Privacy Policy

We understand that your privacy and security of your personal information is extremely important. Because of that, this policy sets out what we do with your information and what we do to keep it secured. It also explains where and how we collect your personal information, as well as your rights over any personal information we hold about you.

This policy applies to you if you use our products or services in store, over the phone, online or interacting with us on social media (our “Services”). This policy gives effect to our commitment to protect your personal information and has been adopted by CUE VAPOR Ltd.

When you visit the CUE VAPOR ‘s web site ("http://www.cue-vapor.com"). we want you to be assured that we make every effort to respect your personal privacy.

Privacy Policy Sections
• Who are we?
• Your duty to inform us of any changes
• What sorts of information do we hold
• How do we use your information
• Age verification
• Who we might share your information with
• Keeping you informed about our products and services
• Access and correction of your personal information
• Right to stop or limit our processing of your data
• How long will we keep your information for?
• Links to other websites
• Sharing your thoughts
• Cookie Policy
• Security
• Contact us
• Policy change

Who are we?
CUE Vapor and cue-vapor.com are trading names of CUE VAPOR Ltd our registered name.
Registered address: Unit 28, Ellough Industrial Estates, Benacre Road, Ellough, Beccles, NR34 7TD
Company number: 133 983 92

CUE VAPOR Ltd is the controller and responsible for your personal data (collectively referred to as “CUE Vapor”, “cue-vapor.com”, “we” and “our” in this privacy notice).

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your duty to inform us of changes
It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What sorts of information do we hold?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data:

• Information that you provide to us such as your name, address, date of birth, telephone number, email address, postal, billing addresses and any feedback you give to us, including by phone, email, post, or when you communicate with us via social media;
• Information about the Services that we provide to you (including for example, the things we have provided to you, purchases, when and where, what you paid, the way you use our products and Services, and so on);
• Your account login details, including your user name and chosen password;
• Information about any device you have used to access our Services (such as your device's make and model, browser or IP address) and also how you use our Services. For example, we try to identify when and how you use our websites and stores.
• Your contact details and details of the emails and other electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication. We want to make sure that our communications are useful for you, so if you don't open them or don't click on any links in them, we know we need to improve our Services.

Links to other websites
We sometimes provide you with links to other websites, but these websites are not under our control. Therefore we will not be liable to you for any issues arising in connection with their use of your information, the website content or the services offered to you by these websites. We advise you to consult the privacy policy and terms and conditions on each website to see how each supplier may process your information.

Sharing your thoughts
When using one of our websites you may be able to share information through social networks like Facebook and Twitter. For example when you 'like', 'share' or review our Services. When doing this your personal information may be visible to the providers of those social networks and their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o apply for our products or services;
o create an account on our website;
o subscribe to our service or publications;
o request marketing to be sent to you;
o enter a competition, promotion or survey; or
o give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
o Technical Data from analytics providers such as Google based outside the EU.
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Viva wallet Limited based inside the EU.
o Identity and Contact Data from data brokers or aggregators such as verify my age based inside the EU.
o Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How do we use your information?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal or regulatory obligations.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Age Verification
It is against the law to sell any electronic cigarette products to under 18’s.

Who we share your information with*
Where you have asked us to provide an age restricted product or service, we may share your information with age verification providers, to ensure that you are of age to purchase out products.

One Account Mobile Limited (1account):
One Account Mobile Limited (1account), and third-party providers of identity data to 1account. This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction legislation. 1account may retain relevant data for the purpose of future verification. All data processed by 1account is subject to appropriate security measures. Data retained by 1account is subject to periodic review to ensure it is not held for longer than necessary. You can find information about 1account and how they manage your personal data by visiting their website: www.1account.net ( One Account Mobile Limited.)

Where you have asked us to provide an age restricted product or service, you consent to allow us to share your information with, and collect information from, One Account Mobile Limited (1account) and third-party providers of identity data to 1account. This consent is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction legislation. You consent to allow 1account to retain relevant data for the purpose of future verification.

All data processed by 1account is subject to appropriate security measures. Data retained by 1account is subject to periodic review to ensure it is not held for longer than necessary. You can find information about how 1account manage your personal data and view their privacy policy by visiting their website: 1account.net.

Information We Collect From Other Sources:

Where you have asked us to provide an age restricted product or service, we may collect information from One Account Mobile Limited (1account) and third-party providers of identity data to 1account. This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction legislation. We will record that your age has been successfully verified so that you don’t need to go through the process again. You can find information about how 1account manage your personal data and view their privacy policy by visiting their website: 1account.net.

Who We Share Your Information With:

Where you have asked us to provide an age restricted product or service, we may share your information with One Account Mobile Limited (1account), and third-party providers of identity data to 1account. This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction legislation. 1account may retain relevant data for the purpose of future verification. All data processed by 1account is subject to appropriate security measures. Data retained by 1account is subject to periodic review to ensure it is not held for longer than necessary. You can find information about 1account manage your personal data and view their privacy policy by visiting their website: 1account.net.

At times the age verification check may fail or be referred. In these scenarios we could request passport/driving license details from you to re-check your details manually against the relevant database to verify age. If you do not wish to release this information to us we can cancel and refund your order.
*Please note that if for any reason you fail age verification there is a strong possibility that your order will be delayed, if this occurs please contact customer services immediately email info@cue-vapor.co.uk

Our current providers for age verification are:

1. One Account Mobile Limited (1account)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Marketing from ourselves
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information or purchased goods or services from our website or stores. In each case, you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside CUE VAPOUR Ltd for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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

Who might we share your information with
We may share your personal data with the parties set out below for the purposes set out in the table above.

Our service providers
We work with suppliers and agencies so they can process your personal information on our behalf. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions For example, our logistic service providers ship your orders. As a result, we provide them details of your order and delivery information.

Other organisations and individuals:

We may transfer your personal information to other organisations in certain scenarios. For example:

• If required to by law, under any code of practice by which we are bound or we are asked to do so by a public or regulatory authority such as the Police or the Department for Work and Pensions;
• If we need to do so in order to exercise or protect our legal rights, users, systems and Services; or
• In response to requests from individuals (or their representatives) seeking to protect their legal rights or the rights of others.

Keeping you informed about our products and services
We would like to tell you about the news, offers, products and services of CUE VAPOR from time to time, but only if you have previously agreed to receive these marketing communications. When you purchase with us we will ask if you would like to receive marketing communications. You can change your marketing choices via My Account or by clicking ‘unsubscribe’ on the emails you receive, or by contacting info@cue-vapor.co.uk

We may do this through the post, by email, text message, online, using social media, push notifications via apps, or by any other electronic means. We won't send you marketing messages if you tell us not to but we might send you occasional service-related messages.

International Transfers
We do not transfer your personal data outside the European Economic Area (“EEA”).Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your rights
Access and correction of your personal information
You have the right to access the personal information that we hold about you in many circumstances. This is sometimes called a 'Subject Access Request'. If we agree that we are obliged to provide personal information to you, we will provide it to you within one month. Occasionally, it may take us longer than one month if your request is particularly complex or you have made a number of requests, in this case, we will notify you and keep you updated.

Before providing personal information to you or another person on your behalf, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.

If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it, though we may need to verify the accuracy of the new data you provide to us.

If you would like to exercise these rights, please contact us on support: info@cue-vapor.co.uk

Right to request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to stop or limit our processing of your data
You have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.
If you would like to exercise this right, please contact us on: info@cue-vapor.co.uk

Right to Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent at any time where we are relying on consent to process your personal data.

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Use Of Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after one year.

Security
We take security measures to protect your information including:
• implementing access controls to our information technology, such as firewalls, Secure Sockets Layer (SSL). ID verification and logical segmentation and/ or physical separation of our systems and information;
• limiting access to our buildings to those that we believe are entitled to be there (by use of passes, key card access and other related technologies);
• never asking you for your passwords;
• advising you never to enter your password into an email or after following a link from an email.

Contact us
If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy, the way your personal information is processed, please contact us by one of the following means:

By email: info@cue-vapor.co.uk
By post: Data Protection Officer CUE VAPOR Ltd, Unit 28, Ellough Industrial Estates, Benacre Road, Ellough, Beccles, NR34 7TD

Policy change
This privacy policy was most recently updated in November 2022