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Cookie Policy

Cookie Privacy Notice
Cuts Ice – Website cookies
This privacy notice was last updated on 24th May 2018.

1. What is the purpose of this Privacy Notice?
Your ‘personal data’ or ‘personal information’ is any piece of information that would allow us to identify you as an individual. The processing of personal data is governed by the EU General Data Protection Regulation (the “GDPR”) and national laws that implement the GDPR in each European Economic Area (“EEA”) country.

We take your privacy very seriously, and this document sets out what personal information we collect from you in relation to this service, how we intend to use it and what your rights in respect of that information are. By visiting our websites, you are accepting and consenting to the practices described in this Privacy Notice.

It is important that you read this Privacy Notice (together with any other privacy notice or fair processing notice we may provide you with on specific occasions when we are collecting or processing personal data about you) and we encourage you to keep copies of all such notices for your records.

Our websites are not intended for children and we do not knowingly collect data relating to children.

2. Who controls your personal information, and how do you get in touch?
The controller of your personal information is Cuts Ice Limited, a company incorporated and registered in England and Wales under company number 07512911 (“we”, “us”, “our”). Cuts Ice Limited is a member of the Cuts Ice group comprising many different legal entities. This Privacy Notice is issued on behalf of all companies in the Cuts Ice group. The Cuts Ice group owns many different brands, as follows, which you may interact with us through:


Should you have any query in respect of this Privacy Notice (including details of the group companies) or your personal information, you can contact us at the following:

 

Data controller

Cuts Ice Limited

Website

http://www.cutsice.com/

Address

Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW

Telephone

+44 208 960 6974

Email

privacy@cutsice.com

3. What information do we collect about you, and for what purpose?
Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your visit to the website. Cookies help us to learn which areas of our websites are useful and which areas need improvement.  We also use these files to provide access to marketing and re-marketing information.  These files contain a unique code to you and can be considered personal data under the GDPR.

4. How do we collect your personal information?
We collect your personal information through different methods, including:

  • Information you give us. You may give us your identity, contact and financial data when you fill in our contact forms, make a purchase from any of our websites or create an account with us.  We may store some or all information in encrypted format in a cookie on your computer.
  • Information we automatically collect about you. We may automatically collect technical data about your equipment, browsing actions and patterns as you interact with our websites. We collect this personal data by using cookies and other similar technologies.
  • Information we receive from other sources. We may receive personal data about you from various third parties and public sources. For example, we may receive:
    • technical data from analytics providers;
    • cookies that allow third party review or interaction with our website that have been saved on your computer from other websites you have visited; and
    • identity and contact data from selected business partners, data brokers or aggregators.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose if you cannot be identified in any way. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Please be aware that our websites may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you by electronic means or permitting our selected third parties to do so. You have the right to withdraw consent to marketing at any time by contacting us.

5. What is our legal basis for collecting and using your personal information?
We will use your personal information (i.e. the cookie) for different purposes depending on the cookie that we set on your system.  Each will be broken down to be clear on their purposes.
Essential / Session Cookies.   Essential cookies enable you to navigate our websites and to use its services and features.  Without these cookies our website will not perform as smoothly and you may lose connectivity to it, and we may not be able to provide our websites or certain services or features.  These cookies are:


Cookie name

Purpose

1st / 3rd Party Cookie

Legal basis

PHPSESSID

To store a simple message when a form is submitted that can be displayed on a different page.

For example, if an enquiry form is completed incorrectly, a message will be stored and presented to the user to indicate the errors in the submission.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional site to you

ageverification

To allow us to indicate if you are over 18 years old and eligible to use our websites and able to purchase products from us.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to indicate if you are over 18 and eligible to purchase our products

FRONTEND_CID

Information relating to the customer including cached information that has previously been used on the website

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional site to you

FRONTEND

The customer's session ID.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional site to you

verify

This cookie helps make sure that no other user can log in with your information. It’s also used to hold information regarding your session, including when you started your session, and other variable relevant to your choices.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional and secure site to you

3b900130939669
ee0f2656102bc9f0f5

The customer's session ID.

1st Party

We need this information for our legitimate interests as the controller of this data as it allows us to provide a functional site to you

Preference Cookies.  Preference cookies collect information about your choices and preferences, and allow us to remember location, language, screen reader or other local settings you have set in your system so that we can automatically adapt our websites to your preferences.  These cookies are:


Cookie name

Purpose

1st / 3rd Party Cookie

Legal basis

EXTERNAL_NO_CACHE

Indicates if caching is disabled or enabled.

1st Party

We need this information for our legitimate interests as the controller of this data to optimise our websites for your enjoyment.

persistent_shopping_cart

A link to information about the shopper's cart and viewing history.

1st Party

We need this information for our legitimate interests as the controller of this data to optimise our websites for your enjoyment.

Analytics Cookies.  Analytics cookies collect information about your use of our websites, and enable us to improve the way it works.  Analytics allow us to see which are the most frequently visited pages, how you use the site, or record any difficulties you may have.  We use the information to improve the site and optimise it for most users that we have.  It also allows us to ensure that there is enough capacity in the system to service your needs.  These cookies are:


Cookie name

Purpose

1st / 3rd Party Cookie

Legal basis

_gat

This is used by Google Analytics to be able to throttle request rates

3rd Party

We need this information for our legitimate interests as the controller of this data to perform analytics on our websites

_ga

This is used by Google Analytics to be able to distinguish users from each other

3rd Party

We need this information for our legitimate interests as the controller of this data to perform analytics on our websites

_gid

This is used by Google Analytics to be able to distinguish users from each other

3rd Party

We need this information for our legitimate interests as the controller of this data to perform analytics on our websites

6. What if you do not want to provide your personal information?
You do not have to provide your personal information to us. However, should you choose not to provide it, you may be unable to use our website and will not be able to request our assistance. Where we need to collect personal data by law or under the terms of a contract we have with you (e.g. if you try to buy anything from us) and you fail to provide it when requested, we may not be able to perform the contract we have or are trying to enter into with you and may have to cancel the product and/or service you have with us (but we will notify you at the time if this is the case).
You can choose whether to accept cookies by changing the settings in your internet browser.  Information about the procedure to enable or disable cookies can be found on your Internet browser provider’s website via its help menu or further information can be found at: http://www.allaboutcookies.org/manage-cookies/index.html.  However, if you disable this function, your experience on our websites may be reduced and some features may not work as intended.

7. How is your personal information protected?
We maintain strong physical, electronic and procedural safeguards to protect the confidentiality, integrity and availability of your personal information. We have taken appropriate security measures against illegal and/or unauthorised access to your personal information, and against the accidental loss of, or damage to, it.

8. Do we share your personal information with anyone?
Data is shared as part of the usage of the website with several parties outside of Cuts Ice that allow us to process your data.  These parties, and the purposes for sharing the data, are set out below:


Google

Google Analytics privacy policy can be found at: https://support.google.com/analytics/answer/6004245?hl=en

Microsoft

Microsoft provide our email service and when you use our contact us forms these will be
https://products.office.com/en-us/business/office-365-trust-center-privacy

Hosting providers

These provide the physical devices that we use to host the website and provide the connectivity so that you can access it.

PayPal / Payment service provider / Bank

If you purchase something from one of our e-liquid brand sites then to process your payment we may need to share information with our partners to process this payment.

Address / Age verification service

As our services are aimed at over 18’s we have a requirement to verify your address and age.  We will share information with our provider to ensure that you are eligible to purchase our products.

We may also need to share your personal information with the following in limited circumstances:

  • IT security providers;
  • Insurers;
  • External advisors (for example solicitors or auditors); and
  • Public authorities or law enforcement.

If we sell or buy (or plan to sell or buy) any business or assets or seek investment from a third-party investor, we may disclose your personal data to the investor or prospective seller or buyer of such business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

Any time we provide access to your personal information to someone else, we will ensure that it is adequately secured to protect your privacy and that they comply with the requirements of the applicable data protection legislation.

9. Will your personal information be transferred outside of the EEA?
If you are a resident of a country in the EEA, we may need to transfer your personal information outside of the EEA, for example where our data storage facilities or processing locations are in another country. 
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by putting adequate, legally-approved safeguards in place, including at least one of the following: 

  • we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

If you would like more information about our safeguards, please contact us using the details inserted in Section 2 above.
10. How long do we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we hold it for, including for the purposes of satisfying any legal, accounting or reporting requirements. In general, we will need to keep the information that we collect from you for the following periods of time:


Cookie Name

Retention period

Third party data privacy notice

PHPSESSID

24 hours

1st party so covered by this data privacy notice

ageverification

24 hours

1st party so covered by this data privacy notice

FRONTEND_CID

24 hours

1st party so covered by this data privacy notice

FRONTEND

24 hours

1st party so covered by this data privacy notice

verify

24 hours

1st party so covered by this data privacy notice

3b900130939669
ee0f2656102bc9f0f5

24 hours

1st party so covered by this data privacy notice

EXTERNAL_NO_CACHE

24 hours

1st party so covered by this data privacy notice

persistent_shopping_cart

24 hours

1st party so covered by this data privacy notice

_gat

1 minute

https://goog.le/cookies and https://goog.le/privacy

_ga

2 years

https://goog.le/cookies and https://goog.le/privacy

_gid

24 hours

https://goog.le/cookies and https://goog.le/privacy

We may sometimes need to keep a copy of your personal information for a longer period, for example in the event of an incident, to investigate a data breach or to comply with legal requirements. We will never keep your personal information for longer than we consider necessary.
In all cases, your personal information will be securely destroyed once the retention periods described above expire.

11. What are your rights in respect of your personal information?
You have rights in respect of the personal information we hold on you, including the right to ask us to:

  • inform you on how we collect and use it (this Privacy Notice is designed to do that);
  • rectify it if you believe that it is incorrect;
  • delete it (only to the extent you consented to us using it);
  • provide you with a copy of any information we hold on you;
  • request the transfer of it to you or a third party;
  • tell you about automated decision-making solutions that we use; and
  • restrict the processing of it e.g. stop processing or using it temporarily.

 

You can also object to our use of your personal information for our legitimate purposes at any time.

Should you want to exercise any of those rights, please contact us using the details set out in Section 2 above. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Out partners use automated decision making for the following reasons:

  • To decide if you are over 18 and able to purchase our products;
  • To process your payment card for your purchase to be approved.

 

Cuts Ice does not handle these processes directly and they are provided to us.  If you would like to know more about these processes and which companies to contact to find out how this data is processed then please contact us using the details set out in Section 2 above.

12. Will we do anything else with your information in the future?
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new, unrelated purpose, we will endeavour to notify you and communicate the legal basis which allows us to do so before starting any new processing.

The exception to this is where use of the personal information is required or permitted by law e.g. to a recall of any of our products, updated allergy advice or for another legal reason that may require us to contact you. In this case, we may process your personal information without your knowledge or consent.

13. You have the right to complain to us or our supervisory authority
You also have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office, which can be contacted at the following:


Supervisory Authority

UK Information Commissioner’s Office

Website

https://ico.org.uk/concerns/

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Telephone

0303 123 1113

Email

https://ico.org.uk/global/contact-us/email/

14. Changes to this Privacy Notice and your duty to inform us of changes
We may need to make changes to this Privacy Notice in the future (for example, to comply with new legal requirements).

Where that is the case, we will provide you with a revised Privacy Notice on our website, which you will be able to access. If required by law, we will seek your prior approval before revising this Privacy Notice.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.