PLOOM PRIVACY POLICY
Effective as of 01.10.2026
1. Definitions and introductory remarks
We respect Your privacy and are committed to protecting Your personal data. Please read the information below carefully to understand how we collect, use, and protect your personal data.
The terms used in this Privacy Policy have the following meanings:
We or JTI | meaning the company JT INTERNATIONAL AKCIONARSKO DRUŠTVO SENTA |
JTI Group | meaning the group of JTI companies to which JTI belongs |
Ploom device | meaning the electronic device for heating a non-combustible tobacco product under the Ploom brand |
Products | meaning the products from the JTI Group portfolio, including the Ploom Device and related accessories |
Website | meaning the content available at the domain www.me.ploom.com, the use of which is subject to the Terms of Use |
Ploom App | meaning a mobile application designed to connect with the Ploom device |
Ploom Club | meaning the loyalty program conducted by JTI with its partners, in accordance with the General Terms of Participation in the Ploom Club program |
LPDP | meaning the applicable Law on Personal Data Protection of Montenegro |
This Privacy Policy presents a notice on personal data processing, explaining how We and our partners collect and use information about You when interacting, in connection with the Products, through both online and offline channels. This may include, for example, when You visit the Website, use the Ploom App, create a user account, use the benefits of the Ploom Club, wish to learn more about the Products, receive promotional or educational content from us, participate in market research, or contact us for customer support or any other reason.
Our Products, as well as all related content, activities, and services, are intended for adults residing in the Montenegro who consume tobacco or related products.
We may from time to time amend and improve this Privacy Policy, in which case the updated version will be made available on the Website and, where appropriate, in other locations, clearly indicating the date on which it takes effect. In certain cases, We may also notify You by email. If You do not agree with the new rules, please refrain from sharing Your personal data with us or our partners in any manner. As for data you have previously consented to be processed, You may exercise Your right to withdraw consent (see Section 12 of this Privacy Policy for more information).
This Privacy Policy, as well as any amendments or supplements thereto, is governed by the laws of Montenegro, namely the LPDP and its accompanying bylaws.
2. Data controller and controller’s representative for Montenegro
DATA CONTROLLER | |
Business name: | JT INTERNATIONAL AKCIONARSKO DRUŠTVO SENTA |
Address: | Subotički put 25, 24400 Senta, Serbia |
Reg. number: | 08052441 |
Email: | zastitapodataka@jti.com |
Phone: | +381 11 20 50 300 |
DATA CONTROLLER`S REPRESENTATIVE | |
Business name: | PLUS D.O.O. ZA TRGOVINU I USLUGE PODGORICA |
Address: | Josipa Broza Tita 29, Podgorica, Montenegro |
Reg. number: | 08762023 |
Email: | info@plusmne.com |
Phone: | +382 20 87 57 73 |
3. From whom do We collect data?
We may collect Your personal data in several ways.
Directly from You, when You provide Your data to us. | For example, when You create Your user account, either independently or with the assistance of sales or other staff; when You subscribe to receive promotional content; or when You contact us by mail, email, or phone; |
Indirectly from You, through services and platforms to which You have given consent to share Your data with us or with their partners. | For example, when You agree that Your data be shared with us through a form on the social network Instagram because You wish to be contacted by our team for information about the Products; or when You agree that Your data be shared through online shopping and delivery services (such as Glovo) for the purpose of registering in the Ploom Club and receiving benefits when purchasing Products; |
Automatically, when using the Website and the Ploom App. | In this case, we (or our partners, on our behalf) use cookies and similar technologies. Please refer to Section 5 of this Privacy Policy for more information on how we use these technologies. |
4. Data We process, how We use it, and on what legal basis
JTI collects data that is adequate, relevant, and limited to what is necessary for the specific purpose of processing. We use, or may use, Your data to achieve several predefined purposes. Each processing activity We carry out is based on appropriate legal ground prescribed by the provisions of the LPDP.
DATA | PURPOSE OF PROCESSING | LEGAL BASIS FOR PROCESSING |
Age (data indicating that you are 18+ years old), country of residence (Montenegro) | Implementation of the Terms of Use and enabling access to the Website and the Ploom App, as their content is intended exclusively for adults residing in Montenegro | Our law-based interest in ensuring compliance with the Terms of Use, as well as implementing our corporate social responsibility policy in the territory where We operate |
First name, last name, date of birth, email address, phone number | Creating a user account through which one becomes a member of the Ploom Club and gains access to other options we offer to registered users | Your consent |
Data necessary for exercising rights and benefits related to our campaigns and those of our partners, particularly within the Ploom Club (e.g., first name, last name, phone number, number of points collected that affect the calculation of the retail price of the Products) | Provision of benefits related to the purchase of Products | Our and our partners’ law-based interest in influencing business performance through loyalty programs and by granting benefits to consumers |
First name, last name, delivery address, email address, phone number | Delivery of gifts to Ploom Club members | Our law-based interest in developing relationships with members of the loyalty program and providing services, benefits, and advantages in accordance with the rules of the loyalty program |
First name, last name, email address, phone number, user account details (where applicable), information about purchased Products | Educational communication with Product buyers, sending informational materials via electronic and/or SMS messages and/or phone calls regarding Product functionalities, optimal use, and similar topics | Your consent |
First name, last name, city/municipality of residence, email address, phone number, user account details (where applicable), information about purchased Products (where applicable) | Marketing communication with individuals who have created a user account, sending promotional materials via electronic and/or SMS messages and/or phone calls about activities, new offers, and benefits related to the Products and our service | Your consent |
Unique smart device identifier, device type, operating system and app version, network connection data including mobile operator and IP address | Sending technical push notifications from the Ploom App to users’ Android devices (e.g., Ploom device battery status) | Our law-based interest in providing, through the Ploom App, services related to the use of the Ploom Device that the user has requested by installing the Ploom App on their smart device |
Unique smart device identifier, device type, network connection data including mobile operator and IP address, information about user interaction with notifications (e.g., whether a notification was read) | Sending marketing push notifications from the Ploom App to users’ Android devices (e.g., updates, promotions, and benefits) | Your consent |
First name, last name, email address, phone number, user account details (where applicable), audio recording of voice or conversation | Managing our customer support service, responding to user inquiries and requests, and improving the operation of our customer support service | Our law-based interest in responding to questions and requests, providing support and assistance related to the Products and our services, ensuring the application of the General Terms of Sale and Ploom Club rules, as well as maintaining an appropriate level of communication with users to build trust and strengthen relationships with them |
First name, last name, email address | Sending invitations and reminders to register Product customers to participate in market research (e.g., by completing questionnaires) | Our law-based interest in conducting market research to monitor defined indicators among registered customers, so that We can plan and create our marketing and sales strategies based on the results of such research |
First name, last name, data from questionnaires used in market research (including age, gender, status as a tobacco or related product user, user habits, tendencies, and preferences) | Conducting market research, developing our Products and services, analyzing user habits and satisfaction, identifying areas for improvement in Products and user experience, and creating marketing and sales strategies based on research results | Your consent |
First name, last name, email address | Delivery of gift vouchers for participation in market research | Our law-based interest in motivating and rewarding participants in our market research activities |
User activity data on the Website collected through cookies and similar technologies | Enabling the functionality of the Website, developing a general content strategy based on user preferences to improve user experience and enhance our Products and services | Your consent |
Data about Your device and browser, data about your interaction with the Website and ads, unique identifiers and other data collected through cookies, pixels and similar technologies | Tailoring advertising to Your interests, showing You more relevant ads on other sites and platforms, and measuring the performance of our advertising campaigns | Your consent |
First name, last name, email address, phone number (where applicable) | Communicating with You and responding to Your questions and requests submitted through the contact form on the Website | Our law-based interest in responding to questions and requests from interested individuals and/or Product users, providing necessary information about the Products, and thereby establishing and maintaining relationships with these individuals and understanding their interests |
First name, last name, address, email address, phone number | Responding to Your questions and requests regarding personal data protection | Fulfillment of our legally prescribed obligations |
First name, last name, address, email address, phone number | Fulfilling obligations toward governmental and other authorities when We are required to disclose the data We process | Fulfillment of our legally prescribed obligations |
First name, last name, address, email address, phone number | Lawful protection of our interests, including conducting proceedings to protect those interests, as well as preventing and/or mitigating potential damage to JTI | Our law-based interest in protecting our company by lawful means |
First name, last name, email address | Notifying registered users about amendments to this Privacy Policy | Our law-based interest in informing data subjects about the rules We apply regarding data processing, whereby in some cases we do so also to fulfill our legally prescribed obligations |
4.1. Consent for personal data processing
We process certain data based on Your consent. You can provide valid consent for processing in several ways: by checking a box on the Website, enabling cookies and similar technologies, such as pixels, via the Privacy Preference Centre (by moving the slider from inactive to active status), by giving Your oral or written statement, or through a clear affirmative action — or even a combination of these methods.
For example, when creating a user account at a point of sale, You may give oral consent to the person collecting data on our behalf, so that You can receive an email or SMS message containing a unique code. By creating a password or providing the code to that person, You confirm that You consent to the processing of Your data for the purposes based on consent, as previously explained to You through the notice displayed at the point of sale.
For more information about Your rights and the option to withdraw consent, please carefully read Section 12 of this Privacy Policy.
5. Cookies and similar technologies
The Website uses cookies and similar technologies for various purposes, including making the Website work properly, improving Your experience and tailoring content and advertising to Your interests. The information collected in this way may, in some cases, constitute personal data, but not necessarily.
Cookies are simple text files stored in a web browser or on a device. Their primary purpose is to enable the website to “recognize” the user upon their next visit. In that case, the website uses the data stored in the cookie to automatically retrieve information about the user’s previous activity on the site. Cookies cannot access data stored on devices, but they can collect information about online activities.
In addition to cookies, the Website also uses pixels, small pieces of code that can record when You visit a particular page on the Website or take an action on it, such as clicking on certain content, and send this information to us and/or our partner that provides this technology.
Cookies and similar technologies may collect different types of information and be used for various purposes. Depending on their purpose, not enabling or disabling them may affect certain features of the Website or the tailoring of content and ads to your interests. You can manage your settings at any time through the Privacy Preference Center.
5.1. Strictly necessary cookies
These cookies are necessary for the proper functioning of the Website and the Ploom App and cannot be disabled in our systems. They are usually activated only in response to Your actions that constitute a request for certain services, such as setting Your privacy preferences, logging into Your account, or filling out forms. You can set Your browser to block or alert You about these cookies, but some parts of the Website and the Ploom App will then not function properly. These cookies do not store personal information. Some of these cookies are persistent, while others are session cookies.
5.2. Performance cookies
These cookies help us understand how users interact with our Website, allowing us to continuously tailor them to user preferences. Based on these cookies, We obtain information such as the number of visits, which pages are most and least visited, which content users access, in what order, and so on. This information is collected through a third party, in an aggregated form, and is therefore anonymous. If You do not allow us to use these cookies, We will not be able to monitor the use and performance of the Website in the described way. Some of these cookies are persistent, while others are session cookies.
5.3. Functional cookies
These cookies enable the Website to provide optimal functionality and personalization to users. They may be set by us or by third parties providing services related to the Website. If You do not allow the use of these cookies, some or all the services may not function properly. These are session cookies.
5.4. Targeted Advertising Technologies
We may use these technologies, such as cookies and pixels, together with our advertising partners to better understand Your interests and show You more relevant ads on other sites and platforms, as well as to measure the performance of our advertising campaigns. The use of these technologies may involve collecting information about Your device and browser, Your interaction with our Website and ads, as well as unique identifiers and other information that allows Your device or browser to be distinguished from others. If You do not allow these technologies, You may still see ads, but they will be less tailored to Your interests.
5.5. Social media cookies
These cookies are set by a range of social media services that We have added to the Website to enable You to share our content with Your friends and communities. They can track Your browser across other websites You visit and build a profile of Your interests. This may influence the content and marketing messages You see on other websites You visit. If You do not allow the use of these cookies, You may not be able to use or view these content-sharing tools. These are persistent cookies.
6. Data We do not process
We do not collect or process special categories of personal data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; genetic data; biometric data for the purpose of uniquely identifying an individual; data concerning health, sexual life, or sexual orientation; nor data related to criminal convictions, offenses, and security measures, or data about minors. Please do not disclose or send us such data.
If You are an Android smart device user, the Ploom App may offer You the option to access the application using facial recognition or fingerprint identification, like how You unlock Your device. It is important to note that this is a local function of Your smart device, and such data is never shared with us. JTI does not collect or process Your biometric data.
7. Use of anonymized data and artificial intelligence
We may use artificial intelligence (AI) technologies to analyze data for the purposes of quality improvement, training, and analytics. All data processed for these purposes is anonymized in accordance with applicable data protection regulations, ensuring that no personally identifiable information (PII) is retained. The anonymization process involves removing or obscuring identifiers to prevent re-identification. Anonymized data may be used internally or shared with approved partners to improve service delivery and operational efficiency.
8. Is there an obligation to provide data?
You are not required to provide Your data, You do so on a voluntary basis. This will be the case, for example, when You create a user account, use the Website or the Ploom App, or contact us and share Your contact details so that We can respond to Your question or request.
Please note that in some cases, We may be unable to perform our activities if You choose not to provide certain data (e.g., You will not be able to become a Ploom Club member if You do not create a user account by entering Your data).
9. Recipients of personal data
Your data is primarily processed and used by JTI.
In some cases, it may be necessary to make your data available to third parties, i.e., recipients. These may include members of the JTI Group that help us respond to Your questions or requests or assist us in carrying out our business activities and processes; or our partners who help maintain the functionality of the Website and the Ploom App, databases, and tools We use; provide courier services related to the sale of Products; offer marketing services, including targeted advertising services; or provide other services (such as market research or customer support).
We will ensure that Your data is handled lawfully and that data recipients process it in accordance with the data protection rules.
In some instances, there may be a legal obligation to make Your data available to competent authorities (e.g., the Tax Administration, courts, and similar institutions).
10. Transfer of data abroad
We primarily use Your data within the territory of Montenegro.
The data We collect is stored on servers located in Switzerland, which are controlled by a company that is a member of the JTI Group.
Customer support services are provided to us by a JTI Group company based in Greece, either independently or through an external partner.
A partner company based in Lithuania manages the technological solutions used by some of our systems and databases.
The data processed by our partners providing targeted advertising services is primarily stored and processed in the EU and the United Kingdom.
The transfer of data in the above cases is carried out to countries that ensure an adequate level of personal data protection within the meaning of the LPDP (including member states of the European Union and the European Economic Area, as well as countries for which the EU has determined an adequate level of protection).
Some of our partners providing targeted advertising services may transfer data to, or allow access to such data, from, other countries not listed here. In such cases, the transfer is carried out in accordance with the applicable personal data protection regulation, which may involve transfers based on an adequate level of protection or, where such a level of protection is not ensured, subject to appropriate safeguards, including standard contractual clauses.
JTI has its registered seat in the territory of the Republic of Serbia, from where business operations in Montenegro are managed, so your data is necessarily subject to transfer to the Republic of Serbia as well.
Please note that every transfer of personal data involves a certain level of risk of loss, damage, and compromise (unauthorized access) of such data. For this reason, we take physical, technical, and electronic security measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data. You can read more about this in section 13 of this Privacy Policy.
Additionally, using the Website, as well as disclosing or transmitting your data via mail, email, telephone, and other available methods outside the Website, implies your consent to the provisions of the Privacy Policy, including your consent to the transfer of personal data to the Republic of Serbia as stated here within the meaning of the LPDP; therefore, if you do not agree with this, please refrain from providing your personal data to us in any way.
11. How long do We keep the data?
We retain Your data only for as long as is necessary to achieve the purpose for which it was collected, after which it will be safely removed from our systems and deleted. More information can be found in the table below.
CATEGORIES OF DATA | DATA RETENTION PERIOD |
Data related to Product customers’ user accounts | Until the deletion of the user account or withdrawal of consent (where applicable), whichever occurs first; |
Data related to user accounts without any Product purchase information | 24 months from the date of collection, or until the deletion of the user account, or withdrawal of consent (where applicable), whichever occurs first; |
Data collected during the process of creating a user account that was not completed | 72 hours from the time of collection; |
Data related to submitted complaints regarding Product non-conformity | Until the expiration of the limitation period for any potential claims arising therefrom; |
Data collected for marketing purposes | Until withdrawal of consent; |
Data collected in connection with push notifications | Until the Ploom App is deleted from the user’s smart device, or until the selected options in the preference center are changed, or until withdrawal of consent (where applicable), whichever occurs first; |
Data collected for educational purposes | Six months from the date of purchase or registration of the Ploom device; |
Data collected in connection with market research | Ten years from the time of collection, or until withdrawal of consent (where applicable), whichever occurs first; |
Data collected in connection with customer support activities and through the contact form | Three months after the last communication with the data subject; |
Data related to exercising rights to benefits | During membership in the Ploom Club and for two years thereafter; |
Contact data | Three years after the last communication (exercise of rights related to data processing); until the deletion of the user account (notification about amendments to the Privacy Policy), or until the processing purpose is fulfilled. |
Data collected through cookies and similar technologies | During the period necessary to achieve the purpose for which the data was collected, depending on the type of technology and the purpose of processing, or until withdrawal of consent, where applicable. |
Your data may be retained for a longer period than the one stated here in the event of a legal claim that may arise from Your use of our Products, services, or benefits, as well as when required by law or in cases involving cookies and other targeted advertising technologies (for more information about these technologies, please refer to Section 5 of this Privacy Policy).
12. Your rights regarding data processing
It is important for You to know that You have certain rights regarding the processing of Your personal data, which are guaranteed by law and may be exercised under the conditions prescribed therein.
RIGHT | DESCRIPTION |
Right of access | You have the right to request information on whether We process Your personal data, as well as access to such data. Upon Your request, We will provide You with a copy of the personal data We process. |
Right to rectification and amendment | You have the right to have inaccurate data relating to You corrected without undue delay, as well as to have incomplete data completed, which may include providing an additional statement. |
Right to erasure of data | You have the right to request the erasure of Your data, in particular: |
Right to withdraw consent | If the processing is based on Your consent, You have the right to withdraw that consent at any time, provided that the withdrawal does not affect the lawfulness of processing based on consent before its withdrawal. |
Right to restrict processing | You have the right to request the restriction of processing of Your data in the following cases: |
Right to object | If You consider it justified based on Your particular situation, You have the right to object at any time to the processing of Your personal data carried out on the basis of the controller’s legitimate interest, including profiling based on those provisions. |
Right to data portability | You have the right to receive the personal data You have previously provided to us in a structured, commonly used, and machine-readable format, and the right to transmit those data to another controller without hindrance, if the processing is based on consent or on a contract and is carried out by automated means. You also have the right to have the personal data transmitted directly from one controller to another, where technically feasible. |
Right to lodge a complaint | You have the right to lodge a complaint regarding the processing of Your personal data with the competent supervisory authority in Montenegro: |
If You wish to exercise any of the above rights, You may contact us in the following ways:
By mail: | JT INTERNATIONAL AKCIONARSKO DRUŠTVO SENTA |
By email: | |
By phone: | +381 11 20 50 300 |
13. Security of Your data
We take the security of Your data very seriously. Therefore, We implement physical, technical, and electronic safeguards to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data. These measures apply both to persons outside our organization and within it, as access to data is limited only to those individuals whose duties require such access and who have been instructed on the rules of personal data protection.
Unfortunately, no security system is entirely impenetrable, and We cannot guarantee that the security of systems under our direct control will never be compromised. In the event of a personal data breach, We will take all available measures and notify the competent authorities in accordance with applicable regulations, as well as the individuals whose data is affected, where possible.
14. Final provisions
In the event of a dispute concerning this Privacy Policy or the processing of personal data based on it, the applicable laws of Montenegro shall apply, and the dispute shall be resolved before the court of competent jurisdiction in Belgrade, Serbia, unless the applicable law prescribes the exclusive jurisdiction of a local court.
This Privacy Policy is drafted in both Montenegrin and English. In the event of any inconsistency between the two versions, the Montenegrin version shall prevail.
