We are committed to protecting your privacy both online and offline, and endeavour to be transparent as to how we collect and use personal data that we collect in the course of our business.
· your use of the Website (notwithstanding the terms contained on any other website)
· Any usage of your data by us as necessary to provide you with the services you request.
If you do not want us to collect, use and transfer your personal information in this way then you should (depending on what it is you object to) Contact Us and ask for your information to be deleted.
2. WHAT WE MEAN BY PERSONAL INFORMATION
3. PERSONAL INFORMATION THAT WE COLLECT
We may collect and process the following data about you:
· information you provide via the "My Account" page when registering to use the Website including your name, email address, job title and any updated information you provide from time to time;
· any comments you may have about your application to register to use the Website;
· Information you provide when you submit or post content to the Website or when you contact us (including when you report a problem with the Website to us).
· additional information we may request from you from time to time either by contacting you directly or through the Website, although there will be no obligation on you to provide this additional information.
· Details of your visits to the Website including, but not limited to, traffic data, location data, web-logs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
We may collect information from your computer and browser including your IP address and cookies information. This is statistical data about our users' browsing actions and patterns and does not identify any individual. Please see Section 9 below for more information.
We will let you know on the registration page if the provision of certain information is optional.
If you provide us with information about another person you confirm that they have appointed you to act for them, consent to the processing of their personal data including sensitive personal data and that you have informed them of our identity and the purposes (as set out below) for which their personal data will be processed.
4. How we use your personal information
We use personal information held about you in order to allow us to provide you with our products, as well as to improve our service. For example, we may use your data in the following main ways:
· to fulfill our contract to you when you purchase goods from us;
· for our legitimate interest of administering and supporting the Website and your use of the Website;
· to comply with our legal obligations, such as ensuring that users purchasing nicotine containing products are 18 years of age or older;
· to provide you with access to the appropriate areas and functions of the Website (including to particular content);
· for our legitimate interest, to contact you by email from time to time in order to ask for your views on the Website and/or any of the content on the Website and our products;
· for our legitimate interest in assessing and analysing our service offering and website in order to enable us to review, develop and improve the services we offer; and/or
· for any other purposes to which you have given your prior consent.
We may also use information provided by you (such as what you think about the Website and improvements that you would like to see made) or statistical information collected, so that we can improve the Website or make your visits to the Website more rewarding.
We do not use your data for any automated decision making or profiling usage, nor do we do not sell, trade or rent your information to other parties under any circumstances. We may provide statistics about our customer sales, traffic patterns and related site information to third parties, but we will not supply any personal information that would enable you to be identified.
In order to provide you with goods, we may need to share your information with our Age Verification partner (currently GBG) or equivalent. Where we do pass your information to an Age Verification partner, we ensure that they have appropriate measures in place to protect your information. Other than this, we do not disclose any of your information to other third parties
We reserve the right to give your personal information to a third party without your consent where we believe that such disclosure is (i) required by law or (ii) necessary to assist in the prevention or detection of any criminal action (including fraud) or (iii) is in the overriding public interest and is permitted by law.
By registering as a user of the Website, you acknowledge and agree that some of the information you provide may be accessed from countries outside the UK. Please note that where necessary, we will only transfer data outside of the European Economic Area where there is an adequate data protection agreement in place preserving your statutory data protection rights.
5. HOW WE PROTECT YOUR PERSONAL INFORMATION
We are strongly committed to data security and we take reasonable and appropriate steps to protect your personal information from unauthorised access, loss, misuse, alteration or corruption. We have put in place physical, electronic, and managerial procedures to seek to safeguard the information you provide to us.
Owing to the nature of the internet we cannot guarantee the security of any information you transmit to us. We recommend that you take every precaution to protect your personal information while you are using the Website and the internet.
6. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We will keep and use the personal information for as long as you are registered as a user of the Website, and for at least 2 years afterwards, in order to deal with any consequent queries or concerns you may have. We may retain the personal information for longer than this if there is a legal reason or requirement to keep the information for longer, for example if it is relevant to any current legal proceedings.
Any references to you in any current records and any statistical or anonymised information (from which you cannot be identified) may be kept for longer periods.
7. UPDATING YOUR PERSONAL INFORMATION
If you are a registered user, you can access all the information we hold about you and you can amend or update any inaccuracies in your personal information by logging on to your personal profile. If you have any other queries regarding the information we hold about you then you should contact us at the contact addresses set out in Section 11.
Whilst we endeavour to ensure that the information contained on the Website is current, we are unable to represent or warrant that the information accessible is accurate, complete or current. We have no liability whatsoever in respect of any use which you make of such information.
The information provided on this website has not been written to meet your individual requirements and it is your sole responsibility to satisfy yourself prior to ordering any products or services from us that they are suitable for your purposes.
Whilst we make all reasonable attempts to exclude viruses from the website, we cannot ensure such exclusion and no liability is accepted for viruses. Thus, you are recommended to take all appropriate safeguards before downloading information or images from this website.
All warranties, express or implied, statutory or otherwise are hereby excluded.
Neither we nor any of our employees or affiliated entities will be liable for any kind of damages and howsoever arising including, without limitation, loss of profits, compensatory, consequential, direct, exemplary, incidental, indirect, punitive or special, damages or any liability which you may have to a third party, even if we have been advised of the possibility of such loss.
We are not responsible for the direct or indirect consequences of you linking to any other website from this website.
These terms and this disclaimer and any claim based on use of information from this website shall be governed by the laws of England and Wales and you agree to submit to the non-exclusive jurisdiction of the Courts of England.
9. IP ADDRESSES AND COOKIES
As set out in Section 3 above, we may collect information about your computer, including where available your IP address (which is a unique identifier of the user's computer or other access device), operating system and browser type, for system administration and to report aggregate information. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies are small files stored in your computer's hard drive by your web browser. When you access the Website, if you have enabled cookies, our computer server will access these cookies so that it can recognise your computer. These cookies help us to improve the Website and deliver a better and more personalised service. They enable us:
· to estimate our audience size and usage pattern;
· to store information about your preferences, and so allow us to customise the Website according to your individual interests;
· to speed up your searches; and
· to recognise you when you return to the Website.
When you first access the sites, we will give you the option to choose not to receive cookies, or to allow you to be prompted every time a cookie is sent to you. Most web browsers automatically accept cookies, and you can change your cookie settings at any time. Please note that in a few cases some features of the Website may not function if you remove cookies from your browser, and you may not experience the Website as intended.
Under data protection law, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require us to change incorrect or incomplete data;
- withdraw consent where consent is the basis for us processing your data;
- require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
- object to the processing of your data where we are relying on our legitimate interests as the legal basis for processing.
If you would like to exercise any of these rights, please contact us as detailed in section 11.
If you believe that we have not complied with your data protection rights, you have a right to complain to the Information Commissioner.
11. CONTACT US
If you have any queries about how we use your information you can contact us by emailing firstname.lastname@example.org or by writing to us at 7 Bankside, 128 Middleton Road, Bognor Regis, West Sussex, PO22 6DB