In principle, we only process your personal data to the extent necessary to provide our content and services and if you are a registered user of our website. Your personal data will only be processed with your consent. An exception applies in cases where prior consent is not possible for factual reasons and/or the processing of your personal data is permitted by law (e.g. for the purpose of concluding or performing a contract with you).
1.2 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: [email protected].
2.1 We primarily process personal data that you provide to us when registering and using this website (e.g. participating in contests, announcing your preferences) or that you provide to us by email, post or other means.
2.2 We also process personal data that we receive about you from third parties. This includes personal data that we receive from our platform providers (e.g. hosting providers) and their affiliated third parties. It also includes personal data that you provide to us on other platforms (e.g. winston.ch or camel.ch) that we operate. In addition it includes personal data that we receive from third parties commissioned by us who provide services to us, e.g. payment service providers, courier services, sales outlets, age verification service providers, technical service providers and market research providers.
2.3 The following categories of personal data may be processed by us:
2.4 If you would like to perform an age verification using an official ID, please note that you will need to take photos of one of your official IDs (ID, passport, driving licence) and scan your face to capture your biometric data. Age verification is carried out on behalf of JTI by an external IT service provider, Veriff OÜ, a limited liability company entered in the Estonian Commercial Register (registration number: 12932944). The data we collect is primarily used for age verification. In addition, Veriff OÜ becomes the controller of your data provided during the age verification process to the extent necessary to demonstrate compliance with the regulations applicable to Veriff OÜ and to further develop, test, improve and modify the functionality of the age verification process, machine learning (data annotation for testing and training), fraud prevention and detection, and to create anonymised or anonymised and aggregated statistical reports and research. For the avoidance of doubt, we expressly draw your attention to the fact that Veriff OÜ does not use your personal data for marketing purposes. You expressly agree to this data processing. Veriff OÜ’s Privacy Notice is available at https://www.veriff.com/privacy-notice.
3.1 We use and process your personal data primarily to contact you, present our offers to you and to promote customer loyalty and engagement for and on Ploom.ch. In detail, your personal data is used for the following purposes:
4.1 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.
4.2 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:
4.3 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.
4.5 Your personal data is currently processed in the following countries:
5.1 For marketing purposes, we will only contact you electronically or by post. You can change the means by which we contact you at any time in your user profile and allow or prohibit individual marketing communication channels. Please note that not all marketing communication media may be visible in your user profile. If a method is not visible in your user profile, please let us know by emailing [email protected] if you wish to unsubscribe.
5.2 Please note that it may take up to 30 days to register or unsubscribe from individual marketing communications. The reason for this is that your personal data may already be included in an upcoming distribution and cannot be removed from it individually.
7.1 Your personal data is generally kept for as long as you are a registered and active user of ploom.ch.
7.2 You can delete your user account at any time. Once you have asked for your user account to be deleted, your personal data will be completely anonymised within 28 days. This means we are unable to draw any conclusions about you as a person. Data we are required to retain due to legal obligations is not deleted. In particular, this includes data in connection with an order. This data is anonymised once the statutory retention period has expired.
7.3 If you do not log into your user account for two years, we will delete it and anonymise your personal data. This does not apply to data that we are obliged to retain due to legal obligations (see previous paragraph). Before deletion takes place, we will notify you by email.
8.1 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.
9.1 You may exercise any rights you may have under the Swiss Data Protection Act 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.
9.2 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 following email address: [email protected]
9.3 Where Veriff OÜ processes data as a controller (see section 2.4), the contact information for further enquiries or to exercise your rights may be found in that company’s privacy notice (available at https://www.veriff.com/privacy-notice).
9.4 Please note that the rights mentioned in section 9.1 may be restricted or excluded in individual cases, e.g. if there are doubts about your identity or this is necessary to protect other people, protect legitimate interests or comply with legal obligations. Please also note that we reserve the right to request a copy of your passport or other identification document in cases of doubt.
Dagmersellen, September 2023
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