Ecigclick Privacy Policy Notice
Introduction & General Terms
This document (“Privacy Policy”), in combination with the Cookies Policy and Competition rules make up our commitment to protecting personal information we hold about our customers, prospective customers, newsletter subscribers, competition entrants, website users or any other data subject whose personal information we hold.
Personal information as outlined in this policy is being processed by Ecigclick (“we”, “our”, “us”, “Ecigclick”). You can find out more about us by visiting https://www.ecigclick.co.uk/about-us. In the event of any part of Ecigclick being sold we reserve the right to continue to share your data to third parties in accordance with the latest preferences you have provided. You will be informed should any change of ownership occur, and the new owner will manage your personal information preferences.
Policy key definitions:
“I”, “our”, “us”, or “we” refer to the business, [Business name & other trading names].
“you”, “the user” refer to the person(s) using this website.
GDPR means General Data Protection Act.
PECR means Privacy & Electronic Communications Regulation.
ICO means Information Commissioner’s Office.
Cookies mean small files stored on a users computer or device.
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.
Our Commitment to you
We are committed to managing & safeguarding your personal information in accordance with current legislation and best practice. Our aim is to be responsible, relevant and secure when using your data. Whenever you provide personal information we will treat that information in accordance with this Privacy Policy.
We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our ‘Legitimate Interests’. We endeavour at all times to keep your data accurate and secure, and to honour your data preferences with regard to receipt of email marketing.
We operate a website that may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, and are also likely to use cookies, and we therefore urge you to review them. They will govern the use of personal information you submit when visiting these websites, which may also be collected by cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
Your personal data will not be disclosed to state institutions and authorities except if required by law or other regulation. Before we release data on this basis, we will ensure that the information is being provided to a genuine and properly authorised investigation.
We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to email all of our registered users to make sure that they are informed of such changes.
However, it is your responsibility to check this Privacy Policy before each use of the Website.
What Data we collect
When you submit an online form or when you visit our website, we may collect both personal and pseudonymous data about you.
When we talk about personal data we mean any information that can identify you as an individual, such as your name and postal address. Pseudonymous data doesn’t identify you as a person but it might be used in aggregate, for instance when you participate in a survey or when we analyse audience interaction with our products and services.
Data you provide to us
When you participate in, access or sign up to any of our activities or online content, such as newsletters, competitions or events, we receive personal information about you. This can consist of information such as your name, email address and when it comes to competitions – postal address, telephone or mobile number. As well as information collected about your use of our services (such as when you enter our sites and how long you stay on them).
Data we collect through your use of our websites
We may collect information about how you use our websites or other content online, and the device(s) you use to access the services. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network device on the internet. Anonymous data will be recorded for the purpose of reporting web traffic statistics, advertisement ‘click-throughs’, and/or other activities on our sites. For detailed information on Cookies we use please see Cookies and how we use them as well as our Cookie Policy.
How we use your data
We may use the information you share with us and the information we collect through your use of our sites in the ways described below and as described at the time of capture.
Competitions & Prize Draws
Newsletters
Events
Customer Services
Research
Cookies and how we use them
Analytics
Online Advertising
Links to third party websites
Using our websites from outside the UK
Competitions & Prize Draws
We will use the details you have shared to manage your entry to any competition or prize draw. This may include your name, e-mail address and telephone number. We shall use such information to notify you if you are the winner. Your data will be retained for the period of the competition only, and will not be added to any marketing lists unless you have consented to this, and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of your prize. Further details relating specifically to competitions and prize draws can be found here
Newsletters
We will use the details you have shared to send you the newsletter to which you have subscribed. We will not add them to any marketing lists, unless you have consented to this.
We will provide a way for you to unsubscribe on every newsletter we send to you. Details you share with us for the purpose of newsletter subscription will never be shared with a third party.
Events
We will use the details you have shared to manage your registration and entry into our event. This may include contact via email with information relating to the event you have registered. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of the event.
Customer Services
We will use the information you provide to deliver customer services and to respond to inquiries or requests that you direct to us. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with third parties where we have appointed them to manage specific aspects of your customer care.
Research
We may use the information you provide to invite you to participate in surveys about our products, advertisers and services. Participation is always voluntary and the answers you provide are anonymous and aggregated to support our learnings and inform changes we can make to improve our services. Your data will not be added to any marketing lists unless you have consented to this and were informed at the point of capture and will only be shared with third parties where we have appointed them to manage research activity on our behalf.
Direct Marketing
We may use the details you share with us to send you offers and promotions by email. We will provide a way for you to opt-out of receiving marketing promotions both at the time of data capture and everytime we contact you thereafter. You can also email admin @ ecigclick.co.uk to request your details are suppressed from all promotional campaigns. We won’t use your personal data for marketing purposes at all if you’ve told us not to.
Legitimate Interest
We may process your personal data on the basis of a legitimate interest which may include promoting similar products or services via direct marketing activity, to manage supression and unsubscribe requests received from you, to identify and prevent fraudulent behaviour, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns.
Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights.
Cookies and how we use them
“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We use cookies for a number of reasons:
Strictly Necessary Cookies – These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information
Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Functional Cookies – These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting Cookies – These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media Cookies – These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
For more information on how we use cookies please read our Cookie Policy.
Analytics
Ecigclick uses Google Analytics as its primary solution for tracking website visits, interactions and events. Ecigclick uses website analytics data to help improve the way we delivery content and online experiences to visitors.
For full details on how Google processes your data please visit: https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008
Online Advertising
Ecigclick may show advertising to users. It does not collect personal information such as your name or email address.
Links to third party websites
When you click on advertisements or links on any of our sites, you will leave that site and go to a third-party site, which is outside of our control. When we place an advertisement on one of our sites, it does not signify that we are endorsing that advertiser’s product or service. We do not accept responsibility for content, have no control over and our Privacy Policy does not apply to these companies, sites or content and if such third-party sites collect personal data, we cannot control how this data is processed, stored or used. We advise that you read their data collection statements, which accompany any registration and their Privacy Policies before you submit your personal information
Using our websites from outside the UK
We use servers located in the EEA to store data. When you submit your details and in whichever country you are situated you agree to the data being transferred to the EEA and processed under the terms of Regulation (EU) 2016/679 (GDPR) including any implementing data protection legislation in the UK. If you are not in agreement please do not add your personal details on the website. Ecigclick makes no representation or warranty that the content and materials on the Website are appropriate or available for use in locations outside of the United Kingdom.
Those who choose to access the Website or use the services from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent applicable.
How we keep your personal data secure
Ecigclick and data processors that have access to, and are associated with, the processing of your personal information are legally obliged to respect the confidentiality of your data and are bound by contract to do so.
Note that our website provides commenting facilities where you can post information. When you do so, be aware that other visitors may collect any information you make public.
Who we share your personal data with
Ecigclick has formed partnerships with a variety of carefully selected companies that we share data with in order to carry out the activities described in the section How we Use your Data, above. Below is a non-exhaustive list of our key partners:
Marketing Partners:
AWIN, Affiliate Future, Shareasale, Amazon, Ebay, Commission Junction, Ebay, Webgains.
How long we keep your personal data for
We will hold your personal information on our systems only for as long as required to provide you with the products and/or services you have requested.
Where you sign up to receive email marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving emails in order to ensure that we continue to honour and respect that request. To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.
In some circumstances you can ask us to delete your data: see ‘Your rights’ 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.
Personal Data – Your rights
Under the GDPR including any implementing data protection legislation in the UK you have the rights shown below:-
Your right to be informed
Your right of access
Your right to rectification
Your right to erasure
Your right to restrict processing
Your right to data portability
Your right to object
Your rights in relation to automated decision making and profiling.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the How we use your data section of this Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
If you wish to exercise any of these rights or simply wish to find out what information, if any, we hold that relates to you, you must make your request in writing by sending an email to admin @ ecigclick.co.uk.
You can help us to process your request quickly by providing us with information that will help us identify records we hold that relate to you. For example your name, email address or in the case of information captured via cookies, the IP address of the device you have used.
Contact our Data Privacy Team
If you have an enquiry or concern about the contents of our Privacy Policy or our handling and use of your data, please email the Privacy Team on admin @ ecigclick.co.uk. If you are not satisfied with our response to your enquiry or concern, you may wish to contact the
Information Commissioner via their website
If we decide to change our Privacy Notice we will post these changes on this page so that you are always aware of what information we collect, how we use it and in what circumstances we disclose it.
Updated 19th May 2018