PRIVACY POLICY

Privacy policy of Freevap.ch, specialist in e-cigarettes and online e-liquids in Switzerland

Protecting your privacy and data is very important to Freevap. That's why we have updated our privacy policy, following the new European RGPD regulation. Our data protection commitment governs how we collect, use, disclose, transfer and store your personal data.

The responsible body : 

PLAYSURE SA
c/o Perreard de Boccard SA, avocats Rue du Mont Blanc 3
1201 Geneva, Switzerland.

Entry in the commercial register : 31-07-2013
Commercial register number : CH-660.2.098.013-4.
IDE/VAT : CHE-189.704.451

SA Playsure with a capital of CHF 100 000.

E-mail : [email protected]

Person in charge of data protection :

Rémy PIGNIER

Please take the time to familiarize yourself with our privacy practices and feel free to contact us if you have any questions.

1. Data collection, processing and use


1.1 Data collection

We collect the personal data you provide to us when you create an account or place an order. You may be asked to give us your name, delivery and billing addresses, telephone numbers, email addresses and date of birth. When you purchase a product from our site, we collect information about your order such as what products you purchased, when you purchased them, and what type of payment you used. We keep this data for the legal period of time permitted for the purposes for which it was collected. 

When you browse our website we may also collect anonymous data such as the type of device you used to get to the site, the browser you used, your browsing behaviour such as the number of pages you visited and information about how you arrived at the site: for example via a search engine or by clicking on an advertisement. We may also collect your IP address.

When you sign up for our newsletter, enter a competition, complete a customer survey or participate in promotions we may collect your personal information or your comments or contributions when you answer questions. We may collect details of any email communication we send to you that you open or click on, including links you click on. We may collect any information you provide to us when you contact us by email, telephone, post or social media. 

Sensitive data is not sought by this site. Sensitive data includes data relating to: race or ethnic origin, political opinions, religious or related beliefs, mental or physical health. If you provide sensitive data, by providing it you explicitly consent to it being used for the purposes for which it was provided.

When you submit your personal data, your consent is requested for us to use it for the purposes highlighted in this Privacy Policy and our Terms and Conditions. We only collect the information you give us: if you do not want us to collect your personal data, please do not provide us with such information. The information we ask for in order to process an order is essential to that processing: if you do not provide us with this information we reserve the right not to accept your order. 

1.2 The use of data

We use the personal data we collect to process your transactions and manage your account in order to provide you with the goods and services you purchase or wish to purchase, to assist you in placing an order or to communicate with you when your order is in progress or being prepared. We use your personal data to respond to requests, questions or comments you have made, to administer promotions, competitions, customer surveys and questionnaires and to inform you of important changes to our site and services.

We use the anonymous data we collect and compile anonymous customer data for internal business purposes such as generating statistics or understanding how you use our site. We may use this data to improve our website and add new features.

If we have collected your IP address, it may be related to your browsing (e.g. products added to your shopping cart) to help us fix bugs or problems on our site, or to help us fight fraud. We may use your IP address to identify the country or city where you are located in order to send you personalised messages relevant to you.

1.3 Data sharing

We will never share your data with third parties outside of Freevap without your prior consent, except as required or permitted by law, and with the exception of our service providers (in particular logistics) or successors in title to our business.

We work with carefully selected service providers who manage certain services on our behalf, such as delivering orders, processing payments, hosting and developing our website and sending emails. These companies may process your personal data in order to carry out the services requested on our behalf.

2. Your rights

2.1 Right to information and rectification

You can request information about your data processed by Freevap. If your data has changed, you can request a correction of the data. Even if your data is not complete, you can request that it be completed. If we have passed on your data to third parties, we will ensure that your data is corrected/completed there (in accordance with current legal provisions).

2.2 Right to have personal data deleted

Deletion of your personal data may be necessary:

  • - If the personal data is no longer required for the purpose of data collection.
  • - If consent to data processing has been revoked or if there is no legal basis for data processing or if there is no overriding interest worthy of protection.
  • - If the data has been processed incorrectly.
  • - If the data must be deleted due to legal requirements.

Please note in this context that the right to cancellation may depend on the existence of an actual thread that continues to require the processing of the data (for example, compliance with legal retention requirements).

2.3 Right to limit data processing 

You can request that the processing of your personal data be restricted:

  • - If the accuracy of your personal information is disputed and we have satisfied ourselves that it is accurate.
  • - If the processing of the data is unlawful and you prefer restriction rather than deletion.
  • - If the data is no longer required, but is needed to enforce legal rights.
  • - If there is a conflict with the data processing, the data processing is restricted until it is determined whether your interests in the data processing are outweighed.

2.4 Right of appeal

If you have a complaint, you can contact Freevap's data protection officer or the competent data protection authority.

The GDPR gives you the right to lodge a complaint with the CNIL:

CNIL
3 Place de Fontenoy – TSA 80715
75334 Paris Cedex 07
Phone : 01 53 73 22 22

2.5 Right to object to data processing

You have the right to object at any time to the processing of your personal data in accordance with Article 6(1)(f) of the new EU GDPR regulation which corresponds to processing data on the basis of a balance of interests.

If you object to the processing of your data, Freevap will no longer process any personal data unless there are interests worthy of protection for Freevap, which make the processing of the data necessary and which outweigh your interests or the data enforcement, assertion or defence of legal rights are necessary.

In the event of a discrepancy, please contact Freevap's Data Protection Officer immediately (contact details can be found in this privacy policy).

2.6 Right to access your personal data

If you have created an account when purchasing from our website, please log in to your account - 'My Account' section on the website and then click on the 'My Personal Data' icon to gain full access to your personal data.

Please note that we are required to keep necessary commitment data (e.g. essential data associated with an order placed) for regulatory reasons.

We may disclose any data, including personal data, if we believe it is necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or current government request.

3. Cookies

We use cookies and similar technologies, such as tags and pixels ("cookies"), to personalise and enhance your customer experience when you use our website. Your consent is required when you visit our website for the first time to do this.

Cookies are small files stored on your computer when you browse certain web pages: we use the encrypted information they contain to enhance your experience on the site. For example, they help us keep track of the products you have added to your shopping cart, identify and resolve errors, and determine which products appear relevant to you as you browse. Please note that cookies cannot damage your computer. We do not store any personal or sensitive data such as bank details in cookies.

Cookies allow the site to function optimally. You may refuse or delete them using your browser settings. However, your user experience may be degraded. 

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