Mitr Privacy Policy

We take privacy seriously. This notice tells you what we do with information about you. Use the drop down triangle to read each section.

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.

1.	Who are the 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 is using information about you, and the relevant PMI affiliate will identify itself to you when collecting your information through, for example, transparent privacy disclosures. When we say “a PMI product” (or similar, e.g. a website, a mobile application, or a call centre), we mean a product (or website, mobile application, or call centre, etc.) of ours or of another PMI affiliate. Depending on the purposes for which information about you was collected, information about you may be shared with, and accessed by, other PMI affiliates, if appropriate to fulfil those purposes. The information 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 affiliates; and the information will be shared with the PMI affiliate that is responsible for the country in which you are normally resident (if it wasn’t the affiliate that first collected the information). Each PMI affiliate that uses information about you will use it only for purposes that have been specified to you, will use it on its own behalf (and not on behalf of others), and will be individually and independently responsible for protecting the information it uses and for helping you to exercise your rights described in this notice. Details of the PMI affiliates and the countries in which they are established are available on the relevant country pages of www.pmi.com.

2.	Why am I seeing this notice?

	You have been guided to this notice because we use information about you. This may be because: • you are a retailer of PMI products; • you have used a PMI “digital platform” (that is, a website or a mobile application); • you have communicated with us in relation to PMI products or services (for example, through a call centre); or • we have collected the information in other contexts that were made apparent to you at the time. This notice provides you with important details about how we use and share information about you, and your rights in relation to that.

3.	How to read this notice?

	This notice gives you general information about the way we use personal information about you. However, we cannot predict exactly how information may be used in the future, so we may provide further information when we interact with you, for example, in notices provided in our digital platforms, informational materials, or marketing materials.

4.	What is the significance of this Privacy Policy?

4.1	This Privacy Policy, along with the “Terms of Use” constitute an “electronic record” in the form of an “electronic contract” as defined under the Information Technology Act, 2000 between Us and the user of the relevant PMI Product. This Privacy Policy does not require any physical, electronic or digital signature.

4.2	This Privacy Policy forms an integral part of the “Terms of Use” of this PMI Product. If You do not agree with the terms of this Privacy Policy, please do not use this PMI Product. By using / visiting this PMI Product You (a) unconditionally accept, and agree to be bound by the “Terms of Use” of the Website, read with this Privacy Policy; and (b) expressly consent to the collection, receipt, possession, storage, usage, dealing, handling or transfer of Your personal information by Us in accordance with the terms of this Privacy Policy.

4.3	We reserve the right, at our sole discretion, to change, modify, add or remove all or any portion of these Privacy Policy without written notice to You. It is Your responsibility to review this Privacy Policy periodically for updates / changes. Therefore, it is suggested that You regularly check the PMI Product to be apprised of the latest changes made to the Privacy Policy.

5.	What information is collected?

	The information about you that we use may include: • Information that you provide> If you are a retailer participating in one of our trade programmes, you will need to provide your name, contact details and other details as requested in order to enable us to administer the programme, such as serving appropriate content, monitoring your compliance with the programme, administering reward schemes, designing and delivering educational materials and training etc.. You may choose to provide us with information in a variety of other contexts – for example, when: selling or dealing with PMI products or services in a store; contacting a PMI call centre; downloading and using a PMI digital platform; registering with a PMI retailer database; registering a device with us; subscribing to a PMI panel portal; registering to receive PMI press releases, e-mail alerts, or marketing communications; participating in PMI competitions, promotions or surveys; or contacting us through one of our digital platforms, or by e-mail, social media or telephone. Not all the services in the examples may be offered in your country of residence. In these cases, the information that we collect and use will normally be apparent from the context in which you provide information. For example, if you order a product from us through an online channel, you will need to provide your name, contact and billing details in order for us to fulfil your order. • Information that is collected automatically When you browse and access PMI digital platforms, we may collect and use certain information about your device and use of those digital platforms. The information collected may include details of your IP address or unique device identifier, location data, details of any cookies that we may have stored on your device, and details of the pages accessed, search terms entered, or links clicked within the digital platform. • Information that we acquire from third parties From time to time, and only 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 on third party social media sites (such as Facebook and Twitter), and marketing lists acquired from third party marketing agencies.

6.	How do we use information?

	We may use and share personal information about you for a variety of reasons, which will be specified to you, or be clear from the context, at the point information about you is first collected. We will collect and use information about you only in accordance with applicable data protection laws. General uses of information about you In general, we may use information about you for the following purposes: (a) information that you provide is typically used for verifying your age and retailer status; dealing with your inquiries and requests; enabling you to use PMI digital platforms; administering your orders and accounts; monitoring your compliance with any programme; processing payments; administering loyalty programmes (where permitted by law); correspondence, including sending you (where permitted by law) marketing communications in accordance with your communications preferences; administrative and troubleshooting purposes; improving PMI products and the information that we (or our affiliates) provide to our customers; inviting you to participate in surveys or market research campaigns; providing you with information about, and managing, PMI affiliates, their promotions (where permitted by law), products and services, events and the regulation of tobacco products; and developing and improving tools to pursue these purposes; (b) information that is collected automatically is typically used for business-analytics related reasons; to manage the relationship with you; to send you personalised communications that may interest you; and to assist us, and our affiliates, to improve the products and services we (and they) offer; and (c) information that PMI affiliates acquire from third parties may (where permitted by law) be combined with other information about you in order to update or supplement PMI affiliates’ records, to learn more about your preferences, and to provide you with information about PMI products or services that is better tailored to your needs. Specific uses of information about you 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.

7.	How do PMI affiliates share information?

	As well as sharing information about you between PMI affiliates for the reasons explained above, we may also share personal information about you with: (a) third parties who provide PMI affiliates or you with products or services (such as advisers, payment service providers, delivery providers, information services providers and age verification providers, if any); (b) PMI affiliates’ carefully-selected third party business partners and advertisers so that they can contact you with products, services and promotions that they think may interest you, in accordance with your preferences for trade programmes, educational materials and training; and (c) 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.

8.	Do PMI affiliates use cookies and similar tracking technologies?

	Cookies or similar technologies may be used on PMI digital platforms to collect certain information automatically. The specific cookies and technologies used will depend on the digital platform in question. For that reason, to learn about the cookies (including Google analytics cookies) and similar technologies used on a digital platform, including how you can accept or refuse cookies, please see the cookie notice made available on or through that digital platform. For example, to learn about cookies or similar technologies used on the www.pmi.com website, please visit the pmi.com cookie notice, a link to which is available within the footer to every page of the website. The pmi.com cookie notice is also available here.

9.	How do I unsubscribe from marketing?

	All PMI affiliates offer an easy way to opt out from receiving marketing communications, such as an “unsubscribe” link, or contact address provided in the message you have received. Some mobile applications offered by PMI affiliates 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.

10.	What security measures are in place to protect information?

	We, like other PMI affiliates, 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 requirements.

11.	Where might information about me be sent?

	As with any multi-national organisation, PMI affiliates transfer personal information globally. Accordingly, personal information about you may be transferred either within or outside the country or territory where it was collected, including to a country, territory or international organisation that may not have equivalent data protection standards. For example, PMI affiliates within the European Economic Area, Croatia and Switzerland (“Europe”) may transfer personal information to PMI affiliates outside Europe for the purposes described in this Notice. In all cases, the transfer will be on the basis of a European Commission adequacy decision or PMI affiliates will implement adequate measures (including appropriate security measures) for the protection of personal information in those countries, territories or international organisations in accordance with applicable data protection laws. We may transfer sensitive personal data or information obtained from You to any other body corporate or person in India, or located in any other country, subject to the condition that such person ensures the same level of data protection that is adhered to by us in India. We may transfer such information for any purpose as specified in this Policy.

12.	How long will information about me be kept?

	The period for which we may retain personal information about you will depend upon the purposes for which the information was collected, whether you have requested the deletion of the information, and whether any legal obligations require the retention of the information, (for example, for tax and accounting purposes). In general, we will not retain personal information about you for longer than is necessary to fulfil the purposes for which the information was collected.

13.	What rights do I have in relation to information about me?

	You may have some or all of the following rights in respect of personal information about you that we hold: (a) request us to give you access to the information; (b) request us to correct it, or update it; (c) request us to erase it. In addition, you may unsubscribe from any marketing communications we send you by following the instructions provided above under the heading “how do I unsubscribe from marketing?”

14.	Who do I contact with questions or grievances?

	If you have any questions, or wish to exercise any of your rights, you can find contact details for the relevant PMI affiliate on the relevant country page of www.pmi.com. Contact details will also be provided within any communications that a PMI affiliate sends to you. If your country has a data protection authority, you have a right to contact your local data protection authority 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. Grievance Officer. Any grievances with respect to any information provided to PMI affiliate(s) in India may be addressed to the following officer: Name: Harraj Singh Contact Details: Address: 4th Floor, Caddies Commercial Tower, Pullman-Novotel Hotel Complex, Asset No.2, Hospitaity District, Aerocity, Near IGI Airport, New Delhi-110037 Phone: +91 (11) 4219 5409 Email: Harraj.Singh@pmi.com Time: 10AM – 5PM (Monday to Friday) The Grievance Officer shall redress all grievances within one month from the date of receipt of grievance.

	Traders (pmiprivacy.com)