Privacy Policy
Cygnet London Limited ("Cygnet London", "we", "us", or "our") is committed to protecting your privacy and handling personal data with discretion and care, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Data Controller
The data controller responsible for your personal data is:
Cygnet London Limited
Email: william@cygnetlondon.com
Personal Data We Collect
We collect personal data only when you voluntarily submit an enquiry via our website or contact us directly. This may include your name, email address, telephone number, and any information you choose to include in your enquiry or correspondence.
We do not collect personal data through browsing, analytics, or tracking technologies.
Age Restriction
Our products and services relate to tobacco goods and are intended solely for persons aged 18 and over. We do not knowingly collect or process personal data from individuals under the age of 18. If we become aware that we have collected data from a minor, we will delete it promptly.
Legal Basis for Processing
We process your personal data on the following legal bases under Article 6 of the UK GDPR:
Legitimate interests: to respond to your enquiry and manage our business relationship with you, where this does not override your fundamental rights and freedoms.
Consent: where you have given clear consent for us to process your personal data for a specific purpose. You may withdraw consent at any time by contacting us.
Legal obligation: where we are required to process data to comply with a legal or regulatory requirement.
How We Use Your Data
Your information is used solely to respond to your enquiry, communicate with you regarding our products and services, manage and fulfil any orders or instructions, and comply with legal and regulatory obligations.
We do not use your data for marketing lists, automated profiling, or unrelated purposes.
Sharing Your Data
Your personal data is not sold, rented, or shared with third parties, except where required for legitimate business operations. Categories of third-party processors we may use include our website hosting provider, secure email and IT service providers, payment processing providers, and professional advisors such as accountants or legal counsel.
All third-party processors are required to handle your data in accordance with applicable data protection law. We may also disclose your data where required by law, regulation, or court order.
International Transfers
We do not routinely transfer personal data outside the United Kingdom. If any transfer is necessary, we will ensure appropriate safeguards are in place in accordance with the UK GDPR.
Data Retention
Enquiry data is retained for a period of 12 months from the date of either party's last communication, after which it is securely deleted, unless an ongoing business relationship exists or retention is required for legal, regulatory, or accounting purposes.
Transactional records relating to the sale or purchase of goods are retained for a minimum of six years in accordance with HMRC requirements.
Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures are reviewed periodically and updated as necessary.
Your Rights
Under the UK GDPR, you have the right to request access to your personal data, to request correction of inaccurate data, to request deletion of your data, to restrict or object to processing, to data portability where applicable, and to withdraw consent at any time where processing is based on consent.
To exercise any of these rights, please get in touch with us using the details below. We will respond to your request within one month.
You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk.
Contact
For data protection or privacy enquiries, please either contact:
Email: william@cygnetlondon.com
Email: lia@cygnetlondon.com