Privacy and Cookies


Effective Date: August 21, 2014

This privacy policy (the “Privacy Policy”) applies to your use of the website and all documents, Web pages, and other Content (as hereinafter defined) hosted thereon and thereunder (the “Site”). Philip Morris Management, S.A. (“PM”) and its Affiliates and subcontractors will operate the Site and provide and update the Content on the Site. As used in these Terms of Use, “Content” includes any information, articles, publication, models, communications, software, text, photos, video, graphics, music, sounds, data and other material and services that can be viewed by users on our Site.

Use of the Site is subject to your agreement with this Privacy Policy. You agree to be bound by this Privacy Policy as set forth below.

We respect your privacy and value the relationship we have with you. This Privacy Policy describes the types of personal information we may collect on this Site, how we may use that information, and with whom we may share it. Our Privacy Policy also describes the measures we take to protect the security of the information you provide to us through this Site. We also inform you how you can reach us to answer any questions you may have about our privacy practices.

1. Types of Information

Collected In order to customize the Site for you, to modify and enhance the Site, we may collect two types of information about you:

Personally Identifiable Information”  This refers to information that lets us know the specifics of who you are.  We collect this information from you (such as your name, address, telephone number, and e-mail address) only if you provide it to us, for example by emailing us or registering on the Site.

Non-Personally Identifiable Information” This refers to information that does not by itself identify a specific individual.  This information may include the Web site’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what Web browser you are using, and your Internet Protocol (“IP”) address.  A URL is the global address of documents and other resources on the World Wide Web (“Web”).  An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the Web.

2. Effect and Modification

By submitting your Personally Identifiable Information to us, you consent to the collection and use of your Personally Identifiable Information in accordance with this Privacy Policy.  We may need to change this Privacy Policy from time to time for various purposes, including to reflect or address changes made to the Site or the Content.  We will post the revised Privacy Policy on the Site, indicate the effective date of the revision and inform you that this Privacy Policy has been changed.  To continue using the Site you must agree to such a revised Privacy Policy.

3. Collection Methods and Use of Information

We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us.  You provide certain Personally Identifiable Information to us when you send email messages, submit forms or transmit other information by telephone or letter.

In addition, we may also collect, or our content server may collect, certain Non-Personally Identifiable Information.  This information, if collected, is compiled and analyzed on both a personal and an aggregated basis.  This information may be automatically collected by your use of the Site, for example as described in Section 8 of this Privacy Policy.

If collected, we will primarily use your Personally Identifiable Information to operate the Site.  We will also use Personally Identifiable Information and Non-Personally Identifiable Information to enhance the operation of our Site, statistically analyze use of this Site, and modify or customize our Site’s content or layout.  We may use Personally Identifiable Information to deliver information to you and to contact you regarding administrative notices.  We may also use Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Terms of Use and this Privacy Policy.

4. Release of Information

We do not sell, trade, or rent your Personally Identifiable Information to others. We do provide some of our services through affiliates, subsidiaries, services providers, partners and other third parties, and we may share your Personally Identifiable Information with such third parties as necessary to host and/or operate the Site (including maintaining appropriate back-ups of data) and to deliver our respective services.  When this happens, we implement contractual agreements with such third parties limiting the use of your Personally Identifiable Information to activities specific to the Site.

Occasionally we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information or Non-Personally Identifiable Information to the appropriate governmental authorities. We may disclose this information upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation.  We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities.  We reserve the right to report to law enforcement agencies any activities that we believe in good faith to be unlawful.

5. Updating and Correcting Information

You agree that the Personally Identifiable Information you provide to us is accurate and truthful.  You may change any of your Personally Identifiable Information or request that we delete your Personally Identifiable Information at any time by contacting us via the “Contact Us” link accessible from the homepage of the Site.  However, full deletion may be impossible because, among other reasons, we may not be able to delete information concerning past transactions on the Site and because your Personally Identifiable Information may be stored in archived backups.

6. Security of Information

We take privacy rights seriously and seek high levels of compliance with all applicable data protection laws and regulations. As such, we maintain safeguards to protect against unauthorized disclosure, use, alteration or destruction of your Personally Identifiable Information. However, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, YOU ACKNOWLEDGE AND AGREE THAT: (A) THERE ARE SECURITY AND PRIVACY LIMITATIONS OF THE INTERNET WHICH ARE BEYOND OUR CONTROL; (B) THE SECURITY, INTEGRITY AND PRIVACY OF ANY AND ALL INFORMATION AND DATA EXCHANGED BETWEEN YOU AND US THROUGH THIS SITE CANNOT BE GUARANTEED; AND (C) ANY SUCH INFORMATION AND DATA MAY BE VIEWED OR TAMPERED WITH IN TRANSIT BY A THIRD PARTY.

7. Transfer outside of European Economic Area and Switzerland

For residents of the European Economic Area and Switzerland, please note that your Personally Identifiable Information may be transferred outside the European Economic Area and Switzerland to countries which do not provide an adequate level of protection according to data protection regulations of the European Economic Area and Switzerland.  We will take all steps reasonably necessary to ensure that your Personally Identifiable Information is treated securely and in accordance with this Privacy Policy and the rules in respect of such disclosure, storage and transfer.  By using the Site, you expressly agree to such disclosure, storage and transfer.

8. Cookies and Web Beacons

When you use our Site we may store cookies on your computer to customize your experience with the Site and to analyze your use of the Site.  A cookie is a small text file, which a Web site stores on your computer’s hard drive (if your browser permits) that can later be retrieved to identify you to us.  Our cookies may store things such as, randomly assigned user identification numbers, the country where you are located, your name, or similar information.  If you wish to restrict or block the cookies which are set by the Site, or indeed any other website, you can do this through your browser settings. The ‘Help’ function within your browser should tell you how or you can visit which contains comprehensive information on how to do this on a wide variety of browsers. If you choose to disable cookies, some parts of the Site may not work properly.

In addition, Google Analytics, owned by Google, Inc. (“Google”), is a web analytics service used by this Site to monitor how you use the Site so that we can improve the Site.  Google Analytics also uses cookies to help it analyze how users use the Site.  The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States of America or elsewhere.  Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, but please note that if you do this you may not be able to use the full functionality of this Site. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

We may also employ Web beacons in connection with your use of the Site. Web beacons are Internet tools that help us determine, for example, whether a Web site page has been viewed. Web beacons help us to enhance the online experience of our visitors and to better understand how the Site is used. They may tell us, for example, whether you have visited the Site before or whether you are a new visitor.

9.  Privacy Policies of Third Party Sites

This Site may contain links to other Web sites, some of which may be operated by third parties.  Except to the extent we operate these sites, we are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of these sites. Moreover, such other sites have their own privacy policies and data collection, use and disclosure practices.  Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties.

10. Miscellaneous Privacy Issues

You must be at least 18 years old to have our permission to use this Site. The Site is not directed to children, and our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors who are under 18 years of age. In addition, should a child whom we know to be under 18 send Personally Identifiable Information to us, we will delete it as soon as possible.

You should also be aware that when Personally Identifiable Information is voluntarily disclosed (e.g. your name, email address, etc.) in a public area on this Site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties.  Such activities are beyond our control and this Privacy Policy does not apply to such information.  If you do not want your comments to be viewed by third parties, you should not make any submissions. NEITHER WE NOR OUR AFFILIATES, SUBSIDIARIES, RELATED COMPANIES, CONTRACTORS, SUBCONTRACTORS OR SUPPLIERS ACCEPT LIABILITY IF A THIRD PARTY POSTS YOUR PERSONALLY IDENTIFIABLE INFORMATION ON A PUBLIC PART OF OUR SITE.

11. Governing Law

You agree that this Privacy Policy is governed by the laws of Switzerland.  In the case of any dispute regarding this Privacy Policy, you agree to submit to the exclusive jurisdiction of the courts located in Lausanne, Canton of Vaud, Switzerland to resolve any legal matter arising from the dispute or claims. You hereby waive, to the fullest extent permitted by applicable law, any objection that it may now or hereafter have to the laying of venue of any such proceedings in such a court and any claim that any such proceedings brought in such a court have been brought in an inconvenient forum.

12. Contact Us

You may choose to communicate with us via the “Contact Us” link available on the homepage of the Site.  We shall use your e-mail address and name only in order to respond to your message.