PRIVACY POLICY

(Last updated: February 2024 (original version: French Version)

1. PURPOSE

Lecigare.ch (represented by Akama International SA) is committed, in accordance with data protection law, to ensuring that all information concerning our clients remains strictly confidential.

You must be at least 18 years old.

This policy applies to all personal data processing carried out by Akama International SA and aims to inform the user about how Akama International SA processes personal data (including details on the type of personal data collected and the purpose of processing) and about the user's rights in relation to their personal data.

2. CONTACT

If you have any questions regarding the privacy policy, you can contact Akama International SA by the following means:

The headquarters are located at: Allée de la Petite Prairie 2, 1260 Nyon

The contact telephone number is: +41 22 361 46 74

Users can establish direct and effective communication with Akama International SA in writing by sending a communication to the address mentioned or by sending an email to: [email protected].

Furthermore, the information of the person responsible for processing your personal data is below:

Name: Akama International SA

Address: Allée de la Petite Prairie 2, 1260 Nyon

Email: [email protected]

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this website, you can contact us at the following address: [email protected].

3. COLLECTION OF YOUR PERSONAL DATA

How do we collect personal data?

In accordance with current regulations on the protection of personal data, particularly: 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 (hereinafter, "GDPR"). The new Federal Data Protection Act (nDPA).

Akama International SA collects the personal data in its possession when the user:

(i). Completes the forms on https://lecigare.ch/ ("Site"), https://diezigarre.ch/ ("Site"), https://thecigar.com/ ("Site"),

(ii). Subscribes to the newsletter;

(iii). Responds to a survey or completes an online form;

(iv). Completes a printed form;

(v). Sends an email or communicates by phone, which are then uploaded into the corresponding forms; As a visitor to our site, you can browse our site without providing any personal data.

However, when you register to receive information/newsletters, and order products as a customer, we may collect the following personal data:

• Contact information such as your name, phone numbers, postal address, and email address • Demographic information (age/gender).

• Details of your purchases

4. HOW YOUR PERSONAL DATA IS USED

A. What personal data do we collect?

Akama International SA collects information when visiting their webpage, mainly by completing its registration forms.

The following data is collected: full name, email, phone number, gender, date of birth, nationality, and address. Generally, when personal data is required to use a service or access certain content, providing it will not be mandatory, except in cases where it is specifically indicated that it is a required data for the provision of the service. In this case, the user can freely choose not to register and/or not to contract the services.

The user declares and guarantees that all data provided by him are truthful and accurate and commits to updating them. Similarly, the user acknowledges that the data required by Akama International SA are necessary, adequate, and not excessive for the purposes expressed in paragraph 3 above, which would be impossible to achieve if these data are not provided. Any false or inaccurate statement resulting from the information and data provided, as well as the damages that such information could cause, will be the responsibility of the user.

B. What is the purpose of collecting personal data?

The personal data requested from the user will be used for the following purposes: We use your information to provide and maintain our sales services, to process and respond to your requests, to communicate with you about your use of our Service or changes to our Service, to respond to your inquiries, and for other customer service and business administration purposes. For example, when you sign up for a newsletter, we may use your personal information to send you an electronic bulletin.

We may use your information for identification and authentication purposes. For instance, when you enter your login ID and password to access one of our registration or login portals, we use your login information to authenticate your identity. We use your information to tailor the content and information that we may send or display to you, to offer location customization, personalized help and instructions, and to otherwise personalize your experience while using the Service. For example, if you allow us to collect geolocation data, we use this information to deliver content specific to your location and identify business listings/locations around your area.

We may use your information to send you news and newsletters, event updates, and to communicate with you about new features, offers, events, or products, or to contact you about information we think may interest you. We may use your information to administer surveys and questionnaires (online and offline) for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products, services, and educational information we provide. Survey responses may be used to determine the effectiveness of our service, various types of communications, advertising campaigns, and/or promotional activities.

We (and our third-party business partners on our behalf) may merge, blend, or otherwise combine information, including your personal information, in pursuit of the objectives described above. We may use your information to comply with our legal obligations or to assert or defend our rights or the rights of a third party, including to comply with law enforcement or government authority requests and to participate in compliance audits. We may use your information when we deem it necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to any person's safety, or to enforce this policy, our terms and conditions, and the integrity of the Service.

We may also de-identify or anonymize your data in such a way that you cannot reasonably be re-identified by us or any other party, and we may use these anonymized data for any purpose permitted by applicable law. To the extent that we anonymize data originally based on personal information, we will retain and use such data in an anonymized form and will not attempt to re-identify the data.

The data submitted for processing will not be used for purposes other than those mentioned above and which motivated their collection. Notwithstanding the foregoing, it is specified that the recorded data may be used, in addition to the purposes for which they were expressly collected, for statistical purposes, incident management, or market research.

However, in case of processing personal data for purposes other than those initially specified at the time of collection, a compatibility analysis will be carried out by Akama International SA in accordance with applicable regulations. The processing will only be authorized if the initial purpose is compatible with the new purpose or authorized in compliance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or the legal justification for processing their data. We remind users that they can object to the sending of commercial communications (unsubscribe) and no longer receive emails from Akama International SA by reliably informing Akama International SA, which will proceed to cease such communications as soon as possible after receiving such a notice.

To this end, they may send an email or letter to the address indicated in section 2, or directly follow the unsubscribe instructions detailed at the end of each email from Akama International SA.

C. How do we use your information?

We will use the information we collect about you for the following purposes:

• User account creation

• Customer support & order processing

• Testimonials

• Collection of customer feedback

• Application of Terms and Conditions

• Support

• Administrative information

• Site protection

• Dispute resolution

• User account management

• Payment processing

• Management of promotions and sweepstakes

• Meeting our product or service research and development needs and improving our Site, our services, and our offerings.

If we wish to use your information for other purposes, we will ask for your consent and will only use your information when you have given your consent and only for the purpose(s) for which you have given consent, unless we are required to do otherwise by law. We will keep your personal information with us for an indefinite number of months after user accounts are no longer active or for the duration necessary to fulfill the purposes for which they were collected, as stated in this privacy policy.

D. Consent

By providing personal data to Akama International SA, the user declares their full and unreserved acceptance of its processing by Akama International SA. The user hereby gives their free, explicit, and informed consent to Akama International SA to use the collected data for the purposes indicated in section 5 above, as well as their incorporation into an Akama International SA database. Akama International SA processes the user's data legitimately by: (i) the conclusion of a service contract with Akama International SA by the user, in accordance with the terms and conditions made available to the user at the end of completing the service request form (before any potential hiring) and that the user (after becoming aware of them), and if they agree, can accept by ticking the box that has been included for this purpose; and (ii) the free, informed, and unambiguous consent of the user, given after reviewing this privacy policy where Akama International SA informs about the processing it will perform with your data, and if you agree, by ticking the box that has been included for this purpose in the service request form.

The processing of data not covered by one of the legal bases indicated above will be carried out by Akama International SA as it deems necessary to protect a legitimate interest and only if they do not infringe on the user's fundamental rights and freedoms.

E. Retention - How long do we keep them?

Data will be destroyed or archived when they are no longer strictly necessary or relevant for the purposes detailed in section C above. Specifically, personal data will be retained as long as the business relationship is active (and as long as the user has not previously requested their deletion) and during the period in which obligations, compensations, and/or liabilities may arise in the context of the business relationship or for the services provided. Akama International SA informs that it will retain the essential information to identify the origin of the stored data for the duration of the customer relationship with Akama International SA and/or the revocation of the user's consent in accordance with the information in section 5 of this privacy policy and/or the duration required by applicable law.

F. Confidentiality / Transfer / International Transfer - Do We Disclose Data to Third Parties?

Akama International SA will keep the personal data it collects private and confidential and will not use them for any purposes other than those established in section 4.C above. Akama International SA requires confidentiality and personal data processing agreements to be signed by its employees and third parties who provide services accessing the database content (or includes such obligations in the service agreements it signs with such providers, as indicated in the following paragraph).

The personal data of the user collected by Akama International SA will not be transferred, sold, exchanged, transmitted, and/or communicated to third parties outside of Akama International SA without the user's consent, except as required by law and/or to provide services to the user. This does not include certain employees and service providers who enable Akama International SA to keep the site operational, to comply with the purposes established in section 4.C above, and/or to provide services to the user, who have assumed the obligation to keep the provided data confidential and commit to comply with the applicable regulations on personal data protection at the time of hiring.

Contracts with service providers specify the purpose, scope, content, duration, nature, and aim of data processing, the type of personal data, categories of data subjects, and the obligations and responsibilities of Akama International SA and contractual third parties. Specifically, Akama International SA may share the personal information provided with controlling companies, subsidiaries, affiliates, related companies, and/or intermediaries linked to Akama International SA. Akama International SA may share certain personal information provided by the user internally within Akama International SA, with certain departments, such as administration, marketing, or IT.

Social Networks. Akama International SA also uses social networks, such as Facebook or Instagram, and has integrated functions from these networks into its services. The user can only use these social networks to the extent that they are registered and have accessed the corresponding social network with their account. These social networks have their own privacy policies and terms and conditions, over which Akama International SA has no interference or control. Finally, you should be aware that Akama International SA may (and reserves the right to) disclose your information in the following cases:

Business Transfer: If we or our subsidiaries are acquired, merged, or invested in by another company, or if any of our assets are transferred or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain information about you to lenders, auditors, and external advisors, including lawyers and consultants.

Compliance with Law: We may disclose your personal information to comply with the law, a judicial proceeding, a court order, or any other legal process, for example, in response to a court order or a subpoena.

Protection and Enforcement of Rights: We may disclose your personal information when we believe it is appropriate to investigate, prevent, or take action against illegal activities, suspected fraud, situations that may pose potential threats to the safety of any person, or violations of human rights. This disclosure may also include using your personal information as evidence in a litigation in which we are involved.

Additionally, we may disclose your personal information when necessary to assist you in exercising your rights under the terms and conditions of Akama International SA and this privacy policy.

Public Safety, National Defense, or Public Health Reasons: In situations where there are well-founded reasons related to community safety, national defense, or public health, your personal information could be disclosed.

Aggregated, Anonymized, or De-identified Information: We may disclose aggregated, anonymized, or de-identified information about you for any purpose permitted by applicable law.

Consent: We may disclose your personal information with your consent.

G. Security - How do we ensure data security?

Akama International SA declares its intention to adopt the necessary technical and organizational measures to ensure the security, integrity, and confidentiality of data in accordance with the provisions of the GDPR and the Swiss Federal Data Protection Act (nLPD), in order to prevent their alteration, loss, unauthorized access, or processing.

Akama International SA does not guarantee absolute privacy in the use of the site, as it cannot be ruled out that unauthorized third parties may become aware of it. The user acknowledges that existing technical security means are not impregnable and that, even by adopting all reasonable security precautions, it is possible to suffer manipulation, destruction, and/or loss of information. In the event of detecting a security incident involving a significant risk to the data owner, this event will be communicated without delay to the competent control authority, as well as the corrective and palliative measures implemented and/or to be implemented. Akama International SA is not responsible for the loss or deletion of data by users. Likewise, Akama International SA accepts no responsibility for any potential damage caused by computer viruses.

Finally, the user must also take steps to protect their information. Akama International SA insists that you take all precautions to protect your personal information when you are on the Internet. At a minimum, you are advised to change your password periodically, using a combination of letters and numbers, and to ensure that you use a secure browser.

We strive to protect the personal data sent to us, both during transmission and once we have received it. However, no method of transmission over the Internet and no method of electronic storage is 100% secure. While we consider the sensitive nature of the personal data we store, and the current state of technology to implement these measures to protect your personal data, we cannot guarantee their security 100%.

H. Data Owner's Rights and Procedures for Exercising Them - What rights do I have as a data owner?

i) The data owner user may at any time exercise the rights of access, rectification, cancellation, opposition, restriction of processing, portability, privacy, and erasure of their personal data, in accordance with the provisions of Articles 15 and following of the GDPR, and the provisions of the nLPD, as applicable. The user may exercise these rights themselves by emailing [email protected], or by any other means provided by the above-mentioned applicable regulations. Akama International SA may request the necessary data to validate the identification of the data owner.

ii) The erasure of certain data will not be carried out when it could harm the rights or legitimate interests of third parties, or when there is a legal obligation to retain the data.

iii) If you reside in the UK or the EEA and are subject to national or local legal exemptions, you have certain data protection rights under certain circumstances. Please contact us if you wish to exercise any of these rights.

iv) Withdraw their consent at any time. Users have the right to withdraw their consent if they have previously given their consent to the processing of their personal data.

v) Object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.

vi) Access their data. Users have the right to know if the data is being processed by the owner, to obtain information on certain aspects of the processing, and to obtain a copy of the data being processed.

vii) Verify and request rectification. Users have the right to verify the accuracy of their data and request that it be updated or corrected.

viii) Restrict the processing of their data. Users have the right to restrict the processing of their data. In this case, the Owner will not process their Data for any purpose other than storage.

ix) Have their personal data erased or otherwise removed. Users have the right to have their data erased by the owner.

x) Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transferred to another controller without hindrance.

xi) Lodge a complaint. Users have the right to lodge a complaint with their competent data protection authority.

I. Links to Third Parties - Does Our Site Contain Links to Other Sites?

The site may contain links to third-party sites, whose privacy policies are foreign to Akama International SA. The linked sites are not affiliated with Akama International SA, and their existence does not imply any suggestion, invitation, or recommendation to visit the destination sites or any link or association between Akama International SA and these sites.

Akama International SA is not responsible for the content, use, and activities of these linked sites, nor for any damages, whether actual or potential, material or moral, direct or indirect, suffered by users and arising from the information contained in these sites or from the relationship that users may establish with third parties whose services have been published on the site. Nonetheless, any feedback on these linked sites will be useful for Akama International SA to improve services and/or ensure the site's integrity.

Akama International SA commits to doing everything possible to prevent the presence of links to sites with illegal content on its site.

J. CHANGES TO THE PRIVACY POLICY

This is the current version of Akama International SA's privacy policy, updated on February 28, 2024 (original version: French version). Akama International SA may, at any time and without notice, modify this privacy policy.

These changes will become operational from their publication on the site or when they are communicated to users by any means, whichever occurs first. The user must stay informed of the terms included here by periodically entering.

K. COOKIES - Do we use cookies?

When the user enters the site, Akama International SA may store information on their computer in the form of a "cookie" or similar file. The site uses cookies to (i) track advertising, (ii) collect data on site traffic, and (iii) enhance the user experience while using the site. The user should be aware that browsing the site does not require the user to authorize the installation of cookies sent by the site. This may only be required for certain services.

The user can clear cookies from their hard drive, prevent access to their computer either through their browser or by selecting the corresponding option when asked if they wish to use cookies for these purposes and in accordance with Akama International SA's cookie policy. Cookies are information files that the site or provider of certain site services transfers to the user's computer's hard drive via the browser program. Cookies themselves cannot personally identify the user (although they may contain the user's IP address) but they allow the user's browser to be recognized and capture and store certain data (user's operating system, domain name of the website from which the site was linked, among others).

Akama International SA reserves the right to contract third-party services to analyze and understand site users, who cannot use the collected information for purposes other than improving Akama International SA's services.

L. CONSENT

The user's use of the site implies full knowledge and approval of Akama International SA's privacy policy and terms and conditions, if any. Similarly, the user agrees to Akama International SA's privacy policy and terms and conditions by completing the service request.