Personal Data Information

Purpose of data processing

Legal basis for processing

For the purpose of verifying age to ensure that products and services are provided to individuals above the legal age limit in accordance with applicable legislation

It is necessary for processing to be carried out in order to fulfill our legal obligation

For the purposes of establishing a contract between us and the consumer within the scope of providing products and services, and fulfilling, monitoring, and concluding our obligations arising from this contract

If processing is necessary for the performance of a contract to which you, as the data subject, are a party, or in order to take steps at your request prior to entering into such a contract

For the purpose of enabling consumers to benefit from various campaigns, programs, services, or applications in compliance with applicable laws

Your explicit consent as the data subject given in a manner that leaves no room for doubt

For the purpose of providing consumers with informative and promotional communications regarding our potential products and services, or informing them about the availability of such communications

Your explicit consent as the data subject given in a manner that leaves no room for doubt,

For the purposes of addressing consumers’ issues, suggestions, and complaints, fulfilling our obligations arising from applicable local legislation—primarily the Consumer Protection Law—and providing after-sales services.

·       If processing is necessary for the performance of a contract to which you, as the data subject, are a party, or in order to take steps at your request prior to entering into such a contract,

·       Processing is necessary in order to fulfill our legal obligations,

·       Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by your rights, interests, or fundamental freedoms as the data subject.

For the purpose of sending informative messages and promotional communications to consumers via communication channels such as SMS and email regarding products and services, including those of third parties,

Your explicit consent as the data subject given in a manner that leaves no room for doubt,

For the purpose of sending you informational messages and promotional communications of third parties

Your explicit consent as the data subject given in a manner that leaves no room for doubt,

For the purposes of carrying out, monitoring, auditing, and concluding our activities related to our products and services, as well as ensuring customer satisfaction and improving customer experience through our Platforms (for detailed information on the use of cookies on the Platforms, please refer to the Cookie Policy)

·       Your explicit consent as the data subject given in a manner that leaves no room for doubt,

·       Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by your rights, interests, or fundamental freedoms as the data subject.

For the purpose of conducting consumer surveys and market research

·       Your explicit consent as the data subject given in a manner that leaves no room for doubt,

If you become a member of Ploom Club, for the purpose of providing you with the services listed below:

·       Creation of your Ploom Club membership, updating of account information, setting of passwords, and closure of the account,

·       Earning points,

·       Viewing the points you have earned in your Ploom Club account,

·       Using your existing points for purchases, earning points, or receiving discounts in various ways,

·       Benefiting from personalized campaigns,

For more information about Ploom Club, please refer to the FAQs.

In the event that you create a Ploom Club membership:

·       Your explicit consent as the data subject given in a manner that leaves no room for doubt,

·       If processing is necessary for the performance of a contract to which you, as the data subject, are a party, or in order to take steps at your request prior to entering into such a contract,

·       Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by your rights, interests, or fundamental freedoms as the data subject.

For the purposes of achieving the data processing purposes mentioned above:

·       For the purposes of conducting internal operations, including the administration of the Platforms, data analysis, testing, research and statistics, and troubleshooting,

·       For the purpose of ensuring that the content of the Platforms and the data of the data subjects are kept up to date,

·       For the purpose of ensuring data security of the Platforms,

·       For the purposes of maintaining data logs of the Platforms, managing traffic, and ensuring accessibility.

For detailed information regarding cookies: please refer to the Cookie Policy.

Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject.

For the purpose of fulfilling legal obligations and carrying out legal, judicial, administrative, and/or other legal proceedings, as well as responding to correspondence received from judicial and/or administrative authorities.

It is necessary for processing to be carried out in order to fulfill our legal obligations.

Purpose of personal data sharing

Legal basis

Recipients

For the purpose of fulfilling our post‑sales warranty obligations and providing technical support within the scope of our products or services

If processing is necessary for the performance of a contract to which you, as the data subject, are a party, or in order to take steps at your request prior to entering into such a contract,

JT International SA, its affiliates, and their subsidiaries, as well as JTI group companies established abroad.

For the purpose of enabling, defining, monitoring, and concluding the benefits provided under Ploom Club membership, including campaigns, discounts, or other advantages

·       If processing is necessary for the performance of a contract to which you, as the data subject, are a party, or in order to take steps at your request prior to entering into such a contract,

·       Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by your rights, interests, or fundamental freedoms as the data subject.

·       JT International SA, its affiliates, and their subsidiaries, as well as JTI group companies established abroad,

·       Other suppliers based in Northern Cyprus from whom services are procured.

For the purpose of carrying out, monitoring, ensuring the continuity of, and concluding our product and service procurement processes

Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject

·        JT International SA, its affiliates, and their subsidiaries, as well as JTI group companies established abroad,

·       Other suppliers based in Northern Cyprus from whom services are procured.

For the purpose of enabling consumers to exercise their rights under applicable local legislation and fulfilling our legal obligations within the scope of consumer rights.

It is necessary for processing to be carried out in order to fulfill our legal obligations

·       JT International SA, its affiliates, and their subsidiaries, as well as JTI group companies established abroad,

·       Other suppliers based in Northern Cyprus from whom services are procured.

For the purpose of fulfilling legal obligations and carrying out legal, judicial, administrative, and/or other legal proceedings, as well as responding to correspondence received from judicial and/or administrative authorities

It is necessary for processing to be carried out in order to fulfill our legal obligations

Judicial and administrative authorities and institutions in Northern Cyprus

In the event that a Ploom Club membership is created, for the purposes of carrying out, monitoring, improving, and concluding the processes related to Ploom Club membership benefits

Provided that the data subject has given consent to the transfer in a manner that leaves no room for doubt and that is not contrary to law or accepted moral principles

·       Third parties located abroad from whom infrastructure and software services are procured,

·        JT International SA, its affiliates, and their subsidiaries, as well as JTI group companies established abroad.

For the purposes of maintaining records related to products or services, improving product and service processes, responding to inquiries within product and service processes, and ensuring, monitoring, maintaining the continuity of, and concluding customer communication

·       For the performance of a contract concluded between the controller and a third party for the benefit of the data subject, or for fulfilling the provisions of such a contract,

·       For the implementation of pre-contractual measures taken at the request of the data subject prior to the conclusion of a contract between the data subject and the controller.

·       Third parties located abroad from whom infrastructure and software services are procured,

·       JT International SA, its affiliates, and their subsidiaries, as well as JTI group companies established abroad.

For the purposes of communicating in relation to products or services, managing communication preferences, ensuring the continuity of communication, and terminating communication

Provided that the data subject has given consent to the transfer in a manner that leaves no room for doubt and that is not contrary to law or accepted moral principles

·       Third parties located abroad from whom infrastructure and software services are procured,

·       JT International SA, its affiliates, and their subsidiaries, as well as JTI group companies established abroad.

For the purpose of procuring server services to ensure the secure storage of personal data, as well as improving such services and ensuring their security and continuity

Provided that the data subject has given consent to the transfer in a manner that leaves no room for doubt and that is not contrary to law or accepted moral principles

·       Third parties located abroad from whom infrastructure and software services are procured,

·       JT International SA, its affiliates, and their subsidiaries, as well as JTI group companies established abroad.