Privacy Policy

Introduction

1.1 Welcome to FREEPODS. This Privacy Policy explains what we do with your personal information when you visit freepods.co.uk (the “Website”), when you make a purchase with us online or by phone, and when you otherwise interact with us as a customer. It describes how we collect, use and protect your personal information, and how we comply with our legal obligations to you.

1.2 This Privacy Policy applies to our consumer customers. If you are not a consumer — for example, if you contact us in a business capacity — please get in touch and we will explain how we handle your information in that context.

1.3 For the purposes of UK data protection law, FREEPODS LTD, whose registered address is at 27 Old Gloucester Street, London, WC1N 3AX (“we”, “our” or “us”), is the “controller” of your personal information. This means we decide why and how your personal information is used, and we are responsible for protecting it. Our contact details are at Clause 14.

1.4 We may update this Privacy Policy from time to time. We will post any changes on this page and, where appropriate, notify you by email — see Clause 13 (Changes).

2. Information We Collect About You

2.1 We collect and use information about you when you use the Website or interact with us, in order to provide you with our products, services and customer support. This may include:

• information you give us directly, such as your name, contact details, delivery address, date of birth, your vaping or flavour preferences, your Subscription details and history, and login credentials;
• information about transactions and orders you place with us, including details of any Subscription you hold;
• correspondence between us, including emails, phone calls and webchat messages with our Customer Care team;
• details of any Loyalty Points you hold or use, where applicable;
• the content of any reviews you leave about our products; and
• details of any adverse reaction or incident you tell us about in connection with using our products (see Clause 2.3).

2.2 We also automatically collect technical information about your use of the Website, such as your IP address, device type, browser type, operating system, and pages visited, including through cookies and similar technologies. Please see our Cookie Notice for full details of the cookies we use, why we use them, and how you can manage your preferences.

2.3 Some of the personal information you provide to us, such as details relating to an adverse reaction or incident experienced while using our products, will include information about your health (“Health Data”). Health Data is a ‘special category’ of personal information under data protection law and we apply a higher standard of care to it. We use Health Data:

• where it is in our legitimate interests, and those of our customers, to evaluate and improve the safety of our products and processes, and to assist you with any adverse reaction or incident you report to us; and
• where it is in our legitimate interests to establish, bring or defend legal claims relating to a report of an adverse reaction or incident.

2.4 Some personal information is required for us to fulfil our contractual obligations to you, or to comply with the law — for example, we need to verify your age before we can sell vaping products to you (see our Age Verification Policy). If you choose not to provide certain information, we may not be able to process your order or continue our relationship with you.

2.5 We may also receive information about you from third parties, such as our age verification provider, our payment processor, and delivery couriers, in connection with fulfilling your order. We explain the purposes for which we use this information throughout this Policy.

3. How We Use Your Information

3.1 The lawful bases we rely on under data protection law, and the main purposes for which we use your personal information, are as follows.

Where you have provided CONSENT, we will rely on this to:

• send you marketing communications by email or SMS where you have opted in (see Clause 4);
• use personal information collected from non-essential cookies (see our Cookie Notice); and
• contact you with market research surveys, where you have agreed to this.

You may withdraw your consent at any time — see Clause 4 and Clause 12.

Where it is necessary to perform our CONTRACT with you, or to take steps you request before entering into a contract, we will use your information to:

• process and fulfil your order or Subscription, including billing, dispatch, pausing, amending and cancelling a Subscription;
• operate your account on the Website;
• administer our Loyalty Points programme, where applicable; and
• respond to any requests you make in connection with your order or account.

Where there is a LEGAL REQUIREMENT, we will use your information to:

• carry out age verification checks (see our Age Verification Policy);
• identify and authenticate you when you contact us or log in to your account;
• respond to requests from public authorities, the police, Trading Standards, or other regulators; and
• comply with a request you make in exercise of your rights under data protection law (see Clause 12).

Where it is necessary to protect your VITAL INTERESTS, we will use your information to:

• notify you of any product safety or recall issue.

Where we have a LEGITIMATE INTEREST, we may use your information to:

• analyse how the Website is used, and improve its content and performance;
• understand your product and flavour preferences, so we can provide a more relevant service;
• respond to your enquiries and provide customer support;
• prevent and investigate fraud and other criminal activity;
• enforce or protect our legal rights, including our Terms and Conditions; and
• carry out general administration, system security, and record-keeping.

3.2 Where we rely on legitimate interests, we have considered that our interests are not overridden by your own interests or fundamental rights. You can ask us for more information about this — see Clause 14.

4. Marketing

4.1 Vaping products are subject to strict UK advertising restrictions, including under the Tobacco and Vapes Act 2026. As a result, we keep electronic marketing communications about our products to a minimum, and any such communications we send will only be sent where the law allows and, where required, with your consent.

4.2 We will only send you marketing communications by email or SMS if you opt in to receive them, for example by registering for an account on the Website or signing up to our newsletter.

4.3 We may also send you account, order and Subscription-related communications (such as order confirmations, dispatch notices, and changes to your Subscription) which are necessary to provide our services to you. These are not marketing communications and you cannot opt out of them while you have an active order or Subscription with us.

4.4 You can withdraw your consent to marketing communications at any time by using the unsubscribe link in any marketing email, updating your preferences in “My Account”, or contacting our Customer Care team — see Clause 12 and Clause 14.

5. Use of Device and Software Usage Information

5.1 We may monitor your use of the Website and record information such as your IP address, operating system and browser type, for system administration and security purposes.

5.2 We collect aggregated statistics about visitors to the Website, such as traffic and sales patterns. This information does not identify you personally and we do not use it to build individual profiles.

6. Cookies

6.1 A cookie (and similar technologies) is a small data file placed on your device to allow a website to recognise you as a user when you return to it.

6.2 We use strictly necessary cookies, and other cookies only where you have consented to them. Please see our Cookie Notice for full details of the cookies we use, the purposes for which we use them, and how to manage your preferences.

7. Automated Decision-Making

7.1 We use automated checks to verify your age when you attempt to buy vaping products from us, as we are legally required to do — see our Age Verification Policy for further detail.

7.2 We do not make any other automated decisions about you that have a legal or other significant effect on you. If you believe an automated age verification decision about you is incorrect, please contact us — see our Age Verification Policy and Clause 14.

8. Sharing Your Information With Third Parties

8.1 We share your information only where necessary to provide our products and services to you, or where the law requires us to. We may share your information with:

• our age verification provider, in order to confirm you are aged 18 or over (see our Age Verification Policy);
• our payment processor, in order to process your payment securely. Your full card details are never revealed to or stored by us;
• delivery couriers, such as Royal Mail, Evri, Yodel or DPD, in order to deliver your order;
• IT and hosting providers, who support the operation of the Website;
• professional advisers, such as our lawyers, accountants and auditors;
• regulators and public authorities, including Trading Standards, the MHRA, and tax authorities, where we are required or permitted to do so by law;
• a prospective buyer of our business or its assets, in connection with any sale, merger or reorganisation of FREEPODS LTD (in which case we will let you know); and
• any other third party where we have your consent, or where we are required to do so to comply with a legal obligation, enforce our Terms and Conditions, or protect our rights, property or customers.

8.2 We require any third party we share your information with to keep it secure and to use it only for the purposes we have authorised, under a written data processing agreement where required by law.

8.3 We may also share non-personal, aggregated statistical data with third parties for analytics purposes.

9. Where We Store Your Information

9.1 We store your personal information in the UK. Some of the third parties described in Clause 8 may be located outside of the UK or the European Economic Area (“EEA”).

9.2 Where this is the case, we will only transfer your information where the transfer complies with data protection law — for example, because the destination country has been assessed as providing an adequate level of protection, or because appropriate contractual safeguards (such as the UK’s International Data Transfer Agreement or standard contractual clauses) are in place.

10. How We Safeguard Your Information

10.1 We take appropriate technical and organisational measures designed to protect your personal information from unauthorised access, misuse, loss or disclosure.

10.2 If you suspect any misuse, loss of, or unauthorised access to your personal information, please contact us immediately — see Clause 14.

10.3 The transmission of information over the internet is not completely secure. While we apply appropriate security measures, we cannot guarantee the security of information you send to the Website, and any such transmission is at your own risk.

10.4 The Website may contain links to other websites. We are not responsible for the privacy practices of any third-party websites, and we encourage you to read their privacy notices before submitting any personal information to them.

11. How Long We Keep Your Information

11.1 We keep information relating to your orders for as long as required by law (for example, for tax purposes) or as needed to deal with any dispute.

11.2 If you have an account with us, we will keep your personal information for as long as your account remains open. You can close your account at any time via “My Account” on the Website, or by contacting us.

11.3 If you are subscribed to our marketing communications, we will keep your information for as long as you remain subscribed. If you unsubscribe, we will keep a minimal record on our suppression list, to ensure we do not contact you again.

11.4 If you contact us with a complaint or query, we will keep your information for as long as is reasonably necessary to resolve it.

11.5 We may keep personal information for longer than the periods above where we reasonably believe we may need it to establish, bring or defend legal claims, or where the law requires us to. Once it is no longer necessary to keep your personal information, we will securely delete or anonymise it.

12. Your Rights

12.1 You have the following rights in relation to your personal information under data protection law:

• Right of access: you can ask us to confirm what personal information we hold about you, and to provide you with a copy of it.
• Right to rectification: you can ask us to correct any inaccurate or incomplete personal information we hold about you.
• Right to erasure: you can ask us to delete your personal information in certain circumstances, for example where it is no longer necessary for the purposes it was collected.
• Right to restrict processing: you can ask us to suspend our use of your personal information in certain circumstances, for example while we investigate a query you have raised.
• Right to object: you can object to our use of your personal information where we rely on legitimate interests, or where we use it for direct marketing.
• Right to data portability: you can ask us to provide certain information you have given us in a structured, commonly used, machine-readable format, or to transfer it to another organisation, where this is technically feasible.
• Right to withdraw consent: where we rely on your consent, you can withdraw it at any time, without affecting the lawfulness of anything we did before you withdrew it.
• Rights relating to automated decision-making: you can ask us not to rely solely on automated processing for decisions that significantly affect you, request a human review, or express your point of view — see Clause 7.

12.2 To exercise any of these rights, please contact us — see Clause 14. We may ask you for information to confirm your identity. Except in limited circumstances, we will respond within one month of receiving your request (or, if later, confirming your identity).

12.3 Some of these rights are not absolute and may not apply in every case. We will explain this to you if it applies to your request.

12.4 If you are unhappy with how we have handled your personal information, you have the right to complain to the Information Commissioner’s Office (“ICO”), the UK’s data protection regulator, at ico.org.uk or by calling 0303 123 1113. We would, however, appreciate the chance to address your concerns first, so please contact us in the first instance — see Clause 14.

13. Changes

13.1 We may update this Privacy Policy from time to time. Any changes will take effect 7 days after the date we post the updated version on the Website, or, where appropriate, from the date we notify you by email.

14. How to Contact Us

14.1 If you have any questions about this Privacy Policy, or wish to exercise any of your rights, please contact our Customer Care team:

Phone: 07344 295 958 (Monday – Friday, 9am – 5pm, excluding Bank Holidays)

Email: info@freepods.co.uk

Post: FREEPODS LTD, 27 Old Gloucester Street, London, WC1N 3AX

This Policy was most recently updated on 1st June 2026.