Data Protection & Privacy Policy

Updated 23 Sep 2018

Welcome to the privacy policy of XVX Vape. XVX Vape (hereinafter referred to as "Cohen Griffin Limited", "XVX Vape" and the "Website") respects your privacy and is committed to protecting your personal data.

BY USING THIS WEBSITE YOU EXPRESSLY AGREE TO ALL OF THE TERMS AND CONDITIONS CONTAINED IN THIS POLICY.



Introduction

XVX Vape cares about your privacy. For this reason, we collect and use personal data only as it might be needed for us to deliver to you our website platform (the "Website") and services (collectively, our "Services"). The Services are operated by Cohen Griffin Ltd (the "Company", "we" or "us") for users of the Services ("You").

We have developed this Policy in order for you to understand how we collect, use, communicate, and disclose and make use of personal information. It also describes options we provide for you to access, update or otherwise take control of your personal data that we process. The following outlines our privacy policy.

If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer ("DPO") and our dedicated team by contacting us at hello@xvxvape.com. This Email inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.



Who are we?

XVX Vape is run by Cohen Griffin Ltd, a business registered in England with company number 09839678. Our office address is M25 Business Centre, 121 Brooker Road, Waltham Abbey, EN9 1JH, United Kingdom. Your personal information (which includes your name, address and any other details you provide to us which concern you as an individual) may be processed both by us and by other companies within our group. Each of the companies authorised to process your information as mentioned above will do so in accordance with this privacy policy.



What information do we collect?

In general, you may visit many pages of the Website without telling us who you are or revealing any personal information about yourself. We may track the Internet domain address from which people visit the Website and analyse this data for trends and statistics, but individual users will remain anonymous unless they voluntarily tell us who they are. XVX Vape collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. From time to time, XVX Vape may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.

We collect personal data whenever you make a purchase with us via our website, via one of our "Partners", by Email, or over the phone. We need this data to be able to take and process your purchase of goods.
For more on how we collect data from other sources (our "Partners"), see below section "Personal data we receive from other sources".

Additionally, when you interact with us through our Services, we may collect information from you, as further described below:

a. Information you provide: We collect information from you when you voluntarily provide such information, such as when you register for access to the Services or use certain Services. Information we collect may include but not be limited to real name, email address, physical address, date of birth, gender, mobile phone number, smoking habits, and any other content you upload to our Website.

b. Automatically collected information: When you interact with us through the Services, we receive and store certain information such as an IP address, device ID, and your activities within the Services. Logging when you access the Services and from where, allows us to better understand our users and keep your account safe.

c. Aggregated information: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on our customer demographics, interests and behaviour based on the information collected. We may also disclose aggregated and anonymised user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

d. Cookies: Like almost all online websites we employ cookies and similar technologies to keep track of your local device's settings and which account you are logged into. Cookies are small pieces of data that websites and services can set on your browser or device that can be read at a later date. In addition to Cookies we may also use web beacons and single pixel gifs to log Email opens.
See our Cookies Policy for more information.

e. Cookies (third party): We use third party web site analytic tools such as Google Analytics on our Website that employ cookies to collect certain information concerning your use of our Services. However, you can disable cookies by changing your browser settings. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider's website via your help screen.
We have specifically instructed Google to not share your information with their third parties.
We use IP Anonymization on Google Analytics.
See our Cookies Policy for more information.



Personal data we receive from other sources (Our "Partners")

We may receive information about you from other sources. These include our business partners ("Partners") and other independent third parties which take purchases on our behalf.
Our Partners include, but may not limited to, Amazon UK, Amazon DE, and Ebay.

Data we receive from our Partners includes any data provided by you, to them, that we require to process your order. For example purchases made on Amazon will be forwarded to us. When you use some of these Partners, you provide the relevant personal details to our Partner, who then forwards your details to us to process, dispatch, and complete the transaction.
The Terms and Conditions and Privacy Policies of these independent Third Parties outline how they forward information to us.

We are bound by our Partner's privacy & data policies to protect your data.

See more:



Why do we process your personal data & how will it be used

We need to process your personal data for processing your purchases as well as delivering, improving, updating, and enhancing the Services & products we provide to you.
We may also use your information for the purpose of providing you with information about our services, products, articles, offers, and news.
We strongly believe in both minimising the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services & products you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes.

We use the information you provide in a manner that is consistent with this Privacy Policy. If you provide information for a certain reason, we may use the information in connection with the reason for which it was provided.



Our legal basis for processing your personal data.

a. Contractual necessity - Providing you with our Services: We handle personal data on this basis to create your account and provide our Services, including purchases and deliveries.

b. Legitimate interests: We process your personal data on the basis of legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of individuals. Including:

  • Providing a safe and secure Website
  • Order communications - sending Email and SMS messages regarding your purchases
  • Marketing - sending Emails to inform you of features, products, or offers
  • Account security - sending communications relating to account security
  • Protecting our users, servers, and services
  • Analysing and improving our Services to you
  • Processing legal requirements

c. Consent: Handling data freely given by clear affirmative action. You have a right to withdraw consent, which must be brought to our attention.



Our disclosure of your information

We will never disclose your information unlawfully. XVX Vape is not in the business of selling your data - we are a lifestyle brand business which respects you as our customer. There are however some circumstances in which we may share your information with certain third parties, as set forth below:

a. Business transfers: As our business grows we might sell or buy businesses or assets. In the event of our take-over, merger, corporate sale, reorganization, or similar, your information may be part of the transferred assets.

b. Legal requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of the Company or Related Companies, (iii) protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

c. Google Analytics: We utilize Google Analytics for website visitor tracking and analysis.
We have specifically instructed Google to not share your information with their third parties.
We use IP Anonymisation on Google Analytics.

d. Trusted third parties: See below "Sharing your personal data with trusted third parties".

e. Liquidation: In the unlikely event that a liquidator, administrator, or receiver is appointed over us or all or any part of our assets that insolvency practitioner may transfer your information to a third party purchaser of the business provided that purchaser undertakes to use your information for the same purposes as set out in this policy.



Sharing your personal data with trusted third parties

We will never sell or share your personal data to any third party unlawfully.
We may share your personal data with trusted third party service providers as necessary for them to perform services on our behalf, such as:

  • Delivering/completing/providing your order. For example: delivery networks / couriers.
  • Communicating with you, such as by way of Email or SMS text message.
  • Customer relationship management.
  • Website analytics.
  • Satisfying legal requirements.

We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilising, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).

Legal compliance:
XVX Vape may disclose your personal information to comply with a court order, subpoena, search warrant, or other legal process; to comply with legal, regulatory, or administrative requirements of any governmental authorities; to protect and defend Company, its subsidiaries and affiliates, and their officers, directors, employees, attorneys, agents, contractors, and partners, in connection with any legal action, claim, or dispute; to enforce the Terms and Conditions of Use of the Website; to prevent imminent physical harm; and in the event that we find that your actions on the Website violate any laws, our Terms and Conditions of Use, or any of our usage guidelines for specific products or services.



How do we store your data, and for how long?

XVX Vape is based in the United Kingdom and operates server infrastructure in the United Kingdom. No matter where you are located you consent to the processing and transferring of your information in the UK/EU. We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilisation of encryption where appropriate.

We have implemented security policies, rules, and technical measures to protect the unauthorised destruction or accidental loss, unauthorised access, improper use and disclosure or alteration of information placed under our control and will ensure to safeguard this information at all times. We do not share your data with any third party companies, except as outlined in this document.

We generally retain personal data for so long as it may be relevant to the purposes identified herein. To dispose of personal data, we may anonymise it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

If you utilise our Services from a country other than the country where our servers are located, your communications with us may result in transferring your personal data across international borders.

Third-party hosting:
We contract with a third party to maintain and host the Website and the Services. Therefore, any information you submit, including personal information, will be placed and stored on a computer server maintained by this third-party host. The third party has agreed to implement technology and security features and strict policy guidelines to safeguard the privacy of your personal information from unauthorized access or improper use.



Opting Out

You may "Opt Out" from marketing e-mails by following the unsubscribe link at the bottom of promotional Email messages, or by contacting us below.

If you choose not to give us your personal information at all, you can still access the Website; however, you will not be able to access areas that require registration or personal information, or place orders.

We reserve the right to send you administrative communications and order confirmation communications, even if you choose to opt out of receiving most Email communications, including but not limited to notices regarding the status of your account and changes we have made to the system or Website to promote safety.



Understanding your rights: Access, update, or delete your data

Your data belongs to you, and we want you to be in full control of what happens to your data.
If you signed up via our Website you can update most of your data by accessing your Account Settings. You can also unsubscribe from certain emails by clicking the unsubscribe link they contain.
If you booked our services via one of our business Partners, you may contact us in regards to your data, as outlined below:

You may close your account at any time and for any reason by sending an email to hello@xvxvape.com.
To access, update, or delete your data you must do a submit a data access request. Do so directly by Emailing us at hello@xvxvape.com, with the subject "Personal Data Request". We will then start the process within 30 days.
Object or restrict the processing of your data by contacting us at hello@xvxvape.com.

If you make a request to delete your personal data and that data is necessary for the products or Services you have purchased, the request will be honoured only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.



Raising a complaint

You have the right to lodge a complaint with the relevant supervisory authority. We would be grateful if you could please contact us first - we will do our very best to resolve your concern.

You can lodge a complaint with the Information Commissioner's Office (ICO) - https://ico.org.uk.



Unsolicited information

In the event you provide us with ideas or suggestions for new or existing products or services, and other unsolicited submissions (collectively, "Unsolicited Information") they will be deemed non-confidential and we shall be free to act on, reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.



Links to other websites

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by us (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.



Changes to this privacy policy

Although most changes are likely to be minor, We may change this policy from time to time, and at Our sole discretion. We encourage visitors to frequently check this page for any changes. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.



Age restrictions

Our Services are available for purchase only for those over the age of 18. Our products & Services are not targeted to, intended to be consumed by, or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us.



Disclaimer of Warranty and Liability

The following provisions may be curtailed or disallowed by the laws of certain jurisdictions. In such case, the terms hereof are to be read as excluding or limiting such term so as to satisfy such law. We do not represent or warrant that the information accessible via this website is accurate, complete or current. We have no liability whatsoever in respect of any use which you make of such information. The information provided on this website has not been written to meet your individual requirements and it is your sole responsibility to satisfy yourself prior to ordering any products or services from us that they are suitable for your purposes. Whilst we make all reasonable attempts to exclude viruses from the website, we cannot ensure such exclusion and no liability is accepted for viruses. Thus, you are recommended to take all appropriate safeguards before downloading information or images from this website. All warranties, express or implied, statutory or otherwise are hereby excluded. Neither we nor any of our employees or affiliated entities will be liable for any kind of damages and howsoever arising including, without limitation, loss of profits, compensatory, consequential, direct, exemplary, incidental, indirect, punitive or special, damages or any liability which you may have to a third party, even if we have been advised of the possibility of such loss. We are not responsible for the direct or indirect consequences of you linking to any other website from this website. These terms and this disclaimer and any claim based on use of information from this website shall be governed by the laws of England and Wales and you agree to submit to the non-exclusive jurisdiction of the Courts of England.



Contacting us

Please also feel free to contact us if you have any questions about this Privacy Policy at hello@xvxvape.com
We will respond to all requests, inquiries, or concerns within 30 days.

You can also write to us at:
XVX Vape
M25 Business Centre,
121 Brooker Road,
Waltham Abbey,
EN9 1JH,
United Kingdom