Privacy Policy
[02 March 2026]JT International
Zagreb d.o.o., Slavonska avenija 6A, 10000 Zagreb ("JTI",
"we", "our") is committed to protecting and
respecting your rights to the protection of personal data and privacy.
This Privacy Policy
("Privacy Policy") (together with the Cookie Policy, Terms of
Use and any other documents referenced herein) sets out the basis on which we
will process personal data collected from you through our website [email protected] (the "Website"), the Ploom Gen
4 App, the Ploom Club, the Ploom Account and communicate with you through our
Ploom Care team, our suppliers or brand ambassadors (who also use the Ploom
Direct App in their interactions with you) and your rights under data
protection regulations. Please read this Privacy Policy carefully to understand
our views and practices regarding your personal information and how we treat
it.
For the purposes of
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27
April 2016 on the protection of natural persons with regard to the processing
of personal data and on the free movement of such data, and repealing Directive
95/46/EC ("GDPR") and the applicable Croatian Act on the
Implementation of the General Data Protection Regulation ("AIGDPR")
and all other applicable regulations on the protection of personal data, JTI is considered to be the controller of
personal data.
Scope of the Privacy policy
This Privacy Policy
sets out how we ensure the use of personal information of visitors to our
website, users of the Ploom Gen4 App, the Ploom Direct app, Ploom Club members,
Ploom account users, and other consumers who interact with us through our Ploom
Care team, vendors, or with our authorized third parties in accordance with data protection regulations.
Questions, comments
and/or requests regarding this Privacy Policy and the personal data we process
about you are welcome, and you can contact us via the Contact Us form
and/or via email at [email protected].
Obligation to notify changes
It is important that
the personal information we hold about you is accurate and up to date. Please
let us know if your personal information changes during your relationship with
us.
Personal data we collect
When you visit our
website, use the Ploom Direct App or the Ploom Gen 4 App, register or log in on
our website, in the Ploom Direct or Ploom Gen 4 App or with the help of our authorized third parties, when you extend the warranty on our website,
when you communicate with us through a contact form, by email or otherwise,
when you communicate with the Ploom Care Team,
Our authorized
third parties, when you respond to
questionnaires, surveys or other questions, or modify any of your heated
tobacco devices or any other product used with this device, we collect and process the following categories of
personal data:
- name and surname;
- date of birth, age;
- contact information
(e.g. email address and phone number);
- information related
to the use of the Ploom product you have purchased, including information about
your consumption of nicotine products;
- details of your
interactions with us, including messages and notes about your communications
and conversations with us;
- recordings of your
voice that we record and store on our servers when you contact the Ploom Care Team;
- your responses to
questionnaires, surveys and other responses related to the use of the Ploom
product you have purchased and the user experience;
- technical
information about the use of our website and contact center, including the time
and duration, the Internet Protocol (IP) IP address with which your device is
connected to the Internet, your login information, browser type and version,
time zone setting, visit data, types and versions of browser, operating system,
and platform add-ons, and information about the use of cookies and tracking
technologies. You can set up your browser to block or notify you about
essential cookies, but in this case, some parts of the website may not work.
For more information about cookies and how to accept or decline them, please
see our Cookie Policy;
- information you
provide when registering a Ploom Account and information about the use of a
Ploom Account;
- data necessary for
the installation and operation of the Ploom application;
- data about the use
of the Ploom application (e.g. user activity, application errors, selected
settings)
- data required for
the installation and operation of the Gen 4 application;
- Gen 4 app usage data
(e.g., user activity, app errors, settings selected); i
- Ploom device data
(e.g. Bluetooth connection, battery capacity, heating modes).
You may provide us
with information about yourself in a variety of ways, including: (-) by visiting
our website; (-) download and use of the Gen 4 App (-) by registering on our
website or through the Gen 4 App or with the help of our vendors or brand
ambassadors (who also use the Ploom Direct App for this purpose); (-) the
extension of the warranty; (-) by filling out the Contact Us form on our
website; (-) communicate with us via email, phone, or otherwise, (-)
communicate with us through the Ploom Care team, vendors, or our authorized third parties (who, in connection with interacting with you,
use the Ploom Direct app), (-) when you complete questionnaires, surveys, or
respond to other questions.
We will only use your
data if there is a valid legal basis for doing so. For example, we will use your information when: (-) we need
to comply with a specific legal obligation; (-) it is necessary for the
conclusion or fulfilment of the contract or the General Terms and Conditions;
(-) it is necessary for the purposes
of our legitimate interest, but only
where your interests and fundamental rights do not override our legitimate
interests; or (-) we have obtained your consent to do so. These legal bases for
the use of your personal data constitute lawful processing. Please note that we
may process your information on several legal bases, depending on the specific
purpose for which we are using your information.
Please note that we do
not use automated decision-making.
Below you can find an overview of the personal data we process, including the purposes of the processing, as well as the legal basis for the processing and the retention period.
|
Personal data |
Purpose of
processing |
Legal
basis/lawful processing |
General retention
period (see also point 10 below) |
|
Age |
When you visit our
website, we need to verify your age and process your personal data to comply
with our legal obligations. |
Processing is
necessary for compliance with a legal obligation |
5 years |
|
Name, surname, date
of birth, phone number, e-mail address, password |
Warranty
Registration and Extension |
Processing is
necessary for the conclusion of a contract and the fulfilment of a
contractual obligation, i.e., the provision of the warranty |
3 years or until the
end of the warranty period |
|
Name, surname, date
of birth, telephone number, e-mail address and other information you provide
in your inquiry |
Use of contact forms |
Where the processing
of your personal data is related to responding to an inquiry or providing customer
support, we have a legitimate interest in responding to the inquiry or providing
sales services to our users, where our interest is not overridden by your
interest or your rights and freedoms. If the inquiry is related to the Ploom Club, the
exercise of rights and benefits based on membership in the Ploom Club, the
sole basis for the processing of data related to
such communication with our customer service is the performance of the
contract (General Terms and Conditions). If the inquiry is related to the exercise of
the rights of the data subject, the legal basis is to comply with our legal
obligations under the applicable legislation on the protection of personal
data. |
3 years |
|
Name, surname, date
of birth, phone number, e-mail address |
Contact to provide
you with questionnaires and surveys about purchased products and customer
experience |
When the processing
of your personal data is related to contacting us to provide information
about the use of the products purchased and your user experience, we have a
legitimate interest in providing
sales-related services to our customers, which is not overridden by your
interest or your rights and freedoms to protect your data. |
3 years |
|
Recordings of your
voice when you call our Ploom Care Team |
Improving the
quality of customer service |
Your consent |
3 years or until
withdrawal of consent |
|
Name, surname, date
of birth, phone number, e-mail address |
Registering or
logging in with our suppliers or our authorized third parties
so that JTI can provide you with more detailed information about the Ploom
product (via email, phone or other communication channels). |
Your consent |
3 years |
|
E-mail address and
phone number |
Registering to receive
e-mails, SMS messages and/or calls with useful user information related to
your Ploom product or other products or services and/or emails, SMS messages
and/or customer support calls. |
Your consent |
3 years or until
withdrawal of consent |
|
Name, surname, date
of birth, telephone number, email address, region or place of residence, and details
of your interactions with us, including messages and notes about your
communications and conversations with us |
Providing general
information and support regarding the products purchased, conducting surveys,
collecting feedback, conducting market research and analysis, and other
communications, research and analysis aimed at improving and developing
products, improving the quality of customer service, and improving customer
experience. |
Your consent |
3 years or until
withdrawal of consent |
|
Name, surname,
e-mail address |
Sending invitations
to registered members to participate in market research |
Our legitimate
interest in conducting market research to improve our services and products
and to pursue business strategies |
3 years
|
|
Name, surname, date
of birth, telephone number, email address, region or place of residence, your
answer and to questions about your use of the Ploom product and user
experience, details of your interactions with us related to the use of the
Ploom product and user experience, including messages and notes about your
communications and conversations with us |
Conducting market
research and analysis through questionnaires and surveys (including
collecting feedback and other communications in this regard) with the aim of
improving and developing products, improving the quality of customer service
and other improving the user experience. |
Your consent |
3 years or until withdrawal of consent |
|
Technical data about
the use of our website and contact center, including the time and duration,
the Internet Protocol (IP) IP address to which your device is connected to
the Internet, your login information, browser type and version, time zone
settings, visit data, types and versions of browser plug-ins, operating
system and platform, and information about the use of cookies and tracking
technologies |
Ensuring the
operation of the website and collecting data on the use of the website for
the purpose of improving and developing the website, improving and developing
products, improving the quality of customer service and other improving the
user experience. |
Legitimate
interest in ensuring the
functioning of the website and its improvement that is not overridden by your
interest or your rights and freedoms to protect your data; in relation to the
data collected through optional cookies, your consent |
3 years, except for
certain data collected through cookies (see Cookie Policy) |
|
Transactional and
engagement logs – technical, system data and operational user data |
Technically enabling
the functionalities of the loyalty program, user accounts, and their
maintenance. Additionally, this
information is used for analytics and improvement of our products and
services. |
Performance
of a contract – specifically,
enabling technical support that is necessary for provision of the service,
e.g., administering your account and enabling its functionalities (e.g.,
granting loyalty points). Where
this data is used for analytics and improvement of our products and services,
we rely on our legitimate interest to improve our services,
business performance, where this is not overridden by your interests, rights
and freedoms.
|
3 years or until
deletion of the user account (whichever is earlier) |
|
Personal data
required for the installation and operation of the Gen 4 Application |
Ensuring that your
Gen 4 App is functioning properly |
Performance of a
contract (or General Terms
and Conditions) - provision of the Gen4 Application |
Until the Gen 4 App
is deleted |
|
Gen 4 App usage data
(e.g., user activity, app errors, settings) and Ploom data (e.g., Bluetooth
connection, battery capacity, heating modes) |
Improve app and
Ploom product performance, enhance features, and provide personalized
support, including sending personalized information and notifications. |
Your consent |
3 years or until
withdrawal of consent |
|
Information related
to the use of the Ploom product you have purchased, including information
about your consumption of nicotine products |
To improve the
performance of our products through software and featured updates and for
future products, and to provide personalized support, including sending
personalized information and notifications. |
Your consent |
3 years or until
withdrawal of consent |
|
Data you provide
when registering a Ploom account (name, surname, date of birth, phone number,
e-mail address, password) and data on the use of the Ploom account and the
Ploom application |
Registration and
securing the operation of the Ploom account |
Performance of
the contract (or general
terms and conditions), more precisely – provision of the Ploom user account
and the Ploom application |
Until you delete
your Ploom account |
|
Data required for
the installation and operation of the Ploom Gen 4 Application |
Ensuring the proper
functioning of the Ploom Gen 4 application |
Performance of a
contract (the General Terms
and Conditions) - provision of the Ploom Gen 4 Application
|
Until you delete the
Ploom Gen 4 App |
|
Data about the use of the Ploom Gen 4 App & Ploom device (e.g.,
frequency of logins, screen loads, button clicks, GPS location) and/or
nicotine consumption (e.g., how many smoking sessions you had, duration,
number of puffs) |
Analyze usage data
to improve our products and services, market research, develop new services,
and improve the user experience of your device |
Your consent |
3 years or until
withdrawal of consent |
|
Name, surname, date of birth, e-mail address,
telephone number |
Creating a user account through which you become a
member of the Ploom Club and realize other opportunities that we offer to register
users |
Performance of
the contract (General Terms
and Conditions), more precisely – provision of the Ploom Club, provision of
membership and benefits in accordance with the General Terms and Conditions
of the Ploom Club |
3 years or until
withdrawal of consent |
|
Name, surname, data from
questionnaires that are part of market research (including age, gender,
characteristics of users of tobacco and related products, user habits,
preferences and preferences) |
Conducting market research,
developing our Products and services, analyzing user habits and satisfaction,
analyzing areas for Product and user experience improvement, creating
marketing and sales strategies based on the results of these surveys |
Your
consent |
3 years until withdrawal
of consent |
|
Name, surname, Delivery Address, E-mail Address and Phone Number |
Delivery of gifts to Ploom Club members |
Performance of a
contract (General Terms and
Conditions), more precisely – provision of benefits in accordance with the
General Terms and Conditions of the Ploom Club |
One year after
delivery of the gift |
|
Name, surname, e-mail address |
Delivery of a gift certificate for participation in market research |
Our legitimate interest in rewarding participants in our market
research |
3 years
after delivery of the gift |
|
Unique identifier of the smart device, device type,
operating system and application version, network connection information
including mobile operator and IP address |
Sending technical push notifications of the
Ploom Gen 4 App to the user's smart devices (e.g. battery status of the Ploom
device) |
Performance of a
contract (General Terms and
Conditions), more precisely – provision of the Ploom Gen 4 Application and services related to the use
of the Ploom device |
3 years
or until you delete your app |
|
Unique identifier of the smart device, device type,
network connection information including mobile operator and IP address,
information about the user's interaction with the notification (e.g., whether
the notification has been read) |
Sending marketing push notifications in the
Ploom gen 4 Application to users' smart devices (e.g. notifications about
news, promotions and benefits) |
Your consent |
Until withdrawal of
consent |
|
Name, surname, e-mail address, telephone number,
user account information (where applicable), data you provide to us in your
enquiry, audio recording of your voice, i.e. the conversation performed -
when you contact us by phone |
Managing our customer support service, responding to
customer questions and requests, as well as improving the work of our
customer support |
Our legitimate interest in responding to inquiries
and requests, i.e., to provide support and assistance in relation to the
Products and our services, and to establish a relationship with
users/customers. If the inquiry is related to the Ploom Club, the
exercise of rights and benefits based on membership in the Ploom Club, the
sole basis for the processing of data related to
such communication with our customer service is the performance of the
contract (General Terms and Conditions). If the inquiry is related to the exercise of
the rights of the data subject, the legal basis is to comply with our legal
obligations under the applicable legislation on the protection of personal
data. |
3 years |
|
Name, surname, address, e-mail address, phone number |
Fulfilling obligations towards state and other
competent authorities, when we are legally obliged to provide the data, we
process upon a valid request from the authorities |
Compliance with legal obligations |
3 years |
|
Name, surname, address, e-mail address, telephone
number and other data relevant to the specific case, depending on the
circumstances of the case (e.g., account-related data,
technical and usage data) |
Lawfully protect our interests and take legal action
(including responding to legal or consumer claims), as
well as conducting proceedings to protect these interests, preventing and/or
limiting damage that may occur to JTI |
Our legitimate interest, which is the protection of our rights
and economic interests – for the purpose of possibly establishing,
exercising or defending legal claims |
3 years |
|
Name, surname, e-mail address |
Notifying registered users of changes to this
Privacy Policy |
Our compliance with legal obligations, more
specifically, meeting transparency requirements to inform data subjects about
information related to data processing |
3 years or until
withdrawal of consent |
Information we receive from you in connection with the age verification process
In accordance with
applicable Croatian laws, the sale of tobacco, tobacco products and related
products is prohibited to persons under the age of 18, which is why access to
the content of our website, the Ploom Direct Application and the Ploom Gen 4 Application
is limited and allowed only to persons over 18 years of age. Therefore, before
entering the website, the Ploom Direct App, and the Ploom Gen 4 App, you must
verify that you are over 18 years old.
If you do not provide age information, you will not be able to access the website or use the Ploom Direct App and Ploom Gen 4 App.
Links to other website
Our website, the Ploom
Direct App, or the Ploom Gen 4 App may contain links to other websites that may
be of interest to you. Please note that by leaving our website, the Ploom Direct
App or the Ploom Gen 4 App via these links, you are also leaving the website or
Ploom Gen 4 App over which we have control. Therefore, we have no
responsibility for the protection, security, and privacy of information you
provide or disclose when visiting other websites, and these websites are not
regulated and are not subject to this Privacy Policy. Before visiting the
website in question, please exercise caution and familiarize yourself with the
privacy policy applicable to that site.
Use of anonymized data and artificial intelligence
We also use artificial
intelligence (AI) technology to improve quality, training, and analytics. All
data we process for these purposes is anonymized in accordance with applicable
privacy regulations, which means that we do not store data that could be used
(directly or indirectly) to identify an individual. The anonymization process
involves removing or covering any identifiers, which prevents the possibility
of (later) re-identification. Anonymized data is used internally but may also
be shared with approved business partners to improve service delivery and
operational efficiency.
Disclosure of your information to third parties
Where required or
permitted by law, we may share your personal information with third parties to
help us conduct our business or comply with legal obligations, including:
- our third-party
service providers (DEKRA ZAPOSLITEV d.o.o., Concentrix International Europe
B.V., suppliers or other business partners) acting as our processors, who are
in the EU;
- the JTI group, where
individual companies within the JTI group of companies act as our processors;
- state authorities
and government departments when required by law, including in response to
requests from the police or other government officials;
- our external professional advisors, such as accountants, banks, insurance companies, auditors and lawyers.
Where we store your personal data
The personal data we
collect is transferred outside the European Economic Area.
Our servers are in the
European Union and Switzerland and for Switzerland the European Commission has
already adopted an adequacy decision, i.e. determined that it provides an
adequate level of protection of personal data.
Regarding the transfer
of personal data within the JTI Group, the companies within the group have
concluded a so-called Intra-Group Data Transfer Agreement, which contains
standard contractual clauses adopted by the European Commission. In particular,
the transfer of data to our company in the Republic of
Serbia, JT International AD Senta, is based on such a contract and standard
contractual clauses, in order to guarantee a level of protection of your
personal data in accordance with the requirements of European law on the
protection of personal data.
If you need further
information about the specific measures we use when transferring your personal
data to third countries, or if you need a copy of the relevant contract, please
let us know by emailing [email protected].
If you would like more
information about where your personal data is processed, you can contact us
using the Contact Us form.
Data protection
Once we receive your
information, we will use appropriate procedures and security measures to
prevent unauthorized access and accidental loss of your information. Access to
your data is limited to employees, contractors, and other third parties who
need this data to carry out business processes. They will process your data
solely on our instructions and commit to confidentiality.
Unfortunately, data
transmission over the Internet is not completely secure. While we do our best
to protect your personal information, we cannot guarantee the security of your
information that will be transmitted to our website, the Ploom app, or the Gen
4 app. We have procedures in place to deal with any alleged data breach, and in
the event of a breach, we will notify you and the relevant regulatory authority
in accordance with data protection regulations.
If we have provided
you with a password (or a password you have chosen) that allows you to access
certain parts of our website or the Gen 4 app, you are responsible for
maintaining the confidentiality of that password. Please do not share your
password with anyone.
How long we keep your data
We will retain your
personal information only for as long as necessary to fulfill the purposes for
which it was collected, including complying with legal, regulatory, tax,
accounting, and reporting requirements. We may retain your personal information
for longer in the event of a complaint or if we believe there is a possibility
of legal action due to our relationship with you.
When determining the
appropriate retention period for personal data, we will take into account the
amount, nature and sensitivity of the personal data, the potential risk of harm
from unauthorized use or disclosure of your personal data, the purposes for
which we process your personal data and whether those purposes can be achieved
by other means, as well as applicable legal, regulatory, tax, accounting and
other requirements.
The general retention
periods for the different types of personal data and the purposes of the
processing are specified in point 4 above. If you want to know more, you can
contact us for more detailed information about the retention periods for the
different purposes of processing your personal data.
In certain
circumstances, we will anonymize your personal information for research or
statistical purposes (so that it cannot be linked to you), and we may use that
information indefinitely without prior notice to you.
Your rights
Your rights in
relation to our processing of your personal data are:
(i) the right to
access your personal data, including the right to obtain a copy of your
personal data.
(ii) the right to
rectify your personal data if it is incomplete or inaccurate.
(iii) the right to
erasure of your personal data, in cases where:
– they are no longer
necessary in relation to the purposes for which they were collected or
otherwise processed;
– you have
successfully exercised your right to object to processing;
– have been unlawfully
processed;
– you withdraw, in
whole or in part, the consent you have given us to the processing of your
personal data for the purposes mentioned above and if there is no other legal
basis for the processing;
– they must be deleted
to comply with a legal obligation under the applicable legal regulations;
(iv) the right to
receive your personal data in a structured, commonly used and machine-readable
format or to transmit such data to another controller.
(c) the right to
restrict the processing of your data in certain cases.
(vi) If the processing
is based on consent, i.e., consent, the right to withdraw consent at any time,
without affecting the lawfulness of processing based on consent before its
withdrawal.
(vii) The right to
lodge a complaint regarding the processing of your personal data with the
competent supervisory authority (Personal Data Protection Agency, azop.hr). However,
we kindly ask you to contact us with your request in the manner described below
before contacting the competent authority.
(viii) You may object
to the processing of your data if we are relying on legitimate interests (or
those of a third party) and you feel that this relates to your situation.
If you wish to
exercise any of the above rights, please write to us via the Contact Us form or contact us by phone on 080 2026 or vie
email [email protected].
We will not charge you
any fee for accessing your personal data or exercising any other rights.
However, if your claim is manifestly unfounded, repetitive, or excessive, we
may still charge you a reasonable fee. Alternatively, in such circumstances, we
may also deny your request.
In certain cases, we
will need to ask you for information that allows us to verify your identity and
ensure your right to access your personal data or to enable you to exercise
other rights. This is a security measure to ensure that your personal data is
not disclosed to a person who does not have a right to it. We may also contact
you to obtain additional information about your request, based on which we can
respond more quickly.
Changes to the Privacy Policy
Any changes to this
Privacy Policy will be posted on this website, and if possible, you will also
be notified by email. Please check for changes or additions to this Privacy
Policy.
