My Privacy Notice

We take privacy seriously. This notice tells you who we are, what information about you we collect, and what we do with it. We will use information about you only in accordance with applicable data protection laws.

Please also read our terms of use related to each feature under the Site for more information.

ABOUT JT International SA (“JTI”)

JT International SA is a company limited by shares organized and existing under the laws of Switzerland, with registered office address at 8, rue Kazem Radjavi, 1202 Geneva, Switzerland, registered with the Commerce Registry of the Canton of Geneva under number CHE-105.274.060 ("JTI”, “we”, “us”, “our”).

JTI operates https://www.mywinstoniraq.com (the "Site"). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.

Privacy Policy

By using the Site, you agree to the collection and use of information in accordance with this policy.

Website usage

By clicking agree, you have confirmed that you are over 18 of age and that you are a smoker.

You consent to interacting with all Winston brand related information that is present on mywinstoniraq.com and you understand that we are not encouraging or discouraging you to or from smoking.

Any loyalty points you collect are solely based on your on-website behavior. Your points are based on the content you consume and your engagement with each of the Site features.

Information Collection And Use

While using our Site, we may ask you to provide us with certain Personal Information that can be used to contact or identify you. Personal information refers to:

Full name
Date of Birth
Mobile Number
Email address
Smoking preferences

Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site ("Log Data").

This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this information.

Communications

We may use your Personal Information to contact you for further communication via:

SMS
Phone calls
Emailers
WhatsApp messaging
Push notifications on the website

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive.

Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

Security & Personal data

The security of your Personal Information is important to us. We strive to use commercially acceptable means to protect your Personal Information, and we guarantee that JTI will not sell your information to 3rd parties and all the information you provide is confidential.

Purpose of the Information

JTI is collecting and processing the personal data of individuals reached via SMS, e-mail, social media or website messages, phone calls or any other means who have approved the collection and processing of their personal data (“Data Subjects”) for market research purposes about the products distributed by JTI and the services offered on the Site.

Purpose of Processing of Personal Data of Data Subjects

Personal Data is processed for the purpose of one-end communications from www.mywinstoniraq.com to the users.

Personal Data That Is Processed Upon Explicit Consent by Data Subjects

Personal data that may be processed in line with explicit consents:

Full name
Date of Birth
Mobile Number
Email address
Smoking preferences

Where we obtain personal data directly from you

You may give us information about you in a number of ways, including when you:

register to be a member of our databases in person during 1-2-1 activations or;
fill in forms on our website www.mywinstoniraq.com, our associated platforms and micro-sites.

Transfer of the Personal Data of Data Subjects

The personal data of Data Subjects may be shared with, or transferred to, the shareholders, authorized persons, subsidiaries, business solution partners, and suppliers of JTI, private entities, and the official institutions or governmental bodies.

The Rights of Data Subjects

Data Subjects have the right to raise and communicate their own requests and objections by email on info@mywinstoniraq.com for correction, ban on temporary access, blocking, ban on communication, processing and deletion, of the personal data. Such requests are resolved by JTI within thirty (30) business days.

Where we store your personal data

Depending on the nature of the personal data and the purposes of data processing, the personal data we collect may be transferred abroad as per your consent of processing your data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data to third countries.

If you want more information on where your data is processed, please use (.).

Data Security

Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access, and to prevent your information from being accidentally lost. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your information on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our platforms. We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

How long we will keep your information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You can contact us and ask us for details of the retention periods for different aspects of your personal data in case you want to learn more.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your information, though these are subject to exemptions.

Request access to your personal data (known as a “data subject access request”).
Request a copy of your personal data we are processing.
Request correction of your personal data where there is incomplete or inaccurate information.
Request erasure/destruction of your information
Object processing of information
Request transfer of your information to you or a third party.
You have the right to withdraw consent where we are relying on your consent to process your data. You can do this by blocking, unsubscribing, opting out in the related communication. If you withdraw your consent for us to contact you with informative communications by a certain method you will no longer receive those communications by that particular type of communication. Please note that it may take up to 30 days for us to process your request.
Right to lodge complaints regarding the processing of your personal data with the relevant supervisory body

If you wish to exercise any of the rights set out above, please use the (.)

Changes To This Privacy Policy and Applicable Law

This Privacy Policy is effective as of January 2022 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this Site.

JTI reserves the right to update or change the Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the www.mywinstoniraq.com after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

This Privacy Policy is subject to Iraq law.