NGVape Privacy Policy

This is the privacy notice of NG Vape. In this document, “we”, “our”, or “us” refer to NG
Vape Carlton Ltd/NG Vape Nottingham Ltd. We are company numbers 10799142/10799162
registered in England.

Introduction
● This is a notice to inform you of our policy about all the information that we record
about you. It sets out the conditions under which we may process any information
that we collect from you, or that you provide to us. It covers information that could
identify you (“personal information”) and information that could not. In the context
of the law and this notice, “process” means collect, store, transfer, use or otherwise
act on information.
● We regret that if there are one or more points below with which you are not happy,
your only recourse is to leave our website immediately.
● We take seriously the protection of your privacy and confidentiality. We understand
that all visitors to our website are entitled to know that their personal data will not
be used for any purpose unintended by them, and will not accidentally fall into the
hands of a third party.
● We undertake to preserve the confidentiality of all information you provide to us
and hope that you reciprocate.
● Our policy complies with UK law accordingly implemented, including that required
by the EU General Data Protection Regulation (GDPR).
● The law requires us to tell you about your rights and our obligations to you in
regards to the processing and control of your personal data. We do this now, by
requesting that you read the information provided here.
● Except as set out below, we do not share, or sell, or disclose to a third party, any
information collected through our website.
● The recipient of personal data is NG Vape Ltd.

The basis on which we process information about you
The law requires us to determine under which of six defined bases we process different
categories of your personal information, and to notify you of the basis for each category. If
a basis on which we process your personal information is no longer relevant, then we shall
immediately stop processing your data. If the basis changes then if required by law, we shall
notify you of the change and of any new basis under which we have determined that we
can continue to process your information.
● Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise
agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the information
you give us. Some of this information may be personal information.
We may use it in order to:
● verify your identity for security purposes
● sell products to you
● provide you with our services
● provide you with suggestions and advice on products, services and how to obtain the
most from using our website
We process this information on the basis there is a contract between us, or that you have
requested we use the information before we enter into a legal contract. Additionally, we
may aggregate this information in a general way and use it to provide class information, for
example to monitor our performance with respect to a particular service we provide. If we
use it for this purpose, you as an individual will not be personally identifiable. We shall
continue to process this information until the contract between us ends or is terminated by
either party under the terms of the contract.
● Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us,
such as when you browse our website or ask us to provide you more information about our
business, including job opportunities and our products and services, you provide your
consent to us to process information that may be personal information. Wherever possible,
we aim to obtain your explicit consent to process this information, for example, by asking
you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by
e-mail to which you would reasonably expect us to reply. Except where you have consented
to our use of your information for a specific purpose, we do not use your information in any
way that would identify you personally. We may aggregate it in a general way and use it to
provide class information, for example to monitor the performance of a particular page on
our website. If you have given us explicit permission to do so, we may from time to time
pass your name and contact information to selected associates whom we consider may
provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it
can be reasonably assumed that your consent no longer exists. You may withdraw your

consent at any time by instructing us at [email protected] However, if you do so, you
may not be able to use our website or our services further.
● The categories of personal data obtained (if the personal data is not obtained from
the individual it relates to).
● The recipients or categories of recipients of the personal data.
● The contact details of our data protection officer (if applicable).
● Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to
us, of doing so. Where we process your information on this basis, we do after having
considered:
● whether the same objective could be achieved through other means
● whether processing (or not processing) might cause you harm
● whether you would expect us to process your data, and whether you would, in the
round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
● record-keeping for the proper and necessary administration of our business
● responding to unsolicited communication from you to which we believe you would
expect a response
● protecting and asserting the legal rights of any party
● insuring against or obtaining professional advice that is required to manage business
risk
● protecting your interests where we believe we have a duty to do so
Article 13(1) of the GDPR provides that:
“(1) Where personal data relating to a data subject are collected from the data subject, the
controller shall, at the time when personal data are obtained, provide the data subject with
all of the following information: … (c) the purposes of the processing for which the personal
data are intended as well as the legal basis for the processing; (d) where the processing is
based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a
third party”.
Article 6(1)(f) of the GDPR provides that:
“(1) Processing shall be lawful only if and to the extent that at least one of the following
applies: … (f) processing is necessary for the purposes of the legitimate interests pursued
by the controller or by a third party, except where such interests are overridden by the

interests or fundamental rights and freedoms of the data subject which require protection
of personal data, in particular where the data subject is a child.”
● Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information
in order to comply with a statutory obligation. For example, we may be required to give
information to legal authorities if they so request or if they have the proper authorisation
such as a search warrant or court order. This may include your personal information.

Specific uses of information you provide to us
● Information provided on the understanding that it will be shared with a third party
Our website may allow you to post information with a view to that information being read,
copied, downloaded, or used by other people. An example of this would be posting a review
on a product.
In posting personal information, it is up to you to satisfy yourself about the privacy level of
every person who might use it. We do not specifically use this information except to allow it
to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide. Once
your information enters the public domain, we have no control over what any individual
third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our
discretion we may agree to your request to delete personal information that you have
posted. You can make a request by contacting us at [email protected]
● Complaints regarding content on our website
Anyone may register and then publish product reviews, including personal name in line with
the content. We attempt to moderate user-generated content, but we are not always able
to do so as soon as that content is published. If you complain about any of the content on
our website, we shall investigate your complaint. If we feel it is justified or if we believe the
law requires us to do so, we shall remove the content while we investigate. Free speech is a
fundamental right, so we have to make a judgement as to whose right will be obstructed:
yours, or that of the person who posted the content that offends you. If we think your
complaint is vexatious or without any basis, we shall not correspond with you about it.
● Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or
otherwise. Our employees and contractors never have access to it. At the point of payment,
you are transferred to a secure iframe or window on the website Secure Trading / PayPal or

some other reputable payment service provider. That page may be branded to look like a
page on our website, but it is not controlled by us.
● Job application and employment
If you send us information in connection with a job application, we may keep it for up to
three years in case we decide to contact you at a later date. If we employ you, we collect
information about you and your work from time to time throughout the period of your
employment. This information will be used only for purposes directly relevant to your
employment. After your employment has ended, we will keep your file for six before
destroying or deleting it.
● Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect
the data you have given to us in order to reply with the information you need. We record
your request and our reply in order to increase the efficiency of our business. We keep
personally identifiable information associated with your message, such as your name and
email address so as to be able to track our communications with you to provide a high
quality service.
● Complaining
When we receive a complaint, we record all the information you have given to us. We use
that information to resolve your complaint. If your complaint reasonably requires us to
contact some other person, we may decide to give to that other person some of the
information contained in your complaint. We do this as infrequently as possible, but it is a
matter for our sole discretion as to whether we do give information, and if we do, what that
information is. We may also compile statistics showing information obtained from this
source to assess the level of service we provide, but not in a way that could identify you or
any other person.

Use of information we collect through automated systems when you
visit our website
● Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web
browser when you visit any website. They allow information gathered on one web page to
be stored until it is needed for use on another, allowing a website to provide you with a
personalised experience and the website owner with statistics about how you use the
website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your
browser. Others last indefinitely. Your web browser should allow you to delete any you
choose. It also should allow you to prevent or limit their use. Our website uses cookies.
They are placed by software that operates on our servers, and by software operated by
third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you
choose not to accept them, we shall not use them for your visit except to record that you
have not consented to their use for any other purpose. If you choose not to use cookies or
you prevent their use through your browser settings, you will not be able to use all the
functionality of our website.
We use cookies in the following ways:
● to track how you use our website
● to record whether you have seen specific messages we display on our website
● to keep you signed in our site
● to record your answers to surveys and questionnaires on our site while you
complete them
● to record the conversation thread during a live chat with our support team
● Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our
website are recorded. We record information such as your geographical location, your
Internet service provider and your IP address. We also record information about the
software you are using to browse our website, such as the type of computer or device and
the screen resolution. We use this information in aggregate to assess the popularity of the
web pages on our website and how we perform in providing content to you. If combined
with other information we know about you from previous visits, the data possibly could be
used to identify you personally, even if you are not signed in to our website.

Disclosure and sharing of your information
● Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other
companies working for them may use technology that automatically collects information
about you when their advertisement is displayed on our website. They may also use other
technology such as cookies or JavaScript to personalise the content of, and to measure the
performance of their adverts. We do not have control over these technologies or the data
that these parties obtain. Accordingly, this privacy notice does not cover the information

Access to your own information

● Access to your personal information
At any time you may review or update personally identifiable information that we hold
about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you may send us a
request at [email protected] After receiving the request, we will tell you when we
expect to provide you with the information, and whether we require any fee for providing it
to you.
● Removal of your information
If you wish us to remove personally identifiable information from our website, you may
contact us at [email protected] This may limit the service we can provide to you.
● Verification of your information
When we receive any request to access, edit or delete personal identifiable information we
shall first take reasonable steps to verify your identity before granting you access or
otherwise taking any action. This is important to safeguard your information.

Other matters
● Use of site by children
● We do not sell products or provide services for purchase by children, nor do we
market to children.
● If you are under 18, you may not use our website.
● Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to
encrypt any data you give us. Whenever information is transferred between us, you can
check that it is done so using SSL by looking for a closed padlock symbol or other trust mark
in your browser’s URL bar or toolbar.
● How you can complain
● If you are not happy with our privacy policy or if have any complaint then you should
tell us by email or by mail, both addresses are listed on point 26.
● If a dispute is not settled then we hope you will agree to attempt to resolve it by
engaging in good faith with us in a process of mediation or arbitration.
● If you are in any way dissatisfied about how we process your personal information,
you have a right to lodge a complaint with the Information Commissioner’s Office.
This can be done at https://ico.org.uk/concerns/
● Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information
only for as long as required by us:
● to provide you with the services you have requested;
● to comply with other law, including for the period demanded by our tax authorities;
● to support a claim or defense in court.
● Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal
jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your
jurisdiction, we should like to hear from you. However, ultimately it is your choice as to
whether you wish to use our website.
● Categories of personal data obtained
For the purposes of a sale on our website:
● Name
● Address
● Email Address
● Telephone Number
● Previous order history
● Loyalty Points balance
● Products purchased
● Method of delivery
● Delivery tracking number
For the purposes of contact our support channels:
● Name
● Address
● Email Address
● Telephone Number
For the purposes of a job application:
● Name
● Address
● Email Address
● Telephone Number
● Uploaded resumes, curriculum vitae
● Reference details if provided
● Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to
you are those posted here on our website on the day you use our website. We advise you to
print a copy for your records. If you have any question regarding our privacy policy, please
contact us.