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SMOKE-FREE FUTURE 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.

This notice applies to the Smoke-Free Future website (“this website”).

Please also read our Smoke-Free Future Terms & Conditions which provide more information about your use of this website, the purpose of this website and any restrictions on eligibility that may apply.

We are Philip Morris Limited, a member of Philip Morris International. Our details (name, address, etc.) will have been given to you separately at the time of 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.

  • 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 Philip Morris Limited.

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).

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);
  • download, or use, a digital touchpoint (e.g. an app or a website);
  • contact us through a touchpoint, or by e-mail, social media, telephone or SMS;
  • 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:

  • attend an event that a PMI affiliate has organised (e.g. through sensors at the event that connect with mobile technology);
  • communicate with us (for example, through a 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 our Smoke-Free Future initiative)

We may also collect information about you automatically through the use of cookies and similar tracking technologies on digital PMI touchpoints (e.g. through your use of this website). 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 this website, including how you can accept or refuse cookies, please read the Smoke-Free Future Cookies Policy.

Where permitted by law, we may acquire information about you from third parties. This may include publicly-available profile information (such as your preferences and interests) on third party social media sites (such as Facebook and Twitter).

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 you give us in forms or surveys
  • information about your visits to our events
  • information about your preferences and interests

Information that we collect from you directly will be apparent from the context in which you provide it. For example:

  • if you sign up to join our Smoke-Free Future initiative, you provide us with your name and contact details;
  • you can also choose to provide information on your preferences and interests (e.g. smoking status) so that we can send you relevant information that will interest you;

Information that we collect automatically will generally concern:

  • details of your visit to this website (such as time and duration);
  • at an event, how frequently you visit, which areas you visit and for how long;
  • your use of this website (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 this website); 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.

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 communicate to you about our Smoke-Free Future initiative and its related programmes, market research and surveys, developing communication strategies, administering campaigns or programmes, and customizing your experiences when you visit this website in the future or when you sign up to our Smoke-Free Future initiative.
  • For us or our business partners to inform you of potential opportunities to get involved in other programmes that we may launch in the future under our Smoke-Free Future initiative.
  • To support all the above, including enabling you to use PMI touchpoints, corresponding with you, customizing your experiences of PMI touchpoints, and administration and troubleshooting.
  • For business analytics and improvements, including improving PMI events, and the information that we provide to users of this website.
  • 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:

  • a legitimate business interest that is not overridden by interests you have to protect the information;
  • where necessary, 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
Communicate about Smoke-Free Future
  • understand your preferences (such as what product categories or events may interest you, or may be better tailored to your needs)
  • invite you to participate in, and administer, surveys or market research campaigns for Smoke-Free Future
  • develop communication and public engagement strategies
  • administer communication and public engagement campaigns
  • customize your experience of PMI touchpoints (for example, to personalize your visit to this website and communications you may receive from us, 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 cookies, 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 operate PMI touchpoints, and to customize your experiences. For using your information to send you direct communications about Smoke-Free Future and related programmes in electronic format, we do so only if we have your consent. You provide us with consent to use your information for this purpose when you sign up to our Smoke-Free Future initiative.

We use your information in these ways that is not overridden by your interests, rights and freedoms to protect information about you.
Market our Smoke-Free Future initiative
  • provide you with information about Smoke- Free Future and related programmes
  • send you targeted online advertisements about Smoke-Free Future and related programmes
  • 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.

For using your information to send you direct communications about Smoke-Free Future and related programmes in electronic format, we do so only if we have your consent. You provide us with consent to use your information for this purpose when you sign up to our Smoke-Free Future initiative.
Support for all the above purposes
  • enabling you to use PMI touchpoints (for example, allowing you to remain logged in to sections of a touchpoint that are reserved for authorized users only).
  • corresponding with you
  • 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 enhance your experiences and provide you with targeted advertising, we are supporting marketing and so we use it on the grounds that we have a legitimate business interest to advertise our Smoke-Free Future initiative and related programmes to you, which 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 promoting our Smoke-Free Future initiative
  • for business analytics and improvements (events, digital PMI touchpoints and the information that we provide to you)
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, PMI touchpoints, this website, events, and to invite others to get involved in promoting our Smoke-Free Future initiative, 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.

We may share information about you with:

  • third parties who provide us or you with products or services (for example, Google and Facebook);
  • PMI affiliates’ carefully selected business partners and advertisers (in areas connected with our Smoke-Free Future initiative) so that they can send you Smoke-Free Future related communication that they think may interest you, in accordance with your preferences; and
  • other third parties, where required or permitted by law.

Sharing data with other PMI affiliates

  • Information about you may 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 affiliates. Philip Morris International Management SA may process the information about you for all the purposes described in this notice.

Sharing data with Third Parties

  • We may share information about you with third parties who provide us or you with products or services (such as advisers, information services providers, etc.).
  • 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 Smoke-Free Future initiative) so that they can send you Smoke-Free Future related communication 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 illegal activity; and in the context of organisational restructuring.

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:

  • 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.

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:

Type Explanation/typical retention criteria
  • marketing to you (including marketing communications) (if you use digital touchpoints and are contactable)
Most of the information in your marketing profile is kept for the duration of our marketing relationship with you; for example, while you continue to use digital touchpoints, or respond to our communications. However, some elements of your marketing 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.
  • marketing to you (including marketing 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 marketing 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 during that time. The reason is that in these circumstances, we assume you would prefer not to receive the communications.
  • marketing to you (including marketing 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.
  • marketing to you (including marketing communications) (incomplete registrations)
If you commence registering yourself in a database, but do not complete the process (for example 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. marketing communications), 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.
  • 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 PMI touchpoints and anonymised/aggregated shortly afterwards.

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.

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.

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
  • 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
  • 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
  • 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:
  • you have provided data to us; and
  • 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

For other countries please consult the website of your country’s authority.

According to which country you are in, you may have some additional rights

If you have any questions about this Privacy Policy, or wish to exercise any of your rights, please contact privacy.officer@smokefreefuture.co.uk Our general contact details will also be given in any communications that a PMI affiliate sends you.

You have a right to contact the Information Commissioner’s Office with any questions or concerns. If we 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.