Consumer Privacy Notice
We take privacy seriously. This notice tells you about our company, the information we collect about you and what we do with it.
Please also read the terms of use related to the service you are interested in, It provides more information about how we do business and the limitations that may apply to eligibility.
Who are we?
We are a three-eight trading establishment registered under Commercial Registration No. (4031052660), Our registered headquarters are located in Makkah, Saudi Arabia.
How do we collect information about you?
We may collect information about you in different ways.
- You can provide us with information directly (such as: Fill out a form or by contacting us).
- We may collect information automatically (such as when you use any of our application or website).
- We may obtain information from third parties (such as: publicly available information on social media platforms such as Facebook and Twitter).
In this notice, We refer to all the ways in which you communicate with us as “consumer touchpoints”. Consumer touchpoints include physical points (such as: retail and event outlets) and digital (e.g.: applications and websites).
We may collect the information you provide directly. It usually occurs when:
- register to become a member of our databases (this can be done in person, via an app or online, for example);
- purchase tobacco products from our website or retail outlet;
- Download or use a digital hotspot (such as: an application or website);
- communicate with us through a touchpoint, email, social media or telephone;
- register our device;
- Subscribe to the TRIO8 Software Portal (if applicable);
- Sign up to receive Trio 8 press releases, email alerts or product messages;
- participate in Trio 8 surveys (where permitted by law); or
- Attend an event organized by Trio 8.
We may collect information about you automatically. It usually occurs when:
- Visit an outlet that sells tobacco products (such as: Collect your data at check-out, or through sensors in the port connected to mobile phone technology);
- Attend an event organized by Trio 8 (such as: purchases that occur at the event or through sensors related to mobile technology;
- communicate with us (e.g., through a touchpoint or social media platforms);
- use consumer touchpoints (e.g., through tracking mechanisms in an app or website); or
- Create public posts on social media platforms that we follow (for example: so that we can understand public opinion or respond to requests related to tobacco products).
We may also collect information about you automatically through the use of cookies and similar tracking technologies on digital consumer touchpoints. The cookies and technologies used depend on the respective consumer touchpoint. To identify cookies (including Google analytics cookies) and similar technologies used in a touchpoint, including how we accept or reject cookies, Please see the Cookie Notice available on or through this touchpoint.
where permitted by law, We may obtain information about you from third parties. This may include information shared between affiliates, publicly available profile information (such as your preferences and interests) on third-party social media sites (such as Facebook and Twitter), and marketing lists obtained from third-party marketing agencies.
We may also collect information in other contexts that have been clarified to you at the time.
What information do we collect about you?
We may collect different types of information about you:
- Information needed to fulfill your requests
- Information needed to provide warranty services
- Information you provide to us in forms or surveys
- Information about your visits to our outlets and events
- Information you provide to us in the communications you make with call centers
- Information about your preferences and interests
- Information needed to verify age
The information we collect directly from you will be clear from the context in which you provide it. For example:
- If you order one of our products through a touchpoint, You provide your name, contact, billing details and selected products so that we can fulfill your order;
- You may provide information about your product preferences and interests so that we can provide products and services of interest to you;
- If you schedule a visit to us (or anyone who supports our products or services), We may collect your name and contact details;
- We may collect information that enables us to verify your age; For example: A copy of your identity document or a photo of your face (where permitted by law).
In general, The information we collect automatically will relate to:
- details of your visit or contact (such as time and duration);
- at a retail outlet or event (including immediate vicinity), how often you visit, areas you visit, how long it takes to visit and purchases;
- your use of digital consumer touchpoints (such as the pages you visit, the page you came from, the page you went to when you left, the search terms you entered, or the links clicked within the touchpoint);
- Your device (such as your Internet Protocol (IP) address, unique device identifier, location data, or details of any cookies we may have stored on your device).
The information we collect from third parties will generally consist of publicly available profile information (such as your preferences and interests); For example: Information obtained from public social media posts.
For what purpose do we use your information and on what legal basis?
In this section, Describe the purposes for which we use personal data. However, This is a global notice, When the laws of a country restrict or prohibit some of the activities described in this notice, We will not use information about you for those purposes in that country.
Subject to the above, We use your information for the following purposes:
- to comply with regulatory obligations, Such as verifying your age and status as a user of our products
- to sell our products to you, Including fulfilling your orders and processing payments
- To provide sales-related services, Including dealing with your inquiries and requests and providing warranty services
- to market our products (where permitted by law), Including managing loyalty programs, product improvement, market research, developing marketing strategies, managing marketing campaigns, and personalizing your experiences at outlets that sell tobacco products and at events
- for us or business partners to inform you of potential opportunities to participate in the marketing of tobacco products (where permitted by law)
- To support all of the above, including the management of your accounts, Allowing you to use consumer touchpoints, messaging with you, managing appointments with us or someone who supports our products or services (for example for a new product or after-sales service), customizing your experiences with consumer touchpoints, management, and troubleshooting
- For business analytics and improvements, Including improving PMI products, outlets, events and the information we provide to our customers
- For other purposes that we inform you, Or it will become clear to you from the context, At the point of collecting information first
The legal basis for our use of your information is one of the following:
- comply with a legal obligation to which we are subject;
- Performance of the terms of the contract to which you are a party;
- a legitimate business interest that is not overridden by your interests to protect the information;
- your consent (which we will request before processing the information); When none of the above applies.
For the purposes for which we use the information, with the corresponding methods of collection and the legal basis for use, Following:
Purpose
Method of collection and legal basis for processing
Compliance with regulatory obligations
- Check your age and status as a user of our products
This information is generally provided to us directly by you.
We use them because it is necessary for us to comply with a legal obligation to sell products to adults only, or in countries where there is no such legal obligation, Because we have a legitimate business interest to sell our products to adults only is not overridden by your interests, rights and freedoms to protect your information.
Sell Our Products
- Fulfill your requests (including sending receipts)
- Payment Processing
- Providing warranty services
This information is generally provided to us directly by you (usually your name, address, email address, and payment information).
We use them to fulfill our contractual obligations to you as a buyer of our products.
Providing sales-related services
- Handling your inquiries and requests
- Communicate with you
- General management and troubleshooting
- Loyalty Programs Management
This information is generally provided to us directly by you.
We use them because we have a legitimate business interest in providing sales-related services to our customers that are not overridden by your interests, rights and freedoms to protect your information.
Marketing our products (where permitted by law)
- understand your preferences (such as products or events that may be of interest to you or may be better tailored to your needs); and market it to you personally where permitted by law
- Loyalty Programs Management
- Invite you to participate in surveys or market research campaigns and manage them
- For Market Research
- Develop marketing strategies
- Marketing Campaigns Management
- personalize your experience with consumer touchpoints (e.g. for personalizing your visit; For example, with greetings or suggestions that may interest you)
This will usually be a combination of information you provide to us (for example: your name, contact and social media details); Information we collect automatically (for example: Use technology to monitor the use of consumer touchpoints) and information we obtain from third parties (where permitted by law) (such as public social media posts).
We use them on the basis that we have a legitimate business interest to market our products, Manage consumer touchpoints and personalize your experiences, In these ways that are not overridden by your interests, rights and freedoms to protect your information.
Marketing our products (where permitted by law)
- To provide you with information about Trio 8, to administer its promotions, products, services, outlets and events, to organize our products; to develop and improve tools for these purposes
This will usually be a combination of information you provide to us (for example: your name, contact details and social media); Information we collect automatically (for example: Use of cookies and similar technologies) and information we obtain from third parties (where permitted by law) (such as public social media posts).
We use them on the basis that we have a legitimate business interest to market these things that are not invalidated by your interests, rights and freedoms to protect your information.
Support for all above purposes
- Manage your accounts
- Enable you to use consumer touchpoints (for example: Allow you to remain registered in hotspot partitions reserved only for authorized users; and manage language preferences and link your shopping cart)
- Correspondence with you
- Manage appointments with us or someone who supports our products or services (for example: regarding a new product or after-sales service)
- Improve your experiences
- Management and troubleshooting
This will usually be a combination of information you provide to us (typically: Name, password (or equivalent)) and information we collect automatically (for example: information about your device, cookies and similar tracking technologies).
We use them on the basis that they are compatible with the purpose of using the information we support. For example: When we manage your account to support a purchase or to provide after-sales service, We use the information to fulfill our contractual obligations to you as a buyer of our products; when we manage your account to display our products, We support and use marketing on the basis that we have a legitimate business interest to market our products that are not overridden by your interests, rights and freedoms to protect your information, and so on.
Business analytics and improvements
- Allow us or business partners to inform you of potential opportunities to participate in the promotion of tobacco products
- For business analytics and improvements (including tobacco products, outlets selling their products, events, digital consumer touchpoints, and information we (or our affiliates) provide to our customers)
This will usually be a combination of the information you provide to us; information we collect automatically; and information we obtain from third parties (where permitted by law).
We use them on the basis that we have a legitimate business interest to analyze and improve the performance of our business, products, consumer touchpoints, outlets and events and invite others to participate in the promotion of tobacco products; Which is not negated by interests, rights and freedoms to protect your information.
Where we do not base our use of your information on one of the above legal bases, We will ask for your consent before processing the information (these cases will be clear from the context).
In some cases, We may use information about you in ways not described above. In this case, We will provide an additional privacy notice explaining this use. You must read any additional notice in conjunction with such notice.
Who do we share your information with and for what purpose?
We may share information about you with:
- Subsidiaries
- third parties that provide Trio 8 or its affiliates or you with products or services;
- carefully selected business partners and advertisers from Trio 8 or affiliates (in regions associated with our products, or in accordance with their style and image) so that they can communicate with you about offers that they think may be of interest to you according to your preferences;
- other third parties, Where required or permitted by law.
Sharing data with subsidiaries
- Your information will be shared with consulting or advertising companies
- Your information may be shared with affiliates or branded entities responsible for the services in the country in which you live (if the affiliates are not collecting information about you for the first time) for all the purposes described in this notice.
- Your information may be shared with any other affiliates you communicate with (for example: If you are traveling and would like to know where to buy tobacco products in a new country or to know where you can find a service or support for tobacco products) to enhance the services we provide to you.
Details of the subsidiaries and the countries in which they operate are available here.
Sharing data with third parties
- We may share information about you with third parties that provide Trio 8 or affiliates or you with products or services (such as consultants, payment service providers, delivery service providers, retailers, product specialists, information service providers, and age verification service providers).
- We may share information about you with carefully selected business partners or advertisers from Trio 8 and/or affiliates (in line with the type of thing you may think is relevant to our products; such as having a similar or complementary image, style, or function) so that they can communicate with you about products, services and promotions that they think may be of interest to you according to your preferences.
- We may share information about you with other third parties, To the extent required or permitted by law, such as regulatory authorities, Government departments; in response to a request from law enforcement authorities or other government officials; when we deem disclosure necessary or appropriate to prevent physical damage or financial loss or in connection with the investigation of suspected or actual illegal activity; and in the context of organizational restructuring.
Where can information about you be sent to?
As is the practice of any multinational organization, We transmit information globally. Accordingly, Information about you may be transferred globally once it is shared with affiliates (if your information is collected within the EEA, It means that that information may be transferred outside of it.)
When using the information as described in this notice, Your information may be transferred either within or outside the country or territory where it was collected, This includes their transfer to a country or territory that may not have equivalent data protection standards.
For example EEA affiliates may transfer personal information to subsidiaries outside the EEA. In all cases, The transport will be:
- Based on the European Commission’s suitability decisions;
- Subject to appropriate safeguards, such as model contracts for the European Union; or
- necessary for the performance of obligations under a contract between you and us (or the performance of pre-contract measures taken at your request) or for the conclusion or performance of the terms of a contract concluded in your favor between us and a third party; Like when it comes to travel arrangements.
In all cases, Appropriate security measures to protect personal information will be implemented in those countries or territories in accordance with applicable data protection laws.
How do we protect your information?
We implement appropriate technical and organizational measures to protect the personal information we hold against unauthorized disclosure, use, alteration or destruction. Where appropriate, We use encryption and other technologies that can help protect the information you provide. We also require our service providers to comply with strict data privacy and security requirements.
How long do we keep your information?
We will retain your information for as long as necessary to fulfill the purposes for which it was collected. We will delete them afterwards. The period varies depending on the purposes for which the information was collected. Please note that you have the right to request deletion of information in some cases. We are also sometimes legally obligated to retain information for tax and accounting purposes, for example.
We usually retain data based on the criteria shown in the table below:
genre
Clarification/typical retention criteria
- Marketing to you (including product messages) (if you use digital touchpoints and can be contacted)
Most of the information in your marketing profile is retained for the duration of our marketing relationship with you; for example, While you continue to use digital hotspots, Or answer our calls. However, Some elements of your marketing profile will expire, Such as records of how we interact with you, naturally after a certain period of time, We therefore automatically delete them after specific periods (usually 3 years) as appropriate for the purpose for which we collected them.
- Marketing to you (including product messages) (if you no longer contact us)
This scenario is similar to the one mentioned above, But if we no longer communicate with you for a long time (usually two years), We’ll stop messaging you with product messages and delete their response history. And it will happen, For example If you never click an event invitation, log into a digital hotspot, or call customer service, During that time. This is because in these circumstances, We assume that you prefer not to receive messages.
- Marketing to you (including product messages) (if you can no longer be contacted)
If you sign up to receive product messages, However, the information you have provided to us to contact you is not correct, We will retain your details for 6 months usually only to allow you to return and correct them.
- Marketing to you (including product messages) (incomplete registrations)
If you start registering in a database, But you didn’t complete the process (for example, If you do not complete the age verification process or do not accept the terms of use of the hotspot), We will retain your details for 6 months only to allow you to return and complete the process.
- Market Research
If you are not registered with us for other purposes (such as: product, warranty and customer service messages), We use your publicly available information to understand the market or your preferences, We will retain your information for a short time to carry out a particular item of market research.
- Procurement & Warranty
If you are purchasing goods, We will retain details of this for as long as required to complete the sale and comply with any legal obligations (for example, for tax and accounting record-keeping purposes). If you also sign up for a device warranty, We will retain these details for as long as they are relevant to the warranty.
- Customer Service
If you contact customer service, We will prepare a record of this (including details of your enquiry and our response) and will keep it for as long as it is relevant to our relationship; For example If you need us to replace a device under warranty or if your recent inquiries are relevant. Temporary records may be (for example, Automated recording of a telephone call requesting that you be directed to a retail store (only so that more permanent records can be made; It will only be kept temporarily.
- System audit logs
System audit logs are usually kept for only a few months.
- Business Analytics
Business analytics data is typically collected automatically when consumer touchpoints are used and anonymization/aggregation soon after.
What rights and options do you have?
You may have some or all of the following rights in relation to the information we hold about you:
- request your access to them;
- request correction, updating or erasure;
- request to restrict our use of it; in certain circumstances;
- object to our use of it; in certain circumstances;
- withdraw your consent to our use of it;
- data portability, in certain circumstances;
- unsubscribe from their use for direct marketing;
- Submit a complaint to the supervisory authority in your country (if applicable).
We offer you easy ways to exercise these rights, Such as “unsubscribe” links or through our contact address mentioned on the Website.
Some of the mobile applications we provide to you may also send you promotional messages about, for example, new products or services. You can disable these messages through the settings on your phone or app.
Your rights depend on the laws of your country. If you are in the EEA, you will be granted the rights set out in the table below. If you’re elsewhere, you can contact us (see the “Who should you contact with questions?” section at the end of this notice) to find out more.
Rights relating to the information we hold about you
More details (Note: Certain legal restrictions apply to all these rights)
- Request your access to it
This is an affirmation of:
- whether or not we process your information;
- Our name and contact details;
- purpose of processing;
- categories of information concerned;
- the categories of people with whom we share information; where any person is outside the EEA and does not benefit from the European Commission’s convenience decisions and appropriate safeguards for the protection of information;
- source of information if we do not collect it from you (and if we have the source);
- (As far as we can do, to which you will be brought to the attention of the existence of an automated decision-making process, including the collection of information, that produce legal effects relating to you; or significantly affect you in a similar way, information relating to the logic in question as well as the importance and expected results of such processing for you;
- Criteria for determining the period during which we will store information.
At your request, We will provide you with a copy of the information we use (provided that this does not affect the rights and freedoms of others).
- Request to correct or update them
This applies if the information we hold is inaccurate or incomplete.
- Request to delete it
This applies if:
- The information we hold is no longer necessary in connection with the purposes for which we use it;
- We use the information based on your consent and then you withdraw your consent (in this case, We will remember not to contact you again, unless you tell us that you want to delete all your information in which case we will respect your wishes);
- We use information based on a legitimate interest and we discover, After your objection, that we have no fundamental interest in continuing to use them;
- The information was obtained or used unlawfully; or
- Compliance with a legal obligation.
- Request to restrict our processing of it
This right applies, temporarily while your case is being considered, If you:
- challenge the accuracy of the information we use; or
- object to our use of information on the basis of legitimate interest
(If you use your right in these cases, We’ll let you know before we use the information again.)
This right also applies if:
- our use is unlawful and you oppose the erasure of the data; or
- We no longer need the data, But you ask for it to file a lawsuit.
- Objection to our handling of it
You have two rights here:
- If we use your information for direct marketing: You can “opt out” (without having to justify it) and we will comply with your request;
- If we use your information on a legitimate interest basis for purposes other than direct marketing, You may object to our use of these purposes, with an explanation of your particular situation, We will consider your objection.
- To withdraw your consent to our use of it
This applies if the legal basis on which we use your information is consent. These cases will be clear from the context.
- Data portability
Just in case:
- provided us with data;
- We used this data, By automated means, on the basis of your consent or on the basis of the fulfillment of our contractual obligations to you,
Then You have the right to receive data again in a commonly used format, and the right to require us to transfer data to another person if it is technically feasible to do so.
- To file a complaint with the competent authorities in the Kingdom of Saudi Arabia
Please refer to the website of the competent authority in your country, If any.
Country-specific bonus points
Depending on the country in which you are located, You may have some additional rights.
Who should you contact with questions?
If you have any questions, or wish to exercise any of your rights, You can send an email on contact@trio8tobacco.com
If your country has a data protection authority, You have the right to contact her with any questions or concerns. If we are unable to resolve your questions or concerns, You also have the right to seek judicial relief before a national court.
Changes to this Notice
We may update this Notice (and any additional Privacy Notice), From time to time. We will notify you of changes required by law to do so; We may announce the update on the Website or via any other means we deem appropriate.
