “Your” data in accordance with internal data protection standards, protect them appropriately. “We” will only transfer information in accordance with applicable data privacy laws. At the time of data transfer, “We” will require the receiving party to keep “Your” data confidential, delete it when it is no longer needed and act in accordance with this Privacy Policy. Accordingly, information about “You” may be transferred outside of “You”r jurisdiction. In the event that the transfer of “Your” data to a foreign country requires the adoption of specific legal measures, “We” will certainly perform them.

When using information in accordance with this Policy, information about “You” may be transferred both within the country where it was collected and outside its borders, including countries where there are no equivalent data protection standards.

How do “We” keep information about “You”?

“We” will take appropriate technical and organizational measures to protect the personal information in our possession from unlawful disclosure, use, alteration or destruction. Where appropriate, “We” use cryptography and other technologies to help protect the information “You” provide. “We” also require our service providers to strictly adhere to the requirements of confidentiality and security of personal data.

How long will the information about “You” be kept?

“We” will retain information about “You” for as long as is necessary to achieve the purposes for which the information was collected in accordance with this Privacy Policy. After all, “We” will delete this information. The storage period depends on the purpose for which the information was collected. To be taken into account, “You” have the right to ask us to delete information. Also in some cases, “We” are required by law to leave information, for example, for tax and accounting purposes or to keep the information for a specified minimum period, to delete or archive it after the specified maximum period has elapsed.

 

Basically “We” keep the data based on the criteria in the table below. If these periods conflict with legal obligations, for example, for tax and accounting purposes, to retain information for a specified minimum period, or to delete it after a specified maximum period, “We” will use the statutory time limits in accordance with the law.

Kind

Definition/Typical Data Retention Criteria

Selling products to “You” (which includes communications about products and services) (if “You” use digital touchpoints and are contactable)

Most of the information in “Your” profile is stored for the duration of the relationship between “You” and us; For example, as long as “You” continue to use digital touchpoints or respond to our communications. However, some elements of  your profile, such as records of how “We” interact with “You”, become out of date after a certain period of time and therefore “We” automatically delete them after a certain period of time (usually after 3 years) depending on the purpose The mentioned information has been collected.

Selling products to “You” (which includes communications about products and services) (if “You” are no longer in contact with us)

This case is identical to the one above, but if “We” have no further contact with “You” for a long period of time (usually 2 years), “We” will stop communicating with “You” and delete “Your” reply history. For example, this will happen when “You” no longer click on an event invitation, log in to a digital contact point, or contact customer care during that period. This is because in this case “We” will assume that “You” prefer not to receive further communications.

Selling products to “You” (which includes communications about products and services) (if “You” are not contacted)

If “You” have registered to receive information (including communications about products and services) but the contact information “You” have provided is incorrect, “We” will retain your data for a period of time, usually only 1 year, to allow “You” to correct said data.

Selling products to “You” (which includes communications about products and services) (incomplete registration)

If “You” start registering “You”r account in the database, but do not complete the registration process (for example, if “You” do not complete the age verification procedure or “You” do not agree to the terms of use of the point of contact, or Privacy Policy), “We” will retain your data (to allow “You” to return later and complete registration process) only for 30 days, taking into account the type of incomplete information.

Market research

If “You” are not registered with us for other purposes (for example, to receive information about products and services, for guarantees, for customer care services) and “We” use publicly provided information about “You” to study the market and better understand your preferences, “We” will retain information about “You” for a short period of time to complete a specific point of market research.

If “We” collect information about “You” in another market research context, “We” will store this information:

·       for a period reasonably necessary for the purposes of market research for a particular item (usually not more than 1 year); and

·       For the purposes of demonstrating fair practice for as long as “We” need to demonstrate this and “We” will regularly review whether this objective has been achieved to determine how much longer it needs to be maintained.

Purchases, Loyalty Transactions and Warranties

If “You” purchase goods or complete a loyalty transaction, “We” will retain the data related to this to the extent necessary to complete the purchase and to comply with legal obligations (for example, for tax, accounting, bookkeeping and fraud prevention purposes). “We” will retain your data as long as it is relevant for warranty and product support services.

Customer care service

If “You” contact customer care, “We” will make a record of the issue (which includes information about “You”r request and our responses) and will retain that information for as long as it is relevant to our relationship, for example if “You” want us to replace “You”r device under warranty or if “You”r previous requests are relevant. Temporary records (for example, an automated record of a telephone conversation in which “You” ask us to give “You” directions to a retail outlet) will be retained only temporarily and may only be relevant until more permanent records are made.

System control records and fraud prevention

System control records are typically retained for up to 6 months for system recovery and up to 10 years for fraud prevention.

Business analytics

“We” retain business analytics data for the duration of our relationship with “You” as described in the first row of the table above. However, some of its elements, such as certain device information (if “You” choose to share it with us), naturally become obsolete after a period of time, so “We” automatically delete them after a certain period of time, when the relevant purpose for which “We” collected them is achieved.

Device data

“We” retain data collected from  your device (if “You” choose to share it with us) for different periods depending on the purposes for which “We” use it:

Product Improvement: 5 years (or less if “You” delete “You”r marketing profile)

Business Analytics: 5 years (or less if “You” delete “You”r marketing profile)

 

Device diagnostics and updates: will be deleted upon delivery of the service;

 

Demonstration of fair customer treatment: 10 years

Age verification

Age detection using computer analysis (this may be used if “You” request information about our products)

Age detection using computer analysis (this may be used if “You” request information about our products)

“Your” image will be deleted instantly after analysis (analysis only takes a few seconds).

What rights and opportunities do “You” have?

“You” have some or all of the following rights in relation to the information “We” hold about “You”:

  • Withdraw your consent to the processing of information on any basis at any time;

 

The right to request information about the processing of information about “You” and a copy of said information;

  • Ask us to change, update, supplement, delete or block such information;
  • Ask us to delete information and in some cases increase this right, the right to be forgotten
  • Object to the use of such information by us in certain cases;
  • The possibility of data portability (transfer) in some cases;
  • Submit a complaint to the Personal Data Protection Service.

 

“We” offer simple ways to exercise these rights, such as using the “unsubscribe” link or using the contact address provided in the messages “You” receive.

Some of the mobile applications “We” offer may also send so-called push-notifications, for example about new products and services. “You” can cancel these notifications at any time by making changes to  your phone or app settings.

The rights “You” have come up with depend on the legislation. “You” have the rights listed in the table below.

Rights in relation to the information “We” hold about “You”

Further data (certain legal restrictions apply to all of these rights)

The right to request information about the processing of information about “You” and a copy of said information

“You” have the right to ask us for information on whether or not information about “You” is being processed by us, what information is being processed, for what purpose and on what basis. “You” may receive this information free of charge, unless  the right to receive information is abused or requires disproportionate effort,

In addition, “You” can receive the following information:

·       Category of persons with whom “We” share information;

·       (if “We” have one) the source of the information, if the information was not collected from “You”;

·       (to the extent that “We” carry out that which has been focused on “You”) the existence of automated decision-making, which includes the analysis of profiles that generate legal consequences in relation to “You” or in a similar way that substantially concerns “You”, as well as information about the logic used in said process and also information about said meaning of processing and expected results; and

·       Criteria that determine the duration for which information will be stored by us.

 

Ask us to change, complete or update information

This applies in cases where the information stored by us is incorrect or incomplete.

Ask us to delete information and in some cases increase this right, the right to be forgotten

This is used in such cases if:

·       The information stored by us is no longer necessary for the purposes for which it was used;

·       “We” use said information based on “You”r consent and “You” withdraw “You”r consent (in which case “We” will remember not to contact “You” again, until “You” tell us that “You” want to completely delete information about “You”, in which case “We” will comply with “You”r requests);

·       “We” use the information based on a legitimate interest, and “We” determine that, following “Your objection, “We” no longer have an overriding interest in continuing to use the information;

·       The information was obtained or used illegally; or

·       This is necessary to fulfill legal obligations.

Ask us to restrict/block information processing

This right applies temporarily while “We” process your case in cases where “You”:

·       Dispute the accuracy of the information “We” use; or

·       “You” object to our use of the information based on a legitimate interest

·       (In the event that “You” exercise the specified right, “We” will notify “You” in advance before “We” decide to use the information again).

·       The specified right is also used in cases when:

·       Our use of the information is unlawful and “You” object to the deletion of the data; or

·       “We” no longer need the data, but “You” require it to initiate a legal dispute.

Object to our processing of information

In this case, “You” have two rights:

(i) If “We” use the information to communicate with “You”, “You” may “opt out” (without giving reasons for opting out) and “We” will comply with your request; and

(ii) If “We” use information about “You” based on a legitimate interest for any purpose other than communicating with “You” about products and services, “You” may object to the use of said information for that particular purpose, while explaining “You”r specific circumstances, and “We” will take your objection into account.

Withdraw your consent to the use of information

This applies to cases where the legal basis for using information is your consent. These cases will be understood depending on the context (for example, if “You” have given your consent using the Preference Center in one of our applications, “You” can withdraw your consent by turning off the appropriate switch).

Ability to transfer data

If:

(i) “You” have provided data to us; and

(ii) “We” use the data by automated means based on your consent or to fulfill our contractual obligations to “You”;

In such a case, “You” have the right to get the data back from us in a commonly used format, and “You” also have the right to ask us to transfer said data to another person if it is technically feasible from our side.

Submit a complaint to the existing supervisory authority

If “You” have a complaint of any kind, “We” welcome the opportunity to help resolve the issue. Before contacting a supervisory authority, please contact us first via the contact details provided at the beginning of this Policy.

Who should “You” contact if “You” have questions?

If “You” have any questions or would like to exercise any of the rights at your disposal “You” can find the contact details of the relevant PMI affiliate and data protection officer at the top of this Policy. Contact information will also be included in any communication sent to “You” by a PMI affiliate.

 “You” have the right to contact it with any questions or concerns. If the relevant PMI affiliate cannot provide a solution to “Your” question or issue, “You” also have the right to claim damages in a court.

Changes to this Policy

“We” may update this Privacy Policy from time to time. “We” will notify “You” of the changes if required by law and “We” will also obtain your consent to such changes.

The last change was made on February 27, 2024.

 

This product is not risk free. It provides nicotine, which is addictive. Only for use by adults.