Privacy Policy
We take privacy seriously. This notice tells you who we are, what information about you we collect, and what we do with it. We will use information about you only in accordance with applicable data protection laws.
Please also read our terms of use relating to the service you are interested in. They providemoreinformation 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 PMI touchpoint (e.g. an app or a website);
contact us through a PMI 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 PMI 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 PMI touchpoint, you provide your name, contact, billing details, and the products you have chosen so that we can fulfil your order;
you may also 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, or where law requires it, 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 |
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Comply with regulatory obligations
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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.
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Sell our products
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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.
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Provide sales-related services
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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.
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Market our products (where permitted by law)
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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, tooperate 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.
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Market our products (where permitted by law)
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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 thingsthat 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.
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Support for all the above purposes
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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 weare 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.
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Business analytics and improvements
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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 andtoimprove 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, or where law requires it, 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.
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Who do we share your information with, and for what purposes?
We may share information about you with:
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Find out more…
Sharing data with other PMI affiliates
Information about you will be shared with Philip Morris Products S.A. (based inNeuchâtel,Switzerland), which is the place of central administration of personal data processing for PMI affiliates. Philip Morris Products S.A. 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
Country-specific additional points
According to which country you are in, we want you to be aware of some further points.
If you are in Japan, find out more...
If you are in Japan, note that we share information about you, for the purposes described in this notice, with other PMI affiliates on the basis of "joint use" under Japanese data protection laws. When we do this, Philip Morris Japan Limited (PMJ) continues to manage your personal information responsibly, and we require those with whom we share the data to do the same. Further, if they are located outside Japan, we take reasonable measures in accordance with the relevant laws and regulations.
Sharing data with Third Parties
To the extent permitted by applicable law, 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).
To the extent permitted by applicable law, 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 illgal activity; and in the context of organisational restructuring.
Country-specific additional points
According to which country you are in, we want you to be aware of some further points.
If you are in Japan, find out more...
If you are in Japan, note that we share information about you, for the purposes described in this notice, with Sojitz Promotion K.K. ("Sojitz P") on the basis of "joint use" under Japanese data protection laws. When we do this, Philip Morris Japan Limited (PMJ) continues to manage your personal information responsibly, and we require Sojitz P to do the same.
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Where might information about you be sent?As with any multinational organization, PMI affiliates transfer information globally. Accordingly, information about you may be transferred globally (for example, if you are in the European Economic Area ("EEA"), your information may be transferred outside the EEA; if you are in Australia, your information may be transferred outside Australia).
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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[http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm];
subject to appropriate safeguards, for example the EU Model Contracts[http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm]; 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.
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How do we protect information about you?
We implement appropriate technical and organizational measures to protect personal information that we hold from unauthorized disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing theinformation you provide. We also require our service providers to comply with strict data privacy and security requirements.
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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, youhave 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.
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