Privacy Policy

Published 27/01/2024, version: 1.0

1. WHO ARE WE AND WHY PRIVACY POLICY MATTERS?

Please take a few minutes to read the following text. At Freesmo Limited (we) we consider the protection of personal data of our visitors and customers (you) as an important and necessary part of our systems and processes. Safeguarding and preserving your privacy is one of our priorities.

This Privacy Policy explains how we process your data that you provide to us or that we collect about you while you visit our websites. All abbreviations that are used in Terms and Conditions are also applicable here.

We may amend this Privacy Policy from time to time, so please check back regularly. If we make significant change we will notify you in a manner commensurate with those changes, for example by email or through a notification on our websites. All changes are summarized in the last section.

2. WHO PROCESS YOUR PERSONAL DATA

The Controller of your personal data is our company Freesmo Limited, company number: 15249787, registered with Companies House and whose registered office is at 12 Palmyra Road, Bristol BS3 3HU, United Kingdom. You can contact us at the address of his registered office or by email info@freesmo.co.uk.

3. WHAT DATA WE PROCESS AND FOR WHICH PURPOSE?

3.1. Information that you provide to us:

We collect your personal data from order forms and other forms available on our websites, and through your account registrations.

Identification and administration data
Name, date of birth, login, password, shipping and billing address, phone and email address.
Data that you provide to us when you register to use our website, order the product on our websites or when you contact our customer care team.
Communication and order data
Personal data that you provide to us when you order products on our websites or when you contact our customer care team.
Product preferences and habits
Within the Freesmo Recommendations Model you will fill in some personal data on your smoking preferences and habits (e.g. number of cigarettes per day, your preferences in the Products, and flavours). We use this information to provide recommendations to you of the most suitable Products based on our previous research in the United Kingdom, as well as product details such as device and refill parameters, and ratings and reviews of devices and flavours. We do not consider the medical suitability of the recommendations. You can buy any, or none, of the recommended Products.
Marketing preferences
Your marketing choices, such as wheter you have consent or opted-out out of our marketing communications.

3.2. Information that we process about you / Cookies:

Please see the Cookies Policy.

Technical information
IP address that you use to connect to the Internet and our websites, your login information, browser type and version, operating system and platform.
Information about your visit
URL to/through/from our websites including date and time, products that were recommended to you, pages you viewed or page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
Technical information and the information about your visit we may process automatically with regards to each of your visits to our websites.

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

4. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The legal basis for the processing of your personal data is one of the following:

Performance of a contract with you (processing the orders of products, its delivery etc.)
Processing of your data is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Compliance with our legal or regulatory obligations.
Your consent, if you grant it.

You can revoke your consent at any point by an e-mail sent to info@freesmo.co.uk.

Purpose / Activity	Type of data	Lawful basis for processing of personal data
To register you as a new customer To create your user account	(a) Identification and administration data	Performance of a contract with you
To provide our service to you on your request	(a) Identification and administration data (b) Communication and order data	Performance of a contract with you
Age verification before delivery of nicotine products	(a) Identification and administration data (especially date of birth)	Compliance with our legal or regulatory obligations
To recommend you suitable products within Freesmo Recommendation Model	(a) Product preferences and habits	Performance of a contract with you
To process and deliver your order and provide you customer service (such as giving back the product) including: (a) Manage payments, fees and charges and refunds (b) Collect and recover money owed to us	a) Identification and administration data (b) Communication and order data	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include also notifying you about changes to our terms and conditions or privacy policy	(a) Identification and administration data	Performance of a contract with you Necessary to comply with a legal obligation
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identification and administration data (b) Technical information	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, customer relationships and experiences	(a) Technical information (b) Information about your visit (Usage of Websites) (c) Communication and order data	Where required, your consent Otherwise, necessary for our legitimate interests (develop our business and improve our products)
To send you marketing materials and for commercial communication To answer you to your questions	(a) Identification and administration data (b) Communication and order data (c) Marketing preferences	Where required, your consent Otherwise, necessary to comply with a legal obligation

5. HOW WE PROTECT YOUR PERSONAL DATA

We apply a number of security measures to protect your personal data that we process. These are technical security measures (security of virtual servers, access logging, secure storage of data, etc.) and organizational measures (restriction of access of employees in accordance with internal policies and procedures).

We may pass on your data to vendors who provide us with IT services and other support services including delivery of the products that you ordered. Some processors process your personal data in another country within the EEA. Our main vendors are:

IT vendors:
Creative OpCo s.r.o., the Czech Republic
Fulfillment company:
Huboo Technologies LTD, the United Kingdom and its delivery partners (especially FedEX, United Kingdom, and its subsidiaries/affiliates)
Payment processor:
PayPal UK Ltd
We use PayPal for the processing of payment transactions through its Payment Gateway, i.e. you share your personal data directly with PayPal. We do not have direct access to your payment details, we just have a possibility to accept online payments from you as our customer. PayPal will use payment details and your personal data for the correct execution of a payment and to be in compliance with legal obligations. Please see in more detail the Privacy Statement of PayPal at: https://www.paypal.com/uk/legalhub/privacy-full?locale.x=en_GB

7. WHERE YOUR DATA ARE STORED

Your data held by us are stored in the servers located within the European Economic Area, which the UK authorities have deemed to have adequate safeguards to protect your personal data.

8. HOW LONG DO WE KEEP YOUR DATA?

We retain your data for as long as necessary to fulfill the purposes for which we collected such data for. That includes also the purpose for fulfilling our legal, accounting or reporting requirements.

In general we consider the nature, amount and sensitivity of the personal data, the potential risk of harm from the unauthorized use or disclosure of your personal data, the purposes for which we process such data and whether we can achieve these purposes through other means, and the applicable legal requirements.

Type of data	How long do we keep them?
Identification and administration data	6 years after the person ceases being customer
Email address (marketing purposes)	As long as your consent is applicable and you do not opt out or withdraw your consent
Communication and Order data	6 years after the person ceases being customer
Product preferences and habits	Duration of the customer relationship
Technical information	2 years
Marketing preferences	As long as it remains relevant to the marketing activities and you do not withdraw your consent.

9. YOUR RIGHTS

To the extent guaranteed by data protection regulations, you may require us to access, update, correct or delete your personal data that we hold. You may also want to restrict our data processing, you may object to the processing, or exercise your right to data portability.

If you have already registered with us and created an account, you can amend and update your details directly in the account settings.

For processing for which we need your consent, you can revoke your consent to the processing of data.

To exercise any of the above-mentioned rights, contact us in writing at info@freesmo.co.uk. Please note that in some cases we cannot comply with your request e.g. we may be unable to delete some of your data due to legal and accounting duties.

You can file a complaint with the supervisory authority - Information Commissioner's Office (see https://ico.org.uk/).

Cookies Policy

Published 10/01/2024, version: 1.0

This Cookies Policy explains what information cookies collect, how we use it and why we process them and sometimes we also store them. We also describe how you can prevent such storing.

1. WHAT ARE COOKIES?

Cookies are small text files that can be used by websites for its operation or even to make your user's experience more efficient. These small files are downloaded to your device for such purposes.

2. HOW DO WE USE COOKIES?

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site (Essential Cookies). Your consent is not required. For all other types of cookies we need your consent. Our websites use different types of cookies. Some cookies are placed by third party services that appear on our pages.

We use cookies to personalize content and ads, and to analyse our traffic. We also share information about your use of our site with our advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

3. HOW CAN I DISABLE COOKIES?

You can choose to prevent the setting of cookies by checking the appropriate box in the Cookies Banner.

You can at any time change or withdraw your consent from the Cookie Banner on our websites or directly in the setting of your browser.

4. THE COOKIES USED ON THE WEBSITES

a) Essential cookies:

Essential cookies are strictly necessary for the operation of these websites. We do not need to ask for your permission to use them.

Name	Purpose	Expires	Third-party cookies
Next-auth (multiple cookies) 1. Host-next-auth.csrf-token 2.__Secure-next-auth.callback-url 3.Secure-next-auth.session-token.0 4.__Secure-next-auth.session-token.1	Logged in user’s session	End of session	No
i18next	Locale setting (language)	End of session	No

b) Analytics and marketing cookies and pixels (optional):

We use in particular the following cookies and pixel for which we need to collect your consent:

Name	Purpose	Expires
Google Tag	To manage the consents	1 year expiration
Google Analytics	For analytics of the websites	1 year expiration
Meta pixel	For analytics of the websites	28 days

The general data and information collected through the analytics and marketing cookies is stored in the log files of the server and concerns the following data :

browser types and versions used,
the operating system used by the accessing system,
the webpage from which an accessing system arrived on this Website (known as a referrer),
sub-websites that are accessed on this Website via an accessing system,
date and time of an access to the Website,
IP address,
internet service provider of the accessing system

When processing this usage data, we do not draw any conclusions as to you (the visitor). We need this data in order to

correctly deliver the content of the Website,
optimize the content of and the advertising for this Website,
ensure the permanent functionality of our IT systems and the technology underlying this Website

5. OUR CONTACTS

If you are looking for additional information, feel free to contact us per email on info@freesmo.co.uk.

1. Main cookies banner

We use cookies.
We use some essential cookies to make the service on the websites work.
We’d also like to use analytics and marketing cookies so we can understand how you use the service and make improvements.

2. When the user has accepted cookies

You’ve accepted additional cookies. You can change your cookie settings at any time.

3. When the user has rejected cookies

You’ve rejected additional cookies. You can change your cookie settings at any time.