Correct as of 10/10/2022
At Vape69, we are 100% committed to protecting your privacy and security.
For all Vape69 services, the data controller — the company that’s responsible for protecting your privacy— is Vape69 Limited.
We are Vape69 Limited (“we”, “our”, “us”) and operate under the name of Vape69, V69 and are registered with the ICO under number ZB216413.
We are the data “controller”, which means we are responsible for deciding how and why your personal information is used. We’re also responsible for making sure it is kept safe, secure and handled legally.
We operate to the highest standards when protecting your personal information and respecting your privacy. If you have any questions about your personal information, or how we use it, you can contact us via email at email@example.com or by writing to us at Data Protection, Vape69 Limited, Irwell Point, 2 Rechar Way, Greater Manchester, M27 8BW
You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them. There is more information on the Information Commissioners website www.ico.org.uk
- Right of access – You have the right to request a free copy of the personal information that we hold about you.
- Right to rectification – If you think any of your personal information that we hold is inaccurate, you have the right to request it is updated. We may ask you for evidence to show it is inaccurate.
- Right to erasure (also known as the Right to be Forgotten) and the Right to restriction of processing – You have the right to request that we stop processing, or delete, all of your personal information that we hold. If you exercise this right we will keep a note of your name linked to your request and it won’t prevent us from processing any new information you provide to us subsequently.
- Right to data portability – You have the right to ask us to electronically move, copy or transfer your personal information in a machine readable format.
- Rights with regards to automated decision making, including profiling – We sometimes use your personal information to make decisions by automated means. This involves us analysing your account activity including applications, orders, payments etc. We do this to confirm your identity, prevent and detect crime, and lend responsibly. This automated decision making is necessary if you would like to continue to shop with us online. You have a right to reject automated decisions but it may mean that you can only shop with us in our stores.
- Right to withdraw Consent – Where we are relying on your consent for processing you can withdraw or change your consent at any time.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
If you have any general questions or want to exercise any of your rights please contact firstname.lastname@example.org or call 0161 521 8725. Our security procedures mean that we may need to request proof of identity before we disclose personal information to you in response to any request.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the Information Commissioners Office, the data protection regulator in the UK, their contact details can be found on their website www.ico.org.uk
We will only ever process your information if we have a lawful basis to do so. The lawful bases we rely on are;
- Contract – This is where we process your information to fulfil a contractual arrangement we have made with you.
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime or to meet responsible lending criteria.
To process any orders that you place with us and to facilitate any returns (Contract)
- We take payment details to process payment for any credit or debit card orders you place with us. We share these details with our chosen payment processors (for example Worldpay or Opayo)
- We use your account information plus your chosen delivery address details to; deliver your purchases and keep you informed of their status, and to process any returns including (where appropriate) collecting the item from you.
- Our chosen payment processors store your payment card details at your request to speed up your checkout in the future (consent)
To provide you with access to an account (Contract)
- To register an account with us we capture information such as your name, date of birth, contact and delivery information, and a password to protect your account (account information). We use the same information on an ongoing basis to manage and provide secure access to your account, and provide you with the services you request.
To provide customer service to you (Legitimate interest)
- We keep correspondence (customer service records) when you contact our customer service teams or interact with us on social media. We use these customer service records to manage your queries or complaints effectively, for quality monitoring and to continually improve our services.
To personalise and improve your experience when you shop (Legitimate Interest)
- We keep a record of how you interact with our website and any marketing you are exposed to, we use this data, along with purchase history, demographics, account information and third party information, to show you products and offers from across our brands that we think you will be most interested in and to tailor your experience.
- We use your account information, information on the devices you use to access our sites and your interactions with us to operate personalised features across our websites, apps and communications.
To inform you about products and services that may interest you (Legitimate Interest)
- We use technologies such as cookies within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you and other customers.
- We receive information on how you interact with our adverts and content on third-party websites and social media platforms (such as Google or Facebook) which we use to tailor the information that is displayed to you.
To keep in touch with you (Legitimate Interest)
- When you register for an account and shop with us we start to keep you up to date with news of products and services including store events, offers, promotions and Sale information, unless you tell us you don’t want us to through your account or using the link in every email that we send to you.
- When we send you communications we use records of how you interact with our website and any other marketing we’ve sent to you, along with purchase history, to tailor the messages to include information you are most likely to be interested in.
- We use your account information to notify you about important service messages, such as material changes to this policy, product recalls or information about your account.
To ensure the Website and the services we offer you operate properly (Legitimate Interest)
- We use other cookies and similar technologies to help us understand how you use the site, this allows us to optimise your shopping experience and continually improve our site.
- We gather information about the devices you use to access our sites (desktop and mobile) for example your IP address and device type, to ensure the site is secure and works across multiple platforms.
- We use information for Logistics planning, demand forecasting, management information, dealing with errors on our site, and general research and development.
To develop and improve our products, range and services (Legitimate Interest)
- We use information about how you browse and engage with our website to improve our websites.
- We use all information, including third party data in the development of new products, services and systems to ensure they work as expected and will be useful to our customers.
To prevent and detect crime (Legitimate interest/Legal obligation)
- We use your account information, order history and payment history to assist in monitoring for fraudulent transactions or suspected money laundering.
- When you register an account or contact our call centres we use your account and purchase history information to confirm your identity.
- We use device identifiers and IP addresses in fraud prevention and investigation, and to maintain network and data security.
To fulfil our legal obligations (Legal obligation)
- We use your data to ensure we comply with any requirements imposed on us by law or court order, including disclosure to law or tax enforcement agencies and authorities or pursuant to legal proceedings.
- We will share data with regulatory and other official bodies if they make formal requests.
- We will maintain records to meet regulatory and tax requirements.
- We will use your account information to contact you in connection with product recalls or other similar product quality issues and to comply with our legal obligations in connection with the sale of age restricted products.
We keep your personal information as long as you are a customer of ours and generally for seven years afterwards to comply with legal requirements. During that time we take steps to remove any personal data as soon as we no longer need it.
We consider you a customer as long as you hold an open account,
for 2 years from the point you last made a purchase from our website or during any time we are managing a customer service request from you.
We work with a number of trusted third parties to provide you high quality services. Anybody we work with is subject to stringent security and data privacy assessments before we begin to do business with them and on an ongoing basis.
We have contracts in place with all suppliers that help us to ensure security and privacy of your personal information, these are reviewed and updated regularly and always in line with data protection laws.
- Delivery Partners – Helping us to deliver the goods you order to you including our brand partners that dispatch and deliver goods to you directly.
- IT Companies – Supporting us in maintaining our website and other business systems including; providing phone lines, data storage facilities, and providing and supporting Cloud based infrastructure used in providing our products and services.
- Marketing Companies and Online Advertising – Helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in, Companies that provide marketing and advertising assistance (including management of email marketing operations, mobile messaging services such as SMS, and services that deploy advertising on the internet or social media platforms, such as Facebook and Google) as well as analysis of the effectiveness of our advertising and communications campaigns.
- We use technologies such as cookies, pixels, and device ID’s within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you.
- Payment processors – Payment card processors to process credit and debit card payments and store payment information; for example Worldpay and Opayo.
- Age Verification Companies – We share your personal information with Age Verification Companies when you first purchase from us. This is a onetime check to verify your age.
- Analytics companies – We may share personal details with specialist companies to analyse customer information to help us better understand how you use our services and to tailor products, services and offers that may be relevant for you.
We utilise companies that help us track and record the way you navigate our website, so that we can understand your online experience and use it to improve our services and offer a more personalised experience.
- Regulators and the Police – We will share data with regulators and other official bodies (including law enforcement) if they make formal requests or pursuant to legal proceedings.
If you use any third-party apps, websites or services to access our services, your usage is subject to the relevant third party’s terms and conditions, cookies policy, and privacy notice. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy notices of the relevant social media platform (Facebook, Twitter etc.). We may be required to share customer information relating to transactions and use of such third party services with that third party.