Privacy Notice



Welcome to The Cigar Club privacy notice.

The Cigar Club respects your privacy and is committed to protecting your personal data. This
privacy notice will inform you as to how we look after your personal data when you visit our
website (regardless of where you visit it from) and tell you about your privacy rights and how
the law protects you.


1. Important information and who we are


Purpose of this privacy notice

This privacy notice aims to give you information on how The Cigar Club collects and
processes your personal data through your use of this website, including any data you may
provide through this website when you complete our enquiry form.

This website is not intended for children and we do not knowingly collect data relating to

It is important that you read this privacy notice together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.


The Cigar Club is the controller and responsible for your personal data (collectively referred
to as “COMPANY”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy notice, including
any requests to exercise your legal rights, please contact the data privacy manager using the
details set out below.

Contact details

Our full details are: The Cigar Club, a company registered in England and Wales with
company number 0654146, registered office: 26 High Street Rickmansworth Herts WD3 1ER

Name or title of data privacy manager: Paul Futcher Email address:
Postal address: The Cigar Club PO Box 696 Rickmansworth Herts WD3 0GE Telephone
number: 01923 770066

You have the right to make a complaint at any time to the Information Commissioner’s
Office (ICO), the UK supervisory authority for data protection issues ( We
would, however, appreciate the chance to deal with your concerns before you approach the
ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes:

This version was last updated on 10th May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep
us informed if your personal data changes during your relationship with us.

Third-party links

This website 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. When you leave our website, we encourage you to read the privacy notice
of every website you visit.

2. The data we collect about you


Personal data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the identity has been
removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we
have grouped together follows:

Identity Data includes first name, maiden name, last name, title.

Contact Data includes email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices you use to access
this website.

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.

We also collect, use and share
Aggregated Data such as statistical or demographic data for
any purpose. 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. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data with your
personal data 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

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with
you and you fail to provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to provide you with goods
or services). In this case, we may have to cancel a product or service you have with us but we
will notify you if this is the case at the time.


3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, and Contact Data by filling in
forms or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:

complete our enquiry form on our website;

contact us by telephone or email to seek a quote; and

when you instruct us to provide services for you by telephone or email and you
become our client.

Third parties or publicly available sources. We may receive personal data about
you from various third parties as set out below:

Technical Data from the following parties:
        o analytics providers such as Google based outside the EU.


4. How we use your personal data


We will only use your personal data when the law allows us to. Most commonly, we will use
your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into
with you.

Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other
than in relation to sending third party direct marketing communications to you via email or
text message. You have the right to withdraw consent to marketing at any time by

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your
personal data, and which of the legal bases we rely on to do so. We have also identified what
our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on
the specific purpose for which we are using your data. Please
contact us if you need details
about the specific legal grounds we are relying on to process your personal data where more
than one ground has been set out in the table below.


Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To respond to your enquiry
raised using our enquiry form
on our website
(a) Identity
(b) Contact
(a) Necessary for our
legitimate interests (for
running a business)
To manage our relationship
with you which will include:

(a) Notifying you about
changes to our terms or
privacy policy
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
(a) Performance of a
contract with you

(b) Necessary to comply
with a legal obligation

To administer and protect our
business and this website
(including troubleshooting,
data analysis, testing, system
maintenance, support,
reporting and hosting of data)
(a) Identity
(b) Contact

(c) Technical
(a) Necessary for our
legitimate interests (for
running our business,
provision of administration
and IT services, network
security, to prevent fraud
and in the context of a
business reorganisation or
group restructuring exercise)

(b) Necessary to comply
with a legal obligation

To deliver relevant website
content and advertisements to
you and measure or
understand the effectiveness
of the advertising we serve to
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
(f) Technical
Necessary for our legitimate
interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing
To use data analytics to
improve our website,
products/services, marketing,
customer relationships and
(a) Technical
(b) Usage
Necessary for our legitimate
interests (to define types of
customers for our products
and services, to keep our
website updated and relevant,
to develop our business and to
inform our marketing strategy)
To make suggestions and
recommendations to you
about goods or services that
may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate
interests (to develop our products/services and grow
our business)



We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
what we think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from
us or purchased services from us and, in each case, you have not opted out of receiving that

Third-party marketing

We will get your express opt-in consent before we share your personal data with third party
for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by
contacting us
at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a service purchase, product/service experience or other


You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note that some parts of
this website may become inaccessible or not function properly. For more information about
the cookies we use, please see our
Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose. If you wish to get an explanation as to how the processing for the
new purpose is compatible with the original purpose, please
contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.


5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set
out in the table in paragraph 4 above.

External Third Parties, for further information please
contact us
Third parties to whom we may choose to sell, transfer, or merge parts of our business
or our 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.

We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.


6. International transfers

For general enquiries via our contact form on our website, we do not transfer your personal
data outside the European Economic Area (EEA).

We shall confirm in our terms of business to you when you become a client whether any
personal data will be transferred outside of the EEA, as this is dependent on the services you
purchase from us.


7. Data security

We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
we limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting

To determine the appropriate retention period for personal data, we consider the amount,
nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use
or disclosure of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable legal

When you leave us as a client, we shall agree a data retention period with you and after
expiry of this period, your personal data shall be deleted

9. Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that
we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though we may need to verify
the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have the
right to ask us to delete or remove your personal data where you have successfully exercised
your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable, at the time of
your request.

Object to processing of your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you
want to object to processing on this ground as you feel it impacts on your fundamental rights
and freedoms. You also have the right to object where we are processing your personal data
for direct marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios: (a) if you want us to
establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us
to erase it; (c) where you need us to hold the data even if we no longer require it as you need
it to establish, exercise or defend legal claims; or (d) you have objected to our use of your
data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you,
or a third party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform a
contract with you.

Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able to provide certain
products or services to you. We will advise you if this is the case at the time you withdraw
your consent.

If you wish to exercise any of the rights set out above, please
contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we may refuse to comply with your request in these

What we may need from you

We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is
a security measure to ensure that personal data is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further information in relation to
your request to speed up our response.

Time limit to respond

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 a number of
requests. In this case, we will notify you and keep you updated.

10. Glossary


Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests are overridden
by the impact on you (unless we have your consent or are otherwise required or permitted to
by law). You can obtain further information about how we assess our legitimate interests
against any potential impact on you in respect of specific activities by
contacting us.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before
entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it
is necessary for compliance with a legal or regulatory obligation that we are subject to.