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INFORMATION ON YOUR CONSENT TO RECEIVE

PERSONALISED COMMUNICATION

FROM PAPASTRATOS

(hereinafter the “Program”)

With this statement of your consent you give us your express consent to receive personalised communication from Papastratos. This communication is only addressed to adult consumers registered in the Papastratos Adult Consumer Database based on the General Terms and Conditions and the age of whom has been confirmed, in accordance with the respective Procedures, Principles and Practices of Philip Morris International (PMI)

Information sections

1. Who is the Data Controller?
2. Which is the purpose of the program and why you give us your consent?
3. Is it possible to withdraw your consent at any time?
4. What kind of personal data do we process and which are their sources?
5. For how long do we keep your personal data?
6. Categories of data recipients
7. Security of processing
8. What are your rights regarding the processing of your personal data?
9. Amendments to the privacy policy – Suspension or modification of the Program

1. Who is the Data Controller?

The société anonyme under the trade name “PAPASTRATOS SINGLE-MEMBER CIGARETTE MANUFACTURING COMPANY SA”, doing business as “PAPASTRATOS SINGLE-MEMBER SA”, having its registered office in Aspropyrgos, at Imeros Topos, Kororemi Site, with General Commercial Registry No. 227601000, with TIN 094011481-Athens Tax Office for Societes Anonymes, Telephone number 210 4193000, Fax number 210 4112303, (hereinafter the “Company” or “We”) is the Data Controller of your personal data.

2. What is the Purpose of the Program and why you give us your consent?

2.1 Purpose of the Program: to carry out personalised communication from the Company to you, both when you come in contact or communicate with us as well as when we send direct communication to your contact details that you provided to us when you registered in the Adult Consumer Database or in other programs of our Company.

This Program includes content of both general as well as of personalised individual commercial and non-commercial communication as well as your service based on the data collected about you within the framework of your registration in the Adult Smokers Database of our Company and/or based on your participation in our various programs, which are stored as history on your Adult Consumer Digital Card and/or with a combination of these data so that we can analyse and predict your preferences and your needs.

In particular, we will contact you about the news, Products, programs, privileges, competitions, studies and articles, participation in surveys of the Company or of third parties and in general about the services and issues of our Company’s customer service, by sending you direct communication, commercial or non-commercial communication within the context of other programs of our Company (provided that you fulfill their relevant terms, such as, indicatively, the Onboarding program, Free Trial program etc.), in the communication means that you stated during your registration in the Adult Smokers Digital Database, such as, indicatively, on your phone (by telephone call or by sms or viber or by other equivalent way) or to your e-mail or to your postal address as well as with the provision of your personalised service and information when you contact our partner either through our call center or when you visit an IQOS store or when you contact our third partners or on our website iqos.gr (chatbox).

2.2. The legal basis for processing is your free consent to receive the above personalised communication under this Program.

Explicit legal identification of adulthood control: Prerequisite for our communication with you under this Program is the confirmation of your adulthood (either upon your registration in our Database and when providing your consent to participate and subsequently, whenever this occurs). The method and timing of confirmation will vary depending on how you register and on how you make your purchases, in accordance with the applicable Philip Morris International (PMI) Procedures, Principles and Practices.

3. Is it possible to withdraw your consent at any time?

You may withdraw your consent and unsubscribe from the Program at any time, in which case your participation will be discontinued and your data will be deleted from the Program (they may be retained for another legal cause by our Company, especially provided that you are registered or you participate in other programs of ours, but they will no longer be used for this Program). The withdrawal of your consent leads to the interruption of receipt of communications under this Program. It should, nevertheless, be noted that with the withdrawal of your consent your participation in other programs of the Company shall not be affected.

You can withdraw your consent easily and in various manners, such as by logging in to your account in iqos.gr (provided that you have activated it) by selecting to unsubscribe using the unsubscribe link [unsubscribe] included in all communications through automated means, by declaring it in any IQOS store or by calling the company at 8001114767 from landlines or 2104193888 from mobile phones, or by sending an email to contact.gr@iqos.gr.

4. What kind of personal data do we process and which are their sources?

The data we collect in order to provide you with personalised communication, are collected from you either by ourselves or through partners of ours who act as processors on our behalf, or through the programs in which you participate as well as by automated means through interaction with us (e.g. indicatively based on the cookie policy of our site, etc.). These data are:



a) Your general information (name, phone, e-mail, etc.) and Demographic data you provided us with upon your registration to the Program. The data collection points are the Program registration points.

b) Your Purchasing data (concerning products, services, point of sale). Collection points are the points of sale, whether physical or electronic, of our Products as well as the data collected as long as you are a member of the Club.

c) Information concerning your satisfaction with the Company or with its partners, its products, its services and the service provided to you, issues you may face, as well as areas of improvement in its products and services, which are collected when we provide customer care services and/or when you voluntarily answer questionnaires or surveys addressed to you.

d) Information concerning your participation and interaction with our programs and/or our automated communication means and/or with the use of cookies, which are collected through your voluntary participation in our programs and/or communications with you and/or on the iqos.gr website.

Learn more about how we process your data for personalised communication:

We need the aforementioned information in order to be able to know you better and understand your preferences and needs (with or without combining your data), on the basis of:
- your demographics and general information;
- your purchases (type, volume, preferences, frequency);
- your satisfaction with the service and our products;
- your level of interaction with our communications and our programs;
- the level of your interaction with the customer care team

in order to adapt and personalise our contact with you in the context of the Program.

As a result of the foregoing, you will receive personalised communication and service that suits you, based on the information you choose to share with us.

For example:

- Information and service to you, as well as sending general news and offers that we believe are of interest to you, based on your details and your profile.

- Adjustment of our recommendations to you, based on the combination of your data in order to predict your preferences and needs, falling within the Scope, such as indicatively:

We will contact you with news concerning the Company and its Products, as well as with recommendations for participation in programs and contests that we determine that are of interest to you based on your preferences and/or which match your satisfaction level arising out of your answers to our questionnaires.

We will ask you questions concerning your satisfaction with our services and the improvement of our products and services that will match your profile and your satisfaction level.

You will receive special, exclusive offers and updates based on your purchases (type, volume, preferences, frequency), your demographic characteristics, the level of your satisfaction and interaction with us.

We will make sure to improve our products, services and our proposals to you for our programs based on the issues you indicate that you face during the provision of services to you and/or your answers to our questionnaires and to the other surveys as well as to continue to provide you with correct service, if your satisfaction level is high, or improve the elements you indicate - if your satisfaction level is low.

We will contact you in the context of after-sales service with recommendations for the proper and safe use of our products or restoring defects, if we conclude, from the information you provide us, that you face problems with our Products.

We will provide services to you during the sale of our Products, with recommendations based on your purchases and preferences.

5. How long do we keep your data for this Program?

The information we collect from you for the Program is retained until your consent is withdrawn in accordance with the provisions of Article 2.2. above. Also, in the event that we do not have any interaction with you for a long period exceeding 36 months, we will proceed to the deletion of your data, in accordance with the respective Procedures, Principles and Practices of Philip Morris International (PMI).

You may of course exercise at any time the right of erasure under Article 7 below, or/and request to unsubscribe entirely from our Adult Consumer Digital Database in accordance with the provisions of the General Terms and Conditions.

In any case, for more information about the general processing of your data by our Company, you can visit [Our General Privacy Policy] that you accepted upon your registration in our Database, as well as any specific privacy policies of our individual programs (such as, indicatively, the Club etc., provided that you have registered with them).

6. Categories of data recipients

In the context of the operation of the Program, our Company cooperates with third companies, which have access only to your data that are strictly necessary for the performance of their services, and which act as Data Processors for the provision of ancillary services in the context of the management of this Program, such as, indicatively, cooperation with physical or electronic shops and associates, who are natural persons, for the collection of your data and for the confirmation of your adulthood upon your registration, or when you carry out purchases or during the provision of any service to you on our behalf, with electronic platforms for carrying out communications with you, by electronic means, cooperation with companies managing call centers, with consulting or advertising companies, companies that provide services concerning the management and hosting of the database etc.

7. Security of processing

The Company takes all required security measures for protecting your personal data and ensuring the confidentiality thereof. For more information, please read our [general Privacy Policy].

The data you submit to the Company are handled exclusively by specifically authorised Company personnel, under the direction of the Company, by authorised third-party associates and only at the order of the Company, as well as by the aforementioned recipients, where necessary. In carrying out the processing, the Company selects persons or associates with relevant professional qualifications, offering adequate guarantees in terms of technical knowledge and personal integrity with regard to keeping confidentiality.

Express legal notice of the obligation of personal participation in all programs of our Company: You are required to keep secure and not to disclose your Account details/password at iqos.gr and/or to the IQOS CLUB Platform, and in particular to safeguard unauthorised access to them by third parties and/or not to use the features and privileges provided to you within the context of your registration at the Adult Consumer Digital Database. Our Company will consider reasonably and in good faith that any access or use of your Account or action related to the utilisation of your privileges and to your participation in our Company's programs was carried out by you provided that it is not notified in advance in writing (and/or by e-mail) of any leakage of your password or of unauthorised use thereof or use of your Devices by third parties or anything else related to your non-individual use or access to the above, for which you bear full responsibility and liability because all our Programs are individual, non-transferable and are subject to nationality control of each related participant.

8. What are your rights regarding the processing of your personal data?

Rights

Pursuant to the applicable legislation, as the case may be and where applicable, you have the following rights: information, access, rectification, restriction of processing, erasure, portability, objection, as well as the right not to be subject to a decision based on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (and/or, in such case, to request human intervention, express your point of view and contest the decision made).

In any event, you have the right to withdraw your consent at any time, in accordance with the provisions of article 2.

How to exercise your rights

In order to exercise your rights, as well as for any matter concerning this privacy policy and the processing of your personal data, you can contact us by:
a) calling the telephone numbers 8001114767, from landlines, or 210 4193888, from mobile phones, from Monday to Sunday, 09:00 – 23:00.
b) e-mail to contact.gr@iqos.gr
c) mail at the postal address: PAPASTRATOS SA Headquarters, Imeros Topos, Kororemi Site, Aspropyrgos, Attn. Legal Department.

We take the confidentiality of all files containing personal data seriously and we reserve the right to request proof of identity from you, if you submit a request to exercise your rights concerning the said files.
In addition, you can log in to your Account at iqos.gr, after activating it, in order to view and update your information, your consent options, as well as our contact details for the exercise of your rights.

Company response time to your requests and relevant procedure

Our goal is to respond to any valid request within thirty (30) days from receipt, at the latest, unless the request is very complex or you have submitted several requests. We will notify you, if we determine that a period exceeding thirty (30) days will be required for our response, for the reasons stated above.

We may ask you whether you could explain exactly what you wish to receive or what your concern is. This will help us to process your request faster. In any event, you should provide specific and true information and/or facts, in order to allow us to respond and/or accurately satisfy your request, otherwise we disclaim any liability for any errors that are beyond our control.

In addition, our Company is entitled to reject requests that are unfounded or excessive or abusive or in bad faith and, in general, unlawful, in accordance with the provisions of the law.

Right to lodge a complaint with the Data Protection Authority

In any case, if you believe that the protection of your personal data is violated in any way, you have the right to lodge a complaint with the Hellenic Data Protection Authority, using the following contact details: Website: www.dpa.gr, Postal address: Karamanli 1-3 Kifisias Ave., 115 23 Athens, Call Centre: +30 210 6475600, Fax: +30 210 6475628, E-mail: contact@dpa.gr.

You can find more details about your rights in our [General Privacy Policy].

9. Amendments to this policy – Suspension or modification of the Program

We reserve the right to modify the Program and/or this Policy, for example, in order to comply with new requirements imposed by applicable laws, directives or technical requirements or in case we revise our procedures or practices. We will notify you of any revision to our Policy, either personally or by publishing it on the website www.iqos.gr. We also encourage you to regularly check this page.

We also reserve the right to terminate the Program, in whole or in part, at any time and/or expel any member from the Program, where there are indications or where it is discovered that said member has committed, in breach of the law or the contract, any act or omission related to the Program, our products, the company and its other programs (and/or in relation to third consumers), upon relevant notice sent to the contact details provided to us by the member. Otherwise, our General Privacy Policy applies, to the extent that it does not conflict with this policy, as the more specific policy for this program.

Last update [8/11/2021]

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