Your specific information for the use of the means of remote legal age verification through YOTI

The Data Controller responsible for the processing of your personal data is the Company (hereinafter collectively referred to as the "Company" or "We").

1. What is the Purpose

  • 1.1 Our Website and all our Programs are addressed to adults only; you declare responsibly to us that you are of legal age at the age gate when entering and/or using our website and at the point of registration to our Adult Consumer Database when creating your Account. Our Company must, however, confirm that you are of legal age prior to the sale of its Products to you, due to their nature, as well as when offering services to you related to any of our Programs ("the Purpose").
  • 1.2. You are given the possibility to choose the means that best suit you in order to fulfill this Purpose since you can opt either to conduct remote age verification (by scanning your face or other remote age verification methods as applied by the Company from time to time) and/or alternatively to verify your age by physical means (by visiting one of our stores). In any case, if you choose the technical means of remote age verification these tools are the necessary and appropriate ones to fulfil our legal obligation remotely.
  • 1.3. For the avoidance of any doubt legal age in Malta is considered over 18 years.
  • 1.4. This legal age verification procedure appears to you, at this stage, since this verification was not previously completed in any other way or in another sales or communication channel with our Company (e.g. in the physical store or otherwise).

2. What data we process about you and how we process it

You are free to choose one of the means of remote or physical legal age verification we offer as laid down below. You can always opt to carry out the procedure physically (by visiting one of our stores).
The data we collect from you is simple data (and not sensitive data or special categories of data) that are necessary, appropriate, relevant and adequate for the fulfilment of the Purpose within our legal obligation. You will find further information, depending on the way you opt to conclude your legal age verification, below:
a) With regard to the process of legal age verification through the scanning of your face, this takes place with the use of the camera of the device you are using while you are in our Website; we only conduct legal age verification with a general analysis of your face characteristics by means of an AI technical application (you may see more detailed information at www.yoti.com) based on a statistical estimation of general age parameters analyzed by the system, with a minimum error rate. This process is carried out real time; none of your data or physical characteristics are stored in any way, no profile is created and no identification nor processing/connection with biometric data or databases are carried out through this method.
b) With regards to physical verification, at one of our stores, our agent (salesperson) will confirm your legal age in person and/or request that you produce an appropriate government issued identity document that proves you are of legal age. Note that we do not collect or store any identification documents.

3. Specific information regarding the procedure of remote age verification

  • 3.1 When you opt for the remote legal age verification (scanning of your face), you must follow the instructions given to you in our website correctly. To be able to proceed with receiving the services and/or privileges of a Program, you must successfully complete the process of legal age verification, as applicable in each case.
  • 3.2 In the event that the scanning of your face cannot be successfully concluded for any reason, twice, you can instead opt to have a human intervention for your verification via physical verification.
  • 3.3 In the event that the verification by means of human intervention (physical verification) fails once, there is no alternative way for verification.
  • 3.4 If the legal age verification cannot be fulfilled by any of the means outlined above, we will automatically log you out from your Account as well as delete your data.

4. Your free consent

  • 4.1 The process of legal age verification is mandatory to fulfil our legal obligations under the Purpose, as explained also in our general Privacy Policy. You may, however, freely choose any of the above means of remote or physical legal age verification. By choosing a specific age verification tool, you are providing us with your consent for the Purpose (i.e. the use of the specific tool for the Purpose). Please note that if you opt for the scanning of your face, you still have the right for human intervention regarding your age verification via physical verification, as laid down in article 3.2. above.
  • 4.2 Once your legal age is verified, you may continue participating in our Programs and receiving the respective services and/or privileges, notwithstanding however any re-verification or new confirmation that our Company may deem necessary at its discretion, for any reason at any later stage for any of its programs or services.
  • 4.3 You may ask to unsubscribe at any time from our Adult Smokers Database, and/or your Account, and/or from any of our programs you have separately enrolled in at any time subject to the respective terms and conditions. Any requests to unsubscribe shall not affect the lawfulness of any remote age verification processing already carried out on the basis of your consent (which processing was in any case temporary and carried out in real-time). In the event you withdraw from the Adult Smokers Database, the whole process of legal age verification may be repeated in the future, depending on the applicable procedures of our Company at the time you opt to re-register.

5. Categories of Recipients
For the due fulfillment of the above procedure, we cooperate with a trusted, reliable and reputable provider of remote legal age verification services named YOTI [www.yoti.com] , that is able to meet and respond to all the appropriate guarantees of data protection and security of its systems and its procedures based on the legal requirements and the strict conditions set by the policies of PMI. We may also work together with our parent company, subsidiaries, or Group affiliates to carry out this process and achieve the Purpose. If any transfers of personal data to third countries need to be carried out, such transfers will comply with relevant legal safeguards. In the case of YOTI itself, which is based in the UK, we rely on the adequacy decision issued by the EU Commission in favor of the UK.
In addition to the above, all the provisions of our general Privacy Policy apply and complement the present information; you are informed of our Privacy Policy and acknowledge having read it when you choose to use the tools of remote age verification.