Terms & Agreements

• PRIVACY NOTICE

We take privacy seriously. This notice tells you (“Data Subject”) who we are, what personal data about you we collect and provides you with information about the processing thereof. We will use information about you only in accordance with applicable data protection laws and these T&A.

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.

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• CONTROLLER

The controller within the meaning of the Federal Act on Data Protection is JT International SA (JTI), a company with registered office address at 8, rue Kazem Radjavi, 1202 Geneva, Switzerland.

If you have any questions about data protection and the processing of your personal data, you can contact the controller at the following email address: XXXXXX.

You may exercise any rights you may have under the Federal Act on Data Protection at any time. In particular, you have the right to obtain information about your stored personal data, to correct or supplement it, object to it being processed or request it be deleted at any time.

You can request the deletion of your personal data, object to the use of your personal data for marketing communication purposes and make certain corrections to your personal data yourself at any time in your user profile. For all further inquiries or exercise of rights, you can contact us at any time at the above-mentioned email address.

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• SITE USAGE

By agreeing to these T&A (by clicking the checkbox), you confirm that you are over the age of 18 and that you are a smoker, vaper, or consumer of nicotine containing products and you consent to the collection and use of your personal data in accordance with these T&A and any applicable data protection laws or regulations.

You consent to interacting with all Ploom brand related information that is present on <address of the web page we use> and you understand that we are not encouraging or discouraging you to or from smoking.

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• PERSONAL DATA COLLECTION AND PROCESSING PURPOSES

While using our Site, we may ask you to provide us with certain personal data. Personal data includes:

• Full name

• Email

• Mobile Number

• City

We use and process the above personal data to contact you, through the local subsidiary at your place of residence to present to you our offers and updates regarding our products and for market research purposes.

In detail, we may use the personal data of Data Subjects:

• To contact them with newsletters, marketing or promotional materials and other information via:

• SMS

• Phone calls

• Emailers

• WhatsApp messaging;

• For market research purposes about the products;

• To analyse our business strategies, improve our products and develop and launch new products;

• To develop and implement marketing strategies and campaigns.

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• RECIPIENTS OF PERSONAL DATA AND TRANSFER ABROAD

JTI ensures that only those employees of JTI who need to process your personal data in order to fulfil the purposes for which it was collected have access to it.

In some cases, we may appoint third parties to provide us with the technical and/or organisational services we need to carry out our business activities. In this context, these third parties may process your personal data. Third parties appointed are, in particular, the following categories of data recipients:

• Companies within the JTI Group;

• Service providers who assist us in providing you with our products and offers, conducting our business activities and/or complying with our legal obligations (e.g. hosting providers, age verification services, email delivery providers, market research service providers);

• Business partners and suppliers who support us in fulfilling our contractual obligations (e.g. sellers of our products, advertising agencies, courier services).

The third parties that process your personal data are contractually obliged to process it solely on our behalf and in accordance with our instructions. We also oblige the third parties to comply with technical and organisational measures that ensure your personal data is protected in accordance with the applicable data protection regulations.

By consenting to these T&A you expressly agree that your personal data may be disclosed to the countries listed herein. Irrespective of your consent, in the event of disclosure to these countries we will always ensure that appropriate data protection is guaranteed for disclosure and processing, or that disclosure is absolutely necessary. In particular, this is ensured in the following ways:

• The Federal Data Protection and Information Commissioner (FDPIC) or the Federal Council has certified that the state can provide adequate protection; and/or

• Standard data protection clauses approved, issued, or recognised by the FDPIC in advance are agreed; and/or

• Disclosure is directly related to the conclusion or processing of a contract between us and you or between us and one of our service providers in your interest.

Your personal data is currently processed in the following countries:

• Switzerland;

• Kingdom of Saudi Arabia

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• DATA SECURITY

We take technical and organisational measures to ensure that your personal data is protected against unauthorised and/or unlawful loss, alteration, disclosure, or access – and contractually obligate all of our recipients of your personal data to do so too. Please note that it is unfortunately not possible to guarantee complete security when transferring personal data and information in general over the Internet or by other electronic means.

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7 APPLICABLE LAW AND PLACE OF JURISDICTION

These T&A are subject to the substantive provisions of Swiss law. The sole place of jurisdiction is Geneva, Switzerland.

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