Privacy Policy

1. Introduction

This Privacy Policy applies to all processing of personal data in relation to the online and offline services and the website www.iqos.nl (the Website) owned and operated by Philip Morris Investments B.V. (Philip Morris).

Philip Morris respects the privacy of all its customers and users of its Website and takes the protection of your personal data very seriously. This Privacy Policy informs you about the way Philip Morris collects, protects, uses and shares your personal data and informs you about your rights with respect to any personal information we collect and hold about you.

Please read this Privacy Policy carefully. By browsing and using the Website and using the services (including making orders), you confirm that you have read, understood, and accepted this Privacy Policy. We may amend this Privacy Policy from time to time. You can always access the latest version of this Privacy Policy on the Website.

All personal data obtained in the context of this Website or services you request from Philip Morris is collected and further processed in accordance with Dutch Data Protection Act (DDPA) and other applicable laws and regulations regarding the collection, using and protection of personal data.

2. What information do we collect

Philip Morris collects certain personal data relating to you when you visit our Website. We may collect and process the following data about you:

Visiting the Website

We are legally required to perform age verification when you order our products. For that reason, we ask you to confirm that you are 18+ as soon as you visit the Website. Only once we have verified that you are 18+, we will allow you to access the Website.

Further, you are only allowed to enter the Website related to the country you are staying in (for example, Dutch residents are only allowed to enter the Dutch website IQOS.nl and not the French website IQOS.fr). In order for us to verify this, we will process your IP address. We will store your IP address so we can verify your country of residence when you place an order, and to show regulators and or auditors that we comply with the applicable age verification requirements.

Registration / orders

When you want to place an order on the Website or if you buy an IQOS device in one of our offline shops, you will first need to register.

If buy a IQOS device in one of our offline shops we will ask you to register on the Website first and provide us with the above personal data. If it is not possible to register on the Website on that moment, we will ask you to fill in our ‘Customer Registration Form’. You will be asked to provide us with the same information as above and the serial number of the IQOS device that you will buy. After we entered your personal data into our system our customer service center will send you an email and ask you to complete your registration on our Website. We ask you to register your IQOS device for customer care reasons such as to provide you with relevant product information (e.g. recalls) or for other product services reasons. We will link the serial number(s) of the IQOS product(s) you bought (online or offline) to your account.

When registering, you will be asked to provide us the following personal data:

• first name
• last name
• address
• date of birth
• telephone number
• email address

When you place an order on the Website, you will be asked to provide the following personal data to us:

• first name
• last name
• delivery address
• billing address
• email address
• telephone number
• payment details (limited to payment details)
• IP address

We use the above types of personal data for processing your order, such as shipping the ordered products to you, handling payment transactions and replace wrong or defect products. Your payment details (such as your bank account or credit card number) are processed by our payment service provider and not by Philip Morris. We only store payment confirmations, so we can verify that you have fully paid for your order. We use your email address to send you emails with order or product information. We can use your contact details to contact you about your order, or to respond, to any questions, complaints or comments that you make in relation to your order. Orders can be placed with the login details when registration is completed. If you do not provide us with the requested information, we will not be able to (fully) process your order. We can use your full name, e-mail address and phone number in order to contact you regarding participation in market research projects for IQOS unless you indicate during the registration process that you do not want us to do so.

If you register for an account without placing any orders on the Website or registering any IQOS devices, please note that we will deactivate your account, including all your personal data within six months after your registration.

We will not use your personal data for direct marketing purposes or to advertise our products to you. Further, your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product to you and market research projects.

Deliveries

Upon delivery of your order, we are legally required to verify if the recipient is 18+. For this reason, we will require the recipient of the order to show a valid ID (in the form of an ID card, driver’s license, passport or other official document suited for age verification of the recipient, indicating that the recipient is 18+). The recipient can be the person that ordered the product, but it can also be another person accepting the delivery on the customer’s behalf. In the latter case, this person needs to prove that the person that ordered the product is 18+ as well, by showing (a copy of) the ID of the person that ordered the product.

By filling out a form on the Website

The Website provides for forms which you can use to send us a message or ask us a question. By filling out a form you will be asked to provide us the following personal data:

• full name
• email address
• your message/question

We use the above types of personal data to be able to contact you in order to respond to your question or message.

By contacting our customer service desk:

In case of questions, remarks or complaints, you can call our customer service desk on the following telephone number: 0800 – 990 0000. When you call this number, we will ask you to provide the following details to us:

• name
• telephone number
• date of birth
• details of your order / question / complaint; and
• in some cases: address - email address - Codentify device

We (only) use the above types of personal data for handling your request, question or complaint and to improve our customer service (by assessing how we can respond more effectively to your customer service requests and support needs). We ask your date of birth for age verification purposes.

When you call us, it could be possible that you want to inform us about any physical complaints you experience. Such information is considered to be ‘sensitive personal data’. To be legally allowed to process such sensitive personal data, we will have to ask for your prior consent thereto. We will do so at the beginning of each call that is made to the service desk.

Philip Morris will record any call that is made to the customer service desk for any of the following purposes:

• to record the fact that a customer has consented to the use of its personal (sensitive) data;
• to follow up on a complaint or question;
• for training purposes;
• to use as proof in potential litigation;
• for age verification purposes;
• to improve the quality of our services

This will be stated prior to the beginning of each conversation with the customer service desk.

We make use of an external call center, currently Teleperformance Portugal SA, based in Portugal, which operates the customer service desk on our behalf. This call center will of course treat your personal data, with the greatest care, strictly confidential and will only share your personal details with us to enable us to follow up on your complaints and questions, and to fulfill the above listed purposes.

3. Cookies

In addition to personal data you provide to us, we use data collection devices such as "cookies" on the Website to collect information about people who visit our website. This data may include details on IP addresses, browser type and screen resolution as well as a set of information on the habits and preferences of the user, the language used and the pages visited more frequently. A cookie is a small text file that is stored on your computer, when visiting a website. You can reset your browser to refuse cookies or warn you when they are being sent. Please note that by turning cookies off or by refusing cookies, you may not have access to all features available on the Website.

This Website uses the following types of cookies:

We use these cookies for the following purposes:

• to help us remember and process the items in your shopping cart;
• to understand and save your preferences for future visits
• to operate, evaluate and improve PMI’s business, products and services;

By means of these cookies we collect the following data relating to you:

• IP address;
• browser type and screen resolution
• Language used
• Frequently visited pages

4. How do we protect your information?

We implement a variety of technical and organizational security measures to maintain the safety of the personal data that you have provided to Philip Morris or that Philp Morris has collected about you as set out in this Privacy Policy from loss, theft, unauthorized access, destruction, manipulation and unlawful processing.

We offer the use of a secure server. All supplied personal data is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.

Furthermore, you are responsible for keeping your login name and password confidential and are responsible for all actions taken with your login name and password. If your password has been compromised for any reason, you should immediately change your password.

5. Do we disclose any information to third parties?

We do not sell or trade any of your personal data to third parties. Within the limitations of the applicable legislation, we may share your personal data with our group entities and some of our trusted third parties when this is necessary to operate our Website, conduct our business or provide our services to you, and only if those parties agree to keep this information confidential and provide adequate safeguards to keep your data safe.

We share your contact details, billing and shipping addresses and payment details with our carrier, (currently the company Arvato) in order to enable this carrier to handle the delivery of your order(s). The delivery timeslot will be communicated to you on the day of delivery by the carrier by SMS (or other means of communications).

We share your personal data with our external call center operator in order for it to operate the call center on our behalf. They also share your personal data with us.

We may share your personal data with other parties than the ones described above, but only if we are legally obliged to do so or to protect our rights, property or safety.

6. Data transfer

The Philip Morris entities and contractual partners with whom we may share your personal data may be located in countries outside the European Economic Area (“EEA”). We shall take adequate measures to ensure that this takes always place in accordance with the relevant legislative requirements in this respect.

7. Retention of your personal data

Philip Morris is aware of the importance of timely deletion of your personal data. Philip Morris shall keep your personal data only for as long as necessary for the purpose for which we collected or processed it.

The personal data in your account will be deactivated within six months after your registration on the Website, in case you never used your account to order products on the Website or to register one of your IQOS devices.

8. Right to information and exercise of your rights

As per your request, we will inform you in writing on whether and what personal data relating to you is collected and processed by Philip Morris in accordance with the applicable law and regulations governing the collection, using and protection of personal data. You may address such request to the following email address: info@iqos.nl. Furthermore, if you want to amend or update the personal information you have provided to us (for example, because it is no longer accurate, incomplete or no longer relevant), or if you wish to exercise your ‘right to be forgotten’ or right to data portability, please also contact us at: info@iqos.nl.

If you are not satisfied with the way we handle your personal data, or any questions or complaints you may have in that respect, please be aware that you can always file a complaint with your local data protection authority in that regard.

If you no longer wish to receive any messages (containing order or product information or product or service updates) from Philip Morris, you may object to the use of your personal data for these purposes by Philip Morris at any time, free of charge, by sending an email to info@iqos.nl.

9. Third party links/services

The Website may include links to third party websites and may link to services of third parties (such as the payment service). Philip Morris cannot in any way be held liable for the processing of personal data by these third parties. These third parties have separate and independent privacy policies. We encourage you to review these privacy policies prior to visiting these websites or using these services.

10. Contact details

Should you have any questions or comments about this Privacy Policy or if you have any queries relating to the processing of your personal data, please contact Philip Morris via info@iqos.nl or 0800 990 00 00.