1. Whose Personal Information Do We Collect
The Company collects personal information from a broad range of individuals in the context of our business activities, including from the following: consumers and customers; individuals that use, or otherwise access, our Site; individuals who visit our premises or facilities; representatives of our suppliers, customers, and other business contacts; employees, contractors and similar types of workers; individuals related to, or otherwise affiliated with, our Company’s employees or contractors; and, other individuals who may contact us.
2. The Types and Categories of Personal Information We Collect
We may collect personal information under a broad range of circumstances. Generally, we collect the following types of information directly from you:
- Identity data, such as your name, title, company/organization name, e-mail address, telephone number (i.e., office, mobile), and physical address (i.e., street, city, state, postal code, and/or country). In the event you visit one of our premises or facilities, we may need to collect and retain certain identity data (e.g., driver’s license) for safety or administrative purposes.
- Registration data, such as information provided by you when you register for an account to use our Site, including user names and passwords.
- Business contact data, such as information related to other employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we may conduct, or possibly conduct, business-related activities.
- Marketing and communications data, including your marketing preferences and your subscriptions to our publications.
- Transaction data, including orders for our products and services and details of payments to and from you, including purchase history and preferences. We do not collect or retain payment card information and use a third-party payment card processor to facilitate payment transactions.
- Job applicant data from those seeking employment with the Company, such as contact information (including name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resume, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; information related to the applicant’s background, criminal record, credit history and similar data; information provided about or by the applicant’s references or other third parties related to his or her employment history, skills, or qualifications; information related to previous applications to, or previous employment history with, the Company; and, potentially sensitive information including information about the applicant’s race, ethnicity, national origin, health (e.g., medical condition), and criminal convictions and offenses.
- Your feedback, including feedback from you about our Site as well as our products and services generally, which may include data gathered from any Company surveys in which you participate.
- Student data from individuals that participate in Lion University or other of our training programs, such as student’s identity data (describe above), courses taken, grades, attendance records, and other routine information pertaining to student activities.
When you do not provide personal information that the Company requests, we may not be able to provide you the requested service or complete a transaction, and you agree that the Company will not be liable or otherwise responsible for any actions resulting therefrom.
3. How We Collect Personal Information
Most often, we obtain personal information directly from the individual. For example, when individuals undertake the following activities, we generally collect their personal information:
- Use or access our Site and/or complete one of our web forms.
- Contact our customer service centers or request information from us in any other manner.
- Visit one of our stores, facilities, or premises.
- Submit an order to, or make a purchase or transaction with, the Company.
- Provide us personal or business contact information via a business card or through similar communications.
- Complete a survey or otherwise provide us feedback.
- Communicate with us via social networking websites, third party applications, or similar technologies.
- Visit one of our offices, premises, locations, or trade counters at an exhibition.
4. How We Use your Information
The Company may use personal information for several business and administrative purposes, or to further our legal or other business interests. Generally, we use personal information for the following reasons:
- Services and transactions. We may use your personal information to deliver services to you or carry out transactions you have requested, including, but not limited to, providing information on the Company’s products or services you have purchased or otherwise use, processing product orders, handling warranty claims, answering customer service requests, and facilitating the use of our Site.
- Marketing. In accordance with applicable laws and regulations, we may use your personal information to inform you of our products or services which may be of interest to you, and to otherwise communicate with you about offerings, events and news, surveys, special offers, and related topics. You are able to opt-out from marketing communications sent via e-mail at any time, free of charge, by using the “unsubscribe” link in any e-mail marketing materials you receive from us.
5. Sharing Information
- Enforcement and Business Interests. We may use the personal information we collect in order to detect, prevent and respond to fraud, intellectual property infringement, violations of our terms and conditions, violations of law, or other misuse of our Site, products, or facilities. We may use personal information to administer and protect our business and our Site, including system maintenance, support, reporting and hosting of data. We may, in our sole discretion, use personal information to promote, defend or protect our legal, regulatory, or business interests.
We do not knowingly sell or rent personal information that we have collected or retain about you to any other third-party for profit or any other purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of personal information because we do not engage in these practices. However, we may share your personal information with selected third parties in accordance with applicable law, including as set out below.
- Service Providers. We may share your personal information with other companies with whom we have contracted to provide services on our behalf, such as hosting websites, conducting surveys, processing transactions, facilitating our marketing activities, analyzing our Site, and performing analyses to improve the quality of our business, Site, products and services. We may also disclose your personal information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, including, but not limited to, posting employment opportunities, receiving and processing applications, obtaining employment verification, and background checks. The Company uses IMPACT for our website design and maintenance and Salesforce to provide certain IT services.
- Distributors and Business Partners. We may share your personal information with third parties that distribute our products to you and engage in similar routine business functions. The Company uses HubSpot to support our email and digital marketing programs.
- Business Restructuring. Circumstances may arise where the Company decides to sell, buy, divest, merge or otherwise reorganize our business in some countries. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.
- Disclosure for Other Reasons. We may disclose personal information if required or authorized to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property or, in urgent circumstances, to protect the personal safety of any individual. We may share your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, and business interests. We may also disclose your information upon your express consent.
In the event that you facilitate a transaction with the Company, or request information from, or otherwise engage with us, and such activities require the Company (in our reasonable judgment) to share your personal information with a service provider or other third party, you hereby direct the Company to intentionally disclose your personal information to the service provider or third party as described herein provided the service provider or third party does not, in its reasonable judgment, sell the personal information, unless that disclosure would be consistent with the law.
6. Legal Basis for Data Processing (European Economic Area only)
In order to comply with certain applicable data privacy laws, the Company is required to set forth the legal basis for the processing of personal information. In accordance with the purposes for which we collect and use personal information, as set out above, the legal basis for the Company’s processing of personal information will generally be one of the following, which are not mutually exclusive: for the performance of a contract that we have in place with you or other individuals, or to take steps at your request prior to entering into a contract; to support the Company or our third parties’ legitimate business interests (e.g., maintaining and promoting our business by providing customers with feedback opportunities, website security and auditing); to comply with our legal obligations; and, with your consent.
7. Links to Other Websites
8. Data Retention and Localization
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. However, no information system can be fully secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the Internet and wireless networks, and you provide us with any information and data at your own risk. The Company shall not be liable or otherwise responsible for any data incidents that may compromise the confidentiality, integrity, or security of your personal information. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a user ID and password to access the Site, you are responsible for maintaining the security and confidentiality of those log-on credentials and not revealing them to others. You must contact us immediately if you have to reason to believe that your user ID or password to our Site have been compromised.
10. No Data Collected from Children
Our Site is not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under sixteen (16) years of age with or without consent from their parents or guardians. If you are under the age of sixteen (16) you are hereby prohibited from using our Site or with providing us with your personal information, unless you can demonstrate affirmative authorization from your parent or legal guardian to do so.
11. Cookies, Analytics, and Online Ads
We use different analytic tools which serve the purpose of measuring, analyzing and optimizing our Site’s performance, supporting our marketing activities, and providing you with customized advertisements that could be of particular interest to you. In particular, we use tools and programs from the following sources:
- Google Analytics and Google Tag Manger. To see how you can opt-out of certain Google features and to better understand Google privacy practices, visit: Google Analytics Opt Out Link.
- We use MailChimp to provide us with real-time data analytics and insights to help track and personalize their marketing activities. For more information about MailChimp’s privacy practices, please see its website.
You can find more information about cookies, behavioral advertising, and online privacy by visiting the following website: www.allaboutcookies.org
12. Your Rights and Responsibilities
You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon any individual’s data privacy rights or privileges. If you provide the Company with any personal information about a third party, you expressly represent that you have the full right and authority to submit the information to the Company.
Depending on the jurisdiction in which you reside or the Company operates, you may have certain data protection rights. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. In the event you submit, or your authorized agent submits on your behalf, a data request, you (and your authorized agent) hereby acknowledge and agree, under penalty of perjury, that you are (or the authorized agent of) the consumer whose personal information is the subject of the request. If you make, or an authorized agent on your behalf makes, any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required under the law before addressing your request. The Company may require you to match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces, or categories of, personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein. We will respond to any data request within the timeframes required by law, and we may charge a fee to facilitate your request, where permitted by law. The rights afforded under data protection laws are not absolute, and the Company may be permitted to refrain from undertaking any action or changing its data processing activities, in response to a data request you submit to us.
Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an option to opt-out from receiving such communications from us in the future, which is how you can opt-out from receiving such communications.
California Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), certain California residents may have additional data privacy rights, such as the right to be notified about what personal information is collected about you, and our intended use and purpose for collecting your personal information. In some circumstances, California residents have the right to know and access the categories or specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months; the categories of sources from which the personal information is collected; and, the business or commercial purpose for which your personal information was collected, used, or disclosed, or sold. In addition, certain California residents have the right to request the Company transfer, to the extent feasible, personal information in certain forms and formats. California residents have the right to request that we (and any applicable service provider) delete/erase your personal information under certain circumstances. As set forth above, the Company does not sell personal information, including the personal information pertaining to minors under the age of sixteen (16). California residents have the right not to be subject to discrimination for asserting their rights under the CCPA, and we do not engage in such practices. California residents also have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes; however, we do not share personal information with third parties with whom we have reason to believe use such information for their own direct marketing purposes.
European Economic Area. To the extent permitted by the European Union (EU) General Data Protection Regulation (GDPR), and applicable EU Member State data protection laws, you may request the following: access to the personal information we hold about you; that inaccurate, outdated, or no longer necessary, information be corrected, erased, or restricted; and, that we provide your personal information in a format that allows you to transfer it to another entity. You also may withdraw your consent at any time if, and only if, we are solely relying on your consent for the processing of your personal information. You may object to our processing of your personal information where that processing is based on our legitimate interest. For purposes of clarity, we do not engage in any activity that subjects our survey participants, customers, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significantly results, impacting them. If you wish to exercise any of these rights, please contact us in accordance with the instructions provided below. If you believe our data processing does not comply with the GDPR or EU Member State law, you may be permitted to lodge a complaint with the competent Data Protection Authority, a list of which can be accessed at: https://edpb.europa.eu/about-edpb/board/members_en. We would however appreciate the chance to address your concerns, so please feel free to contact us regarding any complaint you may have.
Do Not Track. Some web browsers may transmit “Do Not Track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
13. Changes to the Policy
14. Contact Us
Email: infoEMEA@lionprotects.com (Subject Line: “Privacy Request”)
Interactive Web Form: Accessible at http://www.thevapelounges.com/privacy
Toll-Free Number: 1.800.548.6614
- For US and Non-EU Locations: The LION Group, Inc., ATTN: Privacy Matters, 7200 Poe Avenue, Suite 400, Dayton, OH 45414.
15. Effective and Amendment Date
- For EU Locations: The LION Group, Inc., ATTN: Privacy Matters, Industrieweg 5, 5111 ND, Baarle-Nassau, The Netherlands.