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: (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 (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: (i)you have provided data to us; and (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