Personalised Communication Consent

INFORMATION REGARDING YOUR CONSENT TO RECEIVE PERSONALISED COMMUNICATIONS FROM PHILIP MORRIS CYPRUS (hereinafter referred to as the 'Programme')

By virtue of this declaration you are expressly consenting to receiving personalised communications from Papastratos. This communication is addressed exclusively to adult consumers registered in the Philip Morris Cyprus Adult Consumer Database based on the General Terms and Conditions whose age has been confirmed in accordance with the respective Procedures, Principles and Practices of Philip Morris International (PMI).

Information sections
1. Who is the Data Controller?
2. What is the purpose of the programme and why do you need my consent?
3. Is it possible for me to withdraw my consent at any time?
4. What kind of personal data do you process and where do you collect it from?
5. How long do you keep my personal data for?
6. Categories of data recipients
7. Security of processing
8. What are my rights regarding the processing of my personal data?
9. Amendments to the privacy policy – Suspension or modification of the Program

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1. Who is the Data Controller?

The Data Controller of your personal data is the company ‘PHILIP MORRIS CYPRUS LTD’ with registered offices at 23, Kennedy Street, 1075, Nicosia, Cyprus, holder of registration number HE420512, (hereinafter the ‘Company’ or ‘We/Us’).

2. What is the purpose of the programme and why do I grant you my consent?

2.1 The Purpose of the Programme is to carry out personalised communication between the Company and you, either when you contact or communicate with us or when we send you direct communications to the contact addresses or numbers that you provided to us when you registered in the Adult Consumer Database or any other program organised by our Company. This Programme includes content of both general as well as of personalised individual commercial and non-commercial communication as well as the service offered to you on the basis of data collected about you within the context of your registration in the Adult Smokers Database of our Company and/or based on your participation in our various programmes, which are stored as historical information on your record card and/or a combination of these data sources so that we can analyse and predict your preferences and your needs. Specifically, we will communicate with you regarding new developments and/or products, that is, Philip Morris products imported and distributed in the Republic of Cyprus by associates and/or representatives of the Company and/or Philip Morris (hereinafter the ‘Products’), and/or the programmes, and/or the benefits, and/or IQOS CLUB competitions, and/or research studies and articles, and/or participation in surveys of the Company or third parties and in general about our Company’s services and customer service issues, by sending you direct communication, commercial or non-commercial communication within the context of other programmes of our Company (provided that you satisfy their respective terms and conditions, such as, indicatively, the onboarding programme, free trial programmes etc.), via the means of communication you indicated when you registered in the Adult Smokers Database, such as, indicatively, using your phone (by telephone call or SMS or Viber or other equivalent means) or your e-mail or your postal address, as well as with the provision of personalised services and information given when you contact our partner either through our call centre or when you visit an IQOS store or one of our third-party partners or through a dialogue on our website cy.iqos.com (livechat).
2.2. The legal basis for processing is your free consent to receive the above personalised communication under this Program. Explicit legal identification of adulthood control: Prerequisite for our communication with you under this Program is the confirmation of your adulthood (either upon your registration in our Database and when providing your consent to participate and subsequently, whenever this occurs). The method and timing of confirmation will vary depending on how you register and on how you make your purchases, in accordance with the applicable Philip Morris International (PMI) Procedures, Principles and Practices.
2.3. Choice of communications channels: You can choose the means we use to communicate with you about new developments, and/or products, and/or programmes, and/or benefits, and/or IQOS CLUB competitions, and/or research studies and articles, and/or participation in research surveys of the Company or third parties, and in general regarding the services and customer service issues of our Company. More specifically, you can choose whether we contact you via email, SMS, and/or Viber or by telephone call.

3. Is it possible for me to withdraw my consent at any time?

You may withdraw your consent and unsubscribe from the Programme at any time, in which case your participation will be discontinued and your data will be deleted from the Programme (data may be retained for other legal reasons by our Company, especially if you are registered or participate in other programmes, but it will no longer be used for the purposes of this Programme). The withdrawal of your consent leads to the suspension of communication under this Programme. It is nevertheless emphasised that withdrawal of your consent does not affect your participation in the other programmes of the Company.
You can easily exercise the withdrawal of your consent, either as a whole from all means of communication or individually from specific means of communication in a number of ways, including visiting your account at cy.iqos.com, choosing to unsubscribe using the unsubscribe link you automatically receive in all communications, by declaring your wishes at any IQOS store, calling the company on 8000 8803 or by sending an email to

4. What kind of personal data do you process and where do you collect it from?
The data we collect in order to provide you with personalised communication, are collected from you either by ourselves or through partners of ours who act as processors on our behalf, or through the programs in which you participate as well as by automated means through interaction with us (e.g. indicatively based on the cookie policy of our site, etc.). These data consist of the following:
a) Your general information (name, phone number, e-mail, etc.) and demographic data you provide us when you register with the Programme. Data collection points are the points where you register for the Programme.
b) Your purchasing data (relating to products, services, point of sale). Collection points are our products points of sale, whether physical or electronic, as well as data collected whilst you are a member of the Club.
c) Information concerning the level of your satisfaction with the Company or its partners, its products, its services, as well as the service provided to you personally and any issues you may have, as well as areas of improvement in our products and services you would like to see, which are collected when we provide customer care services and/or when you voluntarily answer questionnaires or surveys we address to you.
d) Information concerning your participation and interaction with our programmes and/or our automated means of communication and/or with the use of cookies, which are collected via your voluntary participation in our programmes and/or communications with you and/or on the cy.iqos.com website.
Learn more about how we process your data for personalised communication:
We need the aforementioned information in order to be able to know you better and understand your preferences and needs (with or without combining your data), on the basis of:
• your demographics and general information;
• your purchases (type, volume, preferences, frequency);
• your level of satisfaction with the service and the products;
• your level of interaction with our communications and our programs;
• the level of your interaction with the customer care team
ώστε να προσαρμόζουμε την επαφή μας μαζί σας προσωπικά σε εσάς στο πλαίσιο του Προγράμματος.
As a result of the foregoing, you will receive personalised communication and service that suits you, based on the information you choose to share with us.
For example:
• Information and services provided to you, as well as general news and offers that we believe may be of interest to you based on your personal details and profile.
• We form our recommendations to you based on your combined data in order to anticipate your preferences and needs in the context of the purpose outlined, indicatively including the following:
We will contact you with news concerning the Company and its products, as well as with suggestions for participation in programmes and competitions (assuming you are a member of the IQOS CLUB), which we consider may be of interest to you based on your preferences and/or which match your satisfaction level indicated by your answers to our questionnaires.
We will ask you questions concerning your satisfaction with our services and the improvement of our products and services as they corresponding to your profile and your level of satisfaction.
You will receive special exclusive offers and updates based on your purchases (type, volume, preferences, frequency), your demographic characteristics, your level of satisfaction, and your interaction with us.
We will ensure that we improve our products, services and suggestions we offer you through our programmes based on the issues you tell us you are experiencing when using your services, and/or your responses to our questionnaires and other research, and we will continue to serve you to the best of our ability (if your satisfaction level is high), or work to improve the areas you propose (if you are dissatisfied).
We will contact you in the context of after-sales service with recommendations for proper and safe use of our products or restoration of defects, if we conclude from the information you have provided to us that you are having problems with our products.
When you decide to purchase our products we will offer suggestions based on your previous purchases and preferences.

5. How long do we keep your data for the purposes of this specific Programme?
The information we collect from you for the Program is retained until your consent is withdrawn in accordance with the provisions of Article 2.2. above. Furthermore, in the event that you have not engaged in any interaction with us for an extended period of time (exceeding 24 months), we will proceed to delete your data in accordance with the respective Procedures, Principles and Practices of Philip Morris International (PMI) applicable at the given time.
You may of course exercise your right to unsubscribe as per Article 8 below at any time, and/or request your complete removal from our Adult Consumer Database entirely as provided for in the General Terms and Conditions.
In any case, for more information about the general processing of your data by our Company, you may visit our General Privacy Policy that you accepted upon your registration in our Database, as well as any specific privacy policies of our individual programs (such as, indicatively, the Club etc., provided that you have registered with them).

6. Categories of data recipients
In the context of the operation of the Programme, our Company cooperates with third companies that have access to your data only as strictly necessary for the performance of their services as Data Processors for the purpose of providing ancillary services as needed for the programme’s administrative purposes, including for example, cooperation with physical or online shops or associates who are natural persons for collection of your data and confirmation of your age at registration, when you make a purchase or when they provide any service to you on our behalf, as well as with electronic platforms for the purpose of communicating with you by electronic means, or for the purposes of cooperation with companies that manage call centres, or consulting or advertising companies, or companies providing database management and hosting services etc.

7. Security of processing
The Company takes all required security measures for protecting your personal data and ensuring the confidentiality thereof. For more information, please read our general Privacy Policy
The data you submit to the Company is handled exclusively by specially authorised Company personnel under the direction of the Company, by authorised third-party associates and exclusively under the instructions of the Company, as well as by the aforementioned recipients, wherever this is necessary. The Company selects persons or associates with the corresponding professional qualifications necessary for the conduct of processing, who are capable of offering acceptable guarantees both in terms of technical knowledge as well as personal integrity with regard to the maintenance of confidentiality.
Express legal notice regarding your obligations with regard to your personal participation in all Company programmes:You are required to keep your account details and password at cy.iqos.com and in particular to safeguard against unauthorised access to them by third parties and/or prevent said parties from using the features and privileges provided to you in the context of your registration with the Adult Consumer Database. Our Company will reasonably and in good faith treat any access or use of your account or actions related to the utilisation of your privileges and your participation in our Company's programmes as carried out by you, provided that it has not received advance notification in writing (and/or by e-mail) of any leak of your password or unauthorised use thereof, or use of your devices by third parties, or anything else related to use or access to the above not carried out personally by you, for which you bear full responsibility and liability given that all of our Programmes are personal and non-transferable, and are offered subject to verification that all participants are of adult age.

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

Rights

Pursuant to the applicable legislation, as the case may be and where applicable, you have the following rights: information, access, rectification, restriction of processing, erasure, portability, objection, as well as the right not to be subject to a decision based on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (and/or, in such case, to request human intervention, express your point of view and contest the decision made).
In any event, you have the right to withdraw your consent at any time, in accordance with the provisions of article 2.

How to exercise your rights

In order to exercise your rights, as well as for any matter concerning this privacy policy and the processing of your personal data, you can contact us by:
α) By telephone to the call centre service on 8000 8803, Monday to Friday 09:00 - 21:00 and Saturday 10:00 - 18:00.
b) By email to: contact.cy@iqos.com
c) By mail to the postal address: PHILIP MORRIS CYPRUS LTD Head Offices, Kennedy 23, 1075, Nicosia, Cyprus, marked for the attention of the Legal Department.
We take the confidentiality of all files containing personal data seriously and we reserve the right to request proof of identity from you, if you submit a request to exercise your rights concerning the said files. You can also log in to your account at cy.iqos.com after activating it in order to view and update your information, your consent options, as well as our contact details for the exercise of your rights.

Company response time to your requests and relevant procedure

Our goal is to respond to any valid request within thirty (30) days from receipt, at the latest, unless the request is very complex or you have submitted several requests. We will notify you, if we determine that a period exceeding thirty (30) days will be required for our response, for the reasons stated above.
We may ask you whether you could explain exactly what you wish to receive or what your concern is. This will help us to process your request faster. In any event, you should provide specific and true information and/or facts, in order to allow us to respond and/or accurately satisfy your request, otherwise we disclaim any liability for any errors that are beyond our control.
Our Company may also reject requests that are unfounded, excessive, or abusive, or which are made in bad faith or are generally unlawful, in accordance with the provisions of the law.

Right to lodge a complaint with the Data Protection Authority

In any case, if you believe that the protection of your personal data may have been violated in any way, you have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection (Postal address: P.O.Box 23378, 1682 Nicosia; E-mail: commissioner@dataprotection.gov.cy)
You can find more details about your rights in our General Privacy Policy .

9. Amendments to this policy – Suspension or modification of the Program
We reserve the right to modify the Programme and/or this policy, for example, in order to comply with new demands imposed by applicable laws and directives, or due to technical requirements, or in the event that we revise our procedures or practices. We will notify you of any revisions to our policy either individually or by public announcement on the cy.iqos.com website. We also encourage you to check this page regularly.
We also reserve the right to suspend use of the programme, in whole or in part, at any time and/or exclude any member from the Programme, where there are indications or where it is discovered that the member in question has committed, in breach of the law or the contract, any act or omission in relation to the Programme, our products, the Company or its other Programmes (and/or in relation to third consumers), subsequent to relevant notification sent via means of communication, the details of which have been supplied to us by the member. In all other respects, the General Privacy Policy applies to the extent does not conflict with this particular policy, which is more specifically applicable to the particular programme.

Last update: 10/2023