Your specific information for the use of
the means of remote legal age verification

Data Controller for the processing of your personal data is the industrial société anonyme under the name "PAPASTRATOS SINGLE MEMBER CIGARETTE INDUSTRIAL SOCIETE ANONYME" and the distinctive title "PAPASTRATOS ABES", with its registered office at Aspropyrgos, Imeros Topos, Kororremi, with GEMI registration number 227601000, VAT number 094011481, Tax Office of Athens, telephone number 210 4193000, fax number 210 4112303 (hereinafter referred to as the "Company" or "We").

1. What is the Purpose

1.1 Our Website and all our Programs are addressed to adults only; you declare responsibly to us that you are of legal age at the age gate when entering and/or using our Website and your Account. Our Company must, however, confirm that legal age for the sale of its Products to you, due to their nature, as well as when offering services to you related to any of our Programs ("the Purpose").

1.2. You are given the possibility to choose the mean that best suit you in order to fulfill this Purpose since you can opt either to conduct remote age verification (by scanning your face or via a Video Call or other remote age verification methods as applied by the Company from time to time) and/or alternatively to verify your age with physical means (at the first delivery of the product and/or by visiting one of our stores). In any case, if you choose technical means of remote age verification for your purchases via our remote channels (www.iqos.gr and/or www.zyn.com and our call centers) these tools are the necessary and appropriate ones to fulfil our legal obligation remotely.

1.3. For the avoidance of any doubt legal age in Greece is considered over 18 years.

1.4. This legal age verification procedure appears to you, at this stage, since this verification was not previously completed in any other way or in another sales or communication channel with our Company (e.g. in the physical store, call center, previous remote purchase or other).

2. What data we process about you and how we process it

You are free to choose one of the means of remote or physical legal age verification we offer as laid down below. For purchases through our call center, in specific, the remote age verification is conducted only via the Video Call. You can always opt alternatively to conclude the procedure with physical presence (either upon first delivery or by visiting one of our stores)

The data we collect from you are simple data (and not sensitive or special category) that are necessary, appropriate, relevant and adequate for the fulfilment of the Purpose within our legal obligation. In particular, depending on the way you opt to conclude your legal age verification:

a) With regard to the process of legal age verification through the scanning of your face, this takes place with the use of the camera of the device you are using while you are in our Website; we only conduct legal age verification with a general analysis of your face characteristics by means of an AI technical application (you may see more detailed information at www.yoti.com) based on a statistical estimation of general age parameters analyzed by the system, with a minimum error rate. This process is carried out real time; no data or characteristic of yours are stored in any way, no profile is created and no identification nor processing/ connection with biometric data or databases is carried out by this method.

b) With regard to the process of legal age verification via a Video Call, your legal age is verified through the use of a camera, by reviewing your face and the data of the Adult Smoker Account you have created, with human intervention by one of our agents, in real time. We duly inform you prior to starting the process that a recording of the sound of the call takes place (not the image), based on our legitimate interest to keep a proof of the legal age verification process.

c) With regards to physical verification, 1) at delivery of your first order and/ or 2) in Store our agent (courier or sales person respectively) will confirm your legal age in person and/or requesting to show an appropriate government issued document that proves your adulthood. Note that we do not collect nor store any identification documents.

3. Information regarding the procedure of remote age verification in specific

3.1 When you opt for the remote legal age verification (scanning of your face or Video Call), You must follow the instructions given to you in our Website correctly. In order to be able to proceed with your remote transaction and/or receive the services of a Program, you must successfully complete the process of legal age verification, as applicable per case.

3.2 In case that the scanning of your face cannot be successfully concluded for any reason, twice, you can opt to have a human intervention for your verification via a Video Call and/or physical verification.

3.3 For the legal age verification via a Video Call you will be connected by a link sent in the chatbox, to one agent to proceed with age verification through the Video Call.

3.4 In case that the verification with human intervention (Video Call and/or physical verification) fails once, there is no alternative way for verification.

3.5 In any case that legal age verification is not fulfilled with any of the means set above, we follow a process of automatic log out from your Account as well as deletion of the data and/or termination of the call through the call center, as appropriate.

4. Your free consent

4.1 The process of legal age verification is mandatory in order to fulfil our legal obligations under the Purpose, as explained also in our general Privacy Policy. You may, however, freely choose any of the above means of remote or physical legal age verification. By choosing an age verification mean you provide to us with your consent for the Purpose (i.e. the use of the specific tool for the Purpose). It is noted that if you opt for the scanning of your face, you still have the right for human intervention regarding your age verification via the Call Center and/or the physical verification, as laid down in article 3.2.above.

4.2 Once your legal age is verified, you may continue making distance transactions with us, and/or participating to our Programs and receiving the services, notwithstanding however any re-verification or new confirmation that our Company may deem necessary at its discretion, for any reason at any stage and for any of its programs or services.

4.3 You may ask to unsubscribe at any time from our Adult Smokers Database, and/or your Account, and/or from any of our programs you have separately enrolled in at any time subject to the respective terms and conditions. The above, does not affect of course the lawfulness of the remote age verification processing carried out on the basis of your consent (which processing was anyway temporary and real-time). In the event you exit from the Adult Smokers Database, the whole process of legal age verification may be repeated in the future, depending on the applicable procedures of our Company at the time you opt to re-register or re-transact with us.

5. Categories of Recipients

For the due fulfillment of the above procedures, we cooperate with trusted, reliable and reputable provider of remote legal age verification services that are able to meet and respond to all the appropriate guarantees of data protection and security of their systems and their procedures based on the legal requirements and the strict conditions set by the policies of PMI. We also use partners to provide call center services, as well as Video Call services and/or on premises legal age verification, in general, such as courier and logistic center providers as well as agents. We may also cooperate for this process and for the completion of the Purpose with our parent company and/or our subsidiaries and/or our Group affiliate companies. Transfers to third countries, if any, are based on compliance with appropriate safeguards under applicable law, including also transfer to a country that has obtained an adequacy decision for Yoti (UK).

In addition to the above, all the provisions of our general Privacy Policy apply and complements the present information; you are informed of our Privacy Policy and accept it when you choose to use the tools of remote age verification.