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Privacy policy

For us your privacy is very important. This notice contains information about who we are, what information we collect from you, and what we do with it.

We also invite you to read our terms of use related to the service in which you are interested. They provide more information about how we do business, and any restrictions that may apply.

About us?

We are a member of Philip Morris International. Our information (name, address, etc.) should have been made available at the time of (or when authorizing) the collection of your information about you, for example, in a notice, in an application or website, or in an email that contains a link to this notice.

More information...

  • PMI: Philip Morris International, a leading international tobacco group. It consists of a number of companies or "affiliates".
  • PMI affiliates: Each member of the group of companies Philip Morris International is a "PMI affiliate". "We" (or "our") refers to the PMI affiliate who first collected the information about you.
  • Product of PMI: Means a product of ours or of another affiliate of PMI.

How do we collect information about you?

We may collect information about you in several ways: 
 

  • You can provide us with information directly (eg by filling out a form, or by calling us).
  • We can collect information automatically (eg when you use an application or PMI website).
  • We can acquire information from third parties (eg publicly available information on social networking platforms such as Facebook and Twitter).

In this notification, we refer to all the methods by which you are in contact with us as   "PMI contact points" . The PMI contact points include physical (for example, stores and events) and digital points (for example, applications and websites).

More information...  
We can collect information that you provide directly. In general, this happens when you: 
 

  • You register to be a member of our databases (this could be, for example, in person, by application or online);
  • Purchase PMI products or services in a store;
  • Download, or use, a digital point of contact (eg an application or website);
  • Contact us through a point of contact, or by email, social networks or by phone;
  • Register a device with us;
  • Subscribes to a PMI panel;
  • By registering to receive press releases, news via e-mail or marketing communications from
  • Register to receive press releases, email alerts or marketing communications from PMI;
  • Participate in PMI surveys or in PMI contests or promotions (as allowed by law), or
  • Attend an event organized by a PMI affiliate.

We can collect information about you automatically. In general, this happens when you: 
 

  • Visit any store that sells PMI products (eg collecting your data at the time of payment or through in-store sensors that connect with mobile technology);
  • Attend an event organized by an affiliate of PMI (eg through purchases at the event or through sensors in the event that are connected with mobile technology);
  • Communicates with us (for example, through a point of contact, or social networking platforms);
  • Use PMI contact points (eg through tracking mechanisms in an application or website);or
  • Make public posts on social networks that we follow (for example, to understand public opinion, or respond to requests related to PMI products).

We may also collect information about you automatically through the use of cookies and similar tracking technologies at digital PMI contact points. The specific cookies and technologies used will depend on the PMI point of contact in question. To learn more about cookies (including Google Analytics cookies ) and similar technologies used at a point of contact, including how you can accept or reject cookies, please review the notice about cookies available at or through that point of contact .

When the law permits, we may acquire information about you from third parties. This may include information shared among PMI affiliates, publicly available profile information (such as your preferences and interests), on third-party social networks (such as Facebook and Twitter), and marketing lists acquired from third-party marketing agencies.

We may also collect information in other contexts, in which case we will inform you in due course.

What information do we collect about you?

We can collect different types of information about you: 
 

  • Information needed to complete your orders.
  • Information to provide warranty services.
  • Information that you give us in formats or surveys.
  • Information about your visits to our stores and events.
  • Information that you give us in calls made to telephone customer service centers.
  • Information about your preferences and interests.
  • Information needed to verify your age.

More information...  
The information we collect from you directly will be evident from the context in which you provide it. For example: 
 

  • If you order a product from us through a point of contact, you provide your name, contact, billing information, and the products that you have chosen so that we can complete your order;
  • You can provide information about your product and interest preferences so that we can offer you products and services that are of interest to you;
  • If you schedule an appointment with us (or someone who supports our products or services), we may collect your name and contact details;
  • We may collect information that allows us to verify your age, for example a copy of your identity document or your facial image.

The information we collect automatically will generally refer to: 
 

  • Details about your visit or call (such as time and duration);
  • In a store or event (including areas in the immediate vicinity), how frequent are your visits, what areas you visit and for how long, and what purchases you make;
  • Your use of digital PMI contact points (such as the pages you visit, the page you came from and the page you went to when it came out, entered search terms, or links visited within the point of contact);Y
  • Your device (such as your IP address or unique device identifier, location data, details about cookies that could be stored on your device).

The information we collect from third parties generally consists of publicly available profile information (such as your preferences and interests), for example from publications on public social networks.

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

In this section, we describe the purposes for which we use your personal information. However, this is a global PMI notice, and when 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 foregoing, we use information about you for the following purposes: 
 

  • Comply with regulatory obligations, such as verifying your age and status as a user of our products.
  • Selling our products, including completing your orders and processing your payments.
  • Provide you services related to sales, including answering your concerns and requests, and providing warranty services.
  • Market our products (as permitted by law), including administering loyalty programs, product improvement, market research, development of marketing strategies, administration of marketing campaigns, and customize your experiences in stores that sell PMI products and at events.
  • So that we or our business partners can inform you of possible opportunities to participate in marketing or promotion of PMI products.
  • To support all of the above, including managing your accounts, enabling you to use our contact points, managing yourappointments with us or with someone who supports our products or services (for example, regarding a new product, or after-sales service) , personalize your experiences in the PMI contact points, and administration and problem solving.
  • For business statistics and improvements, including improving PMI products, stores and events, and the information that we (or our affiliates) provide to our customers.
  • For other reasons we will notify you, or that it will be clear from the context, at the point where your information is collected initially.

The legal basis for the use of your information may be one of the following (explained in more detail in the "know more" section):

  • Fulfillment of a legal obligation to which we are subject;
  • The performance of a contract of which you are a party;
  • A legitimate commercial interest that is not exceeded by your interest in protecting the information;
  • When none of the above applies and in accordance with the requirements of each country, based on your consent (which we will request before processing your information).

More information...

The purposes for which we use your information, with the corresponding collection methods and legal basis for use, are:

Object

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 directly by you.

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 commercial interest to sell our products only to adults, provided that such interest is not find surpassed by your rights, interests and freedoms related to the protection of your information.

Sell our products

• Comply with your orders (including sending receipts or billing.

• Process your payments.

• Provide warranty services.

This information is usually provided by you directly (typically the name, address, email, payment information).

We use it to fulfill our contractual obligations towards you as a buyer of our products.

Provide services related to sales

• Respond to your concerns and requests.

• Exchange correspondence with you.

• General administration and problem solving.

• Manage loyalty programs.

This information is usually provided by you directly.

We use it because we have a legitimate commercial interest in providing services related to sales to our customers, provided that this interest is not exceeded by their rights, interests and freedoms related to the protection of their information.

Marketing our products (when allowed by law)

• Understand your preferences (such as what products or events may interest you or can be best customized to your needs) and, where permitted by law, direct marketing strategies to you personally.

• Manage loyalty programs.

• Invite you to participate in, and administer, surveys or market research campaigns.

• For market research.

• Develop marketing strategies.

• Manage marketing campaigns.

• Personalize your experience with PMI contact points (for example, to personalize your visit, such as greetings orsuggestions that may interest you).

This will generally be a combination of information that you provide to us (for example, name and contact information and social media details); information that we collect automatically (for example, using technology to monitor the use of PMI contact points) and (when permitted by law) information we acquire from third parties (such as publications on public social networks).

We use it on the basis that we have a legitimate interest to market our products, to operate the PMI contact points, and to personalize their experiences, provided that this interest is not exceeded by their rights, interests and freedoms related to the protection of their information.

Marketing our products (when allowed by law)

• Provide information about, and to manage, promotions, products and services, stores, events, affiliates of PMI and the regulation of our products; and develop and improve tools to achieve these objectives.

This will generally be a combination of information provided by you (for example, your name and contact details, your usernames on social networks); information that we collect automatically (for example, using cookies and similar technologies) and (when the law permits) information we acquire from third parties (such as public social network publications).

We use it on the basis that we have a legitimate interest in marketing our products as long as that interest is not outweighed by your rights, interests and freedoms related to the protection of your information.

In certain countries, when the law requires it, we will send you these materials in electronic format only with your consent.

Support for all previous objects

• Manage our accounts.

• Allow you to use PMI contact points (for example, allow you to remain connected in sections of a point of contact that are reserved for authorized users only, managing your language preference, associate the shopping cart with you).

• Exchange correspondence with you.

• Manage your appointments with us or with someone who supports our products or services (for example, regarding a new product, or after sales service).

• Improve your experience.

• Administration and troubleshooting.

This will generally be a combination of information provided by you (usually, name, password (or equivalent)) and information that we collect automatically (for example, information about your device, and similar cookies and tracking technologies).

We use it under the foundation that corresponds to the object for which the information we are supporting is used. For example, when we manage your account to support a purchase or to provide after-sale services, we use the information to fulfill our contractual obligations to you as a buyer of our products; When we manage your account to show you our products, we support the marketing and therefore use it on the basis that we have a legitimate commercial interest to market our products as long as that interest is not exceeded by your rights, interests and freedoms related to the protection of your information.

Business statistics and improvements

• It allows our business partners to inform you about possible opportunities to get involved in the promotion of PMI products.

• For business statistics and improvements (including PMI products, stores that sell PMI products, digital PMI points of contact and information that we (or our affiliates) provide to our affiliates).

This will generally be a combination of information provided by you; information that we collect automatically; and (when the law allows it) information that we acquire from third parties.

We use it on the basis that we have a legitimate commercial interest to analyze and improve our commercial performance, our products, PMI contact points, stores and events, and invite others to participate in the promotion of PMI products, provided that said interest You are not overwhelmed by your rights, interests and freedoms related to the protection of your information.


 

When we do not base our use of information about you in any of the above legal cases, we will ask for your consent before processing the information (these cases will be clear from the context).

In certain instances, we may use information about you in ways that are not described above in compliance with the legal requirements of each country. When this is the case, we will provide a complementary privacy notice that explains such use. Any additional notice must be read along with this notice.

With whom do we share your information, and for what purposes?

We may share information about you with: 
 

  • PMI affiliates;
  • Third parties that provide products or services to PMI affiliates or to you;
  • Commercial partners and advertisers of carefully selected PMI affiliates (in areas related to our products, or consistent with their style and image) sothey can contact you with offers that they think may interest you, according to your preferences;Y
  • Other third parties, when required or permitted by law.

More information... 
 

Share information with other PMI affiliates

  • Information about you will be shared with Philip Morris International Management SA (with offices in Lausanne, Switzerland), which is the central management place of data processing and processing for PMI affiliates.Philip Morris International Management SA will process information about you for all purposes described in this notice.
  • Information about you may be shared with the PMI affiliate who is responsible for the country in which you live (if it was not the PMI affiliate that initially collected the information) for all 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 want to know where to buy PMI products in a new country, or where to find services or support for PMI products) for improve our service for you.

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

Share information with third parties

  • We may share information about you with third parties that provide products or services to PMI affiliates or to you (such as consultants, payment service providers, delivery providers, retailers, product advisors, information service providers and verification providers). age).
  • We may share information about you with business partners and advertisers of carefully selected PMI affiliates (in line with the type of thingyou may associate with our products, for example because they have a similar or complementary image, style or functionality) so that they can contact you with products, services and promotions that they consider may interest you, according to your preferences.
  • We may share information about you with other third parties, when required or permitted by law, for example: regulatory authorities;government departments;in response to a request from authorities or other government officials; when we believe that disclosure is necessary or adequate to prevent physical harm or financial loss or in connection with an investigation of illegal activity that is suspicious or real; and in the context of organizational restructuring.

Where can you send information about you?

As with any multinational organization, PMI affiliates transfer information worldwide. Therefore, the information about you can be transferred worldwide (if your information is collected within the European Economic Area, this means that your information may be transferred out of it).

More information...

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

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

  • based on a decision of adequacy of the European Commission;
  • subject to adequate safeguards, for example the EU Model Contracts;or
  • necessary to comply with the obligations under a contract between you and us (or the implementation of pre-contractual measures taken at your request) or to conclude or execute a contract in your interest between us and a third party, such as in relation to travel organization.


 

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

How do we protect the information about you?

We implement adequate technical and organizational measures to protect the personal information we have against its disclosure, use, alteration or destruction not authorized. When appropriate, we use encryption and other technologies that can help secure the information you provide. We also require that our service providers comply with strict security and information privacy requirements.

How long will the information about you stay?

We will keep information about you for the period necessary to meet the objectives for which the information is collected. After this, we will eliminate it. The period will vary depending on the objects for which the information is collected. Please note that in certain circumstances, you have the right to request us to delete the information. Likewise, we are sometimes legally required to maintain the information, for example, for tax and accounting purposes.

More information...

Usually, we retain information based on the criteria described in the following table:

Kind

Explanation / typical retention criteria

Marketing addressed to you (including marketing communications) (if you use digital contact points and it is locatable).

Most of the information in your marketing profile is maintained for the duration of our marketing relationship with you; for example, as long as you continue to use digital contact points, or respond to our communications. However, some elements of your marketing profile, such as the records of how we interact with you, will naturally expire after a period of time, then we automatically delete them after defined periods of time (usually 3 years) as appropriate for the object for which it was collected.

Marketing addressed to you (including marketing communications) (if you no longer contact us).

This scenario is the same as the previous one, but if we do not have contact with you for a period of time (usually 2 years) we will stop sending you marketing communications and we will erase your response history to them. This will happen, for example, if you never click through an invitation to an event, log in to a digital point of contact, or contact customer service, during that time. The reason is that under these circumstances, we assume that you prefer not to receive communications.

Marketing addressed to you (including marketing communications) (if we can no longer locate it).

If you have registered to receive marketing communications addressed to you, but the information you provide to contact us does not work, we will retain your details for a period of generally 6 months to allow you to return and correct it.

Marketing directed to you (including marketing communications) (incomplete records).

If you started registering in a database but did not complete the process (for example, if you do not complete the age verification process or do not accept the terms of use of the contact points), we will retain the details only for 6 days. months to let him go back and finish the process.

Market research.

If you are not registered with us for other purposes (for example, marketing communications, warranty, customer service) and we use your information available to the public in order to understand the market or your preferences, we will retain your information for a short period of time. period in order to realize the particular element of market research.

Purchases and guarantee.

If you purchase goods, we will retain the details of the purchase as long as it is required to complete the sale and to comply with any legal obligation (for example, to maintain fiscal and accounting records). If you also register a warranty for a device, we will retain the details of this as long as it is relevant to the warranty.

Customer Support.

If you contact customer service, we will record the matter (including details of your inquiry and our response) and retain it while it is still relevant to our relationship, for example if you need us to replace a device under warranty, or if your Recent queries are relevant. Temporary records (for example, an automated record of a phone call in which you ask us to direct you to a point of sale) may be relevant only until more permanent records are made and temporarily retained.

System audit records.

System audit records are normally retained for a period of only a few months.

Business statistics

Business statistical data is normally collected automatically when you use your PMI contact points and are anonymously added later.


 

What rights and options do you have?

You may have all or any of the following rights with respect to your information that we have:

  • Ask us to give you access to it;
  • Ask us to rectify, update or delete it;
  • Ask us to restrict our use of the information in certain circumstances;
  • Objecting to our use of information, in certain circumstances;
  • Withdraw your consent to our use of the information;
  • Data portability, in certain circumstances;
  • Exclude our use of information for direct marketing;Y
  • File a complaint with the supervisory authority in your country (if any).

We offer you easy ways to exercise these rights, such as "unsubscribe" links or by providing you with a contact address in the messages you receive.

Some mobile applications that we offer could also send you automatic messages, for example about new products or services. You can disable these messages through the settings on your phone or in the application.

More information...

The rights you have depend on the laws of your country. If you are in the European Economic Area, you will have the rights established in the following table. If you are somewhere else, you can contact us (see the "who should you contact with questions?" Section at the end of this notice) for more information.

Right with respect to the information about you that we have

Additional detail (note: there are certain legal limits applicable for all these rights)

Ask us to give you access to the information.

This is the confirmation of:

• Whether or not we treat information about you;

• Our name and contact details;

• The object of the treatment;

• The categories of related information;

• The categories of people with whom we share the information and, when someone is outside the EEA and does not benefit from a   decision of adaptation of the European Commission , the appropriate guarantees to protect the information;

• (If we have it) the source of the information, if we do not collect it from you;

• (To the extent that we have one that has caught your attention) the existence of an automated decision making, including the creation of profiles, that produces legal effects with respect to you or that affects you significantly in a similar way and information about the logic involved, as well as the importance and expected consequences of such treatment for you; Y

• The criteria to determine the period during which we will store the information.

At your request, we will provide you with a copy of the information about you that we use (as long as this does not affect the rights and freedoms of others).

Ask us to rectify or update the information.

This applies if the information we have is incorrect or incomplete.

Ask us to delete the information.

This applies yes:

• The information we have is no longer necessary in relation to the purposes for which we use it;

• We use the information based on your consent and you withdraw your consent (in this case, we will remember not to contact you again, unless you tell us that you want us to remove all information related to you, in which case we will respect your wishes) ;

• We use the information based on legitimate interest and find that, after your objection, we do not have a primary interest in continuing to use it;

• The information was obtained or used illegally; or

• To comply with a legal obligation.

Ask us to restrict our treatment of information.

This right applies, temporarily while we study your case, if you:

• Challenges the accuracy of the information we use; or

• You have objected to our use of information in the legitimate interest base

(If you exercise your right in these cases, we will let you know before we use the information again).

• Our use is illegal and you object to the deletion of the data; or

• We no longer need the data, but you need it to establish a legal case.

Objecting to our information treatment.

Here you have two rights:

• If we use information related to you for direct marketing: you may "withdraw" (without needing to justify it) and we will comply with your request; Y

• If we use the information related to you on the basis of a legitimate interest for purposes other than direct marketing, you may object that we use it for such purposes, giving an explanation of your particular situation and we will consider your objection.

Withdraw your consent for our use of this.

This applies if the legal basis on which we use information about you is consent. These cases are easily deduced from the context.

Data portability

Yes:

• You have given us information; Y

• We use that data, by automatic means, and based on, either your consent, or based on the fulfillment of our contractual obligations towards you, then you are entitled to receive back the information from us in a commonly used format , and the right to request the transmission of the data to someone else if it is technically possible for us to do so.

File a complaint with the supervisory authority of your country

Each country of the European Economic Area must stipulate one or more public authorities for this purpose.

You can find their contact details here . 

For other countries, please refer to the website of the corresponding authority in your country.


 

Additional points for specific countries

If you are in France, find more information on ...

  • If you are in France, you have the right to give us instructions regarding the information we have about you in the event of your death (specifically, whether we store it or delete it, or others have the right to see it). You can:
    • give instructions to a digital service provider registered with the French data protection supervisory authority (called "CNIL") (these instructions apply to all uses of the information about you);or
    • give us specific instructions that apply only to our use of the information about you.

Your instructions may require that we transmit information about you to a third party (but when the information contains information about others, our obligation to also respect their privacy rights may mean that we can not follow your instructions to the letter). You can appoint a third party to be responsible for ensuring that your instructions are followed. If you do not name any third party in this way, your heirs (unless you specify otherwise in their instructions) will be entitled to exercise your rights over the information about you after your death:

  • to manage your estate (in which case your heirs may access information about you to identify and obtain information that may be useful to manage your estate, including any digital property that can be considered a family souvenir that is transferable to your heirs) ;Y
  • to ensure that the parties using the information about you take into account your death (such as closing your account, and restricting the use of, or updating, information about you).

You can modify or revoke your instructions at any time. For more information about the treatment of information about you in the event of your death, see Article 40-1 of Law 78-17 of January 6, 1978. When you die, by default, you will stop using your account and we will We will remove information about you in accordance with our retention policies (see paragraph "How long will information about you be kept?" for more details).

Who should you contact with questions?

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

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

Changes to this notice

We may update this notice (and any additional privacy notice), from time to time. We will notify you of changes when we have an obligation to do so.

Last modified on March 27, 2018.