The information this Privacy Notice covers
This Privacy Notice covers personal information. Personal information is any information that tells us something about you
How we collect Personal Information
We collect your personal information to provide you with our VAYP Services, so that we can stay in touch with you, to improve and personalise our VAYP Services for you, to handle any questions or complaints you may have, and to comply with our regulatory obligations. This involves:
What Personal Information we collect
Identity Data is information that specifically identifies you. It includes your first name, last name, username or similar identifier, title, address, date of birth and gender. We use this information to register and create your account, and to ensure we are dealing with the correct adult vaper. In some cases, we may need your national ID detailsContact Data includes billing address, delivery address, email address and telephone numbers. We use these details to deliver our VAYP Services to you.
Financial Data includes your bank account and payment card details. Using our website, you submit these details to our payments service provider, TAP when you buy VAYP products online.
Transaction Data is generated as a record of your purchases through our website and includes details about payments to and from you and other details of products you have purchased from us.
Account Profile Data is the personal information contained in your account. It includes your username and password details as well as your Identity Data, Contact Data and Communications Data. It is also a record of your engagement with us through your feedback and survey responses.
Communications Data includes your preferences in receiving product information from us and your communication preferences to ensure we engage with you as you wish.
Technical Data is the information behind the technology and the devices you use to connect with the VAYP device, our website and the VAYP app. It tells us how our products and services are performing and we use this data to make our VAYP Services operate better. [Read more]
Usage Data is the information generated, including using cookies, as you use our VAYP Services. We use third-party analytics providers to analyse how you are using those VAYP Services. This data, especially when we use it as Aggregated Data, tells us how the VAYP experience could be improved and what we can do to enhance the services we offer.
[We use a third-party service, Google Analytics, to collect standard internet log information and details of your behaviour patterns as you navigate around our website or the VAYP app. It does this using information from cookies. This helps us to find out the number of users to the various parts of our website or the VAYP app and how they interact with the content on the site. We also use this information to maintain and monitor the performance of our website and the VAYP app, and to look for ways of improving our website and the VAYP app and the services it offers you. This information does not identify any individuals. You can see our Cookies Policy here.
Third-Party Data is the information we receive from analytics providers as mentioned above under Usage Data and, for instance, when we analyse your feedback on review sites. We also receive information about you from social media providers when you register for a VAYP account via your social media accounts like Facebook or Twitter
Aggregated Datais derived from your personal information but is not considered “personal data” in law as it is anonymous and the data does not directly or indirectly reveal your identity. This data is used for statistical research and to inform business strategy
We collect website and app Usage Data and Technical Data automatically from your mobile or other device using cookies, web beacons and similar technologies.
Age-verification and identification
You must be at least 18 years of age to use our VAYP devices, our website and the VAYP app. This is to ensure that we meet our legal obligations. Before you enter our website you will be asked to verify your age. When you register an account via the website or the VAYP app, or when you purchase a VAYP product or service, you will need to provide Identity Data so that, with your consent where necessary, we can authenticate your age.
Not participating in the age-verification or identification process will obstruct your interactions with us. If you have any questions about the age-verification or identification process, please contact our Customer Service here or via firstname.lastname@example.org and an advisor will be happy to help you.
The VAYP device, our website and the VAYP app are not intended for children and we do not knowingly collect data relating to children.
How we use your Personal Information
Your personal information is used for the following purposes:
Account creation. If you sign up for an account with us, either on our website or via the VAYP app, we use your personal information to register your account and carry out age-verification. We also use your information to pair your VAYP device to the VAYP app.
Delivering your VAYP products and services. We use your personal information to deliver our products and services to you. This includes contacting you about your orders, managing payments, fees and charges, collecting and recovering money owed to us, delivering products and services to you, and providing you with information about the products you have purchased, including any product safety information.
Account management. We use your Personal Information to administer your account and to manage our relationship with you, which will include notifying you about any changes to our terms or Privacy Notice, enabling you to use promotional codes or discounts.
Providing customer service. If you contact us, we will save your contact details to respond to your query. The information you provide in email is saved in our system to ensure you receive the correct support from our Customer Service team and to inform our understanding of your VAYP experience.
Providing product reviews and feedback. If you leave a review about a VAYP product on our website or the VAYP app, we collect personal information about your experience as a vaper. You can choose what information you provide. The information is collected to give readers of the review a better understanding of our products and services. We analyse this feedback and feedback on other review sites to learn how we can make improvements to our products and services.
Events. We use your personal information when we invite you to events hosted by us or on our behalf. If you participate in an event, we collect information about you to better understand your preferences. Offline data collection may be part of a promotional initiative, such as a prize draw or competition.
Conducting surveys. Occasionally we invite you to fill out a questionnaire. You are free to choose if you would like to fill out the questionnaire. The information you provide will be used to better understand your preferences and to serve you better.
Product Information. If you are an existing customer or if you have made a sales enquiry, we may contact you by email / SMS / telephone /post with product information about our products which are similar to the products previously provided to you, unless you have told us you do not want to hear from us. Otherwise we will only contact you if you have agreed we can.
Where appropriate and with your consent (by setting your preferences in the preferences centre during or at any time after the registration process), we may pass your information to our affiliate Imperial companies where you are located so that you receive further personalised information and services that might interest you. You may ask us at any time not to use your information by contacting us using the contact details below. [Read more]
Research and analysis. We use all the data we collect (largely as Aggregated Data), including your feedback, your responses to surveys, your online behaviour and your use of your VAYP device and the VAYP app, to conduct research and analysis to improve and develop our business.
Administering and protecting our business. We use all the data we collect to administer and protect our business, our VAYP devices, our website and the VAYP app, and our information and systems. This includes carrying out activities like trouble-shooting, data analysis, testing, system maintenance, system security, support, reporting and hosting data.
When you purchase VAYP products in a market place. If you buy a VAYP product in a market place, we will receive information about your purchase and personal data held by the market place.
The lawful basis that allows us to use your Personal Information
We need to tell you the lawful basis that permits us to use your Personal Information.[Read more]
Our use of your personal information is allowed:
• with your permission (for example, where the information is sensitive like health information);
• where we need your personal information to enter into a contract with you (for example, when your make a purchase via our website);
• where we perform tasks in the public interest or to comply with a legal obligation (for example, where we need verify your age or your identity); and/or
• where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests (for example, when we use your information to help us improve and develop our Services).
If you do not provide the Personal Information
We need some of your Personal Information by law, to respond to your enquiries, to enter into a contract with you (for example, to make sure we can deliver the products/services you asked for to you). Without this information, we may not be able to continue with the process that you want us to. We’ll explain when this applies where we collect your Personal Information if it is not clear why we need it.
Who we share your personal information with
We will treat all your personal information as confidential and in accordance with data protection laws. We may, however, need to share your personal information with our affiliates that are part of the Imperial Brands group and with third parties who provide us with services.
Your personal information will only be transferred to countries in the European Economic Area (the “EEA”) or where the recipient has confirmed an adequate level of protection for it, for instance, by contractual agreement. You can ask us about the arrangements we have in place.
How we look after your Personal Information
Information sent via the internet is not always secure. We cannot guarantee the security of the information while it is being transmitted to our website or the VAYP app as you register your account; any transmission is at your own risk. However, once we’ve received it, we take appropriate security measures to keep it safe.
How long we hold personal information for
We keep your personal information for as long as is necessary to fulfil the purposes for which it was collected. After that we will delete or de-identify your personal information unless we hold it to comply with our legal obligations, resolve disputes and enforce our agreements.
Links to third-party websites
Our website may include links to third-party websites, plug-ins and applications (such as Facebook and Twitter). Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party links and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Your information rights
If you wish to exercise the rights set out in this section, please make your request in writing using the contact details in the How to contact us section below. We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information we need.
In summary, you have the right, within certain legal parameters, to ask us:
• for details about how we use your Personal Information;
• to see what Personal Information we hold about you;
• to correct your Personal Information;
• to erase your Personal Information in certain circumstances;
• not to use your personal information in a particular way;
• to port your Personal Information in a commonly used electronic format;
• to restrict how we use your Personal Information;
• not to send you product information materials; and
• not be subject to automated decisions about you and to request human intervention.
Sometimes you will be able to exercise your rights through your account settings. We have noted where this is possible in the further information provided below
If you have given us permission to use your personal information in any particular way, you have the right to withdraw that permission at any time. You can do this in the preference centre in your account or by contacting us.
Changes to this Privacy Notice
We will keep this notice up to date and you can find the date it was last updated at the bottom of the page. If there are any changes to the way in which your personal information is used, we will update this privacy notice and, where appropriate, notify you of the changes by email. We recommend that you check this page from time to time to ensure that you are aware of any changes.
Who we are and how to contact us
The data controller of all personal information collected from your use of the VAYP Services Empire Heights Podium, Office P3-A08-05. P.Box 57254, Business Bay, 57RM-QQ, Dubai, UAE.
Lodging a complaint
If we cannot resolve your complaint or you are unhappy with how we have processed your personal information, you have a right to complain to the Dutch Autoriteit Persoonsgegevens or the UK’s Information Commissioner's Office. You can find out how to do this by visiting https://autoriteitpersoonsgegevens.nl/en or www.ico.org.uk respectively.
This Privacy Notice is effective from 19 December 2019. Previous versions of the Privacy Notice can be found here