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Privacy and Personal Data Protection Statement

dated March 11, 2019

By using this Website and accepting the Terms of Website Use and this Privacy Statement, you confirm that you are at least 18 years of age, reside in Ukraine, and are a consumer of tobacco and/or tobacco-containing products; you unconditionally and irrevocably understand and agree to the following terms and purposes of your personal data use, and also unconditionally and irrevocably understand and agree that such use of your personal data shall not be grounds for payment of any remuneration or compensation to you. I give consent for processing of my personal data in accordance with PMI Privacy Notice.

PMSD LLC respects its consumers' privacy. We undertake to take appropriate measures to secure the personal data you provide to us when visiting and using this Website. This Privacy Statement describes all types of personal data we receive through the Website, how we use them and whom we provide them to, and also indicates that you grant your consent to PMSD LLC to process your personal data. Our Privacy Statement also describes the measures we take to ensure information security.

If you do not agree to this Privacy Statement, you may not use the Website. We reserve the right to make changes at any time to this Privacy Statement, so we recommend you regularly review our website privacy statement.

1. Consent to Processing Your Personal

Data Your registration on the website shall mean that you grant consent to use and process your personal data and perform other actions stipulated by the Personal Data Protection Act of Ukraine. You confirm that all of your personal data are reliable and accurate. You fully understand that you are liable for providing PMSD LLC with inaccurate personal data.

You confirm that you voluntarily and at no cost provide PMSD LLC with your consent to any perpetual processing of any of your personal data (including surname, name and patronymic, birth date, residential address, landline and/or mobile telephone number, e-mail address, information about your consumption of tobacco-containing products, etc.) in the database of adult consumers of tobacco-containing products of PMSD LLC, including collection, registration, inclusion in databases, accumulation, storage, adaptation, change, update, use, dissemination (distribution, sale, transfer, granting access to any third parties, including non-residents (foreign parties to relationships), without any separate notice to you of such distribution, sale, transfer or granting access), anonymization, destruction of personal data in personal database, both in the territory of Ukraine and abroad, and otherwise collecting, perpetual storing, using and distributing your personal data in order to: (1) provide you, as an adult consumer, with information about upcoming events, arrangement, and services, as well as relevant and reliable information about the Products, devices for its use or employment, as well as the sales points, pursuant to consumer rights protection legislation of Ukraine, (2) make and execute transactions via Internet shop and fulfill the terms of such transactions, (3) receiving feedback regarding quality of customer support, analysis of consumer opinion related to Products, etc., (4) and for another purpose to be separately identified by correspondence or verbally by phone call.

You also hereby agree to entitle any third parties, including non-residents (foreign parties to relationships), to process your personal data for the said purpose. In addition, you consent to FMSD LLC to process your personal data for this purpose, if such personal data has been transferred to FMSD LLC by third parties, provided that such persons obtain your consent and comply with other requirements of Ukrainian legislation on personal data protection.

You also confirm that you voluntarily grant to PMSD LLC, its branches, affiliates, and their authorized persons your consent to PMSD LLC to obtain/perpetual store copies of documents (passport, driving license, etc.) provided by you necessary for your identification and verification of your age if these were provided. You authorize PMSD LLC, its branches, affiliates, and their authorized persons to send information to the addresses, e-mails and phone numbers specified by you according to the purpose of your personal data processing. You agree to immediately inform PMSD LLC of any change in your personal data and/or status as a tobacco-containing product consumer. You also confirm that PMSD LLC may verify your personal data, including the mobile phone number, involving the respective mobile operator. For the purposes of such verification, you enable PMSD LLC and the appropriate mobile operator to exchange data relating to your telephone number. This agreement shall be valid until you revoke it by sending a written notice to PMSD's mailing address.

This is to inform you that your personal data are owned by PMSD LLC. When registering on the Website, the following personal data may be collected: surname, name, patronymic, birth date, place (address) of residence (registration), landline and/or mobile phone numbers, e-mail address, sex, etc. As a personal data subject, you shall be entitled to: 1) know about the sources of collection, location of your personal data, the processing purpose, place of location or place of residence (stay) of the owner or manager of personal data, or give a corresponding order for obtaining this information to authorized persons, except when established by law; 2) receive information about the conditions for granting access to personal data, in particular, information about the third parties to which your personal data are transferred; 3) access to your personal data; 4) within thirty calendar days from the date of receipt of the request, except when provided for by law, receive an answer as to whether your personal data is being processed, and also receive the contents of such personal data; 5) make a reasoned request to the personal data owner objecting to your personal data processing; 6) make a reasoned request to modify or destroy your personal data by the owner and manager of personal data if these data are processed illegally or are unreliable; 7) protect your personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, their non-provision or untimely provision, and also protect against the provision of information that is unreliable or discredits honor, dignity and business reputation of a natural person; 8) file complaints about the processing of your personal data to the Human Rights Ombudsman of the Verkhovna Rada of Ukraine or to a court; 9) take remedial actions in case of violation of personal data legislation protection; 10) warn regarding the limitation of the right to your personal data processing when giving consent; 11) withdraw consent to personal data processing; 12) be aware of the mechanism of automated processing of personal data; 13) be protected against an automated decision having legal effects for you.

For all questions concerning the processing of your personal data by PMSD LLC, please write to the address: 30 Spaska St., Kyiv, 04070, Ukraine, “PMSD” LLС, or by phone 4767, or by e-mail: support@iqos.com.ua

2. How We Protect Your Personal Data

Personal data security is a priority for us. We comply with and ensure that Eligible Third Parties comply with appropriate administrative, technical and physical security measures designed to protect against unauthorized disclosure, use, modification or destruction of personal data you provide to us when visiting and using this Website. We use secured communication channels to secure the transfer of your personal data.

3. How We Use Personal Data

When you visit our Website, your browser automatically sends us the internet protocol (IP) address and some other information (such as the type of browser you use). We do not use client-side marks for storing your personal data and access information. PMSD LLC and its branches, affiliates and their authorized persons acting in accordance with the confidentiality agreements shall be entitled to perform automated and non-automated processing, including collection, systematization, accumulation, storage, refinement (updates, modification), use, distribution (including transfer together with a cross-border transfer), anonymization, blocking, destruction of your personal data, for the purpose of any of the above persons and/or their authorized representatives to contact with you anyway in relation to the purpose of your personal data processing by electronic communication or other means (including phone calls, mail, e-mail, SMS, MMS) in accordance with the requirements of legislation of Ukraine.

4. Information We Provide

PMSD LLC does not transmit or disclose your personal data we receive on this Website to any third parties for their own marketing purposes. Your personal data received on this Website may be disclosed to any Eligible Third Parties and, to the extent not prohibited by applicable legislation, may be transferred to another country where we and/or any Eligible Third Parties carry out activities, including, but not limited to, the import of your personal data. PMSD LLC and Eligible Third Parties may also disclose your personal data if required by applicable laws. By your inclusion to our database of adult consumers of tobacco products, you will definitely and irrevocably understand and agree to the above-mentioned conditions of disclosure and transfer of your personal data.

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