Who are we?
We are Triaga Inc., a Delaware corporation with our registered address at 1900 Stantonsburg Road, Wilson, NC 27893.
The best way to contact us is by using our IQOS Customer Care online chat tool on our Website. You can also contact us by telephoning our Customer Care team at 1-844-275-4767 or by emailing us at contact.us@iqos.com; and
We are affiliate members of Philip Morris International, a collective group of businesses. All affiliate members of the group are listed here.
How do we collect information about you?
We may collect Personal Information about you in various ways.
- You may provide us with Personal Information directly (e.g. filling in a form, making a call to us, or uploading information to us via a mobile app).
- We may collect Personal Information from a PMI electronic device, if you choose to send Personal Information to us.
- We may collect Personal Information automatically when you interact with our systems or we communicate with you (e.g. when you use a PMI app, chatbot or website or, where we use technologies to observe when you receive or open e-mails or receive SMS messages).
- We may also acquire Personal Information from third parties (e.g. publicly-available Personal Information on social media platforms such as Facebook and X, or statistical information about the population in certain geographical areas). For example, we may infer information about you from aggregated information we acquire from third parties. This may include, for example, statistical information about people in certain geographical areas.
In this notice, we refer to all the methods by which you are in contact with us as “PMI touchpoints”. PMI touchpoints include both physical (for example, via retail outlets and events, consumer contact centres), and digital (for example, via apps and websites).
What information about you do we collect?
The description of our data practices in this Notice covers the twelve (12) months prior to the date noted at the bottom of this page (the “Effective Date”).
We may collect various types of information about you:
- information about your orders, including information necessary to fulfil them
- information necessary to provide warranty services
- information about the referrals you make
- information you give us in forms or surveys, and similar information that you give to third parties to be transferred to us
- information about your location, where you choose to share it with us (for example, on your mobile phone)
- information about your visits to our outlets or events (or outlets or events of others with whom we work)
- information you give us in communications (e.g. calls, chats, e-mails, SMS messages) you have with contact centers
- information about your preferences and interests (including information that we infer from other information, for example from statistical information)
- information necessary to verify your age
- information generated by your electronic device (for example, IQOS), if you choose to share it with us
- information about your experiences using our products and services
- statistical information about you (for example, statistical information about people in certain geographical areas)
We may receive or collect your Personal Information directly from you or from your devices, from third parties, or from other individuals and businesses, as well as public sources of data.
Generally, we process your Personal Information to provide you our products and services and as otherwise related to the operation of our business, including for one or more of the following "Business Purposes":
- selling our products and services to you;
- managing our interactions and transactions with you;
- marketing our products and tailoring our offering to you based on your preferences and purchase history;
- fraud prevention and security;
- maintaining products that you have purchased and debugging;
- performing market research;
- Quality Assurance (see more detail below);
- Processing Interactions and Transactions (see more detail below); and notice
- performing research and development to improve our products.
For what purposes do we use information about you?
Table 1: Personal Information Collection and Disclosure – By Processing Purpose
(See Table 2 for an explanation of the Categories of Information)
Processing Purpose(s) | Example(s) of Processing Purpose | Categories of Information Involved |
1. Selling our products and services to you | Provide our products and services: to provide you with PMI products and services such as IQOS and Zyn, including offers relating to these products; Enable additional features: to provide you with additional features to enhance our products and services, such as providing you with support and IQOS coaches; Process orders: to process or fulfil an order or transaction; Contact you: to contact and communicate with you about your use of our products and services, including changes to our products and services or our policies; Account management: to process your registration relating to our products and services, verify your info is active and valid, and otherwise manage your account Customer Service: to respond to any questions, comments, or requests you have for us or for other customer service purposes Payment and other purchase-related purposes: to facilitate a purchase made using our products and services, including payment processing Other: marketing, administrative, operational, business, and commercial purposes subject to applicable law and not inconsistent with this Privacy Notice or other notice by us at collection | Identifiers, Customer Account Details/Commercial Information, Internet Usage Information, General Geo-location Data, Sensory Data, Inferences |
2. Managing Interactions and Transactions | Auditing: related to counting unique visitors and auditing compliance with user interaction or transaction specifications and standards | Identifiers, Customer Account Details/Commercial Information, Internet Usage Information |
3. Security | Security/fraud prevention: to protect the security of Company, our products and services, and its users and to prevent and address fraud and violations of our terms and policies | Identifiers, Internet Usage Information, Customer Account Details/Commercial Information |
4. Debugging | Repairs: identify and repair errors that impair existing intended functionality of our products, devices and services | Identifiers, Internet Usage Information, Customer Account Details/Commercial Information |
5. Providing Advertising & Marketing Services | Content and offers customization: to customize your experience with our products and services, or to serve you specific content and offers that are relevant to/customized for you Advertising, marketing, and promotions: to assist us in determining relevant offers; to develop and evaluate marketing and advertising campaigns; and for promotional activities, such as running sweepstakes, contests, and other promotions | Identifiers, Internet Usage Information, Customer Account Details/Commercial Information, Geo-location Data, Inferences |
6. Quality Assurance | Quality and Safety of Service: undertaking activities to verify or maintain the quality or safety of our products, devices and services, and to improve, upgrade, or enhance our products, devices and services. | Identifiers, Internet Usage Information, Customer Account Details/Commercial Information, Geo-location Data, Inferences |
7. Processing Interactions and Transactions | Short-term, transient use: including, but not limited to, non-personalized advertising shown as part of a Consumer’s current interactions related to use of our products and services | Identifiers, Internet Usage Information, Customer Account Details/Commercial Information, Geo-location Data, Sensory Data, Inferences |
8. Research and Development | Research and analytics: to better understand how Consumers access and use our products and services, both on an aggregated and individualized basis, to improve our products and services and respond to user preferences, and for other research and analytical purposes Market research and customer satisfaction surveys: to administer surveys and questionnaires, such as for market research or customer satisfaction purposes | Identifiers, Internet Usage Information, Customer Account Details/Commercial Information, General Geo-location Data, Inferences |
9. Additional Business Purposes | Compliance with legal obligations: to comply with legal obligations, as part of our general business operations, and for other business administration purposes Prevention of illegal activities, fraud, injury to others, or violation of our terms and policies: to investigate, prevent or take action if someone may be using info for illegal activities, fraud, or in ways that may threaten someone’s safety or violate of our terms or policies Purposes disclosed at Personal Information collection: We may provide additional disclosures at the time of Personal Information collection Related or compatible purposes: for purposes that are related to and/or compatible with any of the foregoing purposes | Identifiers, Personal Records, Personal Characteristics or Traits, Customer Account Details/Commercial Information, Internet Usage Information, General Geo-location Data, Sensory Data, Professional or Employment Information, Inferences |
10. Commercial Purposes | We may collect and use your Personal Information for commercial purposes such as for interest-based advertising and sharing Personal Information in a manner that is deemed a sale under the California Consumer Privacy Act or other applicable U.S. state privacy laws.
| Identifiers, Personal Records, Personal Characteristics or Traits, Customer Account Details/Commercial Information, Internet Usage Information, General Geo-location Data, Sensory Data, Professional or Employment Information, Inferences |
Table 2: Personal Information Collection and Disclosure – By Category of Information
(See Table 1 for a more detailed description of the Processing Purposes)
Category of Information: Identifiers | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Personal Records | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Personal Characteristics or Traits | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Customer Account Details/ Commercial Information | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Internet Usage Information | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: General Geo-Location Data | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Sensory Data (Non-Biometric) | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Professional or Employment Information | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Inferences from Information Collected | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Sensitive Personal Information | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Sensitive Personal Information | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Sensitive Personal Information | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
|
Category of Information: Sensitive Personal Information | |
Examples of Information Collected and Retained |
|
Sale/Share Recipients |
|
Business Purpose Recipients |
|
Processing Purposes |
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*Only to the extent such data is collected by a cookie or other Tracking Technology.
Information that we collect from third parties will generally consist of publicly available information (such as your preferences, interests and experiences), for example from public social media posts.
Where might information about you be sent?
As with any multinational organization, we transfer information globally to our affiliates and service providers. Your Personal Information may therefore be transferred to other countries as part of our standard operations. Whenever we transfer your Personal Information abroad, we will protect it appropriately and only transfer information in compliance with applicable data privacy laws.
How do we protect information about you?
We implement appropriate technical and organizational measures to protect personal information that we hold. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers that process your Personal Information to comply with appropriate data privacy and security requirements as required by applicable law. But note, given the inherently open nature of the Internet, PMI cannot guarantee that information transmitted between you and us will always remain secure. We may also require you to assist us to safeguard your Personal Information. For instance, if you create an account with us, you should use unique and strong passwords, not share your passwords with others, and take any other measures we may require under the terms of use applicable to the PMI products or services you use.
How long will information about you be kept?
We will retain Personal Information about you for the period necessary to fulfill the purposes for which the Personal Information was collected in accordance with our internal data retention standards. If there are multiple purposes for which Personal Information was collected, we will retain it for the longer period. After that, subject to the legal obligations discussed in the next paragraph, we will delete it.
Typically, we retain data based on the criteria described in the table in the "find out more" section below. Where these periods conflict with legal obligations, for example, for tax and accounting purposes, to either retain the information for a set minimum period of time, or to delete it after a set maximum period of time, we apply the periods required for those legal obligations instead.
What rights and options do you have?
We provide you with the privacy rights described in this section pursuant to requirements of the applicable state law in which you reside, provided any such request meets the requirements for a Verifiable Consumer Request (defined below).
California residents may have additional rights. For more information, see Section ("Additional Notice for California Residents").
The consumer rights we accommodate are as follows:
Right to Limit Sensitive Personal Information Processing
You may have the right to request that we limit our processing of sensitive personal information (please see below for instructions on how to do so). However, we may continue processing such personal information for the following processing purposes or any other permitted purposes under such U.S. state privacy laws:
- To perform our services at your request or at your direction;
- To prevent, detect, and investigate security incidents, fraudulent activity, illegal actions, etc.;
- For short term transient use, including, but not limited to, non-personalized advertising as part of your interaction with our products and services; and
- To maintain or service accounts, provide customer service, process or fulfill offers, orders and transactions, verify customer information, process payments, or provide similar services.
Right to Know/Access
You may have the right to know and confirm that we are processing your personal information. You may also have the right to access what personal information we have collected about you. To the extent feasible, you may request for us to also provide a copy of your Personal Information that you previously provided in readily usable format to permit you to transfer your data to another entity. In accordance with applicable law, we may limit the number of these requests we process.
Residents of California, Colorado, and Virginia are entitled to access information maintained by us up to twice in a 12-month period. Residents of Connecticut and Utah are entitled to access information maintained by us once in a 12-month period, with subsequent requests subject to a service fee.
You may request to confirm if we are processing your information and, if we are, to obtain a transportable copy of your information that we have collected and are maintaining, as required by applicable U.S. state privacy laws. If you wish to receive specific pieces of your information, we will attempt to honor such requests where reasonably possible.
Do Not Sell/ Share/Target for Advertising
Various U.S. state privacy laws have broad and differing concepts of “selling” information for which an opt-out is required, with some states including information transfers for non-monetary consideration and other states only including information transfers for monetary consideration. California also has an opt-out from “sharing” for cross-context behavioral advertising purposes (use of information from different businesses or services to target advertisements across websites or apps). Other states have an opt-out of “Targeted Advertising” (defined differently, but also addressing tracking, profiling, and targeting of advertisements).
We may sell or share your information and/or use your information for targeted advertising, as these terms apply under U.S. state privacy laws. However, you may have the right to opt out of such disclosures.
We will not sell your information, share your information for cross-context behavioral advertising, or process your information for targeted advertising if you make a Do Not Sell/Share/Target opt-out request as follows:
Opt-out for non-cookie information: If you want to limit our processing of your non-cookie information (e.g., your email address or web browsing activity) for Targeted Advertising, or opt-out of the Sale/Sharing of such information, you may make an opt-out request using the method described in “Find out more” under this section.
Opt-out for cookie information: If you want to limit our processing of your cookie-related informationfor Targeted Advertising, or opt-out of the Sale/Sharing of such information, you may exercise an opt-out request by accessing our cookie preference center on the site that you’re visiting. This cookie management tool enables you to exercise such an opt-out request and enable certain cookie preferences on your device. Since your browser opt-out is designated by a cookie, if you clear or block cookies on your device, your preferences may no longer be effective, and you will need to enable them again via our cookie management tool.
Opt-out preference signals ("OOPS", as they are known in California; also known as global privacy control or "GPC"): Some U.S. state privacy laws require businesses to process OOPS or GPC signals, which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual's choice to opt-out of the Sale and Sharing of information. To use an OOPS/GPC, you can download a compatible internet browser or a plugin for your current internet browser and follow the settings to enable OOPS/GPC. We have configured the settings of our consent management platform to receive and process OOPS/GPC signals on our website, as explained in our cookie preference center on the site that you’re visiting. We process OOPS/GPC signals with respect to any sales and sharing of information with third parties that may occur via cookies or other Tracking Technologies, as discussed above and apply it to the specific browser on which you enable OOPS/GPC. We do not: (1) charge a fee for use of our service if you have enabled OOPS/GPC; (2) change your experience with any product or service if you use OOPS/GPC, although it may affect our ability to accurately track your activities for crediting your account with qualified rewards; or (3) display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the OOPS/GPC, except for indicating whether we recognize the signal.
Your device and/or browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. As of the Effective Date of this Notice, our online services do not support such “Do Not Track” requests.
Right to Delete
Except to the extent we have retention rights under applicable law, you may request that we delete your information. Our retention rights include, without limitation:
- To complete transactions and services that you have requested;
- For security purposes;
- For legitimate internal Business Purposes (e.g., maintaining business records);
- To comply with law and to cooperate with law enforcement; and
- To exercise or defend legal claims.
Also, if you elect to delete certain PMI Loyalty Program information, such as your loyalty account, you will lose certain PMI Loyalty Program benefits, which may include all the [PMI] points and rewards you have earned.
Correct Your Information
You may have the right to bring inaccuracies you find in the information that we maintain about you to our attention, and we will act upon such a report as required by applicable law.
You can also make changes to your information in your online account in the account settings section of the account. That will not, however, necessarily change your information in other places where we may maintain it.
To learn more about how we process your consumer privacy requests, please see the "find out more" section below.
Shine the Light
We provide California residents with the option to opt-out to sharing of “personal information,” as defined by California’s “Shine the Light” law, with third parties (other than with PMI affiliates) for such third parties own direct marketing purposes. California residents may exercise this opt-out, request information about our Shine the Light law compliance, and/or obtain a disclosure of third parties we have shared information with and the categories of information shared. California residents may make such a request, or inquire further about our compliance with this law, by using the address set forth in the Contact Us section above. You must put the statement “Shine the Light Request” in the body of your correspondence. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. This right is different than, and in addition to, CCPA rights, and must be requested separately. We are only required to respond to one request per person each year. We are not required to respond to requests made by means other than through the provided e-mail address or mailing address (requests by phone, fax, chats, social media, etc.). We are not responsible for requests that are incomplete or not labeled and sent properly.
Additional Notice to California Residents
This part of the Notice applies to consumers who reside in the state of California.
For California residents, the term “Consumer” refers to both individuals as well as households and is not limited to individuals regarding household goods and services and provides protections in a business-to-business context (e.g., as a service provider or customer, or an employee of a service provider or customer).
Personal Information We Collect and for What Purposes
For a description of the Personal Information we collect, the purposes for which we use this information, and the recipients of this information (including in the last twelve (12) months), see “For what purposes do we use information about you?” of this Notice.
Notice of Financial Incentive
For a description of how we use Personal Information as part of our loyalty programs and the financial incentives we may offer for collection and processing of your Personal Information, see “For what purposes do we use information about you?” of this Notice.
iii. Your California Privacy Rights
Under California law, if you are a California consumer, you have rights regarding your Personal Information, including:
- The Right to Know what personal information we have collected, including the categories of Personal Information, the categories of sources from which this information is collected, the purposes for collecting, selling, or sharing this information, and the categories of third parties to whom we disclose this personal information. You also have the right to know the specific pieces of Personal Information we have collected.
- The Right to Delete Personal Information that we have collected, subject to certain exceptions.
- The Right to Correct inaccurate Personal Information we maintain.
- The Right to Opt-out of the sale or sharing of Personal Information we collect.
- The Right to Limit the use of sensitive personal information we collect for certain purposes.
- The Right to Non-Discriminatory Treatment if you exercise your privacy rights (although we may charge a different price or rate, or offer a different level or quality of goods or service, to the extent that doing so is reasonably related to the value of the applicable Personal Information).
For more information on these rights, see “What rights and options do you have?” of this Notice for more information.
You may exercise your rights by following the instructions under Find out more in our “What rights and options do you have?” section. You can also use our “What rights and options do you have?” of this Notice for more information, including a description of how we verify requests, how opt-out preference signals are processed, and how authorized agents can make a request on your behalf.
We do not knowingly sell or share the information of California residents under the age of sixteen (16)[, unless we receive affirmative opt-in authorization from (i) the under-16 California resident if he or she is at least 13 years of age, or (ii) the parent or guardian of the California resident if he or she is less than 13 years of age]. If you think we may have Sold or Shared Personal Information of a California resident under 16 years of age[ without the appropriate affirmative opt-in authorization], please report that to us as described in the Contact Us section above.
If you have questions, see “Who should you contact with questions?” of this Notice for contact information.
Who should you contact with questions?
If you have any questions, or wish to exercise any of your rights, you can find contact details here.
If your state has a data protection authority, you have the right to contact it with any questions or concerns.
Changes to this notice
We may update this notice (and any supplemental privacy notice), from time to time. Where the law requires it, we will notify you of the changes; further, where the law requires it, we will also obtain your consent to the changes.
Last reviewed: June 25, 2024.
Last updated/Effective Date: June 25, 2024.