GENERAL TERMS AND CONDITIONS

 

PART A. GENERAL TERMS AND CONDITIONS OF USE OF THE WEBSITE

PART B. GENERAL TERMS AND CONDITIONS OF ELECTRONIC PURCHASE OF IQOS PRODUCTS

 

PART A. GENERAL TERMS AND CONDITIONS OF USE OF THE WEBSITE

 

1. Our company

These terms (hereinafter referred to generally as the ‘Terms and Conditions’) govern your relationship with the societe anonyme with the 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, holder of General Commercial Registry No. 227601000, and Tax ID No 094011481 issued by the Athens Tax Office for Commercial Companies, telephone number 210 4193000, fax number 210 4112303, (hereinafter ‘Papastratos’ or ‘the Company’ or ‘We/Us’) with regard to the services and procedures referred to herein. These Terms and Conditions, together with PMI Group’s General Terms for Privacy Policy, constitute a set of terms and conditions that are implemented and apply to our relationship as far as all matters regulated hereunder are concerned (hereinafter referred to in their entirety as the ‘Terms of Use’ ). The Terms of Use may also be supplemented as necessary by the more specific terms of any of our Company programs in which you choose to participate.

2. Who, in general, are our services and programs intended for?

In general, all the abilities, services, programs and procedures referred to herein and provided by Papastratos are addressed exclusively to persons who cumulatively meet the following conditions:

i) they are natural persons, over 18 years old (age that must already be in any of your contact with our company and its products)
(ii) they are smokers and/or users of other tobacco products, new tobacco products, e-cigarettes or nicotine products in general, or related products, as determined by the relevant laws at any given time
iii) they reside or are staying in Greece; and
iv) they have full legal capacity (hereinafter referred to as ‘You’ or ‘the User’ or ‘Users’).

3. What are these Terms of Use concerned with?

Both your access to and use of the Website for the sale of Papastratos Products, iqos.gr (hereinafter "the Website" ) and your registration as an adult consumer in our Company’s Adult Consumer Database (hereinafter "our Database" or "Adult Consumer Database” ) as detailed below are governed by these Terms of Use. Papastratos invites you to read these Terms of Use carefully before you visit or use the Website, as well as when you register in our Database. Papastratos reasonably considers that you are aware of the Terms and have accepted them, both if you choose to continue navigating through our Website, and when you accept the Terms of Use for the purposes of registering in our Database (whichever is applicable in any given case).

These terms are divided into three Sections:

Α. Terms and conditions for registration in the Adult Consumer Database
Β. Terms and conditions of access and use of the iqos.gr Website
C. General terms and conditions governing all of the above (A and B)

Α. Terms and conditions for registration in the Adult Consumer Database

3.1.General description of registration in the Database

3.1.1. Papastratos produces, represents and distributes on the Greek market, among other things, non-combustible tobacco products, i.e. tobacco products that do not involve combustion, including new tobacco products consisting of electronic devices bearing the IQOS brand name or the names of third party beneficiaries contracted with Papastratos, and heated tobacco sticks, electronic cigarettes, and refill containers, as well as other related products, add-ons and accessories (hereinafter referred to as the ‘Product’ or the ‘Products’). When you purchase a Product in an IQOS physical store, or in the IQOS online store, or in a physical or electronic store belonging to third parties affiliated with Papastratos that carry the Products, or when you participate in other Company programs related to the purchase of Products (such as the Free Trial Programme) you can register in the Papastratos Adult Consumer Database and obtain an Adult Consumer Digital Card (hereinafter the ‘Adult Consumer Digital Card’ or ‘the Card’ ) in order to receive the service, communications and privileges provided by Company as well as to make remote purchases of Products (e.g. through the e-shop or by telephone) and to participate in the Company’s special programs, if you wish to do so.

3.1.2. You may register in the Papastratos Database in one of the following ways:

- Registration at an IQOS store

- Registration through a third party associate of Papastratos (in person or remotely)

- Registration through a call centre or on the recommendation of an associate tobacco product retailer

- Register when you make a purchase from the iqos.gr online store (e-shop)

3.1.3. To register in the Database and obtain and maintain an Adult Consumer Digital Card you must meet the requirements of article 2.1. above. It is expressly pointed out that the Company relies at the outset on your solemn declaration regarding your age for the purpose of your registration in our Database. However, it is explicitly emphasised that full use of the facilities offered by registering for the Card, as well as activating your participation in Company individual programs (such as, indicatively, personal communications, IQOS TOGETHER, MGM, Club etc), if you have registered with them, presupposes (and is subject to) confirmation of your adult age by Papastratos and/or its associates under the procedures applicable at any given time.

3.2.1 Why should I register in the Papastratos Adult Consumer Database?

1. So that you can make online and remote purchases of Products from Papastratos distribution channels;
2. So that you can be identified as an adult consumer (from the point of confirmation of your age and after) by our sales distribution channels, after-sales service partners, and the programs in which you wish to participate;
3. So that you can receive the commercial guarantee corresponding to the Product you have purchased throughout the guarantee period, without the need to provide proof of purchase (if you register your device according to the Product you are purchasing) 4. So that you can take advantage of the ‘On Boarding’ Customer Service Consultant program’, provided you meet the requirements of Article 6.2. below;
5. So that we can provide you with general after-sales customer care services, based on your Card information, when you contact us (e.g. in stores, at the call center, via the Website, through our Company’s the social media accounts or by any other means from you to us, on your own initiative); Your card information includes indicatively your order history, status of registered devices, contact details and personal information.
6. So that you can subscribe to individual programs offered by Papastratos if you wish to participate in them;

Details regarding points 3-5 above can be found in paragraph 6 of these Terms of Use.

3.2.2. It is expressly noted that in order to make commercial communications and personalized contact with you, you will be asked to give separate free consent to receive commercial communications (which you can grant or revoke at any time individually). Any other communications we make with you in this context, are exclusively for emergency or force majeure purposes only (for example, security reasons, identity checks, change of person for the purpose of device registration, changes to these Terms or other terms in programs you have registered for, etc.), operational/procedural services and after-sales services at your request (e.g. in the context of service warranties, etc.) and does not constitute (nor does it intend to constitute) any form of commercial communication. You may also participate separately in the CLUB or in our other programs by registering with them and observing the terms and conditions that apply to each as appropriate.

3.3. What do I need to do to ensure that I register properly?

When you register with the Papastratos Database in any way, you must:

3.3.1. Provide accurate and correct information, make sure it stays it accurate and up-to-date throughout your relationship with us, and refrain from altering or modifying it incorrectly or from providing out-of-date or untrue information, and ensure you declare your age truthfully and responsibly. Especially in case you declare your details for your registration through any of our third party associates, you should check with them that your information is entered correctly. The above information uniquely identifies you in relation to the Company.

3.3.2. In case of any subsequent changes in any information them or in case you lose the device you have registered or transfer it to another third-party adult smoker, you must inform Papastratos at contact@iqos.gr or through the Website under the ‘Support’ field or directly by telephone on 800 111 4767 (free of charge from a landline) or 210 4193888 (charges depend on telecommunications providers). Papastratos is not responsible for any action or any error or problem created due to the submission of incorrect, inaccurate or untrue data or in the case of incorrect or untimely notification of the above.

3.3.3. Before you register you must be aware of the contents and accept the Terms and Conditions and our Privacy Policy. In any case, the Terms of Use shall always be made available to you in any communication from us to you (as foreseen and permitted) but also at any time on the iqos.gr Website. Lastly, you can request information in the ‘Support’ field of our Website, on the customer service page on Facebook, as well as from our call center.

3.3.4. The information required for your registration is that necessary, relevant and appropriate in order for Papastratos to be able to identify you when providing you with after-sales customer service, including in compliance with its legal obligations to ensure that you are over 18 years old. More information on the processing of your data can be found in the PMI Group General Data Privacy and Protection Terms and Conditions [link].

3.3.5. You may have only one Card in our Database. Any attempt to have duplicate accounts, to register twice or to register a person using altered/false information/other accounts (same name, surname, delivery/billing address, phone number) may result in deletion of previous accounts opened after the original account, and if these actions are repeated, Papastratos may deactivate the consumer’s initial registration. In addition, any attempted fraud detected within and in connection with active promotions on the iqos.gr Website shall lead to the exclusion of the user committing the fraud or attempted fraud from any discount or prize.

4. Creating an Account with iqos.gr

4.1.How to create your account with iqos.gr

4.1.1. By registering in our Database and opening an Adult Consumer Digital Card, you also acquire a personal Account which is accessible by you through our iqos.gr Website, and contains the personal information that you have declared for the purposes of your registration in our Database.

4.1.2. To activate your Account you must have confirmed that you are the owner of the telephone (mobile) number you have registered, by following the double opt in confirmation process, by entering the One Time Password code which you will receive on your mobile phone or by confirming your email in the following way: By following the double opt-in process by clicking on the relevant link which you will receive in your e-mail after completing your registration. Please note, if your Account is created by a representative of the Company for you (remotely via call center following your call or through your visit to a store), the confirmation of the e-mail is optional.

Your Account will remain inactive until the confirmation is completed. If your Account remains inactive for more than 30 days, it may be deleted.

4.1.3. Your personal Account is used for the following purposes:

- Making purchases from the e-shop gr.iqos.com and participation in the company's commercial programs.
- Accessing and managing your personal information and the information contained in your account;
- Registering and keeping track of your Devices, for example in connection with commercial guarantee coverage;

4.1.4. In any case, you also need to open an Account to make purchases via the e-shop or by phone in order confirm that you are of age at the time the Products are delivered.

4.1.5. It is noted that your Account is the ‘front end’ of your Tab in the Database and contains the data that are necessary to be able to proceed with the abovementioned purposes. Only authorised persons of our Company can access your Card details in full (back end), and the collection and processing of your data is governed by the PMI Privacy Policy which you are made aware of and have accepted during your registration in our Database. The creation of more than one Account is prohibited, and the provisions of Article 3.3.5 above shall also apply.

4.2. What are the conditions for correct maintenance of my Account at iqos.gr?

Your Account is accessible to you under the following terms and conditions.

In particular, with regard to the correct maintenance of your Account, the following apply:

4.2.1. When activating your Account at iqos.gr, you must also create a secret password, based on the currently applicable security rules of Papastratos governing creation of passcodes which you will be made aware of at the time. You will be able to access your personal Account using this code, and it will uniquely identify you with regard to any actions or omissions made through your Account.

4.2.2. You should always keep your password confidential and secure. In particular, you have sole responsibility for protecting your password and keeping it secret. For this reason, we would ask you to change your secret password at regular intervals. You should also completely avoid giving your password to third parties, in order to prevent any unauthorised access or use of your personal Account and the features provided through it (and in particular, but not exclusively, to any minors). You must inform Papastratos immediately if you have reason to believe that (a) your secret password could or may have been disclosed to a third party or (b) there is a risk that your password may be used without your permission.

4.2.3. You also bear full and exclusive liability for any action (act or omission) carried out through your Account. Papastratos disclaims any liability for damages arising from the use of your Account (including against third parties), due to unauthorised access or use of your account, unless you have previously informed Papastratos in a timely and appropriate manner, via email to contact@iqos.gr, or through the Website via the ‘Support’ field, or by telephone at 800 111 4767 (charge free from a landline) or 210 4193888 (charges depend on the telecommunications provider). It is emphasised that any action taken through your account prior to notification of Papastratos in accordance with the above, will be treated as an action taken from your end .

4.2.4. You can at any time amend specific details in relation to your personal data which is stored in your personal Account, under the ‘My IQOS ™’section of the iqos.gr Website.

5. Deletion

5.1. You have the option to automatically deactivate your Account at any time you wish, via the Account itself. We emphasise that in the event that you do deactivate your Account in iqos.gr your information will not be completely removed from the Papastratos Database or from other programs of the Company that you may have registered for; you will only lose the ability to log in and access your Account (and you will not be able to make purchases from the iqos.gr e-shop or by phone). You can reactivate your Account through the Website or by calling 800 111 4767.

5.2. You can also request complete deletion of your personal information from the Papastratos Database by submitting a request for deletion at any time you choose, and this will result in the permanent deletion of your Account with the e-shop, as well as removal of your participation in all the Company’s programs and deletion from the Papastratos Database altogether (through anonymization or/and technically equivalent measure)

5.3. Deletion from individual programs of the Company that you may have registered with does not imply deletion of your Account at iqos.gr and/or from the Papastratos Database (your Card and your Account in the e-shop are maintained until you request their deletion through a request for deletion as indicated in paragraph 5. 2 above).

5.4. Following deactivation of your Account, your Account data will be retained for a specified period of time as determined by PMI's data retention policy for security reasons, in the context of our legal interest in complying with business continuity and data recording procedures. In any event, if there is no activity through your account for a period of 36 months, your data will be deleted entirely (without prejudice to any request under paragraph 2 above, or to your data being held for compliance with legal obligations by the Company). If you wish the deletion of your data to take place immediately, you must make a declaration to this effect by email to contact@iqos.gr or by telephone at 800 111 4767 (charge free from a landline) or 210 4193888 (charges depend on the telecommunications provider) requesting deletion as indicated in paragraph 5. 2 above .

5.5. Papastratos reserves the right to refuse to create an Account and/or delete your Account and/or your Card entirely from our Database at any time, for any reasonable reason or cause. In particular, (but not exclusively) the Company is entitled to proceed with any of the above for any material reason, indicatively including but not restricted to the following: if there are indications of bad faith, illegal or non-contractual use of the Account, submission of untrue or false information and/or declaration of adult age, as well as any non-compliance with these terms. In this case details of the User are kept as provided for in paragraph 5.4 above, to ensure that the same User cannot register another account.

6. More information regarding privileges of registration in our Database and device registration

6.1. Commercial warranty during the estimated duration (without submission of receipt)

6.1.1. After completing your registration in our Database you may then register your device (depending on the Product you have purchased) in order to be able to monitor the warranty period and ensure continue you meet the conditions, without having to provide proof of purchase of the device to be serviced (in order to prove date of purchase and confirm that you are still within the warranty period).

6.1.2 The services you receive is always based on the terms of the commercial warranty contained in the Product packaging (for new tobacco product devices or electronic cigarettes) that you have purchased.

6.1.3. Each time you make use of the warranty the event is recorded in our Database and your Account, so that your service history is readily available and your entitlement under the warranty can be easily established every time.

6.1.4. If you do not register your device, you do not of course lose your rights under the terms of the commercial guarantees that accompany your device. However, you will have to provide proof of purchase each time to confirm that your device is still covered by warranty (otherwise, since the date of purchase, the length of the warranty period, and warranty expiry date cannot be ascertained, you will not be entitled to receive services under warranty).

6.1.5. It is stressed that in order to receive the above, the personal information with which you register your device must be identical to the personal data you submitted during your registration in our Database. If you give your device as a gift to a third person adult smoker, then the device should be registered in the details of that third person. We reserve the right to request information that evidences the above, as well as to take action in cooperation with you to register the device to the third party who has the device in their possession.

6.1.6. None of the above restricts or invalidates your rights under legal guarantees pursuant to the Civil Code, as applicable at any given time.

6.2. Onboarding Program

6.2.1. After registration in our Database, if you have registered a device and given your consent to commercial communications from Papastratos, you will have the right to participate in the specially-designed customer service and support program, which is available after purchase or use of a new device from our Company’s range of Products, as long as your adult age has been verified. This program is part of the general after-sales customer services that our Company offers because our Products represent a new state-of-the-art technology with increased safety and correct use requirements. Extra service and support is necessary to ensure smooth transition while getting used to using the Products in question. The continuation or modification of its operating terms and conditions or the termination of this program is at the sole discretion of the Company.

6.2.2. This program was created especially for those who have purchased a Product from our Company that includes an electronic device (new tobacco product or electronic cigarette) for the first time, to meet your after-sales needs, support the product’s proper and safe use, or service needs or its adjustment in general as a state-of-the-art technology product. A specialized personal consultant will contact you within the first few days after purchasing your first device from our Product range, using the contact details you have submitted, in order to offer you information and resolve any questions you may have regarding the safe and correct use of the product that you have purchased, as well as to give you advice on good maintenance, cleaning and charging methods, and to resolve any issues related to your experience while using the product.

6.2.3. This Program will be activated if it is established when you register that it is your first device from our Product range, that you have purchased or are using it through a Papastratos Program, and that you have given your consent to commercial communications. The program will also be available for the next device you register if the device in question is another version of the Product that has significant differences from your previous devices.

6.2.4. If you do not wish to continue with the above program you may state this to our partner or contact the Company as indicated in Article 1 of these Terms. The interruption of communications for the specific Program does not imply your deletion altogether from the Database or other programs in which you participate (unless you explicitly request deletion from them). The interruption of communications under this Program, does however imply interruption of all communications from Papastratos.

6.3. General after-sales service (Customer Care) based on your Card

Once you are registered in our Database, we will provide you with after-sales service based on the information contained on your Card, when you contact us to request our assistance, or have questions or other issues related to Products that have you bought, either in store, via the call center, the Website, the social media accounts of our Company or by other means, on your own initiative from you to us. In this context, our Company will suggest solutions to your problems, give you advice on the correct and safe use of products based on your questions, and will generally provide you with whatever service may be required based on your needs.


6.4. IQOS TOGETHER Program

If you register an IQOS and / or IQOS VeeV device and/or Lil Solid, you have the opportunity to participate in programs such as IQOS CLUB or in combination with the terms of IQOS CLUB for point collection and redemption (such as indicatively the IQOS TOGETHER Program and any other programs provided from time to time by the Company).

More specifically, the following are emphasized for IQOS TOGETHER:

i) The IQOS TOGETHER Program allows you, as an adult smoker with an Adult Consumer Digital Card in our database, having registered and maintained at least one IQOS and /or IQOS VeeV Device and / or Lil Solid as a consumer of IQOS products, having accepted the terms of IQOS CLUB or having become an active Member of the IQOS CLUB – whichever comes first (in order to be fully informed about how to earn and redeem points) to inform an adult smoker friend of yours that he or she can be informed about Papastratos' Products, if he/she wishes so, (hereinafter referred to as the "Update") either a) through a partner by calling him or her on the phone number provided by your friend or b) by visiting an IQOS retail point (physical or electronic) with the procedures described in more detail in the terms of the Program. Your friend must be an adult smoker, and must not have previously registered/had a Card on our Company's Adult Consumer Database and must have given consent to you to be informed in accordance with the above, which you cumulatively guarantee to us upon your participation in the Program in any way (see relevant terms and conditions accepted by your friend).

ii) Τhe steps explained during the use of a) the special Application, if you are a Member of the IQOS CLUB, b) through our Partner, c) through the Website iqos.gr or d) by using your mobile as a MOBILE CODE as described in more detail in the terms of the Program, may be used to complete the process of Updating a friend by telephone from our Partner or through a store. The relevant deadlines must also be adhered to, as well as the numerical limit imposed each time for each period of time.

iii) If your adult smoker friend purchases a Product using the sms code or the IQOS / MOBILE CODE within the time limit set each time, you will be awarded Points (the amount of which will be determined each time based on Papastratos' policy and will be posted on the Website, the IQOS CLUB Platform, or other platforms and media of the company or with your individual information to your contact details, on a case-by-case basis – hereinafter referred to as "Points Performance Policy"). Points can only be collected and redeemed under the specific terms outlined in the Program's terms as well as the IQOS CLUB's Terms of Use in each case.

iv) By selecting options a-c) of point (ii) above to participate in the Program, you are informed about the terms of the program through the present terms and confirm your acceptance, particularly when using these options. Your participation through the use of IQOS / Mobile Code implies that you are aware of the Program's terms, which are included in this notice and accessible via a link in this article, as well as in the Program's public posts, and which you are reasonably expected to have considered before receiving your friend's consent for the use of IQOS / MOBILE CODE, and in any case and at the time of your notification about the use of the IQOS/MOBILE CODE by your friend.

**Explicit Note: The reference to privileges and programs in article 6 above is merely indicative and non exhaustive. In any case, if you are interested in participating in any of Papastratos' Programs, you will be invited to be informed on (and accept) the specific terms of each program, which will govern and determine your relationship with our Company for each of these Programs at any time.

Β. General Terms and Conditions of Website Use

7. Description of Our Website

These terms are governed by and construed in accordance with the laws of Greece. The User and Papastratos, upon acceptance of these Terms and Conditions, agree to be subject to the exclusive jurisdiction of the courts of Athens, Greece.

7.1. The iqos.gr Website is a point of sale for the Company's Products. If you do decide to enter the site, you do so on your own initiative after you submit a solemn declaration stating that you are an adult (over the age of 18). The Website belongs to Papastratos which manages it in its entirety, but the sale of the Products may be carried out either by Papastratos itself or by Sellers in accordance with the General Terms and Conditions of Sale of Products through the e-shop or by telephone, as applicable. More specifically, sales may be made through cooperating companies that are third-party resellers of Papastratos or its representatives, who are able to sell the Products available to Papastratos in Greece (hereinafter the ‘Sellers’), as defined in the General Terms and Conditions for Electronic Purchase of Products as applicable at any given time.

7.2. It is noted that if you wish to make a purchase through iqos.gr or by telephone, the creation of a personal Account is essential for Papastratos and the cooperating Sellers to be able to meet their legal obligations with regard to the taking of appropriate safeguards and measures as far as possible for the purpose of demonstrating compliance with applicable law, ethical practices, and our internal policies that are intended to prohibit the sale of tobacco products to minors. Accordingly, the creation of an account on the Website is necessary in order to secure as far as possible the observance of the legal age limit of eighteen (18) years (which must be confirmed when the product is delivered to you). The creation of an Account also means than your residence within Greek territory is verified.

8. Website Features

8.1. Purchase of IQOS products, add-ons, and accessories: Through the Website you are given the opportunity, if you wish, to visit the e-shop to purchase Products. To this end, it is absolutely essential that the creation of an Account shall have taken place prior to purchase, in accordance with the specific provisions of Article 7.2 above. Electronic sales of the Products through the e-shop or by telephone are carried out in accordance with the Terms and Conditions for Sale of Products through the e-shop or by telephone, of which you will be made aware and shall have accepted before the completion of your purchase.

It should be noted that Papastratos is not a contracting party to the Product sales agreements between each respective Seller and the buyers of Products purchased through the e-shop. It therefore bears no liability for the fulfilment of their contractual obligations, or for any other issue that may arise as a result of or occasioned by the purchase of a Product through the e-shop.

8.2. Nearest store locator The Website also provides you with an automated tool that you can use to find the nearest physical store selling our Products. This tool is made available to you exclusively for your convenience, and the results it produces depend entirely on the information entered by you at the given time. Papastratos bears no responsibility in relation to the results exported with the use of the automated tool, nor for any inaccuracy or deviation the results in relation to actual distances.

8.3. Information section on the Company's Products: Papastratos provides information of various content regarding the Products and their operation in general via informative articles, photos, and videos that are available on its Website. This information is supplied so that you receive essential product information, as well as providing the minimum information that is required to be made available to adult consumers without constituting a suggestion or encouragement to purchase tobacco products. In all cases, the respective posts are made within the Website, which is a legal point of sale for tobacco products.

8.4. Communication with Papastratos: Communications from Papastratos with you via the tools available on our Website takes place at your own initiative and request, and not at the initiative of Papastratos. Even in cases where Papastratos communicates with you using the contact information that you have submitted to us, communications will take place at your prior request and under the terms of the Papastratos Privacy Policy as well as the specific terms of the respective program, of which you will have been made aware your request for communication.

9. Terms and conditions of access and use of the Website

9.1.First of all, you may only access the Website if you make a solemn declaration stating that you are over 18 years of age. You may only make purchases through the e-shop if you create an Account, as indicated above.

9.2. The Website is also exclusively aimed at users residing or staying in Greece. Access to the Website is prohibited for devices and IP addresses that are not within the Greek territory.

9.3. Under the Terms of Use, you are granted non-exclusive permission for access and personal use of the Website for the purposes specifically detailed in these Terms of Use. This permission does not under any circumstances imply licence to download or modify the Website or any part thereof, which is permitted only with the written authorisation of Papastratos. Access permission granted hereunder does not allow any resale or commercial use, reproduction, creation of copies, copying, transmission, announcement, circulation, amendment, or concession of permission, or concession to any other form of exploitation of this Website or its content, any collection and use of any catalogues, descriptions or photographs of products, any derivative use of this Website or its content, any receipt or copying of account details for the benefit of another commercial trader, or any use of data extraction tools, bots, or other similar data collection and extraction tools. Use in any manner, or any other form of exploitation of the Website and its content for professional or commercial purposes, is strictly prohibited. Papastratos reserves exclusive rights over the domain name ‘iqos.gr’. In addition, all trademarks appearing on the Website are duly subject to legal protection.

9.4. We ask you not to post or share the content of the Website publicly or individually with third parties. Any posting by any user of content from this Website to any other third party website shall not automatically enable access to the content of this Website. Access to it is possible only if the conditions of Article 9.1 above are cumulatively met. Accordingly, in order for any third party to gain access to the Website, even if they access it through a specific link published by a user on any website, they must first declare that they are over 18 years of age. The User must take all reasonable steps to prevent posts appearing on websites addressed to minors.

9.5. It is expressly forbidden to approach any minor in relation to tobacco products in order to inform or encourage them to use this Website or our Products.

9.6. You must abstain from any use of the Website in an unlawful, offensive, or obscene manner, in contravention of these Terms and Conditions. Use of the Website is granted only if you act in a fair and lawful manner, and refrain from any action that causes or may cause damage to the reputation of Papastratos or its undesirable exploitation. In addition, creating links that imply any kind of relationship with Papastratos or approval or support from Papastratos when such relationship does not exist is strictly prohibited. The Website may not be placed in a frame on any other website and it is prohibited to create a link to any part of this Website other than the home page under any circumstances. Papastratos reserves the right to withdraw permission for the creation of links without justification, without liability for compensation, and without prior warning.

10. Intellectual Property, Software, Content and Trademarks

10.1. The intellectual property rights over the software as well as the content and the trademarks shown on the Website belong either to Papastratos, or to its associated companies, or companies of the Philip Morris Group, or to other lawful beneficiaries, and are protected by the applicable laws on intellectual property rights. Users and any other third parties do not have and do not acquire any permission or consent to use the trademarks of Papastratos, or trademarks belonging to companies of the Philip Morris Group in any manner, without the special written permission of Papastratos.

10.2. The appearance and display of Website content may not be taken as transfer and/or concession of permission and/or a right to use said content. You may save, print, and display available content for personal use only. Users and any third parties are prohibited from publishing, handling, distributing, copying in whole or in part, transferring, processing, storing, republishing, modifying or otherwise reproduce, in any form, any part of the content or copies of the content displayed on this Website. In the event of unauthorized use, the permission conceded by Papastratos authorizing access to the Website shall automatically and immediately cease to apply.

10.3. You are prohibited from using frames or frame techniques in order to frame any trademark, logo, or other proprietary information (including images, text, page layout, or format) of the Papastratos Website and its associated companies, or the companies of the Philip Morris Group, without its written consent. The User is not allowed to use any ‘meta-tags’ or any other ‘hidden text’ based on trade names or trademarks of Papastratos or its associated companies, or companies of the Philip Morris Group, without its written consent.

C. General terms and conditions governing all of the above (A and B)

11. Special term

11.1 It is expressly pointed out that our Company does not provide any kind of advice or guidance on health issues, for which your doctor is solely responsible, whom you should contact directly and whose advice you should follow. If in the course your communication with us, you voluntarily and of your own initiative raise any health issue, our Company is only obliged to record the incident (completely anonymously) and report it to the competent authorities, as provided for by law.

11.2. Our non-combustible Products are intended for adult consumers who would otherwise continue to smoke or use nicotine Products and they do not constitute an alternative to stopping smoking, nor are they designed to be an aid for giving up. They are not harmless, they contain nicotine which is addictive. Further information about the risk is available on the website iqos.gr. In any case, your registration in our Database (and participation in any program of our Company) is based on the recognition and acceptance by you of the above, as the result of a personal and informed choice, as an adult consumer.

12. Limitation of Liability of Papastratos

12.1. You enter and navigate the Website on your own initiative and at your own risk, fully aware that you are visiting a point of sale for tobacco Products having given your solemn declaration that you are over 18 years old.

12.2. Your connection to the Website is conducted through technical means and via the providers of your choice. Papastratos shall provide no guarantees of the following: (i) the proper operation of the websites and/or applications; (ii) rights of access and use; (iii) the full, accurate, and updated nature of the contents, the information, or the data available on the websites; (iv) the absence of any defects or errors in the content and/or the operation of the Website and/or the applications; (v) the absence of viruses or other malicious software; and (vi) the absence of certain attributes that might be expected in relation to the Website and the other applications, or their content. Accordingly, Papastratos wishes to inform you that the entire content of the Website, and the Product information (which can be purchased by the User only through the e-shop) are provided ‘as is’, without any requirements or other guarantees as to their truthfulness, accuracy, or suitability for the use or the purpose for which the Products sold are intended.

12.3. Papastratos takes any reasonable measures to prevent unauthorised access to the Website, i.e. by persons not meeting the requirements set out in Article 2 above. For this purpose, among other things, access to the Website is automatically deactivated after 30 minutes without any further action on your part (so that the Website does not remain open for viewing). However, you must also take all possible precautions to avoid use of the Website by unauthorised persons, such as, for example, avoiding making use of the website in the presence of such persons (e.g. minors, vulnerable groups in relation to tobacco Products, etc.) or leaving the website open with or without your supervision in front of such persons.

12.4. You agree to indemnify, defend and relieve Papastratos, the companies of the Philip Morris International Group and its directors, executives, employees, consultants, agents and associates of any and all third party claims, liability, damages and/or costs arising due to or on the occasion of any culpable, illegal or non-contractual use of the Website by you or the culpable breach by you of any of the Terms of Use. In any case, you must promptly notify Papastratos at contact@iqos.gr or through the Website in the ‘Support’ field, or at the telephone numbers 800 111 4767 (charge free from a landline) or 210 4193888 (charges depend on the telecommunications provider), if you have become aware or have reasonable suspicion or indications that the Website has been used (even if it is due to negligence on your part) in an illegal or non-contractual manner, so that Papastratos can take the necessary steps to limit any damages.

12.5. This Website contains hyperlinks (links) to other websites, which are not connected with Papastratos, and whose content is not controlled by the latter (the ‘Linked Websites’). Accordingly, Papastratos cannot guarantee the correctness, legality, completeness, updating, truth, accuracy or quality of the content posted on the Linked Websites and is not responsible for it or for any loss or damage that may be caused by or due to its use either because of or on the occasion of Product sales through it. Papastratos in no way endorses or accepts or approves the content or services of the Linked Websites, to which users are referred via hyperlinks.

12.6. In addition, as a user you bear full and exclusive liability for any loss or damage caused to Papastratos due to untrue, erroneous or out of date information submitted by you. It should be stressed that any notification sent (as part of the legal obligations of Papastratos or in the case of special communications as indicated in these Terms of Use) to the email address submitted by you when you created your account shall be deemed to be effectively delivered, even if you did not receive it due to an error in the information provided by you and/or due to a technical or other fault in your server, and/or your telephone, and/or your telecommunications provider, and/or due to a change in your information (if you have failed to notify Papastratos in a timely manner, as indicated above).

13. Other Terms

Papastratos reserves its rights, indicatively, and not exclusively, to the following:

13.1. to change part or all of these Terms of Use at any time and to choose the manner in which Users are informed as appropriate (either individually via personal contact information, or by public posts on its Website or a combination thereof or in any other way, at its discretion);

13.2. to renew or upgrade part of or the entire content of the Website;

13.3. renew or upgrade part of or the entire interface, organisational structure, or configuration of the Website, as well as its technical specifications, and

13.4. limit access to the whole Website or part thereof. Papastratos also reserves the right, without justification and without prior notice to website users, to cancel, suspend (permanently or temporarily), or to terminate operation of the Website at any time.

14. Applicable law and jurisdiction

These Terms of Use are governed by and construed in accordance with the laws of Greece. Users unconditionally agree, by acceptance of these Terms and Conditions, that any dispute against Papastratos that may arise from the use of the Website, or for the purpose of resolving issues arising in execution or interpretation of the Terms of Use, shall fall under the exclusive jurisdiction of the competent courts of the city of Athens in Greece.

15. Final provisions

15.1. The above Terms of Use bind the parties (Papastratos and Users) collectively, and as a whole constitute the entire contract between the parties, prevailing over any and all previous and current contracts between the User and Papastratos, they are of indefinite duration, and may be terminated at any time from any location (by Papastratos or the User). More specifically, Papastratos may terminate these Terms by sending a respective email to the email address declared by the User setting a reasonable deadline, after the expiration of which the Customer’s entire account will be deactivated as indicated the above. You may terminate the relationship under these terms by following the deletion procedure indicated in Article 5 above.

15.2. Should any term be deemed abusive or is cancelled, this shall not affect the remaining terms, which shall continue to apply and remain binding on the parties. In any case, to the extent that this is feasible, a single term/sub-term or part thereof may be treated individually, in order for the remainder to be rendered valid and the term shall be construed accordingly. Otherwise, you agree that the term must be corrected and shall be construed in a manner that most approximates to the original meaning of the term/sub-term, in accordance with the law.

15.3. Any delay by the parties in exercising some or all of the rights stemming from these Terms shall not result in the weakening or waiver of such rights, which may be exercised at any time at a later stage, at the discretion of their holders.

15.4. The headings contained in these Terms and Conditions are used for reference purposes only, and shall not affect the meaning or interpretation thereof.

 

PART B. TERMS AND CONDITIONS FOR THE SALE OF PRODUCTS VIA THE iqos.gr E-SHOP AND/OR VIA TELEPHONE ORDERS

1. Overview of purchases via the iqos.gr e-shop or by phone

1.1. Remote purchasing of smokeless tobacco products, i.e., heat-not-burn tobacco products, meaning, tobacco products are used without being burnt, such as new tobacco products consisting of electronic devices bearing the trade name IQOS or third party names of beneficiaries contracted with Papastratos and heated tobacco sticks, e-cigarettes and refill containers and other related products as well as additions and accessories ('Products') made available on the Greek market by the company under the name 'PAPASTRATOS SOLE PROPRIETORSHIP SOCIETE ANONYME CIGARETTE COMPANY' and the distinctive title 'PAPASTRATOS SOLE PROPRIETORSHIP S.A.", located ar Imeros Topos St., Kororemi Location, with registration number GEMI 227601000, VAT No. 094011481, Tax Office of Athens, telephone no. 210 4193000, fax no. 210 4112303, e-mail address contact.gr@iqos.com (hereinafter referred to as "Papastratos", or the "Company"), is carried out through the iqos.gr website (hereinafter referred to as the "e-shop") which is accessible through the Company's iqos.gr website (hereinafter referred to as "iqos.gr" or "Website") or by phone through the call centre phone lines 800 111 4767 (free of charge from a landline) / 210 4193888 (charge depending on the communication provider) | opening hours of the IQOS call centres daily 09:00 - 23:00 (hereinafter referred to as the "Call Centre"). The Website and the Call Centre will be hereinafter collectively referred to as “Remote Sales Channels”.

1.2. Papastratos is fully and exclusively responsible for determining the mode of operation and the content of the Remote Sales Channels as well as the terms and process for the submission by consumers of their orders, the execution of these orders and the delivery of the Products.

1.3. The sale of the Products is carried out either by Papastratos itself or by its third party partners on behalf of Papastratos (hereinafter the "Sellers"). The Sellers act as agents-indirect representatives of Papastratos, contracting with the final consumer on behalf of Papastratos. Consumers who wish to purchase Products through the Remote Sales Channels place their orders on these Remote Sales Channels in accordance with the provisions hereof. On completion of the submission of the order, Papastratos will send the relevant confirmation via e-mail to the consumer, informing him/her at the same time of the details of the Seller, who proceeds with the sale and delivery of the Products on behalf of Papastratos, and who also collects the purchase fee, and who will execute the sale according to the terms of this Agreement and issue the relevant retail receipt (hereafter Papastratos and the Sellers are referred to as "We"). Each Seller is basically designated on the basis of the geographical area they serve and/or other criteria relating to logistics (e.g. stock) and/or aimed at facilitating faster and more effective Consumer service.

1.4. It should be noted that access to and browsing on the e-shop, making purchases through it or by telephone, and the information, content (including videos), update, as well as the overall features and functions on the Remote Sales Channels, are addressed to individuals who meet the following cumulative requirements:

    i. they are natural persons, over 18 years of age, and have full legal capacity (such age must have already been completed at the time of accessing the Website and performing any action relating to it)

    ii. they are smokers and/or users of other tobacco products, new tobacco products, e-cigarettes or nicotine products in general, or related products, as determined by the relevant laws at any given time

    iii. they reside or are staying in Greece (hereinafter referred to as the (“Consumers”).

1.5. Purchases from the Remote Sales Channels are also governed by these General Terms and Conditions for Sale of Products through the e-shop iqos.gr or through telephone orders (hereinafter the "Terms of Sale"), which you acknowledge and accept before completing your purchase. It should be noted that each time a Consumer makes a purchase from the e-shop or a telephone order, a separate special purchase and sale contract will be drawn up, which will be governed by the more specific terms of the purchase and sale based on the Terms and Conditions in force (at the time of the purchase and sale).

1.6. For any problem arising in connection with the order of a product through the e-shop or a telephone order, the Consumer may contact our Call Centre.

1.7. Important Legal Notice: The Products listed above in Article 1.1 are sold through the Remote Sales Channels and telephone orders. The Website is exclusively addressed to individuals who meet the requirements of Article 1.4., and its sole purpose is to inform Consumers about the Products and the option of making remote purchases of Products at the Consumer’s initiative, and it is not a recommendation or incitement to purchase a Product. Papastratos adopts reasonable measures, to the extent possible, to avoid selling Products to minors (including but not limited to requiring a statement of adulthood to enter the site, to create an account and at the onset of a telephone conversation, checking age upon delivery and other reasonable measures, as the case may be). Consumers access the Website and use the Remote Sales Channels of Papastratos at their own initiative and responsibility, fully acknowledging and understanding the health risks of using tobacco and nicotine products. We reserve the right to deny access to the Website, and to refuse sale and/or delivery of Products to any person if we have any reasonable indication or evidence that such person violates the above terms and/or refuses to cooperate with confirming the above.

1.8. Only persons who state that they are adults upon entering the Website and/or while contacting the Call Centre, and have created an account based on Article 2 hereunder, may make their purchases through the Remote Sales Channels. However, in any case, conclusion of a sale and purchase contract and delivery of the Products are conditional upon checking and verifying adulthood upon delivery, based on the special term of Articles 3.2. and 7.9. below.

1.9. With regard to the Products, it should be clarified that:

  • Consumables: We define the heated tobacco sticks (in tobacco products) and the liquid refill containers (in e-cigarettes) used by customers using the corresponding electronic devices as Consumables.
  • Accessories: We define all the peripherals of the Device that accompany it and facilitate its use (cleaners / cables / lids / cases / individual parts of the Device sold separately -holder-charger-) as Accessories.
  • Device or Devices: We define the electronic devices that customers use when using Consumables as Devices.
  • Kit or Mobility Kit: We define the offer package that includes the complete set of with the Device or the Devices sold "complete" with or without the Consumables (according to the respective offer) as Kit or Mobility Kit.

2. Creation of Account

2.1. In order to make any purchase of Products remotely, it is mandatory for the Consumer to create an account at iqos.gr in accordance with the provisions of Article 4 of the Terms of Use of iqos.gr (hereinafter the "Account") which he/she accepts when opening his/her Account. Opening an Account is a necessary condition for the completion of the sale and purchase through the Remote Sales Channels, for the purpose of fulfilling the legal obligations in order to demonstrate compliance with the applicable legislation, ethics and policy of Papastratos with regard to tobacco or nicotine products. It is expressly clarified that each Seller which is processing the Consumer’s order acquires access to the Consumer’s Account details for the sole purpose of carrying out and concluding the sale and delivery of the Products of the specific order each time.

2.2. You may change certain details of your Account and enter different details while making your purchases (e.g. delivery or invoicing address). However, YOU MUST NOT CHANGE YOUR IDENTIFICATION INFORMATION (name and date of birth) as it will be impossible for the identification process to verify your age at the time of delivery of the Product as mentioned in article 3.2 below.

2.3. Delete Account: Consumers have the right to deactivate their Account at any time, by clicking on the “Deactivation” button, as set forth in Article 5 of the Terms of Use of iqos.gr. It should be noted that in the event of deactivation of the Account on the e-shop, the conduct of purchases and the delivery of Products by orders through the Remote Sales Channels will no longer be possible.

3. Conduct of transactions on the e-shop or by telephone

3.1. 3.1. The Products posted on the e-shop are available for sale to Consumers on the e-shop or by telephone. Those sales are exclusively addressed to adult consumers (B2C). It is clarified that for remote contracts, a consumer is a natural person who is acting for reasons that do not fall within the scope of his or her commercial, business, craft or professional activity.

3.2. Special term of sale: In order for any Consumer to make a purchase from the e-shop or by telephone, they must cumulatively meet the requirements set forth in Article 1.4. above. Users who have not reached legal age (18) are prohibited from carrying out any action on the Website or the e-shop, or making telephone orders. Papastratos and each Seller on its behalf reserves their right not to execute their contractual obligations vis-à-vis the Consumer/buyer if the data stated (identification and adulthood) are not verified upon first delivery of the Product or any subsequent order is not received by an adult person, as provided for in Article 7.9. below. The sale is carried out on the condition precedent of confirmation of adulthood upon delivery, which is canceled if the sale is not concluded and any money paid in advance is returned to the Consumer.

3.3. It is expressly noted that the Website which hosts the e-shop is not a proposal to Consumers to conclude a contract; rather it is an invitation to Consumers to submit a proposal at their own initiative, based on Article 1.7. above, subject to availability and price check, and the contract is concluded, upon receipt of the order confirmation e-mail, with the Seller to be notified to the Consumer by Papastratos, and is subject to the above condition precedent under Article 3.2.

3.4. When the Product is ready to be delivered, we will notify you by e-mail and/or sms, which will include the necessary details for monitoring delivery of your order Should any problem occur with regard to the order or the delivery times as set forth above, you will receive relevant information by email, sms, and/or by telephone. In case of late delivery, you may either request that the delivery be made within a new time limit or you may be released from the contract by terminating it. In the event that the Product is ultimately unavailable or an error in availability or price is detected, or in the event of cancellation/termination of the contract under 3.2., the Seller shall refund without undue delay all monies paid.

3.5. Order confirmation and notification about the stages of execution of the sale until delivery of the Product or about any issue may be made by e-mail and/or by telephone, or by sms to the details you have entered in your Account.

3.6. From time to time, if such an option is available, you may pre-order Products which will be delivered after their official placement on the market. When available for sale on the e-shop, those Products bear a special label, and are accompanied by information about the cost and the estimated time of delivery thereof. In pre-orders payment is possible only by credit card and PayPal account (if it is available) via the e-shop (not by cash on receipt). With regard to all other aspects, the pre-ordering procedure is completed and carried out exactly in the same manner as any other order placement and purchase from the e-shop (unless any particular condition is applicable, as appropriate).

4. Maximum amounts of orders

4.1. Each Consumer can buy up to:

    4.1.1. five (5) Kits or Mobility Kits (i.e. a box containing the complete set of the Device with or without its Consumables, depending on the applicable offer) per order, per type/code of Product

4.2. The maximum purchase limits can be changed and there is an automated system that does not allow the addition of additional Products above the limit set each time.

4.3. Papastratos also reserves the right to refuse, at any time, any purchase or the execution of any order if there are suspicions that these terms are being violated or that a Consumer is making purchases (in the same or separate orders) that are not intended for private use or in any other case where there are suspicions of violation of the law or these terms.

5. Product Prices

5.1. The product prices indicated on the e-shop are in Euros (€), they include the value-added tax (VAT), and they are total.

5.2. In general, we reserve the right to freely set the prices of the Products, to modify them, and change and/or withdraw offers and/or the pre-ordering option at any time. Consumers will be informed of the price and/or offer, and/or pre-ordering option applicable each time from the relevant post on the e-shop (and such information will apply to future purchases, rather than already placed orders). We also reserve the right to change the commercial policy on the delivery cost and the payment methods through the e-shop and telephone orders, at any time. In any case, Consumers will always be informed about the prices and the costs before their order is sent.

5.3. Even though every effort is made to make sure that all the details, descriptions and prices displayed on this Website are accurate, errors may occur. In that case, you will be notified, as provided for in Article 3.5. above.

6. Payment arrangements

6.1. The following payment methods are available for purchase of Products through the e-shop:

    6.1.1. cash on delivery (in cash or by remote POS) of the Product (the limit allowed for payment of the price in cash is that stipulated each time by the laws)

    6.1.2. credit or debit card

    6.1.3. PayPal (without prejudice to Article 6.4 below)

6.2. It is explicitly specified that payment by credit card or PayPal only (i.e. not cash on delivery) is possible in the case of pre-order of a Product

6.3.6.3. In the event of price payment by credit card, this may be carried out by use of cards acceptable by the e-shop. If the Consumer chooses to pay by remote POS or credit card, the procedure will be carried out and concluded through an acknowledged payment service provider, offering, as stated by it, all the safety guarantees for the conduct of electronic payments. The payment data submitted by the Consumer are collected and processed solely by the associated payment service provider, who is exclusively responsible for processing them in order to complete the payment. The payment service provider will be responsible for any problem that may arise during payment by credit card. The Seller does not store and does not process the Customers’ card details. We may reject a Consumer’s order or rescind the sale at any time if it is established or speculated that there is any problem in relation to the card details. It goes without saying that the Consumer shall bear the full and exclusive liability for properly entering and completing their credit/debit card details in the payment system.

6.4. We reserve the right to amend the payment method options (e.g. disabling the option of payment via Pay Pal or by specific credit or debit cards) depending on business needs and capacities, with a view to the optimal operation of the system and proper fulfilment of the transactions. If such an amendment is implemented, the removed payment method will not be available to be selected by the Consumer in the order submission procedure.

7. Details of delivery arrangements

7.1. The Products purchased by the Consumer through the e-shop are delivered by the Sellers or their associates (courier companies).

7.2. Products may only be delivered within Greece, as sale of Products abroad is not permitted.

7.3. The Consumer will bear the transport costs, if any.

7.4. The order will be dispatched within the delivery time mentioned in article 7.6 below

7.5. The following delivery options are not available:

    7.5.1. Appointment for receipt of delivery.

    7.5.2. Delivery made to a point other than the one indicated in the delivery address you have given in your order (exceptionally, it is possible to pick up from a courier branch that we cooperate with upon request).

    7.5.3. Saturday Delivery

7.6. More specifically, the following apply (which may be amended from time to time and for future purchases by posting on the Website and/or these terms and conditions - in any case, the terms and conditions stated on the Website shall prevail):

Order consignment time Delivery time Place of delivery

By 12:00 on weekdays (excluding holidays and weekends)

On the same day only in Attica

Only for specific places of delivery (see Attachment Table)

By 16:00 on weekdays (excluding holidays and weekends)

From the next business day and within 5 business days

Throughout the Greek Territory (see Attachment Table)

After 16:00 or for an order placed during weekends or holidays

From the day after next and within 5 business days

Throughout the Greek Territory (see Attachment Table)

In more detail here.



7.7. Where days or weekdays are indicated above, they shall always mean “business days”. It should be noted that the schedule of delivery of the Products may change for reasons of Force Majeure or unforeseeable incidents beyond our influence and control. In this case, we will contact the Consumer by email or telephone or by text message in order to provide the Consumer with the relevant information. It is also noted that the above time limits do not apply to pre-ordering, but the estimated delivery time, as indicated on the e-shop, and as explicitly agreed between the Seller and the Consumer upon placement of the pre-order, shall be applicable instead.

7.8. We shall not bear any liability in the event that the person performing the delivery (Seller or third-party collaborating company) appears within the above time limits but does not manage to deliver the Product, due to erroneous delivery data, or absence of the Consumer. In that case, we are entitled to release the Products ordered and to cancel the order, refunding the amount paid within a few days.

7.9. In any case, the Consumer must appear in person to pick up the Products, and have the proper identification documents (to demonstrate that he/she is the same person as the Account User, and his/her age). Otherwise, any person responsible for the delivery or employee of the store that has been selected as pick-up point, acing as agent of the Seller, will refuse to deliver the Product, which will be returned to the Seller. The sale contract will be automatically canceled, as provided for in Article 3.2. above, since verification of the age and the identity of the Consumer, following an identity check, is a necessary condition for the delivery of the Products, without the establishment of which the sale would have never been concluded (legal transaction foundation - condition precedent). After the successful completion of the first order, for each future order, the possibility for the Products to be collected by an adult who will present himself/herself for collection at the point indicated by the Consumer as the point of delivery of the Product (the deliverer may also request to verify the identity of the receiver for identity verification purposes) is provided. We reserve the right to make any amendment to the above delivery arrangements, at any time, informing Consumers by changing these terms or through specific posts on the Website.

8. Withdrawal

8.1. The rescission right is granted only to natural persons acting in their capacity as consumers, in accordance with Law 2251/1994. Provided that the Consumer is a natural person acting (only) as a consumer, he/she may rescind this agreement without providing any explanation, without prejudice to the terms of Article 8.7.3 below.

8.2. In particular, the Consumer is required to inform us of his/her intention to rescind, within the following time limits:

  1. for Consumables and Accessories: within 14 days
  2. for Devices: within 30 days

  3. from the day that:

  • the Customer acquired the physical possession of the Products, or
  • the Customer acquired the physical possession of the last Product, in the case of a contract concerning numerous Products forming part of the same order, which are delivered separately.

To comply with the withdrawal period, contacting us or sending your declaration of exercise of your right to retract before the withdrawal period referred to in Article 8.1 above expires will suffice.

8.3. The rescission procedure is as follows:

  • The consumer contacts the Company through its contact details in one of the following ways: through the Live Chat on the www.gr.iqos.com website, via a personal message on one of the support pages: IQOS Greece (Facebook), @iqos_support_gr (Twitter), IQOS Support Greece (Viber) or by calling the Call Center about his decision to withdraw by mentioning the details related to his order as they are included in the withdrawal form
  • Then, arrangements will be made for a carrier or a third-party associate (courier) of the Seller to receive the Product returned, along with the rescission form, from the Consumer
  • The Product will be received for inspection, and the Seller will return the money corresponding to the price paid for the returned Product

**It should be noted that filling in the rescission form is highly significant for the conclusion of the rescission/return procedure: the Consumer must state the details recorded therein when contacting one of our representatives, for the conclusion of the rescission/return. Therefore, and with a view to facilitate the process, we encourage all our Customers to fill in the above form electronically or by hand, and to enclose it in/attach it to their contact with our representative, so that the order can be more easily traced and the return of the Product can be properly managed.

8.4. Notes regarding rescission:

    a) if the Consumables have been purchased in a box they can only be returned if the box has not been opened (the security seal has not been removed). Individual Consumables that have either been taken out of the box that was purchased or have been purchased from the outset as separate or as part of an offer or package, but outside the box, cannot be returned. The aforementioned restriction becomes necessary for reasons related to the fulfilment by our company of the traceability and security feature obligations arising from Articles 106A and 106B of the National Customs Code (L. 2960/2001).

    b) Accessories can be returned only if they are not damaged and have not been used (in any way other than that necessary to test the product in question).

    c) With regard to Devices, is possible to exercise the right to withdrawal even for a Device that has been used. It should be expressly noted that the said extended time limit (30 days) and the rescission terms are granted voluntarily as an additional benefit (in addition to the statutory one) as part of a special “Money Back” programme. This programme may be cancelled at any time and the withdrawal may be applied within the time limits and under the conditions laid down in the legislation.

    d) In the case of purchasing a Kit or Mobility Kit, a refund is possible only for the Device and Accessories but not for the Consumables (if they are not in a closed box as mentioned in point a) above, depending on the applicable offer)

    e) General obligations of the Consumer:

    -The Consumer shall bear the indirect cost of return of the Products, provided that the Consumer selects his/her own means of return of the Products (not the means/manner indicated to the Consumer by Papastratos, after consultation, in one of the manners listed in Article 8.3.). The cost depends on the price list of the relevant courier company selected by the Consumer.

    - With the exception of paragraph c) above, the Consumer is liable under law for any decrease in the value of the Products that results from handling the products in a manner that was not necessary to specify the nature, the characteristics and the functioning thereof. It should be noted that in order to determine the nature, characteristics and function of the Products purchased by the Consumer, he/she must handle and examine them in a way that he/she would be allowed to do in a physical store.

    - In order for a return to be accepted, the Product sent by the Consumer for collection by the Seller must be (cumulatively):

  • in the condition in which it was received,
  • if the original packaging has been opened, it must be intact, without damage or tears and must be returned with the Product,
  • complete (with all its accessories);
  • - sent back with all the documents that accompanied the product, as well as with the rescission form. In the event that the Product is not accompanied by its documents, the Product cannot be identified with a specific order.

f) A product that is personalized (e.g. a monogram has been engraved on it, the base contains a different lid from the original packaging, etc.) cannot be returned as a result of withdrawal.

8.5. Effects of rescission

If the Consumer withdraws from this contract (and if all the conditions of article 8.7. are met), the money paid by the Consumer as consideration for the specific Product he/she is returning (including delivery costs, provided that these have been borne by the Consumer without undue delay, after the Product has been returned and checked) will be refunded to him/her. You shall be liable only for any decrease in the value of the products that results from handling the products in a manner that was not necessary to specify the nature, the characteristics and the functioning thereof.

8.6. The Consumer expressly agrees that the money will be refunded by the respective Seller through a deposit to a bank account indicated by the Consumer if the payment was made by cash on delivery, otherwise to the card used for the payment (the same means of payment you used for the original transaction). The Consumer must correctly disclose his/her details and accepts that the deposit of the money to the account he/she has disclosed to us or to the card used exempts him/her from the obligation to return the money as described above. If payment has been made by PayPal, the money will be refunded either (a) to the card, when payment originates from a card, or (b) to the bank account, when payment originates from a bank account, or (c) to PayPal Balance, when payment originates from PayPal Balance (provided, of course, that it still applies as a payment method for the transaction at issue).

8.7. The above also applies in case of rescission of pre-order.

9. Guarantees - after-sale customer support services

9.1. With regard to actual defects and lack of agreed properties, the provisions on liability of the seller shall apply, in accordance with the provisions of Articles 534 et seq. of the Civil Code and Article 5 of Law 2251/1994, as amended and currently in force.

9.2. The commercial guarantees for the Products (where guarantees are provided) are provided by Papastratos. It should be noted that Sellers do not grant any commercial guarantee or any extension thereof (however, the statutory guarantee derived from the sale shall apply, as it is provided for by the Civil Code and is each time applicable). With regard to the guarantee, the terms indicated in the Product packaging and the provisions of Article 6.1 of the Terms of Use of iqos.gr shall apply.

9.3. If you wish to contact us for any issue concerning the guarantees of your Product, you can call our Call Centre daily from 09:00 to 23:00.

9.4. For your after-sales support services provided by Papastratos, you can contact the Company's in one of the following ways: via Live Chat at www.gr.iqos.com, via a personal message on one of the support pages: IQOS Greece (Facebook), @iqos_support_gr (Twitter), IQOS Support Greece (Viber) or by calling the Call Center.

10. Responsibility for the operation of the Website

10.1. 10.1. The whole content of the Website is provided “as is”, without any requirements or other guarantees of its accuracy or suitability for the use or the purpose for which the products sold are intended. Thus, access to the Website exclusively lies with the responsibility of each Consumer. In addition to that expressly mentioned in these terms, to the maximum extent allowed by the Law, the Company shall not bear any obligations and guarantees which it has not expressly undertaken. In any case, the provisions of the Terms of Use of iqos.gr shall apply, to issues involving accessing and using the Website, keeping the Account at iqos.gr properly, and to issues pertaining to the limitation of the liability of Papastratos.

10.2. Consumers must promptly notify Papastratos by calling the Call Centre, if they have reasons to believe that:

  • their secret password may have become know to a third party, or
  • there is a risk that their password may be used without their permission.

Consumers shall bear full and exclusive liability for any action (act or omission) carried out through their account. The Company and the Sellers disavow any liability for damages arising from the use of a User’s account on the grounds of unauthorised access or use of the User’s account, provided that the Consumer has not previously duly notified them.

10.3. We exert our best efforts, in the context of the technical inspections we regularly carry out, so that the services, content and transactions are executed seamlessly, and without any interruption, and that the highest standard of security is maintained. However, Papastratos shall not be liable in case that, for any reason, including negligence, the operation of the e-shop is suspended, or access to it becomes difficult and/or impossible, and/or if, despite the security measures implemented, viruses or any other harmful software are detected and transmitted to the terminals of users/guests, or if unauthorised third parties interfere in any manner with the content and the operation of the e-shop, rendering its use difficult, or causing problems to its proper operation, or intercept details concerning the users’ personal data. Moreover, Papastratos shall not be liable in case of suspension of the access to the e-shop for reasons beyond our control, as well as for reasons due to a technical or other weakness of the network, or to reasons of force majeure, or to unforeseeable circumstances.

10.4. We exert our best efforts to ensure that the photographs of the Products displayed on the e-shop, as well as any videos posted on the e-shop, depict the actual state of the Products, to the extent possible. However, in any event, the Consumer accepts that the Products displayed in the photographs and the videos may deviate from the actual state, form, size, colour, and overall image of the Products sold by the e-shop. We shall not bear any liability in the event of any deviation of the photographic depiction of the product or the depiction thereof in a video from its actual image.

10.5. For any other damage sustained by the Consumer as a result of using or navigating on the e-shop, we disavow any liability for any consequential, potential and indirect damages, or for loss of profit, including profits not made, loss of data, suspension of activity, damage to fame or reputation, or for the cost of purchase of substitute products, or any other damage, of whatever nature, that could arise from the use of the Website and its features, or the content thereof, or from the inability to use the Website, the inability to participate in any tendering procedure or offer, and/or the inability to purchase or send any item or product relating to the Website and its features, regardless of whether such damages could have been foreseen, or whether they arise in the framework of the contract, the conduct of the purchase, out of the products appearing on the e-shop, due to tort or by negligence, under applicable laws, or in another manner. In any case, however, and provided that any damage is due to the proven fault of the Seller, the latter shall bear liability only for the coverage of any actual damage caused to the damaged party that demonstrably originates from and relates directly to the event giving rise to the damage, and the wrongful act or omission. In the event of negligence, any damage shall be limited to the amount of EUR one thousand (€1,000). Thus, all the liability limitations contained in these Terms of Use, which are acknowledged and accepted by the Consumer in their entirety as being valid and consistent with good faith and transactional practices, apply.

10.6. The Consumer uses the e-shop and acquires access to the content posted, at their own initiative and exclusive responsibility, having full knowledge of the fact that the Website contains tobacco products, new tobacco products and/or e-cigarettes and accessories thereof. The Consumer agrees to compensate, defend and release the Company, the Seller, the companies of the Philip Morris International Group, the managers, officers, employees, consultants, representatives and associates thereof of any and all claims of third parties, liability, damages and/or costs arising as a result or on the occasion of any wrongful illegal or anti-contractual use of the Website from the User, or as a result of the wrongful breach on the User’s part of any of the Terms of Use. In any case, the Consumer must promptly notify the Company via the Call Centre at telephone lines 800 111 4767 (free of charge from a landline phone) / 210 4193888 (charge depending on the telecommunications provider)| operating hours of the IQOS call centres Daily 09:00 – 23:00, or by live chat, Viber, or messenger, or at contact.gr@iqos.com, or by filling in the relevant form on our Website, if he/she has become aware or has reasonable suspicion or indications that the Website has been used in an illegal or anti-contractual manner by him/her (even due to his/her negligence) or by any other person, so that the Company will be able to take the necessary measures to limit any damage.

11. Licence to access and use the e-shop - Intellectual Property, Content and Trademarks

11.1. The e-shop is addressed to Consumers that cumulatively meet the conditions set forth in Article 1.4. above. The Consumer is granted a non-exclusive license of access and personal use of the e-shop, as specified in the Terms and Conditions. In the event of unauthorised use or breach of any term hereof, the license granted by the Company shall cease to be effective.

11.2. The intellectual property rights on the software and on the content of the e-shop are either held by Papastratos, or companies of the Philip Morris Group, or the lawful beneficiaries thereof, and are protected by the applicable laws on intellectual property rights. The Consumer does not hold any licence or consent to use, in any manner, the trademarks displayed on the e-shop, or the trademarks owned by third-party legal entities. Papastratos reserves exclusive rights over the domain name ‘iqos.gr’. Moreover, all the trade names displayed on the e-shop are duly subject to legal protection.

12. Final provisions

12.1. Papastratos reserves the right to select, at its sole discretion, the Products it will make available for sale in its Remote Sales Channels, and to amend, renew, and/or withdraw them at any time, without incurring any liability, and without any prior notification to consumers (each change will be made before conclusion of the sale contract with a specific consumer, and will concern future orders).

12.2. The Consumer must be each time informed about the Terms and Conditions concerning purchases through the Remote Sales Channels of Papastratos before concluding the purchase, as they may be amended from time to time by a mere post on the Internet (with effect for future purchases). The Company reserves the right (indicatively):

    a. to change, at any time, all or part of the Terms (in each case, the parties are bound by the terms as they are in force at the time of the sale);

    b. to renew or upgrade part or the whole of the Website content, the interface, the structure, or the configuration of the e-shop, as well as its technical specifications;

    c. to limit access to the whole e-shop or a part thereof or to the Remote Sales Channels in general;

    d. to cancel, suspend permanently or temporarily, or terminate the operation thereof;

    e. to modify the Products offered for sale, to permanently or temporarily cease, or to cancel the sale of Products;

    f. to change the manner of operation of the e-shop, and the charges;

    g. to post information for a specific period of time and/or until exhaustion of the stock, to make ordinary or extraordinary discounts, etc.

12.3. Should any term of the contract be judged as abusive or be cancelled, this shall not affect the remaining terms of the contract, which will continue to apply and to bind the parties. When a single term or any part thereof may be treated individually, in order for the remainder to be rendered valid, that term shall be construed accordingly. Otherwise, the parties agree that the term will be repaired and it will be construed in a manner that approaches the original meaning to the greatest extent, in accordance with law.

12.4. These terms have been drawn up and are construed in accordance with the laws of Greece. Upon accepting these Terms and Conditions, you understand that you are subject to the exclusive jurisdiction of the courts of Athens, Greece.

12.5. Any delay by the parties in exercising some or all of the rights stemming from these Terms shall not result in the weakening or waiver of such rights, which may be exercised at any time, at the discretion of their holders.

12.6. Alternative dispute resolution: According to Directive 2013/11/EU, which was incorporated in Greek legislation by Joint Ministerial Decision 70330/2015, there is provision for the option of online dispute resolution for consumer disputes, under the process of Alternative Dispute Resolution (ADR), throughout the European Union. Consumers acting in the capacity of consumer and having any problem with a purchase made from the e-shop may initiate the ADR process via the single EU-wide platform for online dispute resolution (ODR platform), which is available at https://webgate.ec.europa.eu/odr/main/index.cfm?event=main.home.chooseLanguage, which allows consumers and suppliers to submit any disputes that may arise from online purchases to an online dispute resolution procedure. The certified Alternative Dispute Resolution (ADR) Body is: the European Consumer Centre of Greece (ECC GREECE) – Consumer Ombudsman, 144 Alexandras Ave, 11 471, Athens, +30 2106460284 +30 2106460784, info@eccgreece.gr and http://www.synigoroskatanaloti.gr/. It should be noted that a necessary condition for consumers to have recourse to the Alternative Dispute Resolution process is that they have previously notified their problem to the email contact.gr@iqos.com, seeking a solution. According to law, the ADR process is not binding upon the parties, which may depart from it at any time. The consumer may contact the above ADR body, in order to seek guidance throughout the process of submission and processing of their complaint. For more information regarding alternative dispute resolution, you may visit the website http://www.synigoroskatanaloti.gr/stk_odr.html.




Personal Data Protection and Privacy Policy for sales of products via e-shop iqos.gr and/or via telephone orders

1. General Information

1.1. Papastratos is fully and exclusively responsible for determining the method of operation and content of the Remote Sales Channels, as well as the terms and procedure for the placement of consumers' orders, the execution thereof and the delivery Products. The Products are sold through the Remote Sales Channels either by Papastratos or by third-party associates (hereinafter referred to as the “Sellers”). Those associates contract with the final consumer in their name, but on behalf of Papastratos, as agents-indirect representatives thereof. Retail sale from Sellers to final consumers is governed by the Terms and Conditions for the sale of products via the iqos.gr e-shop and/or via telephone orders (hereinafter referred to as the “Terms of Sale”),based on the terms and procedures designated by Papastratos.

1.2. In that context, we prioritise respect for your privacy and for protection of your personal data. We take appropriate measures, in accordance with the applicable laws on data protection. We have established this Data Protection and Privacy Policy (hereinafter referred to as “Privacy Policy” or “Policy”), for your information about the processing of your personal data while you make purchases of Products through the Remote Sales Channels, on your initiative as a Consumer. This Policy is supplementary (to the extent otherwise provided herein, this Policy takes precedence as the more specific information document):

    i)of the PMI Privacy Policy and should be read in conjunction with it,

    ii) the Terms and Conditions of sale of products through the e-shop iqos.gr and/or through telephone orders (hereinafter referred to as "Terms of Sale"),

which form an integral part hereof, and govern purchases made via the e-shop and/or by telephone in a unified and cumulative manner.

Please note that other programmes or actions of Papastratos are governed by different Privacy Policies, which are duly indicated to you each time.

1.3. You must accept these terms before you make your purchases through the Remote Sales Channels. We encourage you to read this Policy from time to time to keep up to date with any changes we make.

1.4. Identity and details of Papastratos as data controller: Where Papastratos is the controller of the processing of your personal data in accordance with the distinctions of articles 3 and 5 below, the data controller is a limited liability company under the name "PAPASTRATOS SOLE PROPRIETOR SOCIETE ANONYME SIGARETTE COMPANY" and the distinctive title "PAPASTRATOS SOLE PROPRIETOR S.A.", with its registered office at Aspropyrgos, Imeros Topos, Kororemi location, GEMI registration no. 227601000, VAT no. 094011481, Tax Office of Athens, telephone no. 210 4193000, fax no. 210 4112303, e-mail address contact.gr@iqos.com.

1.5. Communication regarding personal data protection: For any issue concerning this Policy and the processing of the Personal Data of Consumers by Papastratos as part of the purchases through Remote Sales Channels, based on the provisions of Articles 3 and 5 below, the Consumer may contact us in one of the following manners:

    a) by telephone service at 8001114767 (free of charge from a landline phone) or at 210 4193888 (charge depending on the telecommunications provider) daily from 09:00 to 23:00;

    b) by e-mail to contact.gr@iqos.com;

    c) by mail at the postal address: PAPASTRATOS SINGLE MEMBER S.A. Headquarters, Imeros Topos, Kororemi Site, Aspropyrgos, Attn. Legal Department.

For the processing carried out by the respective Seller from whom the Consumer purchases the Product in accordance with the Terms of Sale, whose details appear on the receipt delivered to him/her upon delivery of the Product, you can contact the details indicated on the sales document or on the list available here.

2. Who does this Policy concern?

This Policy is addressed to consumers, who:

    i) are natural persons, over 18 years of age, and have full legal capacity (such age must already have been completed upon access to iqos.gr and performance of any action relating to the Website), and whose adult status is confirmed by us upon delivery of the Product;

    ii) are smokers and/or users of other tobacco products, new tobacco products, e-cigarettes or nicotine products in general, or related products, as determined by the relevant laws at any given time

    iii) reside or are staying in Greece (hereinafter referred to as the “Consumers’’)

and wish to purchase the Products through the Remote Sales Channels (either through the e-shop or by telephone) on your own initiative, after you have declared your age and have created an Account based on the Terms and Conditions of iqos.gr and the Terms of Sale. Users who have not reached legal age (18) are prohibited from carrying out any action on the Website or the e-shop, or making telephone orders.

3. Who are the Data Controllers and for which processes?

3.1. The processing of your personal data for the purchase of Products through the Remote Sales Channels requires cooperation between more companies, as regulated by the individual contracts of the parties, and the role thereof is explained hereunder, in accordance with the legal requirements.

3.2. Papastratos is the Data Controller for all the processing functions and actions performed by the Remote Sales Channels both before and after conclusion of the order. Each Seller acts as a Data Processor for the processing of consumers’ data, as part of executing the sale cycle, based on explicit orders and procedures designated by Papastratos. In particular, the Seller takes all the necessary actions on behalf of Papastratos and based on the orders of Papastratos as an agent/indirect representative thereof, from the moment when the order is forwarded to the Seller by Papastratos through the Remote Sales Channels, until final delivery of the Products, as well as with regard to fulfillment of the obligations pertaining to customer service, management of complaints and requests, verification of identity during delivery, and registration of consumers or their devices in databases or programmes of Papastratos.

3.3. Each Seller is an independent Data Controller where processing is necessary for the Seller’s statutory obligations as an agent/indirect representative (including, but not limited to, tax obligations), as well as for payment by the consumer (carried out in collaboration with a third-party provider with whom they transact independently). In particular, with regard to the processing made by each Seller as an independent Data Controller, such Seller bears full and exclusive liability for the legality and compliance thereof with the current laws on data protection. You can be informed about the Privacy Policy of each Seller that carries out the sale on behalf of Papastratos on the website of each Seller.

4. What personal data categories do we collect from you and how?

4.1. Your Personal Data include any information that allows, either on its own or in combination with other information, your single identification, under the provisions of the Regulation, the applicable Greek laws, and the decisions of the Data Protection Authority (DPA), as well as the directives and decisions of the competent European bodies.

4.2. We collect for you the following categories of data concerning you from the following sources:

    Directly from you, when you submit such data either to us or to our processing partners:


    Τρόπος Δεδομένα
    when placing an order via the e-shop and/or the call centre until delivery thereof, including the exercise of the right to rescind the contract

    Identity details

    (first name, surname)

    Legal Age details

    (date of birth, legal age status)

    Communication details

    (e-mail, phone number)

    Necessary data for the exercise of the right of withdrawal based on our business model

    (date of exercise of the right of withdrawal, order number, etc.)

    Your participation data for other Papastratos Programmes

    (such as which tier you belong to in the IQOS Club, whether you are entitled to a voucher, etc.)

    during the identification/identity check and confirmation of your adult status (through the age gate of the Website and through the proper identification documents/documents proving adult status presented at the delivery of the Products) and the creation of an account

    Identity details

    (first name, surname)

    Communication details

    (e-mail)

    Legal Age details

    (date of birth, legal age status)

    when you contact us for issues of guarantees and/or after sales service

    Identity details

    (first name, surname)

    Communication details

    (e-mail, phone number)

    Purchase details

    (Type/product purchased, time of purchase, time and place of delivery, purchase value, device barcode and other data relating to the order)

    Background in relation to warranties/ after sales

    (time and actions related to the provision of guarantees/ after sales)



    Through automated means:

    Τρόπος Δεδομένα
    from your navigation on the e-shop

    Technical information

    (Internet Protocol (IP) address, operating system)

    from your access to your account

    log files for logging into the iqos.gr account

    (date , duration)



4.3. As a Data Controller, we have the obligation to keep your data accurate and updated, and, we therefore encourage you to contact us using the contact means listed above if your data have changed or if you have provided inaccurate data to us by mistake.

4.4. Where the provision of data is necessary for the conclusion of the contract, failure to provide such data shall mean that the contract cannot be concluded.

5. Purpose and Legal Basis of Processing

5.1. The table below shows the purposes of processing the Consumer's personal data, the categories of personal data collected either by Papastratos or through partners and processed, and the legal basis for processing, in cases where Papastratos processes the Consumer's personal data as a Data Controller, i.e:


No PURPOSE FOR PROCESSING LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA RELATING TO THE PURPOSE OF THE PROCESSING

1.

Making your purchases and fulfilling your order through Remote Sales Channels (from the submission of the order until its delivery, including the exercise of the right of withdrawal) and/or in order to provide you with any discounts or redemption of points/coupons that you are entitled to as a member of Papastratos programmes

execution of a contract

We process your personal data necessary for the conclusion and execution of the contract for the purchase and sale of our Products through the Remote Channels and the provision to you of any discounts or other offers to which you may be entitled.


2.

Confirmation of legal age, identification check, and creation of an account

compliance with a legal obligation

Collection and processing of your personal data is necessary in order for us to check your legal age identity, and verify that you meet the purchase conclusion requirements, therefore fulfilling our legal obligations regarding prevention of sale to individuals below the legal age in view of the nature of our products, and in order to demonstrate compliance with the applicable legislation, ethics and policy of Papastratos with regard to tobacco or nicotine products.


3.

Provision of customer service (as part of the provision of guarantees and Customer Care and After Sales Services),management of complaints and requests with regard to the Product you purchased from the Remote Sales Channels, and contact for issues pertaining to guarantees

legal obligation or execution of a contract per case of after sales service below

As part of our business model, following a request submitted by you, we process your personal data and we communicate with you by the contact means and at the contact details you will indicate to us in order to fulfil the statutory or commercial guarantee, as well as the obligations to provide after sales services to consumers, after they have purchased our Products


4.

Safety and proper operation of the Remote Sales Channels

The legal interest of Papastratosfor safety and proper operation of the e-shop, the call centre, and your account, which, in the case at issue, is fairly balanced against your privacy and your rights.



5.1.1. If we need to exercise or defend our legal claims, we process your personal data, relying on our legal interest, which has been fairly balanced against your privacy.

5.1.2. Moreover, we process your personal data as part of our compliance with our legal obligations when documents, applications, orders, court documents etc. are notified to us.

5.1.3. It should be noted that the data you enter in the website of the payment company-credit institution cooperating with the e-shop are not collected and are not processed by either Papastratos or by the Seller, but are collected and processed by the said payment company-credit institution.

5.1.4. Where the legal basis for the processing of your data involves the legal interest of Papastratos, you can object to the processing by contacting Papastratos at contact.gr@iqos.com.

6. Retention time of personal data

We will retain your personal data for as long as it is necessary for the fulfillment of the processing purposes for which they were collected and for as long as you continue interacting with us (e.g. for the execution of your purchases, for tax purposes, etc.). For more information about issues concerning the time of retention of your data, please refer to the PMI Privacy Policy.

7. What are your rights? How can you exercise them?

7.1. The current laws on the protection of your personal data enable you to exercise your rights listed below regarding the protection of your personal data:

  • Access
  • Rectification
  • Erasure
  • Restriction
  • Portability
  • Right to Object
  • Right to human intervention
  • Withdrawal of consent

You can find more information about your rights in the PMI Privacy Policy , and you can exercise your rights by contacting………………………

7.2. For the purposes for which the relevant Seller has been identified above as aindependent Controller, you may exercise your above rights by submitting your request to the contact details of the relevant Seller, which are indicated on the Product document which you purchased or in the list available here and/or to Papastratos (who will forward the request) and respectively to Papastratos for the processing carried out by itself as Data Controller in the contact details mentioned in Article 1. 4 above.

7.3. Moreover, you have the right to submit your grievances or your complaint to the local supervisory authority in relation to the processing of your personal data. In Greece the supervisory authority for data protection is the Data Protection Authority (DPA) – www.dpa.gr

7.4. We also support Alternative Dispute Resolution - Mediation as a more lenient means of resolution of any disputes between us.

7.5. While exercising your rights, you need to take into account the following considerations:

  • Identification: It is necessary that we identify you in order to respond to your requests to exercise your rights, and we therefore reserve the right to request some proof of your identify.
  • Response time We will respond to valid and accurate requests within a period of one (1) month from receipt thereof, unless the request is particularly complex, or you have submitted multiple requests. If we need more time to respond to your request, due to the foregoing causes, we will notify this to you within one month at your contact details, but the response time will not be longer than three months.
  • -Specific requests: 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. We reserve our right to deny invalid, excessive, abusive, or illegal requests, under the law.
  • Cost: We will not charge you with any cost for the exercise of your rights in relation to your personal data, unless, pursuant to the law, your request for access to information is invalid or excessive, in which case we have the right to charge a reasonable fee under the specific circumstances. In any case, we will inform you of any charges before we finish processing your request.

8. Recipients of your data

8.1. As part of the operation of remote sales (via the e-shop and/or via telephone orders), in order for you to purchase the tobacco products sold through the Remote Sales Channels, we can forward your personal data to third-party companies with which we cooperate, in order to execute your purchases (e.g. companies acting as agents-indirect representatives of Papastratos, courier companies, companies offering data management and hosting services, consulting companies (e.g. business consulting companies etc.), companies related to the safety and operation of the Product, companies providing technical support and operation of the Remote Sales Channels, companies providing call centre services, electronic platforms for contacting you, advertising companies, etc.), and as part of our business operation (e.g. accountants, lawyers).

8.2. All the cooperating companies that support the systems and the operation of Papastratos and sales through the Remote Sales Channels acquire access only to your data that are absolutely necessary for the service they offer to us. They are bound by a contract to keep your data confidential and to adopt all the technical and organisational measures for safe processing, and not to use your information in any manner other than for the purpose assisting us to provide you with the products we have agreed.

8.3. Should we receive a request from a competent Administrative Authority, a Public Prosecutor, a Court or another Authority, we may need to forward those data to such Authorities (with or without prior notification to you) based on the relevant provisions of the law. Moreover, in the event of a legal order, a service mandate, or an official preliminary examination, we have the right to promptly disclose the relevant evidence to the respective authority.

8.4. The majority of your data recipients are within the EEA. Article 9 below shall apply to transfers of personal data out of the EEA.

9. Data Transfers out of the EEA

As a rule, we retain your personal data within the European Economic Area (EEA). If data are to be transferred to third countries out of the European Economic Area for which there is no adequacy decision of the European Commission, or to International Organisations, all the appropriate guarantees will be received (pursuant to Articles 46, 47, 49 of the GDPR depending on the specific case) and additional technical and organisational measures, provided for in the current laws on personal data protection and on the decisions and directives of competent European bodies regarding transfers to third countries, will be adopted.

10. Data security

We take all necessary technical and organizational security measures in order to protect and maintain the security of your personal data in accordance with the specific provisions of the PMI Privacy Policy. The data you submit to Papastratos are handled exclusively by its specifically authorised staff, under its direction, 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, Papastratos selects persons or associates with relevant professional qualifications, offering adequate guarantees in terms of technical knowledge and personal integrity with regard to keeping confidentiality.

On your part, you must not disclose your credentials/password of your Account and, in particular, you must prevent unauthorised access to your Account by third persons. In any case, we identify you as a Consumer and verify that you are an adult at the delivery of the Products.

11. Modifications to this Policy

We reserve the right to modify this Policy, for instance, in order to comply with new requirements imposed by applicable laws and directives, or in case we revise our procedures or practices. We will notify you of any revision to our Privacy Policy, by publishing it on the Website.


PMI CONSUMER PRIVACY NOTICE

We take privacy seriously. This notice tells you who we are, what information about you we collect, and what we do with it. Click on “find out more” in each section for further information.

Please also read our terms of use relating to the service you are interested in. They provide more information about the way we do business, and any restrictions on eligibility that may apply.

Who are we?

We are a member of Philip Morris International. Our details (name, address, etc.) will have been given to you separately at the time of (or to confirm) the collection of information about you, for example, in a notice on an app or a website, or in an e-mail, containing a link to this notice.

Find out more…

  • PMI: Philip Morris International, a leading international tobacco group. It is made up of a number of companies or “affiliates”. 
  • PMI affiliates: Each member of the Philip Morris International group of companies is a “PMI affiliate”. “We” (or “us” or “our”) refers to the PMI affiliate that first collected information about you. 
  • PMI product: means a product of ours or of another PMI affiliate. 

How do we collect information about you?

We may collect information about you in various ways.

  • You may provide us with information directly (e.g. filling in a form, or making a call to us). 
  • We may collect information automatically (e.g. when you use a PMI app or website). 
  • We may acquire information from third parties (e.g. publicly-available information on social media platforms such as Facebook and Twitter). 

In this notice, we refer to all the methods by which you are in contact with us as “PMI touchpoints”. PMI touchpoints include both physical (for example, retail outlets and events), and digital (for example, apps and websites).

Find out more…

We may collect information that you provide directly. Typically this will happen when you:

  • sign up to be a member of our databases (this could be, for example, in person, via app, or online); 
  • purchase PMI products or services at a retail outlet; 
  • download, or use, a digital touchpoint (e.g. an app or a website); 
  • contact us through a touchpoint, or by e-mail, social media or telephone; 
  • register a device with us; 
  • subscribe to a PMI panel portal; 
  • register to receive PMI press releases, e-mail alerts, or marketing communications; 
  • participate in PMI surveys or (where permitted by law) PMI competitions or promotions; or 
  • attend an event that a PMI affiliate has organised. 

We may collect information about you automatically. Typically this will happen when you:

  • visit an outlet that sells PMI products (e.g. by collecting your data at check-out, or through sensors at the outlet that connect with mobile technology); 
  • attend an event that a PMI affiliate has organised (e.g. through purchases at the event or through sensors at the event that connect with mobile technology); 
  • communicate with us (for example, through a touchpoint; or social media platforms); 
  • use PMI touchpoints (e.g. through tracking mechanisms in an app or a website); or 
  • make public posts on social media platforms that we follow (for example, so that we can understand public opinion, or respond to requests concerning PMI products). 

We may also collect information about you automatically through the use of cookies and similar tracking technologies on digital PMI touchpoints. The specific cookies and technologies used will depend on the PMI touchpoint in question. To learn about the cookies (including Google analytics cookies) and similar technologies used on a touchpoint, including how you can accept or refuse cookies, please see the cookie notice made available on or through that touchpoint.

Where permitted by law, we may acquire 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 Twitter), and marketing lists acquired from third party marketing agencies.

We may also collect information in other contexts made apparent to you at the time.

What information about you do we collect?

We may collect various types of information about you:

  • information necessary to fulfil your orders 
  • information necessary to provide warranty services 
  • information you give us in forms or surveys 
  • information about your visits to our outlets and events 
  • information you give us in calls you make to call centres 
  • information about your preferences and interests 
  • information necessary to verify your age 

find out more…

Information that we collect from you directly will be apparent from the context in which you provide it. For example:

  • if you order a product from us through a touchpoint, you provide your name, contact, billing details, and the products you have chosen so that we can fulfil your order; 
  • you may provide information on your product preferences and interests so that we can offer you products and services that will interest you; 
  • if you make an appointment to see us (or someone supporting our products or services), we may collect your name and contact details; 
  • we may collect information that enables us to verify your age, for example a copy of an identity document or your facial image. 

Information that we collect automatically will generally concern:

  • details of your visit or call (such as time and duration); 
  • in a sales outlet or at an event (including areas in the immediate vicinity), how frequently you visit, which areas you visit and for how long, and which purchases you make; 
  • your use of digital PMI touchpoints (such as the pages you visit, the page from which you came, and the page to which you went when you left, search terms entered, or links clicked within the touchpoint); and 
  • your device (such as your IP address or unique device identifier, location data, details of any cookies that we may have stored on your device). 

Information that we collect from third parties will generally consist of publicly-available profile information (such as your preferences and interests), for example from public social media posts.

For what purposes do we use information about you, and on what legal basis?

In this section, we describe the purposes for which we use personal information. However, this is a global notice, and where the laws of a country restrict or prohibit certain activities described in this notice, we will not use information about you for those purposes in that country.

Subject to the above, we use information about you for the following purposes:

  • To comply with regulatory obligations, such as verifying your age and status as a user of our products 
  • To sell our products to you, including fulfilling your orders, processing your payments 
  • To provide sales-related services to you, including dealing with your inquiries and requests, and providing warranty services 
  • To market our products (where permitted by law), including administering loyalty programs, product improvement, market research, developing marketing strategies, administering marketing campaigns, and customizing your experiences at outlets that sell PMI products and at events 
  • For us or our business partners to inform you of potential opportunities to get involved in marketing or promoting PMI products 
  • To support all the above, including administering your accounts, enabling you to use PMI touchpoints, corresponding with you, managing your appointments with us or with someone supporting our products or services (for example, regarding a new product, or after-sales service), customizing your experiences of PMI touchpoints, and administration and troubleshooting 
  • For business analytics and improvements, including improving PMI products, outlets and events, and the information that we (or our affiliates) provide to our customers 
  • For other purposes that we notify you of, or will be clear from the context, at the point information about you is first collected 

The legal basis for our use of information about you is one of the following (which we explain in more detail in the “find out more” section):

  • compliance with a legal obligation to which we are subject; 
  • the performance of a contract to which you are a party; 
  • a legitimate business interest that is not overridden by interests you have to protect the information; 
  • where none of the above applies, your consent (which we will ask for before we process the information). 

find out more…

The purposes for which we use information about you, with corresponding methods of collection and legal basis for use, are:

Purpose Method of collection and legal basis for Processing

Comply with regulatory obligations:
  • verify your age and status as a user of our products

This information is generally provided to us by you directly.We use it because it is necessary for us to comply with a legal obligation to sell products only to adults, or, in countries where there is no such legal obligation, because we have a legitimate business interest to sell our products only to adults that is not overridden by your interests, rights and freedoms to protect information about you.

Sell our products:
  • fulfil your orders (including sending receipts)
  • process your payments
  • provide warranty services

This information is generally provided to us by you directly (typically, name, address, e-mail address, payment information).We use it to discharge our contractual obligations to you as a buyer of our products.

Provide sales-related services:
  • deal with your inquiries and requests
  • correspond with you
  • general administration and troubleshooting
  • administer loyalty programs

This information is generally provided to us by you directly.We use it because we have a legitimate business interest in providing sales-related services to our customers that is not overridden by your interests, rights and freedoms to protect information about you.

Market our products (where permitted by law):
  • understand your preferences (such as what products or events may interest you or may be better tailored to your needs) and, where permitted by law, market to you personally
  • administer loyalty programsadminister loyalty programs
  • invite you to participate in, and administer, surveys or market research campaigns
  • for market research
  • develop marketing strategies
  • administer marketing campaigns
  • customize your experience of PMI touchpoints (for example, to personalize your visit, such as with greetings or suggestions that might interest you)

This will typically be a combination of information that you provide to us (for example, your name and contact and social media details); information that we collect automatically (for example, using technology to monitor use of PMI touchpoints) and (where permitted by law) information that we acquire from third parties (such as public social media posts).We use it on the grounds that we have a legitimate business interest to market our products, to operate PMI touchpoints, and to customize your experiences, in these ways that is not overridden by your interests, rights and freedoms to protect information about you.

Market our products (where permitted by law):
  • provide you with information about, and to manage, PMI affiliates, their promotions, products and services, outlets, events and the regulation of our products; and to develop and improve tools to pursue these purposes

This will typically be a combination of information that you provide to us (for example, your name and contact details, your social media handles); information that we collect automatically (for example, using cookies and similar technologies) and (where permitted by law) information that we acquire from third parties (such as public social media posts).We use it on the grounds that we have a legitimate business interest to market these things that is not overridden by your interests, rights and freedoms to protect information about you.In certain countries, where required by law, we will send you these materials in electronic format only with your consent.

Support for all the above purposes:
  • administering your accounts
  • enabling you to use PMI touchpoints (for example, allowing you to remain logged in to sections of a touchpoint that are reserved for authorized users only, administering your language preference, associating your shopping cart with you)
  • corresponding with you
  • managing your appointments with us or with someone supporting our products or services (for example, regarding a new product, or after-sales service)
  • enhancing your experiences
  • administration and troubleshooting

This will typically be a combination of information that you provide to us (typically, name, password (or equivalent)) and information that we collect automatically (for example, information about your device, and cookies and similar tracking technologies).We use it on the grounds that correspond to the purpose for using the information that we are supporting. For example, where we administer your account to support a purchase or to provide after-sales service, we use the information to discharge our contractual obligations to you as a buyer of our products; where we administer your account to show you our products, we are supporting marketing and so we use it on the grounds that we have a legitimate business interest to market our products that is not overridden by your interests, rights and freedoms to protect information about you, and so on.

Business analytics and improvements:
  • allowing us or our business partners to inform you of potential opportunities to get involved in promoting PMI products
  • for business analytics and improvements (including for PMI products, outlets that sell PMI products, events, digital PMI touchpoints and the information that we (or our affiliates) provide to our customers)

This will typically be a combination of information that you provide to us; information that we collect automatically; and (where permitted by law) information that we acquire from third parties.We use it on the grounds that we have a legitimate business interest to analyze and to improve our business performance, our products, PMI touchpoints, outlets and events, and to invite others to get involved in promoting PMI products, that is not overridden by interests, rights and freedoms to protect information about you.

Where we do not base our use of information about you on one of the above legal bases, we will ask for your consent before we process the information (these cases will be clear from the context).

In some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.

Who do we share your information with, and for what purposes?

We may share information about you with:

  • PMI affiliates; 
  • third parties who provide PMI affiliates or you with products or services; 
  • PMI affiliates’ carefully selected business partners and advertisers (in areas connected with our products, or consistent with their style and image) so that they can contact you with offers that they think may interest you, in accordance with your preferences; and 
  • other third parties, where required or permitted by law. 

find out more…

Sharing data with other PMI affiliates

  • Information about you will be shared with Philip Morris International Management SA (based in Lausanne, Switzerland), which is the place of central administration of personal data processing for PMI affiliates. Philip Morris International Management SA processes the information about you for all the purposes described in this notice. 
  • Information about you may be shared with the PMI affiliate that is responsible for the country in which you live (if it wasn’t the PMI affiliate that first collected the information) for all the purposes described in this notice. 
  • Information about you may be shared with any other PMI affiliate that you contact (for example, if you travel and you want to know where to buy PMI products in a new country, or where to find service or support for PMI products) in order to enhance our service to you. 

Details of PMI affiliates and the countries in which they are established are available here.

Sharing data with Third Parties

  • We may share information about you with third parties who provide PMI affiliates or you with products or services (such as advisers, payment service providers, delivery providers, retailers, product coaches, information services providers and age verification providers). 
  • We may share information about you with PMI affiliates’ carefully-selected third party business partners and advertisers (in line with the kind of thing you might associate with our products, for example because they have similar or complementary image, style, or functionality) so that they can contact you with products, services and promotions that they think may interest you, in accordance with your preferences. 
  • We may share information about you with other third parties, where required or permitted by law, for example: regulatory authorities; government departments; in response to a request from law enforcement authorities or other government officials; when we consider disclosure to be necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; and in the context of organisational restructuring. 

Where might information about you be sent?

As with any multinational organisation, PMI affiliates transfer information globally. Accordingly, information about you may be transferred globally (if your information is collected within the European Economic Area, this means that your information may be transferred outside it).

find out more…

When using information as described in this notice, information about you may be transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards.

For example, PMI affiliates within the European Economic Area (“EEA”) may transfer personal information to PMI affiliates outside the EEA. In all cases, the transfer will be:

  • on the basis of a European Commission adequacy decision
  • subject to appropriate safeguards, for example the EU Model Contracts; or 
  • necessary to discharge obligations under a contract between you and us (or the implementation of pre-contractual measures taken at your request) or for the conclusion or performance of a contract concluded in your interest between us and a third party, such as in relation to travel arrangements. 

In all cases, appropriate security measures for the protection of personal information will be applied in those countries or territories, in accordance with applicable data protection laws.

How do we protect information about you?

We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy and security requirements.

How long will information about you be kept?

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes.

find out more…

Typically, we retain data based on the criteria described in the table below:

Type Explanation/typical retention criteria

  • marketing to you (including marketing communications) (if you use digital touchpoints and are contactable)

Most of the information in your marketing profile is kept for the duration of our marketing relationship with you; for example, while you continue to use digital touchpoints, or respond to our communications. However, some elements of your marketing profile, such as records of how we interact with you, naturally go out of date after a period of time, so we delete them automatically after defined periods (typically 3 years) as appropriate for the purpose for which we collected them.

  • marketing to you (including marketing communications) (if you are no longer in contact with us)

This scenario is the same as the above, but if we don’t have any contact with you for a long period (typically 2 years), we will stop sending you marketing communications and delete your history of responses to them. This will happen, for example, if you never click through to an invitation to an event, log on to a digital touchpoint, or contact customer care, during that time. The reason is that in these circumstances, we assume you would prefer not to receive the communications.

  • marketing to you (including marketing communications) (if you are not contactable)

If you have registered to receive marketing communications, but the information you give us to contact you doesn’t work, we will retain your details for a period of typically only 6 months to allow you to return and correct it.

  • marketing to you (including marketing communications) (incomplete registrations)

If you commence registering yourself in a database, but do not complete the process (for example, if you don’t complete the age verification process, or you don’t accept the touchpoint’s terms of use), we will retain your details for only 6 months to allow you to return and complete the process.

  • market research

If you are not registered with us for other purposes (e.g. marketing communications, warranty, customer care), and we use publicly available information about you in order to understand the market or your preferences, we will retain the information about you for a short period in order to perform the particular item of market research.

  • purchases and warranty

If you purchase goods, we will retain details of this for so long as required to complete the sale, and to comply with any legal obligations (for example, for tax and accounting record-keeping purposes). If you also register for a warranty for a device, we will retain details of this for so long as relevant to the warranty.

  • customer care

If you contact customer care, we will make a record of the matter (including details of your enquiry and our response) and retain it while it remains relevant to our relationship, for example if you need us to replace a device under warranty, or if your recent enquiries are relevant. Temporary records (for example, an automated recording of a telephone call in which you ask us to direct you to a retail outlet) may be relevant only until more permanent records are made, and will be retained only temporarily.

  • system audit logs

System audit logs are retained typically for a period of only a few months.

  • business analytics

Business analytics data is typically collected automatically when you use PMI touchpoints and anonymised/aggregated shortly afterwards.


What rights and options do you have?

You may have some or all of the following rights in respect of information about you that we hold:

  • request us to give you access to it; 
  • request us to rectify it, update it, or erase it; 
  • request us to restrict our using it, in certain circumstances; 
  • object to our using it, in certain circumstances; 
  • withdraw your consent to our using it; 
  • data portability, in certain circumstances; 
  • opt out from our using it for direct marketing; and 
  • lodge a complaint with the supervisory authority in your country (if there is one). 

We offer you easy ways to exercise these rights, such as “unsubscribe” links, or giving you a contact address, in messages you receive.

Some mobile applications we offer might also send you push messages, for instance about new products or services. You can disable these messages through the settings in your phone or the application.

find out more…

The rights you have depend on the laws of your country. If you are in the European Economic Area, you will have the rights set out in the table below. If you are elsewhere, you can contact us (see the paragraph “who should you contact with questions?” at the end of this notice) to find out more.

Right in respect of the information about you that we hold Further detail (note: certain legal limits to all these rights apply)

  • to request us to give you access to it

This is confirmation of:
  • whether or not we process information about you;
  • our name and contact details;
  • the purpose of the processing;
  • the categories of information concerned;
  • PMI
  • the categories of persons with whom we share the information and, where any person is outside the EEA and does not benefit from a European Commission adequacy decision, the appropriate safeguards for protecting the information;
  • (if we have it) the source of the information, if we did not collect it from you;
  • (to the extent we do any, which will have been brought to your attention) the existence of automated decision-making, including profiling, that produces legal effects concerning you, or significantly affects you in a similar way, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; and
  • (if we have it) the source of the information, if we did not collect it from you;
  • the criteria for determining the period for which we will store the information.
On your request we will provide you with a copy of the information about you that we use (provided this does not affect the rights and freedoms of others).

  • to request us to rectify or update it

This applies if the information we hold is inaccurate or incomplete.

  • to request us to erase it

This applies if:
  • the information we hold is no longer necessary in relation to the purposes for which we use it;
  • we use the information on the basis of your consent and you withdraw your consent (in this case, we will remember not to contact you again, unless you tell us you want us to delete all information about you in which case we will respect your wishes);
  • we use the information on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it;
  • the information was unlawfully obtained or used; or
  • to comply with a legal obligation.

  • to request us to restrict our processing of it

This right applies, temporarily while we look into your case, if you:
  • contest the accuracy of the information we use; or
  • have objected to our using the information on the basis of legitimate interest
  • (if you make use of your right in these cases, we will tell you before we use the information again).This right applies also if:
    • our use is unlawful and you oppose the erasure of the data; or
    • we no longer need the data, but you require it to establish a legal case.

  • to object to our processing it

You have two rights here:
  1. (i)if we use information about you for direct marketing: you can “opt out” (without the need to justify it) and we will comply with your request; and
  2. (ii)if we use the information about you on the basis of legitimate interest for purposes other than direct marketing, you can object to our using it for those purposes, giving an explanation of your particular situation, and we will consider your objection.

  • to withdraw your consent to our using it

This applies if the legal basis on which we use the information about you is consent. These cases will be clear from the context.

  • to data portability

If:
  1. (i)you have provided data to us; and
  2. (ii)we use that data, by automated means, and on the basis either of your consent, or on the basis of discharging our contractual obligations to you,
then you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible for us to do so.

  • to lodge a complaint with the supervisory authority in your country

Each European Economic Area country must provide for one or more public authorities for this purpose. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm For other countries please consult the website of your country’s authority.

Country-specific additional points

According to which country you are in, you may have some additional rights.

If you are in Greece, find out more…

Who should you contact with questions?

If you have any questions, or wish to exercise any of your rights, you can find contact details for the relevant PMI affiliate, and if applicable data protection officer, here. Contact details will also be given in any communications that a PMI affiliate sends you.

If your country has a data protection authority, you have a right to contact it with any questions or concerns. If the relevant PMI affiliate cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.

Changes to this notice

We may update this notice (and any supplemental privacy notice), from time to time. We will notify you of the changes where required by law to do so.

 

Latest Update: May 2022

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