Privacy Policy

Cigara  – Privacy Notice

As an essential part of our business, we collect and manage customer data. This notice explains when and why we collect personal information about you; how we use it, the conditions under which we may disclose it to others and how we keep it secure.

1.     About Cigara

EFF Marketing Limited, trading as Cigara, is a electronic cigarette retail company. We are a Limited Company registered in England and Wales, Company Registration Number 08190917.


We observe data protection legislation and are committed to protecting and respecting privacy and rights. Specifically, we act as a Data Controller in respect of the information gathered and processed by us.


We are registered with the Information Commissioners Office under registration number Z3129632. Our Data Protection Officer is Frazer Eden. If you have any comments or queries regarding the use of your data, they can be contacted as follows:


Address: GM House, Wilkinson Way, Blackburn, BB1 2EH                 


Telephone: 0843 538 4584

2.     What Information Do We Collect About You?

The information we will request from you is includes but may not be limited to your:


  • Name
  • Date of Birth
  • Address
  • Telephone Number
  • Email Address


This information is required if you wish to join our membership scheme. It is also required to verify your age. You may provide us with this information verbally, or in writing.


Please also be advised that when you visit our website, cookies will be used to collect information about you such as your Internet Protocol (IP) address which connects your computer or mobile device to the Internet, and information about your visit such as the pages you viewed or searched for, pages response times, and download errors for example. We do this so that we can measure our website’s performance and make improvements in the future. Cookies are also used to enhance our website’s functionality and personalisation, which includes sharing data with third party organisations. You can control this by adjusting your cookies settings.


All stores include CCTV monitoring, and therefore any information captured via this medium, will automatically be stored for up to 28 days.


2.1   Children

Our services are not aimed at children as we deal with age restricted products therefore we will not hold any data for a minor.

3.     Why Do You Need This Information?

The primary reason for asking you to provide us with your personal data is to allow us to offer you our membership scheme. This can include, but is not limited to:


  • Verifying your identity;
  • Verifying your age
  • To communicate with you;
  • Responding to any complaint made against us.

4.     Who Has Access to My Personal Data?

Cigara operates a data protection regime to oversee the effective and secure processing of your personal data. Ordinarily we will only use your information within Cigara; we will not share your information with third parties. However we do hold all customer information in a cloud based service with EPOS NOW Ltd company no. 07666961.

5.     Your Rights

Under the terms of data protection regulation, you have the following rights available to you:


5.1   Right to be Informed

This Privacy Notice fulfils our obligation to tell you about the ways in which we use your information.


5.2   Right to Access

You have the right to ask us for a copy of any personal data that we hold about you. This is known as a “Subject Access Request”. Except in exceptional circumstances (which we discuss and agree with you in advance), you can obtain this information at no cost. We will send you a copy of the information within 30 days of your request. If for any reason we are not able to comply with this timeframe, we will let you know the reasons why and confirm the date by which we will comply. 


A request for access to your personal data means you are entitled to a copy of the data we hold on you – such as your name, address, contact details, date of birth, information regarding your health etc. To make a Subject Access Request, please write to our Data Protection Officer Frazer Eden. They can be contacted as follows:


Address: GM House, Wilkinson Way, Blackburn, BB1 2EH


Telephone: 0843 538 4584


5.3   Right to Rectification

If any of the information that we hold about you is inaccurate, you can contact us and request that we correct it.


5.4   Right to Erasure or the ‘Right to be Forgotten’

From 25th May 2018, you can ask us to erase all personal information that we hold about you. Where it is appropriate that we comply, your request will be completed within 30 days.


5.5   Right to Object

You have the right to object to:


a)     The continued use of your data for any purpose listed in Section 3 above, for which consent is identified as the lawful basis for processing i.e. you have the right to withdraw your consent at any time.

b)     The continued use of your data for any purpose listed in Section 3 above, for which the lawful basis of processing is that it has been deemed as legitimate.


5.6   Right to Restrict Processing

If you wish us to restrict the use of your data because:

       i.         You think it is inaccurate but this will take time to validate;

      ii.         You believe our data processing is unlawful but you do not want your data erased;

    iii.         You want us to retain your data in order to establish, exercise, or defend a legal claim, or

    iv.         You wish to object to the processing of your data, but we have yet to determine whether this is appropriate.


5.7   Right to Data Portability

If you would like to move, copy or transfer the electronic personal data that we hold about you to another organisation, please contact our Data Protection Officer.


5.8   Rights Related to Automated Decision Making

Automated individual decision-making is a decision made by automated means without any human involvement. For example, the collection and analysis of data to gain insights in to behaviours and characteristic. Automated individual decision-making does not have to involve profiling, although it often will do.


This right does not apply if the automated decision is:


  • Necessary for entering into, or the performance of, a contract between you and Cigara;
  • Based on your explicit consent; or
  • Authorised by EU or UK law which also sets out suitable safeguards to the rights, freedoms and legitimate interests of the individual (e.g. for fraud and tax-evasion monitoring/prevention or to ensure the security and reliability of the services you provide to the individual).


If you would like to object to automated decision making without any individual involvement, and to the profiling of your data, please contact our Data Protection Officer.


6.     How Do We Protect Your Personal Data?

We recognise that your information is valuable and we take all reasonable measures to protect it whilst it is in our care.


We have exceptional standards of technology and operational security in order to protect personally identifiable data from loss, misuse, alteration or destruction. Similarly, we adopt a high threshold when it comes to confidentiality obligations; both internal and external parties have agreed to protect confidentiality of all information, to ensure all personal data is handled and processed in line with our stringent confidentiality and data protection policies.


We use computer safeguards such as firewalls and data encryption and annual penetration testing. We also enforce, where possible, physical access controls to our buildings and files to keep data safe.


7.     How Long Do We Keep It For?

Your personal information will be retained, usually in computer or manual files, only for as long as necessary to fulfil the purposes for which the information was collected; or as required by law; or as long as is set out in any relevant contract you may hold with us.


8.     Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate further. Our Data Protection Officer is Frazer Eden and you can contact them as follows:


Address: GM House, Wilkinson Way, Blackburn, BB1 2EH


Telephone: 0843 538 4584


If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO). You can contact the ICO as follows:


Telephone: 0303 123 1113



9.     Marketing Communications

We may contact you for the purpose of direct marketing. This means that we may use personal data collected in line with this Privacy Notice, to contact you about our products, services and events. These communications may be delivered by post, email or social media platforms. We will not send marketing communications via SMS or call you without your specific consent. We would never pass or sell your details to a third party.


9.1   Collecting Your Personal Data

We collect your personal data in a number of ways, including but not limited to:


  • Submitting an online enquiry;
  • Following/liking or subscribing to our social media channels;
  • Taking part in any competition or promotion run on our website of through our social media channels;
  • By completing a questionnaire or survey via our website;
  • Asking a question, or submitting your query or complaint via our website, email or social media channels;
  • Posting information on our website or social media channels, for example, commenting or joining in discussions;
  • When you leave a review about us on, Google Reviews or other media platform.

Whenever we collect your personal data, you will be provided the opportunity to ‘opt in’ to receiving marketing communications from us. We hope you find our communications useful, but if you choose not to receive such information, we confirm that this will have no effect on accessing our legal services.

9.2   How We May Use Your Details

The following are examples, although not exhaustive, of how we may use your personal information for our legitimate business interests:


  • Fraud prevention;
  • Direct marketing;
  • System security;
  • To monitor and record information relating to the use of our services, to include our website;
  • Identifying usage trends;
  • Enable business development including sending legal updates, publications and details of events;
  • Determining the effectiveness of promotional campaigns and advertising.


We may use your personal information for legitimate interests such as direct marketing or under reasonable expectation to provide you with information you would expect to receive or that would benefit or enhance our relationship with you. This information helps us review and improve our service.


9.3   Your Rights

You have the right to object to this processing. Should you wish to do so, please contact our Data Protection Officer, Frazer Eden. You can contact them as follows:


Address: GM House, Wilkinson Way, Blackburn, BB1 2EH


Telephone: 0843 538 4584


9.4   How We Protect Your Information

We will only ever use personal information to target individuals with marketing materials. We may use personalisation to collect analytics to inform marketing and produce relevant content for the marketing strategy to enable it to enhance and personalise the customer experience.