Vapouround Magazine, The Vapouround Club: Vapouround/Orange Fox Media Ltd. Privacy Notice
Your membership of the Vapouround Club is governed by the club membership terms and conditions available here. This privacy notice gives you further information about the way we (Vapouround/Orange Fox Media Ltd) collect and use personal information about you, which is known as “personal data” under data protection legislation.
You have the right to object to us processing your personal data for direct marketing, which we do only with your explicit consent, and also to processing which is carried out for the purposes of our legitimate interests. For more information, see the “Your Rights” section below.
CHANGES TO DATA PROTECTION LAW
The law in relation to data protection is changing in the EU with effect from May 25 2018. This Privacy Notice has been updated in compliance with the General Data Protection Regulation 2018 for those who receive marketing content by email from Vapouround and Vapouround Club members registering with effect from May 25 2018, to reflect your new and enhanced rights and to update how we process your personal data.
You should read through this Privacy Notice to fully understand the basis upon which we collect your personal data, how we use it, where we store it and to whom it is disclosed.
Commitment to Privacy
We are committed to protecting your personal data and right to privacy. We will always keep your personal data safe and comply with applicable data protection legislation.
KNOW YOUR RIGHTS
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country. If you are based in the UK, please go to https://ico.org.uk/ for more information.
What does this mean?
1. The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this Privacy Notice.
2. The right of access
You have the right to obtain access to your personal data (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice).
This is so you’re aware and can check that we’re using your personal data in accordance with data protection law.
3. The right to rectification You are entitled to have your personal data corrected if it’s inaccurate or incomplete.
4. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict pro-cessing
You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
7. The right to object to pro-cessing
You have the right to object to processing for direct marketing (which we do only with your consent) and also to processing which is carried out for the purposes of our legitimate interests.
8. The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
9. The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
Please see the Requests section for more information on how we will handle your requests.
WHO WE ARE
Please click here to see who we are in the “About Us” section of our website. The entities listed are of Vapouround (Orange Fox Media Ltd) only. References in this Notice to “we” or “us” are to the entities listed. Each of the listed entities are committed to protecting your privacy and are joint data controllers within the meaning of data protection laws applicable in the European Union (EU) and European Economic Area (EEA).
As data controllers, we have arrangements between us to ensure that we handle your personal data correctly and in accordance with data protection law. We have nominated a Data Compliance Officer within Vapouround (Orange Fox Media Ltd.). These arrangements reflect our respective roles and responsibilities in relation to you, and considers which entity is in the best position to fulfil each obligation to you. If you would like more information, you can contact us by emailing firstname.lastname@example.org Please insert My Data Protection in the subject field of your email. Alternatively, you can call 01332 650 239 and ask to speak with the Data Compliance Officer.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
We collect the personal data you freely provide to us as part of your registration to the Vapouround Club or Vapouround Magazine’s mailing list, and any further personal data you provide to update your details from time-to-time. This may include details like your name, address, place of residence, gender, date of birth, email address, landline and mobile phone numbers and perhaps other contact details relating to your role within the vape industry. As per our terms and conditions, registration of the Vapouround Club depends on proof of employment within the vape industry. Registration to our business-to-business database also requires age verification (18+) and a confirmation that you work within or on behalf of the vape industry.
We may also collect information about your preferences. We may ask you to provide us with information about your favourite e-liquids, hardware, juice ranges, manufacturers, vape shops and expos so that we may tailor our news, offers, competitions and membership boxes to your personal preferences, and about your marketing preferences so we can make sure that we are contacting you using your preferred method of communication.
Please note that in order for you to register with the Vapouround Club, we require the following:
– your name
– your email address
– a contact number
– your home address (for delivery of the membership box)
– your company’s name
– your company’s contact number
– your company’s address
– some bank details where VIP memberships are requested
When you are added to a mailing list, we will request your email address and possibly your name.
Please note: Credit / debit card details are processed through a secure third-party website which specialises in this area and are not stored on paper on the premises by Vapouround (Orange Fox Media Ltd).
You cannot register to become a member of the Club via social media. But you may see an option to register advertised on social media, which will include a secure link that will take you to our website where you can register.
If you have given us permission to do so, we will collect information about your approximate location based on your IP address with Google Analytics when you open emails.
We collect cookies from your mobile device when you visit a website associated with the Vapouround Club or one of our associated brands.
When we interact with you (for example, when you are using services we provide) we may learn certain details about you that do not fit into one of the categories above. We may record this information where it is necessary in order to ensure we can remember important details about you in future. We ensure that only a small number of authorised personnel within the Vapouround (Orange Fox Media Ltd) marketing department have access to this personal data and we will not use it for any purpose other than to build an ongoing relationship with you.
Throughout your membership we may – if you have given us your consent to market to you – ask for your feedback on certain items about your experiences with us, our mailing list content and whether you are likely to recommend the Club. The feedback we receive from you may affect the nature or volume of marketing material you receive from us where you have consented to receive such marketing material.
HOW WE USE YOUR PERSONAL DATA
We are processing your personal data to be able to provide you with the latest news, offers, giveaways, competitions and industry updates plus membership to and participation in the Vapouround Club and in particular to do the following:
• when we make Club members aware of special offers / upgrades / updates / events, we can tailor these to you to make sure you are sent the kinds of offers you will be most interested in
• when we think that as a valued member of our Club, you deserve a reward
In addition, we use your personal data:
• to manage and improve the Vapouround Club and the marketing content we communicate to you via email
• to better understand your behaviour in order to develop and improve the products contained in the membership box, so as to provide you with an enhanced Club experience;
• to analyse the effectiveness of our marketing and to help us provide more relevant offers, advice and information to you and other members;
• to build up a clearer picture of our members, both as a group and as individuals and thereby provide you with a seamless, relevant and consistent service;
• to provide you with information about events, special offers, promotions and other relevant matters concerning Vapouround Magazine and the goods which they sell and services they provide (if you have given your consent for us to do so);
• to advertise our magazine on social media to other people who may also be interested in what we have to offer (if you have given your consent for us to do so);
• to advertise offers or promotions made available by our third party partners (as set out under the Who We Share Your Personal Data With section) if you have given us your consent to do so;
• to provide any services which you may request or which we may offer as part of your Club membership;
• to ensure that the information we hold is kept accurate and up to date;
• (if we have your consent, where this is required by law) for research and analysis and in order that we may contact you on occasion for such a purpose or for the purpose of conducting surveys or focus groups; and
• to notify you about changes to our services
HOW LONG WE STORE YOUR DATA FOR
We will keep your personal data for as long as you continue to interact with us (for example, if you read or click on an email we send you, make a purchase from Vapouround, or attend an event we host or organise.) If we do not have any interaction with you for three years, we will attempt to contact you to see if you still want to be on our mailing list or be a Club member.
If we do not hear from you or if you tell us, at any time, that you no longer want to be on our lists or be a Club member, then we will delete your personal data from our records. This may mean you may no longer receive a membership box.
WHO WE SHARE YOUR DATA WITH
We share your personal data between ourselves – as we are identified in the About Us section – by having joint access to a central database shared by all Vapouround (Orange Fox Media Ltd.) entities. The Vapouround Club shares the personal data of its own Club members with Vapouround Magazine, by including it as part of our central database. This allows you as a Club member to benefit from a relationship with the Vapouround brand.
For the purposes set out above, we may also provide your personal data to our suppliers and processors who perform certain business services for us. We share your personal data with third parties who:
• process transaction information as outlined above, where you have signed up for the VIP membership package
• if you have given your consent for us to do so communicate with you on our behalf via email;
In addition, we may disclose your personal data:
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection; and
• to successors in title or replacement operators of all or part of our respective businesses.
THE LEGAL BASIS FOR US USING YOUR PERSONAL DATA
1. It is necessary for us to process your personal data for the performance of the contract between us in relation to Vapouround and the Vapouround Club.
2. In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:
• sending you marketing communications;
• advertising on social media platforms;
• using your location to deliver specific messaging and content to you; and
• using your location to monitor the effectiveness of our messaging.
3. In most cases, it is in our legitimate interests to collect and use the personal data referred to above (see What Personal Data Do We Collect About You? above) so that we can:
• provide you with a service that is as useful, enjoyable and beneficial to you as possible, including by personalising our contact with you, making sure we tell you about all the offers that relate specifically to your preferences, and contacting you using your preferred method of communication; and
• better understand our customer base so that we can improve our services and marketing activities (which could also benefit you).
When we rely on our legitimate interests in order to collect and use your personal data, we must consider whether those legitimate interests are overridden by your interests or your fundamental rights and freedoms by carrying out a legitimate interest assessment. We may continue only if we decide that your interests, rights and freedoms do not override our legitimate interests. We have undertaken a legitimate interests assessment to reaffirm this legal basis is suited to our mailing lists.
We have considered these matters, and where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not use your personal data unless there is another legal basis for us to do so (either that it is necessary for us to perform our contract with you, or on the basis of your consent). For example, we believe that collecting your location data may be intrusive, and so we will only do so with your consent.
What happens if you do not provide us with the personal data we request or ask that we stop processing your personal data?
If you ask that we stop using your personal data (see Your Rights above) then we may not be able to provide you with all the benefits of our mailing list or the Club.
HOW WE CONTACT YOU
The Vapouround Club and our mailing lists work best when we are free to communicate with you to share details of promotions, upgrades, rewards, giveaways, events and offers you might be interested in.
In order to provide you with the benefits of Vapouround, we may, if we have your consent, contact you by phone or email.
If you no longer wish to receive such or certain communications, you can let us know by emailing us at email@example.com with My Data Protection in the subject field. You may also choose to click unsubscribe on an email at any time and this will notify us that you wish to be removed from our mailing list. Your email address will be removed from such list and it will be placed on a list of unsubscribers, which we will never contact.
Please note that the legal basis for us carrying out automated decision making or “profiling” activity is that it is in our legitimate interests to do so, having taken into account whether your interests and fundamental rights and freedoms are overridden by this type of processing. See The legal basis for us using your personal data (above) for more information.
Requests to us
We are required by law to act on requests and provide information free of charge, except where your requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.
Please consider your request responsibly before submitting it. Please submit your request in writing to firstname.lastname@example.org We’ll respond as soon as we can. Generally this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
If you need to contact us for any reason (including to exercise any of your rights in relation to data protection as set out above) please send us your request by emailing email@example.com and put My Data Protection in the subject field. Alternatively, you may call 01332 650 239.