Go Vapour UK Ltd (“We”) are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Go Vapour UK Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Go Vapour UK Ltd, 2 Newbury Street, Andover, Hampshire SP11 6WL. For all data matters contact Nicholas Morris on email@example.com.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
To reply to any emails you may have sent us or to reply to any queries you may have raised with us.
To administer your membership of our loyalty card programme.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data:- your email address, your name, your date of birth, your postcode, your home or mobile telephone number or both.
We have obtained your personal data from you directly or where a gift card has been purchased on your behalf we may have had this information provided by the purchaser.
5. What is our legal basis for processing your personal data?
A) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
|☐ Consent of the data subject;
|☐ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
|☐ Processing necessary for compliance with a legal obligation
|☐ Processing necessary to protect the vital interests of a data subject or another person
|☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
|X Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
|When you join our loyalty card scheme we have a duty to protect your accumulated points for your own benefit. We record sufficient information to identify you as the rightful beneficiary of accumulated points (subject to the terms & conditions of the scheme) and to prevent fraudulent use of your loyalty card. We also collect your postcode to provide us with information on where our customers come from geographically and as an additional security check. When you contact us by email we collect your email address in order to respond to your enquiry.
B) Special categories of personal data (article 9 of GDPR)
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with Go Vapour staff with a legitimate need for access to that data, for example to accurately administer your participation in our loyalty scheme or to reply to your emails or telephone calls to us or to contact you to inform you of any issues relating to our administration of your membership of our loyalty scheme relating directly to you. We will share your information with law enforcement agencies or for other statutory purposes when lawfully required to do so.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and for a period of at least one year and not exceeding TWO years from the last date you made use of our loyalty card scheme in order to not unduly penalise infrequent use of the scheme since deletion of your data will cancel your membership of the scheme and irretrievably void any accumulated points.
8. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences:- you will not be able to participate in our loyalty reward scheme
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA however you will no longer be able to participate in our loyalty reward scheme if you withdraw your consent.
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
We do not transfer personal data outside the eea.
11. Automated Decision Making
We do not use any form of automated decision making in our business.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DATA PROTECTION OFFICER at firstname.lastname@example.org.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.