Privacy Notice

PART C: GENERAL PRIVACY POLICY

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 official distributors of of Philip Morris International’s products. 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 “”. “

We” (or “us” or “our”) refers to PHILIP MORRIS CYPRUS LTD which collects information about you.

PMI product: means a

product

of PMI or an 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 our 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 “touchpoints”. touchpoints include both physical (for example, retail outlets and events), and digital (for example, apps and websites).

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 our 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;

register to receive press releases, e-mail alerts, or marketing communications;

participate in surveys or (where permitted by law) or attend an event that PHILIP MORRIS CYPRUS LTD or a PMI affiliates has organised.

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

communicate with us (for example, through a touchpoint; or social media platforms);

make public posts on social media platforms that we follow (for example, so that we can understand public opinion, or respond to requests concerning our products).

We may also collect information about you automatically through the use of cookies and similar tracking technologies on digital touchpoints. The specific cookies and technologies used will depend on the 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 centers.

information about your preferences and interests

information necessary to verify your age

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 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?

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 inform you about our products, 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

To support all the above, including administering your accounts, 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 our 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).

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.
Commercial communication understand your preferences (such as what products or events may interest you or may be better tailored to your needs) administer loyalty programs invite you to participate in, and administer, surveys or market research campaigns for market research develop marketing strategies customize your experience of 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 our 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.
Information which relates to our products and services provide you with information about 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. 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 our 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 our activities. for business analytics and improvements (including for PMI products, outlets that sell PMI products, events, digital PMI touchpoints and the information that we 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, touchpoints, outlets and events, and to invite others to get involved in our activities, 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 and PMI affiliates;

third parties who provide to us 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 PMI and 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 consumers. 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, us, PMI and 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 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?

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
commercial activities (including communications) (if you use digital touchpoints and are contactable)	Most of the information in your profile is kept for the duration of our relationship with you; for example, while you continue to use digital touchpoints, or respond to our communications. However, some elements of your 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.
commercial activities (including 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 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.
commercial activities (including 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.
commercial activities (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. 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 our 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…

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; the categories of persons with whom we share the information and, where any person is outside the EEA and does not benefit from a European Commission adequacy decision, the appropriate safeguards for protecting the information; (if we have it) the source of the information, if we did not collect it from you; (to the extent we do any, which will have been brought to your attention) the existence of automated decision-making, including profiling, that produces legal effects concerning you, or significantly affects you in a similar way, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; and (if we have it) the source of the information, if we did not collect it from you; the criteria for determining the period for which we will store the information. On your request we will provide you with a copy of the information about you that we use (provided this does not affect the rights and freedoms of others).
to request us to rectify or update it	This applies if the information we hold is inaccurate or incomplete.
to request us to erase it	This applies if: the information we hold is no longer necessary in relation to the purposes for which we use it; we use the information on the basis of your consent and you withdraw your consent (in this case, we will remember not to contact you again, unless you tell us you want us to delete all information about you in which case we will respect your wishes); we use the information on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it; the information was unlawfully obtained or used; or to comply with a legal obligation.
to request us to restrict our processing of it	This right applies, temporarily while we look into your case, if you: contest the accuracy of the information we use; or have objected to our using the information on the basis of legitimate interest (if you make use of your right in these cases, we will tell you before we use the information again).This right applies also if: our use is unlawful and you oppose the erasure of the data; or we no longer need the data, but you require it to establish a legal case.
to object to our processing it	You have two rights here: 1. (i)if we use information about you for direct marketing: you can “opt out” (without the need to justify it) and we will comply with your request; and 2. (ii)if we use the information about you on the basis of legitimate interest for purposes other than direct marketing, you can object to our using it for those purposes, giving an explanation of your particular situation, and we will consider your objection.
to withdraw your consent to our using it	This applies if the legal basis on which we use the information about you is consent. These cases will be clear from the context.
to data portability	If: 1. (i)you have provided data to us; and 2. (ii)we use that data, by automated means, and on the basis either of your consent, or on the basis of discharging our contractual obligations to you, then you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible for us to do so.
to lodge a complaint with the supervisory authority in your country	Each European Economic Area country must provide for one or more public authorities for this purpose. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm a> For Cyprus, please consult the Website of the Data Protection Commissioner ( http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_en/home_en?opendocument a> ).

Privacy Policy for Digital communication channels


PHILIP MORRIS CYPRUS LTD with registered office at John Avenue Kennedy 23, Globe House, 2nd floor, TK 1075, Nicosia, Cyprus and EU registration number 420512 ("PM Cyprus") as data controller is committed to protecting your personal data. Personal data ("personal data") is information/data that directly or indirectly identifies you and relates to you or to other individuals.


The Personal Data Policy for communication channels describes the types of personal data we collect through PM Cyprus' communication channels and how we collect, transmit, process, use and share your personal data as well as the practices we apply to protect your personal data. The term "Digital communication channels" includes communication with the PM Cyprus Facebook page (IQOS Cyprus), Live Chat via IQOS.com and via Viber at IQOS Support Cyprus or from any social media (page / account / profile) at which PM Cyprus maintains an account.


1.Purpose of processing
PM Cyprus, as the Controller, processes your personal data through the communication channels that are absolutely necessary, relevant and convenient for the purpose of (a) providing customer support and service (b) managing complaints (c) improving of its services (d) its compliance with existing legislation, for example ensuring that the communication channels are not used by minors.

2.Legal basis for personal data processing
In order to lawfully process the Data described above, we rely on one or more of the following legal bases:
(a) in cases where we have obtained your consent; you can withdraw your consent at any time by contacting us through the communication channels.
(b) PM Cyprus’ compliance with its legal and regulatory obligations such as for example the Health Protection (Smoking Control) Law of 2017 (Law 24(I)/2017) as it may be amended
(c) the legitimate interest of PM Cyprus such as to improve the content of the communication channels or to improve the level of your service
(d) for the performance of a contract
(e) for the exercise or defense of judicial or extrajudicial proceedings.

3.Which of your personal data do we process?
Specifically, the data collected when using the communication channels are:
• contact information, including first and last name, telephone number and email address;
• identifying information such as your year of birth or whether you are an adult and your state of residence.
• technical information, including the time and date the use of communication channels has taken place, your location;
• any other categories of personal data that you may provide to us during our relationship

4.Retention time
We will retain your personal data only for as long as is necessary to fulfill the purposes of collection and processing. We will retain your personal data for the purposes of complying with our legal/regulatory obligations for the provision of our services and the exercise or defense of judicial or extrajudicial proceedings.

We determine the retention period of your personal data taking into account the volume, nature and sensitivity of the personal data, the possible risks from the unauthorized use, loss or disclosure of the personal data, the purposes of the processing and whether these purposes may be fulfilled by other means, and applicable legal obligations.

When you use the communication channels of PM Cyprus, your communication will be kept by PM Cyprus for as long as is necessary to fulfill the purpose of the processing (ie the best possible service for you and for your subsequent related or additional requests) and will be deleted 12 months after fulfillment of the processing purpose.

Your posts on PM Cyprus social media (where these are in accordance with our terms and conditions) are retained until you delete them or where applicable under the data retention rules of the respective social media.

5.Your obligations regarding the non-disclosure of personal data
a) You must not disclose your sensitive personal data using the communication channels, especially when this happens publicly (eg by public posting).
b) You must also refrain from disclosing (either on our page or in personal communication with us) personal data of third parties without their prior express consent to this end.
c) For the greatest possible protection of your data, we suggest that you use the private means of communication provided by the respective social media and that you do not choose to publish the information concerning you, otherwise the PM Cyprus bears no responsibility for any information you may make public.

6.Processing for statistical analysis

In the event that part of the information you provide us is used for statistical analysis purposes (insight information ) the information that will be used for this purpose will be anonymized immediately (at the latest within 15 days of its use for the above purpose) while the results of the statistical analysis will be completely anonymous and will be kept in a completely separate place (isolation principles). For the fulfillment of said compatible further purpose, access to your personal data will only be given to persons who are absolutely necessary for the fulfillment of this purpose and no one other than PM Cyprus or a third party.

7.Recipients of your personal data

The PM Cyprus may use subcontractors/processors for the operation of communication channels, for your service, the storage of personal data and the fulfillment of its obligations. This includes:
• External partners, such as IT support, consultants and any other third-party suppliers who provide us with support.
• Professional advisers and auditors, such as external legal advisors and accountants;
• Government agencies and authorities

8.Transmission of personal data to Third Countries

In some cases we may transfer your personal data to countries that do not provide a satisfactory level of personal data protection. Where necessary, we will take steps to ensure that personal data receives the necessary protection such as the use of personal data transfer agreements. In the event that we use such agreements or similar measures, we may be able to provide you with a copy or sample if you contact us through the communication channels.

9.Security measures

PM Cyprus declares that it takes all those legal, organizational and technical measures to protect and secure your personal data. We use various security technologies and procedures to protect your personal data from unauthorized access and disclosure, loss, use or alteration. When we use a third-party service provider, the provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal data.
The information you submit to PM Cyprus through the communication channels are managed exclusively by specially authorized personnel of PM Cyprus. To carry out the processing PM Cyprus selects persons with corresponding professional qualifications who provide sufficient guarantees in terms of technical knowledge and personal integrity to maintain confidentiality.

10.What are your rights?

In some cases you may be entitled to:
• request a copy of your personal data that we hold
• request the correction and/or deletion of your personal data, or restriction of processing or object to the processing of your personal data
• withdraw at any time your consent to the processing of your personal data, where the processing is based on consent
• request to receive and reuse your Data in a structured, commonly used and machine-readable format;
• ask us to transfer your personal data to other organizations .
• lodge a complaint with the Office of the Data Protection Commissioner if you believe that your rights have been infringed.

In case you wish to exercise any of the above rights or if you have any questions, comments or requests regarding the way PM Cyprus processes your personal data, please let us know through our communication channels.

11.PMI Consumer Privacy Statement

The protection of personal data is a serious matter for us. This statement tells you who we are, what information we collect about you and what we do with it. Click here to learn more.


Country-specific additional points
According to which country you are in, you may have some additional rights.
Who should you contact with questions?
If you have any questions, or wish to exercise any of your rights, communicate with us at .
You may also contact the Office of the Commissioner for the Protection of Personal Data at commissioner dataprotection.gov.cy .
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: 28/02/2022