VAPE BIG LIMITED PRIVACY POLICY

Welcome to Vape Big Limited's Privacy Policy

Vape Big respects your privacy and is dedicated to safeguarding your personal data. This Privacy Policy aims to provide you with information about how we handle and protect your personal data when you visit our website, www.vapebig.co.uk (regardless of your location), and to inform you of your privacy rights and how the law safeguards your data.

This Privacy Policy is presented in a structured format, allowing you to navigate through specific sections as needed. To better understand the terms used herein, please consult the Glossary section provided.

1. Important Information and Who We Are

Purpose of this Privacy Notice

This Privacy Policy outlines how Vape Big collects and processes your personal data when you use our website, including any data you provide during registration, newsletter subscriptions, or product purchases.

Our website is not intended for individuals under the age of 18, and we do not knowingly collect data related to individuals under this age.

Please read this Privacy Policy in conjunction with any other privacy notices or fair processing notices we may provide on specific occasions when collecting or processing your personal data. This Privacy Policy supplements other notices and does not supersede them.

Controller

Vape Big Limited is the data controller responsible for your personal data, collectively referred to as "Vape Big," "we," "us," or "our" in this Privacy Policy.

You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection authority, regarding data protection matters (www.ico.org.uk). However, we encourage you to reach out to us first to address your concerns.

Changes to the Privacy Notice and Your Duty to Inform Us of Changes

This version was last updated on 21st April 2022. It is crucial to keep your personal data accurate and up-to-date. Please inform us promptly of any changes in your personal data during your relationship with us.

Third-Party Links

Our website may contain links to third-party websites, plugins, and applications (e.g., Trustpilot and PayPal). Clicking on these links or enabling connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When leaving our website, we recommend reviewing the privacy notice of every website you visit.

2. The Data We Collect About You

Personal Data Defined

Personal data, or personal information, refers to any information that can identify an individual. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer various types of personal data about you, which we have grouped as follows:

• Identity Data: Includes your first name, last name, username (or similar identifier), title, date of birth, and age verification results.
• Contact Data: Includes your billing address, delivery address, email address, and telephone numbers.
• Transaction Data: Encompasses details about products you've purchased from us, returns, refunds, and other relevant information to manage our customer relationship.
• Technical Data: Includes your internet protocol (IP) address, login information, browser type and version, browser plugin types and versions, operating system, and platform.
• Usage Data: Comprises information about how you use our website.
• Marketing and Communications Data: Involves your preferences for receiving marketing communications from us and your communication preferences.

We may also collect, use, and share Aggregated Data, which is not considered personal data as it does not directly or indirectly identify you. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data in a way that directly or indirectly identifies you, we will treat it as personal data and use it in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (such as racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic data, or biometric data). Additionally, we do not collect information about criminal convictions and offenses.

Consequences of Not Providing Personal Data

If we need to collect personal data by law (e.g., to verify that you are over the age of 18), and you fail to provide this data when requested, we may not be able to perform the contract we have or are trying to enter into with you. For example, we may have to cancel your order, but we will notify you if this is the case at the time.

3. How Is Your Personal Data Collected?

We collect personal data through various methods, including:

• Direct Interactions: You may provide us with Identity and Contact Data by filling in forms or corresponding with us through various channels (e.g., post, phone, email) when you:
  • Place an order for our products
  • Create an account on our website
  • Subscribe to our newsletter
  • Provide feedback
• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns through cookies, server logs, and similar technologies.
• Third Parties or Publicly Available Sources: We may receive personal data about you from third parties or publicly available sources, including:
  • Technical Data from analytics providers like Google (based outside the EU)
  • Contact, Financial, and Transaction Data from technical, payment, and delivery service providers like PayPal (based outside the EU)
  • Identity Data from identity verification providers like Jumio (based outside the EU)
  • Identity and Contact Data from data brokers or aggregators (e.g., Experian Ltd, based inside the EU)
  • Identity and Contact Data from publicly available sources (e.g., Companies House and the Electoral Register, based inside the EU)

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly, we use your personal data for the following purposes:

• To perform a contract we have with you or to take steps at your request before entering into a contract.
• To fulfill our legitimate interests (or those of a third party) when your interests and fundamental rights do not override those interests.
• To comply with a legal or regulatory obligation.

For more details on the lawful bases for processing your personal data, click here.

We do not rely on consent as a legal basis for processing your personal data, except for sending direct marketing communications via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We have outlined in the table below a description of all the ways we plan to use your personal data, along with the legal bases for processing and our legitimate interests, where applicable.

 

Purpose/Activity	Type of Data	Lawful Basis for Processing
To register you as a new customer	(a) Identity	Performance of a contract with you
	(b) Contact
To process and deliver your order including:  Manage payments	(a) Identity	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
	(b) Contact
	(c) Financial
	(d) Transaction
	(e) Marketing and Communications
To manage our relationship with you, including: Notifying you about changes to our terms or privacy policy	(a) Identity	Performance of a contract with you Necessary to comply with a legal obligation
	(b) Contact
	(c) Profile
To enable you to partake in a prize draw, competition, or complete a survey	(a) Identity	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and grow our business)
	(b) Contact
	(c) Profile
	(d) Usage
	(e) Marketing and Communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)	(a) Identity	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise)
	(b) Contact
	(c) Technical
	(d) Transaction	Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, grow our business, and inform our marketing strategy)
	(b) Contact
	(c) Profile
	(d) Usage
	(e) Marketing and Communications
	(f) Technical
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences	(a) Technical	Necessary for our legitimate interests (to define types of customers for our products/services, to keep our website updated and relevant, to develop our business, and inform our marketing strategy)
	(b) Usage
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity	Necessary for our legitimate interests (to develop our products/services and grow our business)
	(b) Contact

Marketing

We aim to provide you with choices regarding certain personal data uses, particularly in marketing and advertising.

• Promotional Offers from Us: We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what products, services, and offers may be relevant to you (marketing). You will receive marketing communications from us if you have requested information from us or purchased goods from us and have not opted out of receiving such marketing.

• Opting Out: You can ask us to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us. Please note that opting out of marketing messages will not affect personal data provided to us as a result of a product purchase or other transactions.

Cookies

You can configure your browser settings to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or function improperly.

The "remember me" feature enables automatic login by creating a cookie containing a unique login ID, eliminating the need to enter login details on subsequent visits to our site. However, this option should not be selected if you share your computer with others, as personal or member-only information may be accessible to other users.

We use "analytical" cookies that allow us to recognize and count the number of visitors and see how they navigate our site, helping us improve its functionality and user experience.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably believe that we need to use it for another purpose and that purpose is compatible with the original one. If we need to process your personal data for an unrelated purpose, we will notify you and explain the legal basis for doing so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the rules specified above, when required or permitted by law.

5. Disclosures of Your Personal Data

We may share your personal data with the following parties for the purposes listed in section 4 above:

• Internal Third Parties: As defined in the Glossary.
• External Third Parties: As defined in the Glossary.
• Third Parties to Whom We May Choose to Sell, Transfer, or Merge Parts of Our Business: In the event of changes to our business structure, the new owners may use your personal data in accordance with this privacy notice.

We require all third parties to respect the security of your personal data and process it in compliance with the law. We do not permit our third-party service providers to use your personal data for their own purposes, and we only allow them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

7. Data Security

We have implemented appropriate security measures to prevent the accidental loss, unauthorized access, use, alteration, or disclosure of your personal data. We limit access to your personal data to employees, agents, contractors, and other third parties who have a legitimate business need to know. They will process your personal data only under our instructions and are subject to a duty of confidentiality.

We have established procedures for addressing suspected personal data breaches and will notify you and the ICO of any breaches when legally required to do so.

8. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including compliance with legal, accounting, or reporting requirements.

The appropriate retention period for personal data is determined by considering the data's volume, nature, and sensitivity, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data, whether we can achieve those purposes through alternative means, and applicable legal requirements.

We are required by law to retain basic customer information (including Contact, Identity, Financial, and Transaction Data) for six years after you cease being a customer for tax purposes.

In some situations, you can request the deletion of your data, as described in the "Request Erasure" section below. We may also anonymize your personal data for research or statistical purposes, rendering it non-identifiable and usable indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws related to your personal data. Please refer to the links below for more information about these rights:

• Request Access to Your Personal Data
• Request Correction of Your Personal Data
• Request Erasure of Your Personal Data
• Object to Processing of Your Personal Data
• Request Restriction of Processing Your Personal Data
• Request Transfer of Your Personal Data
• Right to Withdraw Consent

If you wish to exercise any of these rights, please contact us. We do not typically charge a fee for these requests unless they are unfounded, repetitive, or excessive. In such cases, we may charge a reasonable fee or refuse to fulfill the request.

We may need to request specific information from you to verify your identity and confirm your right to access your personal data (or exercise any other rights). This is a security measure to ensure that personal data is not disclosed to unauthorized individuals. We may also contact you for additional information to expedite our response.

We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have multiple requests, it may take longer to process. In such cases, we will notify you and keep you updated on the progress.

10. Glossary

LAWFUL BASIS

• Legitimate Interest: Refers to the interest of our business in conducting and managing our operations to provide you with the best service, products, and secure experiences. We assess and balance the potential impact on you and your rights (both positive and negative) before processing your personal data for legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are required or permitted by law). You can obtain more information about how we assess our legitimate interests for specific activities by contacting us.

• Performance of Contract: Involves processing your data when necessary for the performance of a contract to which you are a party or for taking steps at your request before entering into such a contract.

• Comply with a Legal or Regulatory Obligation: Involves processing your personal data when necessary for compliance with a legal or regulatory obligation to which we are subject.

THIRD PARTIES

External Third Parties: As described in the Glossary, these include various service providers who support our business operations, such as cloud computing and web design, professional advisers, tax authorities, email newsletter and marketing service providers, identity verification services, and payment providers.

YOUR LEGAL RIGHTS

• Request Access to Your Personal Data: You have the right to request access to a copy of the personal data we hold about you and verify its lawfulness.

• Request Correction of Your Personal Data: You can request that we correct any incomplete or inaccurate data we hold about you.

• Request Erasure of Your Personal Data: You have the right to ask us to delete or remove your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or when you withdraw consent.

• Object to Processing of Your Personal Data: If we rely on legitimate interests (or those of a third party) to process your personal data and you believe it impacts your rights and freedoms, you can object to such processing.

• Request Restriction of Processing Your Personal Data: You can request that we suspend the processing of your personal data in specific situations, such as when you want to verify its accuracy or when you object to processing.

• Request Transfer of Your Personal Data: You have the right to receive your personal data in a structured, commonly used, and machine-readable format or request its transfer to another party.

• Right to Withdraw Consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing prior to withdrawal.

If you have any questions or concerns about this privacy notice or your personal data, please contact our Data Privacy Manager at support@vapebig.co.uk or by mail at 61a Bridge Street, Kington, HR5 3DJ. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection, at www.ico.org.uk.