Terms of use

The operator of this website is Philip Morris Hungary Ltd. (1085 Budapest, Kálvin tér 12.), a member of Philip Morris International (henceforth: PMI). You use the website on your own responsibility; by using it you accept the Terms and Conditions listed below. We take no responsibility and provide no (express or indirect) guarantee with regard to the website or its use.



The website uses cookies and similar technologies for recording certain user information automatically. In order to learn more about how you can enable or disable cookies, please read our notice about cookies and cookie settings.



The term "tobacco heating device" used in the Terms and Conditions of Use refers to devices which heat tobacco sticks and which are distributed by Philip Morris Hungary Ltd.



The purpose of the website, usage rights



The purpose of the website is to inform smokers above the age of 18, who live in Hungary, about

  • the points of sale of tobacco heating device and its accessories and basic information about device’s technology, and the science and research behind tobacco heating device,
  • the use, operation, technical specifications, troubleshooting, warranty conditions of tobacco heating device, including answers for frequently asked questions,
  • our services related to our tobacco heating devices,
  • to provide adequate information and education for registered users through E-COACH videos and additional product information.



  • To view the restricted contents of the website and the application developed by PMI available only for registered users, a user account has to be set up by registering the consumer and the product through the system provided by Philip Morris Hungary Ltd. (website registration) which requires for application usage a password to be set up on receiving an e-mail notification and requires for website usage a password to be set up or direct access is available with one-time code requested and sent to the registered phone number or e-mail address. Thereafter, the restricted contents of the website will also be available to registered consumers. The tobacco heating device buyer / user can register in the point of sale of the tobacco heating device during the purchase or after it through our Customer Care via phone. Some personal data have to be provided by the buyer/user for registration, which we process in accordance with our Privacy Notice and with the "Protection of your data" section in these Terms and Conditions of Use. It is important that users should provide accurate, complete and up-to-date information when setting up their account. The registered user agree to ensure that the provided data will always be accurate, complete and up-to-date and to inform Philip Morris Hungary Ltd. of any changes therein by modifying profile information in the website or via Customer Care.




    Only those adult smokers are authorized to register and use the website who have bought a tobacco heating device, live in Hungary and have made a statement of being over 18 years old.


    Additional conditions of registration include the acceptance of these Terms and Conditions of Use, acknowledgement of having noted of the Privacy Notice and statement about the given tobacco heating device Club membership and participation in market research.


    Philip Morris Hungary Ltd. reserves the right to monitor the activities below of registered users related to the device and

  • in case of claim for replacement check with a personal / physical inspection that the device is defective and the cause of the defect,
  • limits the number of devices that can be registered to the profile, - either in general or for specific consumers- or draws the consumer's attention to the possibility of the restriction if the number of device registrations to the consumer profile has exceeded the average number of registered devices to consumers.
  • If users fail to meet the above conditions, they cannot register and may not visit the content of the website available only for registered users.



    Registered users shall manage their user name and password enabling login to the website confidentially and inaccessibly to others and if any suspicion arise that these were acquired by an unauthorized person, they shall immediately notify Philip Morris Hungary Ltd. by sending an e-mail to PMHU.GDPR@pmi.com.



    Registered users are responsible for all activities conducted in their accounts, whether or not they are aware of them.



    Registered users are not to use either the password or the account of another person. They may not attempt to make any unauthorized access to the website. In the event that they attempt to do so, or assist others in doing so, or if they distribute any guidance, software or devices to that end, the account will be closed.



    It is possible to transfer the device(s) assigned to the profile of an existing registered user to another profile, this can be initiated by any party, via the website or Customer Service.



    If the registered user passed away and the heir wants to register the device under his/her own name, it can be done based on the instructions of the Customer Service and by filling out the document "Declaration for the registration of the device of the owner of a deceased tobacco heating device".



    If users exchange their device with someone, Customer Service can provide assistance in exchanging the devices by having one or both parties fill in the "Consent to transfer of data" document, so Customer Service can release the contact information of the user who gave the consent to the other party.



    Protection of your data



    We handle the personal data provided by you in the manner described below in our Privacy Policy and in these Terms and Conditions of Use.



    Please note that if a registered user deletes the registered profile (which can be done after login to the profile on the website or through our Customer Care following the necessary identification) Philip Morris Hungary Ltd. does not retain the data or statements needed for creating the profile and the data generated in the course of the website use, so it will not be able to provide such information retroactively after deletion. The personal data related to the registered user's profile will be deleted within 30 days from the profile deletion from all our systems. If you only want to disconnect one of your devices from your profile, do so and do not delete your profile, in this case your profile will remain with the remaining registered device.



    The profile deletion is the consumer’s responsibility if the consumer is no longer a smoker or no longer uses tobacco heating device.



    Other data processing activities related to the consumer, such as business analytical activities, complaints, warranty claim protocols, telephone conversations with customer service, telephone conversations with support and feedback teams, and personal data handled in the context of a personal customer support expert visit are handled, stored and then deleted in accordance with the provisions of the Privacy Policy.



    The profile of the registered user is deleted by Philip Morris Hungary Ltd. - except in the following cases - only at the request of the user:

  • in case of buyback of the registered product - if the user does not register another product - the profile will be deleted after 3 months;
  • or if the registered users with or without tobacco heating device CLUB membership do not log in their profile for 3 years, do not contact our Customer Service team or our customer support experts, do not update their profile, do not register new device to their profile, and do not open any e-mails sent by us, then after 3 inactive years - even if we tried to contact the user in the meantime - the profile will be deleted.
  • or if no device has been registered for a consumer profile for more than 75 days, despite an attempt of being contacted in the meantime.


  • The registered users accept that automatic messages will be sent to the registered e-mail address and will be received by them to ensure the proper provision of information about several steps in relation with their registered tobacco heating device and/or the handling of their user profile (like registration, new password creation, personal data modification, cancellation, etc.).



    The registered users accept that other technical emails what promotes the proper use of the devices will be sent them to their registered email address (for example the importance of software update).



    Detailed data processing information:



    I. GENERAL PART
    Content and purpose of this Privacy Policy This Privacy Policy contains relevant information related to the data processing activities of the Controller, which are the subject of data processing activities, the personal data of consumers (hereinafter collectively referred to as: consumer data processing). The General Part of this consolidated Privacy Policy contains the provisions governing all consumer data processing described in the Special Part, and the Special Part contains the rules applicable to each consumer data processing described therein. For data processing activities not covered by this detailed Privacy Policy, the provisions of the PMI General Consumer Privacy Policy shall apply. The referenced privacy policy and this Terms and Conditions of use can be found at the visited website.
    The Controller Philip Morris Hungary Ltd.
    Address: 1085 Budapest, Kálvin tér 12.

    Phone:+36 80 888 222

    E-mail: PMHU.GDPR@pmi.com
    Rights of the Data Subject Data Subjects are entitled to request the following from the Controller

    1. access to personal data concerning him as a Data Subject,

    2. supplementation, correction, deletion or restriction of the processing of their personal data,

    3. they may object to the processing of their personal data. In this case, the Controller shall not further process such personal data, unless data processing is justified by compelling legitimate reasons which take precedence over the interests, rights and freedoms of the Data Subject or which are related to the submission, enforcement or protection of legal claims.

    „We recommend to use the following form for submitting a request: „https://hu.iqos.com/documents/en/Elektronikus_nyomtatvany_erintetti_joggyakorlas_EN.pdf”, please send the completed form to PMHU.GDPR@pmi.com



    4. The protection of your data is very important to us, so we ask that if you have any problem with the protection of your data, contact us at one of the following contact details in order to find a satisfactory solution as soon as possible: Phone: +36 80 888 222 E-mail: PMHU.GDPR@pmi.com

    5. The Data Subject has the right to submit a complaint to the supervisory authority (National Authority for Data Protection and Freedom of Information, 1055 Budapest, Falk Miksa utca 9-11., https://naih.hu, telephone number: +36 (1) 391-1400, postal address: 1363 Budapest, Pf. 9., e-mail: ugyfelszolgalat@naih.hu). If the Data Subject is a foreign citizen, they may also submit a complaint to the supervisory authority of their place of residence.


    6. Data Subjects may go to court if their rights are violated. The court shall act with priority in the case. Data protection lawsuits fall within the jurisdiction of the tribunal, which may, at the choice of the Data Subject, be sued in the court of the Data Subject's domicile or residence.

    The Controller informs the owner of the personal data that any person who has suffered pecuniary or non-pecuniary damage as a result of a breach of law is entitled to compensation from the Controller for the damage suffered in accordance with the rules of civil law.

    Before contacting the supervisory authority or the court with your complaint, please contact our Company, if possible, at the e-mail address indicated in The Controller section of this policy.
    Automatic decision making There is no automatic decision making during data processing.
    Nature of reporting The provision of personal data is voluntary.


    II. SPECIAL PART

    II.1. PMHU customer and product registration system / Data processing activities related to tobacco heating device profile registration
    General purpose of data processing The purpose of data processing is to enable the Controller to perform the contract for the provision of additional services to the Data Subjects in connection with product warranty and product support information, as well as the right of withdrawal.
    Data Subjects of data processing Data Subjects of data processing are consumers who purchase a tobacco heating device (hereinafter: device) and who choose to register the device in the Controller's customer and product registration system using a tablet displayed in the national tobacco shop that distributes the device, through the website of the purchased device, or through the Controller's customer service in order to be able to
  • hire additional warranty services and product information support related to the purchase of the device; and
  • exercise the right of withdrawal in the case of an undamaged, complete device.


  • For the purposes of applying this privacy policy, an individual is also considered to be a Data Subject who purchases the device for another individual and also registers the profile with his or her own data.
    Legal basis for data processing Processing is carried out on the legal basis set out in Article 6 (1) b) of the GDPR, i.e. the processing is necessary for the performance of a contract to which the Data Subject is a party.
    Purpose of the personal data processed and the processing of individual data Mobile phone number
    The mobile phone number is used for several purposes. On the one hand, as a first step in registration, it is necessary to provide this personal data by the Data Subject in order to avoid double registration. On the other hand, if the Data Subject requests the replacement of the device, the Controller will perform a (remote) inspection of the product with regard to registration and in case of a favourable assessment of the warranty claim, the Controller will send an SMS containing the replacement code to the Data Subject's mobile phone number. The consumer will also receive a unique identification code via SMS before performing operations requiring consumer identification. Instead of entering the password the registered consumer can request a one-time verification code to enter the profile on the website, the code will be sent via SMS to the registered mobile phone number.
    Simultaneously with registration, a user account is automatically created for the Data Subject for the website of the purchased device (hereinafter: the website), which account allows the Data Subject to view the content available only to registered Data Subjects on the website. The mobile number (or e-mail address) is required in addition to the password generated by the Data Subject and known only to the Data Subject in order for the Data Subject to access the website and view restricted content in the “Products” and “Product Use Videos” menu item. In the event that the Data Subject has forgotten their password, they will receive a one-time code via SMS from the system to their mobile phone number, which will allow them to reset the password required to log in to the website. The registered consumer can login also with a one-time verification code, which is sent to the registered mobile phone number via SMS.

    Last name
    It is necessary to process this personal data for the purpose of identifying the Data Subject as a contracting party to the Controller in order to be entitled to extra warranty and product support information, as well as to the right of withdrawal.

    First name
    The processing of this personal data is necessary for the purpose of identifying the Data Subject as a contracting party to the Controller in order to be entitled to extra warranty and product support information, as well as the right of withdrawal.

    Consumer identifier
    The Controller processes this data in order to identify the consumer in the system.

    E-mail address
    Registered Data Subjects will receive automatic system messages to the e-mail address provided during registration.
    By using the e-mail address with a password, Data Subjects can access the website, reset their password and change their telephone number. The registered consumer can login also with a one-time verification code, which is sent to the registered e-mail address via e-mail.
    The mobile phone number and e-mail address are alternatives to each other in the operations described. For example, Data Subjects can access the website with either an e-mail address and a password, or a mobile phone number and a password. Access to the website is also possible with one-time code requested and then sent to the registered e-mail address or phone number.
    In case of the validation of a warranty claim, Data Subjects will also receive the related minutes and notifications to their e-mail address. The e-mail address is processed for the above purposes.
    Delivery of the electronic document certifying the purchase of the device to the Data Subject.

    Date of birth
    Date of birth as personal data shall be processed for the following two purposes:

    1. considering that only persons who have reached the age of 18 may register under the Terms of Use, the date of birth must be provided by the Data Subject and processed by the Controller in order to verify this circumstance,
    2. on the other hand, the Controller prepares cumulative reports and analyses in order to improve the quality of its services to an even more appropriate level for consumers, and in the course of this data processing activity it also processes the birth date constituting the consumer's personal data for the purpose indicated herein.

    Administrative address of place of residence
    The administrative address of the Data Subject's place of residence is managed by the Controller in order to be able to contact the Data Subject by post if other channels (e.g. mobile phone, e-mail) are not available in order to facilitate the enforcement of warranty claims, as well as to develop and enhance services for consumers, the Controller shall take into account the location of the consumers.

    Smoking condition
    Based on the terms of use, only persons who already smoke can register, as the device has also been developed for adults who already smoke, so this data of the Data Subject is processed by the Controller in order to check compliance with the terms of use.

    Unique device identification code
    To identify and handle the device used by the Data Subject.

    Gender (an optional, non-compulsory data field) The Controller handles this personal data in order to ensure a more personalised contact.
    Duration of data storage The data processing between the parties is based on the duration of the contract for the additional services outlined above (i.e. the period between registration and cancellation of registration) and the validity of the warranty claim. In the event that a Data Subject cancels their registration, this will also lead to the deletion of their data.
    In case of surrender (withdrawal), the profile will be deleted after 3 months.
    In case a registered Data Subject is inactive for 3 years, their registration will be cancelled.
    In case of no device is registered to the data subject’s profile for 75 days, the profile will be deleted.
    Relationship between failure to disclose data and statutory warranty rights Failure to disclose data shall not affect the Data Subject's statutory warranty rights attached to the device.
    Transfer of personal data, data processors, description of their services The Controller uses the services of the following data processors during the data processing indicated in this data processing policy:

    1. MONOLITH Advanced Internet Solutions LTD the data processing company operating the registration interface
    2. Comdata Hungary Kft. the company operating the customer service
    3. STARJOBS Magyarország Kft. the company involved in customer support through temporary workers as a temporary employment agency
    4. Tobacco retailers
    (a) if assistance is provided in the registration of the device at the express request of the Data Subject,
    (b) if the device is being replaced.


    II.2.
    Data processing activities related to IQOS (in the following: tobacco heating device) Club membership
    General purpose of data processing The purpose of data processing is to enable the Controller to fulfil the contract for the provision of additional services to the Data Subject, i.e. beyond the registration as regards warranty and product support related to tobacco heating device Club membership, in connection with the Data Subject's choice of tobacco heating device CLUB membership and assess how the Data Subject received the phone call.
    Data Subjects of data processing Data Subjects of data processing are consumers who purchase a tobacco heating device (hereinafter: device) and who decide to choose tobacco heating device CLUB membership in order to use the tobacco heating device Club membership-related,
  • i.e. additional warranty services beyond those provided by registration, and
  • extra product support, information (phone and e-mail support, answering questions, product usage assistance, feedback)
  • in addition to registering the device on the website of the purchased device or by using a tablet placed at the national tobacco shop that sells the device or through the Controller's customer service.
    Legal basis for data processing Processing is carried out on the legal basis set out in Article 6 (1) b) of the GDPR, i.e. the processing is necessary for the performance of a contract to which the Data Subject is a party.
    Purpose of the personal data processed and the processing of individual data Voice recording, listening in
    The customer service conversation with the Data Subject is recorded for the purpose of subsequent service quality inspection, improvement the quality of services and later demonstration of what has been said. The Controller’s competent staff may listen in the conversation in real time in order to monitor customer service quality and to improve the quality of services.

    Mobile phone number
    If the Data Subject has a request to replace the device, the identification SMS sent to their mobile phone number can prove that they are entitled to use the additional warranty service based on tobacco heating device CLUB membership, as well as to receive additional support, answers to their questions, product usage assistance and to give feedback. The consumer will also receive a unique identification code via SMS before performing operations requiring consumer identification.

    Last name
    It is necessary to process this personal data for the purpose of identifying the Data Subject as a contracting party to the Controller in order to be entitled to the extra warranty, product support and information.

    First name
    It is necessary to process this personal data in order to identify the Data Subject as a contracting party to the Controller in order to be entitled to the extra warranty, product support and information.

    Consumer identifier
    The Controller processes this data in order to identify the consumer in the system.

    E-mail address
    The Data Subject joined to the tobacco heating device CLUB (visit the website for detailed terms and conditions of membership) will receive automatic system messages to the e-mail address provided by him or her. With tobacco heating device CLUB membership, the Controller not only provides additional warranty services, but also customer support and other product information to the Data Subject, such as the most basic technological information about the device, news, product range and price changes; knowledge of the use, operation, technical knowledge and troubleshooting of the device. Data Subjects may provide feedback on their device, product usage habits, and the tobacco heating device Club. In case of the enforcement of a warranty claim, Data Subjects will also receive the related minutes and notifications to the e-mail address. Data Subjects will receive this information as an additional product support service via e-mail.
    The e-mail address is processed for the above purposes.

    Administrative address of place of residence
    The administrative address of the Data Subject's place of residence is processed by the Controller in order to be able to contact the Data Subject by post if other channels (e.g. mobile phone, e-mail) are not available in order to facilitate the enforcement of warranty claims.
    Furthermore, the Controller reserves the right to give gifts at any time in return for the Data Subject’s feedback on the tobacco heating device Club and to deliver such gifts to the Data Subject to the place of residence specified.

    Gender (an optional, non-compulsory data field)
    The Controller handles this personal data in order to ensure a more personalised contact.

    Data related to product usage, feedback and areas of interest
    The Controller obtains data on product use, feedback and areas of interest from Data Subjects (e.g. consumers’ opinion about the tobacco heating device and whether they would recommend the product to others) within the framework of feedback from Data Subjects in order to improve its services and personalise its shipments and information, as well as to use the data in a statistical way in order to develop its strategy and business plans.

    Opening data of e-mails and newsletters sent to the Data Subject:
    The Data Controller monitors with the help of the used electronic mail system whether Data Subjects open the newsletters and informative emails sent to them for the purpose of improving the effectiveness of fulfilling the contractual obligation to send out information (newsletters), improving the quality of this service, in particular by updating the managed e-mail addresses as necessary.

    Consumer's attitude towards phone calls:
    This personal data is created on the basis of the operator's assessment based on the operator's phone conversation with the Data Subject, the purpose of data management is to improve the quality of the Data Controller's services.
    Duration of data storage Data processing between the parties is based on the duration of the contract for additional services outlined above (i.e. the period between the start of tobacco heating device CLUB membership and its termination by the Data Subject) and on the term of enforceability of warranty claims. In the event that a Data Subject cancels their registration, this will also lead to the deletion of their data managed in connection with tobacco heating device CLUB membership. (The Data Subject's entire profile will be deleted, so if there are more than one tobacco heating devices assigned to the Data Subject, the CLUB membership and related data for each device will be deleted.) The Data Subject may at any time decide to cancel tobacco heating device CLUB membership only, in which case the data processing of the Data Subject for purposes related to tobacco heating device CLUB membership will be terminated; however, data supplied earlier by the Data Subject (e.g. the fact and description of phone conversations, the fact and description of discussions with a customer support expert), and the registration previously performed by the Data Subject (see point II/1) will remain until the date of cancelling the registration.
    The period of retention of customer service voice recordings is 3 months from the date of recording; voice recordings will be deleted afterwards. In case of surrender (withdrawal), tobacco heating device CLUB membership – together with the profile – will be cancelled after 3 months. In case a Data Subject is inactive for 3 years, their registration and tobacco heating device CLUB membership will be cancelled.
    Data regarding the opening of e-mails and newsletters is managed by the Data Controller until the IQOS Club membership is terminated.
    Relationship between failure to disclose data and statutory warranty rights Failure to provide data shall not affect the Data Subject's statutory warranty rights attached to the device.
    Transfer of personal data, data processors, description of their services The Controller uses the services of the following data processors during the data processing indicated in this data processing policy:

    1. MONOLITH Advanced Internet Solutions LTD
    the data processing company operating the registration interface

    2. Comdata Hungary Kft.
    the company operating the customer service

    3. MULTICOM Contact Szolgáltató és Tanácsadó Kft. the company operating the outbound telephone customer service

    4. Tobacco retailers,
    a) if assistance is provided during the registration of the device for the selection of tobacco heating device CLUB membership at the expressed request of the Data Subject,
    b) if the device is replaced

    5. STARJOBS Magyarország Kft.,
    the company involved in customer support through temporary workers as a temporary employment agency

    6. The service provider preparing and making arrangements for the delivery of the gift for the Data Subject’s feedback as tobacco heating device CLUB member, the registered seat of which is in Hungary..

    7. IPSOS Zrt. (headquarter: 1139 Budapest, Pap Károly utca 4-6.) the company carrying out the market research activity


    II.3.
    Business analytics
    General purpose of data processing To analyze data in order to understand consumers and in connection with business initiatives, issues and product development, and to understand consumer habits.
    Data Subjects of data processing Registered consumers and tobacco heating device Club members
    Legal basis for data processing The legal basis for the processing is the legal basis set out in Article 6(1)f) of the GDPR, i.e. the legitimate interest of the Controller. The legitimate interest of the Controller is as follows: to offer and develop goods and services that best satisfy the needs of consumers.
    Purpose of the personal data processed and the processing of individual data In the event that data are not provided, the data that a consumer does not intend to provide will not be used for business analytics purposes.
    The personal data processed and the purpose of the processing of the respective data For registered consumers, the personal data specified in section II.1. For tobacco heating device Club members, the personal data specified in section II.2.
    Data retention period The personal data used are deleted in the manner and at the time specified in sections II.1 and II.2.
    Transfer of personal data, data processors, description of their services In the course of the processing described in this privacy notice, the Controller uses the services of the following processors:

    1.MONOLITH Advanced Internet Solutions LTD
    the data processor operating the registration interface

    2. intecs data, s.r.o.
    the team developing the analytics interface

    3.Microsoft Corporation
    the entity storing the underlying data of PowerBI

    4. STARJOBS Magyarország Kft.,
    the temporary employment agency involved in customer support via temporary workforce.


    II.4.
    Data processing activities related to qualitative and quantitative market research activities
    General purpose of data processing Understanding consumer perception in relation to various business initiatives, issues, product development, learning about consumer switching. The purpose of processing the personal data on the list of those who unsubscribed is to prevent the Controller from contacting those Data Subjects for market research purposes who withdrew their consent earlier granted thereto.
    Data Subjects of data processing Consumers who have given their consent to participate in market research. In case of the list of those who unsubscribed, those consumers who withdrew their consent earlier granted to the Controller to contact them for market research purposes.
    Legal basis for data processing In the course of market research activities, processing is carried out on the legal basis set out in Article 6 (1) a) of the GDPR, i.e. on the basis of the Data Subject's consent.
    In the course of voucher management activities, processing is carried out on the legal basis set out in Article 6 (1) (b) of the GDPR, i.e. for the performance of a contract to which the Data Subject is a party; and in case of the list of those who unsubscribed, on the legal basis set out in Article 6 (1) (f) of the GDPR, i.e. in the legitimate interests pursued by the Controller, namely to prevent legal disputes by the fact that the Controller shall not contact those Data Subjects for market research purposes who withdrew their consent earlier granted to the Controller to contact them for such purpose.
    Consequence of failure to provide data In case of any failure to provide data, the consumer shall not have the opportunity to participate in the market research.
    Purpose of the personal data processed and the processing of individual data The processing of personal data by the Controller takes place only for the following purposes:

    1. for the performance of a market research activity called the “Adoption tracker”,

    2. in connection with the related voucher management,

    3. and in connection with the processing of the list of those who unsubscribed.

    1. With the consent of the Data Subject, the following personal data will be transferred to the data processor for market research purposes: Consumer identifier, full name, e-mail address, age, gender, date of device purchase, and a reference to whether the Data Subject has viewed the video presenting the device.. In the case of personal data other than those mentioned above, in relation to any data collected by the Market Researcher (IPSOS Zrt), e.g. for taxation and accounting purposes, the Market Researcher shall be considered as Controller.

    .2 On the legal basis of performing a contract to which the Data Subject is a party, the following personal data of participants entitled to be involved in market research will be transferred to the data processor in order to incentivize consumers’ participation in market research, for the purposes of gift voucher delivery, answering questions related to voucher use, and claims management: the Data Subject’s name and e-mail address. The data processor obtains the following personal data from the voucher service provider: voucher code, voucher validity, date of sending the voucher to the Data Subject.

    3. The list of those who unsubscribed, generated by the data processor, contains the Data Subjects’ consumer identifier and e-mail address. The legal basis for processing the personal data included in the list of those who unsubscribed is the legitimate interest pursued by the Controller, the purpose of which is to prevent the Controller from contacting those Data Subjects for market research purposes who withdrew their consent earlier granted for such purpose.

    In the case of personal data other than those mentioned above, in relation to any data collected by the data processor, the Market Researcher shall be considered as Controller.
    Duration of data storage The processing of personal data lasts until the withdrawal of the Data Subject's previous consent for market research purposes or the deletion of the profile, provided that data will be processed for voucher management purposes during the 1-year validity period of the voucher.
    Transfer of personal data, data processors, description of their services The Controller uses the services of the following data processor during the data processing indicated in this data processing policy:

    1. IPSOS Zrt. (Registered office: 1139 Budapest, Pap Károly utca 4-6.) the company carrying out the market research activity
    II.5.
    Data processing activities related to customer service and customer support .
    1. General purpose of data processing a) Answering consumers' questions, customer support, service development, efficiency measurement and planning, investigating their comments, general communication with consumers,
    b) handling consumers’ complaint,
    c) manage consumers’ warranty claims.
    2. Data Subjects of data processing Consumers.
    3. Legal basis for data processing a) In the course of data processing for the purpose indicated in point II.5.1. a), data processing is carried out on the legal basis specified in point f) of Article 6 (1) of the GDPR, i.e. on the basis of the legitimate interest of the Data Controller, which legitimate interest is the effective and high-level support of consumers,

    b) in the course of data processing for the purpose specified in point 1 b), the data processing is carried out on the one hand on the legal basis specified in Article 6 paragraph (1) point b) of the GDPR, i.e. in order to fulfill the legal obligation of the Data Controller, the CLV of 1997 on consumer protection Act 17/A. § (5) and (7), on the other hand, it takes place on the legal basis defined in Article 6 (1) point f) of the GDPR, i.e. on the basis of the legitimate interest of the Data Controller, which legitimate interest is to facilitate the proof and defense of consumer claims. On the individual legal bases of data management II.5.l. also those contained in point 5,

    c) in the case of data processing for the purposes specified in point II.5.1 c), the data processing is carried out on the one hand on the legal basis specified in Article 6 (1) point b) of the GDPR, i.e. in order to fulfill the legal obligation of the Data Controller and 19/2014 on the procedural rules for handling warranty claims (IV. 29.) on the basis of Section 4(1) and Section 6(1) of the NGM Decree, on the other hand on the legal basis defined in Article 6(1)(f) of the GDPR, i.e. the legitimate interest of the Data Controller takes place on the basis of which is a legitimate interest in the efficient and high-level fulfillment of consumers' warranty needs. On the individual legal bases of data management l. also those contained in point II.5.
    4. Consequence of failure to provide data The Controller does not become aware of the issue, claim validation or complaint and thus cannot provide information or take appropriate steps in connection with the event.
    5. Purpose of the personal data processed and the processing of individual data a, The personal data that the Data Controller manages for the purpose indicated in the II.5.1. a) point:

    i. Voice recording
    Questions and comments made by the Data Subject on +36 80 888 222 will be recorded for the purpose of answering the question, investigating the comment and quality assurance.

    ii. Last name / First name
    The processing of this personal data is necessary for the purpose of identifying the Data Subject.

    iii. Mobile phone number
    The processing of this personal data is necessary for the purpose of contacting the Data Subject.

    iv. E-mail address
    It is stored for the purpose of contacting the Data Subject.

    v. Consumer identifier
    The Data Controller processes this data for the purpose of identifying the consumer in the system in the case of a request from a registered consumer regarding a non-traditional product (i.e. tobbacco heating devices, e.g. IQOS).

    vi. Device codentify code
    In the case of a non-traditional product, identification and management of the device used by the registered consumer.

    vii. Other personal data
    In the case of registered consumers:
  • Preliminary communications with the consumer (e.g. topics, e-mail communication),
  • the support used by the consumer in the premises of a contracted partner or at another location from the customer support expert, the description of which is recorded in the Data Controller's system,
  • Data related to participation in the program announced by the Data Controller, the description of which is recorded in the Data Controller's system (e.g. in relation to product use, cleaning of the device, online registration, software update, device check, services used, completion of program announcement or other circumstances),
  • The opinion of the registered consumer regarding the IQOS device and related services (e.g. would you recommend the product to others if you answer the asked questions),
  • Opening data of e-mails and newsletters sent to the Data Subject: the Data Contoroller monitors with the help of the used electronic mail system whether Data Subjects open the newsletters and informative emails sent to them for the purpose of improving the effectiveness of fulfilling the contractual obligation to send out information (newsletters), improving the quality of this service, in particular by updating the managed e-mail addresses as necessary,
  • Consumer's attitude towards phone calls: this personal data is created on the basis of the operator's assessment based on the operator's phone conversation with the Data Subject, the purpose of data management is to improve the quality of the Data Controller's services.


  • viii. Other personal data provided by the consumer
    Any other personal data provided by the Data Subject during the telephone call or in e-mail. Personal data (first name, last name, mobile phone number, e-mail address, e-mail subject, message) provided by the Data Subject in the Contact Us electronic form on the website.

    b, The personal data that the Data Controller manages for the purpose indicated in the II.5.1. b) point:

    i. Name of the consumer
    ii. Consumer’s address
    iii. Place, time and method of presenting the complaint
    iv. Detailed description of the consumer's complaint
    v. Signature of the person taking the record
    vi. The consumer's signature on the record
    vii. In the case of a verbal complaint communicated by telephone or using other electronic communication services, the unique identification number of the complaint
    viii. Response to the consumer's complaint
    ix. Voice recording of the conversation with the consumer
    x. Consumer identifier
    xi. Device codentify code
    xii. Consumer’s mobile phone number
    xiii. Consumer’s e-mail address

    The i-viii. for the processing of personal data specified in point II.5.3. c) on the legal basis of fulfilling the legal obligation specified in points ix-xiii. and the processing of personal data defined in point II.5.3. c) is carried out on the legal basis of the legitimate interest defined in point 3. c)..

    c, The personal data that the Data Controller manages for the purpose indicated in the II.5.1. c) point:
    i. Name of the consumer
    ii. Consumer’s address
    iii. The name of the movable asset sold
    iv. The purchase price of the movable asset sold
    v. Data needed to identify the product
    vi. The consumer's mobile phone number: in the case of a replacement product, it is processed for the purpose of negotiating the delivery date
    vii. Consumer's e-mail address: the protocol and notification related to claim enforcement will be sent to the consumer's e-mail address
    viii. Administrative address of the consumer's place of residence: it is processed for the purpose of determining the regional representative to be appointed to hand over the replacement product.
    ix. Voice record about the conversation with the consumer.
    x. Consumer identifier
    xi. Device codentify code

    The processing of personal data defined in the i-v. points is carried out on the legal basis of fulfilling the legal obligation defined in the II.5.3. c) point, and the processing of personal data defined in the vi-xi points is carried out on the legal basis of the legitimate interests defined in the II.5.3. c) point.
    6. Duration of data storage Data Subjects can provide their personal details by phone or by e-mail.
    In the case of a voice recording, 3 months from the date of the recording. In the case of communication by e-mail the retention period is 3 months from the date of origin of the e-mail in case of communication not considered as a complaint, and 3 years from the date of origin of the e-mail in case of a complaint.
    In the case of handling a consumer warranty or guarantee claim, the retention period of the personal data entered in the records is 3 years from drawing up such records.
    7. Transfer of personal data, data processors, description of their services The Controller uses the services of the following data processors during the data processing indicated in this data processing policy: 1. MONOLITH Advanced Internet Solutions LTD
    the data processing company operating the registration interface

    2. MULTICOM Contact Szolgáltató és Tanácsadó Kft.
    the company operating the outbound telephone customer service

    3. STARJOBS Magyarország Kft.,
    the company involved in customer support through temporary workers as a temporary employment agency

    4. HD-CORD Kft.
    the company involved in customer support as a service provider

    5. Comdata Hungary Kft.
    the company operating the customer service



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    Latest update: 2022.09.28.