We take privacy seriously. This notice tells you who we are, what information about you we collect, and what we do with it.
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 or sms, containing a link to this notice.
We may collect information about you in various ways.
In this notice, we refer to the methods by which you are in contact with us, i.e. apps and websites, as “PMI touchpoints”.
We may collect information that you provide directly. Typically this will happen when you:
We may collect information about you automatically. Typically this will happen when you:
We may also collect information in other contexts made apparent to you at the time.
We may collect various types of information about you:
Information that we collect from you directly will be apparent from the context in which you provide it. For example:
Information that we collect automatically will generally concern:
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.
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:
The legal basis for our use of information about you is one of the following:
The purposes for which we use information about you, with corresponding methods of collection and legal basis for use, are:
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.
We may share information about you with:
Sharing data with other PMI affiliates
Details of PMI affiliates and the countries in which they are established are available from here.
Sharing data with Third Parties
As with any multinational organisation, PMI affiliates transfer information globally. Accordingly, 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).
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:
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.
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.
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.
Typically, we retain data based on the criteria described in the table below:
You may have some or all of the following rights in respect of information about you that we hold:
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.
The rights you have depend on the laws of your country. If you are in the European Economic Area, you will have the rights set out in the table below. If you are elsewhere, you can contact us (see the paragraph “who should you contact with questions?” at the end of this notice) to find out more.
According to which country you are in, you may have some additional rights.
If you are in France…
If you are in France, you have the right to give us instructions regarding information we hold about you in the event of your death (specifically, whether we should store or delete it, and whether others should have the right to see it). You may:
(A) issue general instructions to a digital service provider registered with the French data protection supervisory authority (called “CNIL”) (these instructions apply to all use of information about you); or
(B) give us specific instructions that apply only to our use of information about you.
Your instructions may require us to transfer information about you to a third party (but where the information contains information about others, our obligation to respect also their privacy rights might mean that we can’t follow your instructions to the letter). You may appoint a third party to be responsible for ensuring your instructions are followed. If you do not appoint a third party in that way, you successors will (unless you specify otherwise in your instructions) be entitled to exercise your rights over information about you after your death:
(i) in order to administer your estate (in which case your successors will be able to access information about you to identify and obtain information that could be useful to administer your estate, including any digital goods or data that could be considered a family memory that is transferable to your successors); and
(ii) to ensure that parties using information about you take into account your death (such as closing your account, and restricting the use of, or updating, information about you).
You may amend or revoke your instructions at any time. For further information on the processing of information about you in the event of your death, see Article 40-1 of the law 78-17 dated 6 January 1978. When you die, by default, you will stop using your account and we will delete information about you in accordance with our retention policies (see the paragraph “How long will information about you be kept?” for details).
If you have any questions, or wish to exercise any of your rights, you can find contact details for the relevant PMI affiliate, and if applicable data protection officer, here. Contact details will also be given in any communications that a PMI affiliate sends you.
If your country has a data protection authority, you have a right to contact it with any questions or concerns. If the relevant PMI affiliate cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.
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.
Last modified December 2018.