Privacy & Cookie Policy

Not Blowing Smoke Limited
understands that your privacy is important to you and that you care about
how your personal data is used. We respect and value the privacy of
everyone who visits this website,
(“Our Site”) and will only collect and use personal data
in ways that are described here, and in a way that is consistent with our
obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand
it. Your acceptance of this Privacy Policy is deemed to occur upon your
first use of our site and you will be required to read and
accept this Privacy Policy when signing up for an Account. If you do not
accept and agree with this Privacy Policy, you must stop using our site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:


means an account required to access and/or use certain
areas and features of Our Site;


means a small text file placed on your computer or device
by Our Site when you visit certain parts
of Our Site and/or when you use certain
features of Our Site. Details of the
Cookies used by Our Site are set out in
Part 14, below; and

“Cookie Law”

means the relevant parts of the Privacy and Electronic
Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is owned and operated by Not Blowing Smoke Limited, a Limited Company registered in
England under company number 10400046.

Registered address:
Not Blowing Smoke Limited,
23 Chiltern Drive,
Surbiton, Surrey,
United Kingdom,

Main trading address:
Not Blowing Smoke Limited,
21 Church Street,

VAT number: GB247624590.

Data Protection Officer: Owner & Data Controller.

Email address: [email protected]

Telephone number: 01483 861121.

Postal Address:
Not Blowing Smoke Limited,
21 Church Street,

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site.
Our Site may contain links to other websites. Please note
that we have no control over how your data is collected,
stored, or used by other websites and we advise you to
check the privacy policies of any such websites before providing any data
to them.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU
Regulation 2016/679) (the “GDPR”) as ‘any information relating to an
identifiable person who can be directly or indirectly identified in
particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables
you to be identified. Personal data covers obvious information such as your
name and contact details, but it also covers less obvious information such
as identification numbers, electronic location data, and other online

5. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to

a) The right to be informed about our or collection and use of your
personal data. This Privacy Policy should tell you everything you need to
know, but you can always contact us to find out more or to
ask any questions using the details in Part 15.

b) The right to access the personal data we hold about you. Part 13 will
tell you how to do this.

c) The right to have your personal data rectified if any of your personal
data held by us is inaccurate or incomplete. Please
contact us using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask us to
delete or otherwise dispose of any of your personal data that we have.
Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal

f) The right to object to us using your personal data for
a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided
personal data to us directly, we are
using it with your consent or for the performance of a contract, and that
data is processed using automated means, you can ask us
for a copy of that personal data to re-use with another service or business
in many cases.

h) Rights relating to automated decision-making and profiling. We do not
use your personal data in this way.

For more information about our use of your personal data
or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the
Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your
personal data, you have the right to lodge a complaint with the Information
Commissioner’s Office.

6. What Data Do We Collect?

Depending upon your use of Our Site, we
may collect some or all of the following personal and non-personal data
(please also see Part 14 on our use of Cookies and similar
technologies and our Cookie Policy):

  • Name;
  • Date of birth;
  • Address;
  • Email address;
  • Telephone number;
  • Business name;
  • Information about your preferences and interests;
  • IP address;
  • Web browser type and version;
  • Operating system;

7. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data.
This may be because the data is necessary for our
performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal
data may be used for any of the following purposes:

  • Providing and managing your Account;
  • Providing and managing your access to Our Site;
  • Personalising and tailoring your experience on Our
  • Supplying our products and services to you. Your personal details are required
    in order for us to enter into a contract with you.
  • Personalising and tailoring our products or services for you.
  • Communicating with you. This may include responding to emails or calls
    from you.
  • Supplying you with information by email or post that
    you have opted-in to (you may unsubscribe or opt-out at any time from
    your account or on any communication you receive from us.
  • Analysing your use of Our Site and gathering feedback
    to enable us to continually improve Our Site and your user experience.
  • Verifying your age through our trusted third parties upon registration.

With your permission and/or where permitted by law, we may also use your
personal data for marketing purposes, which may include contacting you by
email telephone, text message or post with information, news, and
offers on our products and services. You
will not be sent any unlawful marketing or spam. We will always work to
fully protect your rights and comply with our obligations
under the GDPR and the Privacy and Electronic Communications (EC Directive)
Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties (including Cloud IQ & AdButler) whose content appears on
Our Site may use third-party Cookies, as detailed below in
Part 14. Please refer to Part 14 for more information on controlling
cookies. Please note that we do not control the activities
of such third parties, nor the data that they collect and use themselves,
and we advise you to check the privacy policies of any
such third parties.

We use the following automated systems for carrying out
certain kinds of decision-making and profiling. If at any
point you wish to query any action that we take on the
basis of this or wish to request ‘human intervention’ (i.e. have someone
review the action themselves, rather than relying only on the automated
method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.

  • The following automated decision-making method(s) may be used:

We rely on ID3 to automatically verify the age of our customers to ensure
everyone who purchases from us is over 18 years old. We take your first
name, last name, date of birth and billing address to verify your age
against multiple sources.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in
light of the reason(s) for which it was first collected. Your personal data
will therefore be kept for the following periods (or, where there is no
fixed period, the following factors will be used to determine how long it
is kept):

  • Your data including, addresses, emails and phone numbers will be kept
    for a maximum of 6 months before its erased from our systems. By
    continuing use of your account held with us this 6 month period will
    automatically extend from the date you last used your account.
  • You always have the right to ask us to immediately erase your personal
    information from our systems and this will be completed within 24 hours
    of your request.

9. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data in the UK. This means
that it will be fully protected under the GDPR.

We share your data within the group of companies of which we are a part of. Where this involves the transfer of personal
data outside the EEA, our group ensures that personal data
is protected by requiring all companies within the group to follow the same
rules with respect to personal data usage. These are known as “binding
corporate rules”. More information on binding corporate rules is available
from the

European Commission

10. Do You Share My Personal Data?

We will not share any of your personal data with any
third parties for any purposes, subject to one important exception.

In some limited circumstances, we may be legally required
to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal
obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site,
you may be given options to restrict our use of your
personal data. In particular, we aim to give you strong
controls on our use of your data for direct marketing
purposes (including the ability to opt-out of receiving emails from us me which you may do by unsubscribing using the links
provided in our emails and, at the point
of providing your details [and by managing your Account).

11.2 You may also wish to sign up to one or more of the preference services
operating in the UK: The Telephone Preference Service (“the TPS”), the
Corporate Telephone Preference Service (“the CTPS”), and the Mailing
Preference Service (“the MPS”). These may help to prevent you receiving
unsolicited marketing. Please note, however, that these services will not
prevent you from receiving marketing communications that you have consented
to receive.

12. Can I Withhold Information?

You may access certain areas of Our Site without providing
any personal data at all. However, to use all features and functions
available on Our Site you may be required to submit or
allow for the collection of certain data.

You may restrict our use of Cookies. For more information,
see Part 14.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you,
you can ask us for details of that personal data and for a
copy of it (where any such personal data is held). This is known as a
“subject access request”.

All subject access requests should be made in writing and sent to the email
or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your
request is ‘manifestly unfounded or excessive’ (for example, if you make
repetitive requests) a fee may be charged to cover our
administrative costs in responding.

We will respond to your subject access request within 48
hours and, in any case, not more than one week of receiving it. Normally,
we aim to provide a complete response, including a copy of
your personal data within that time. In some cases, however, particularly
if your request is more complex, more time may be required up to a maximum
of three months from the date we receive your request. You
will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies
on your computer or device. First-party Cookies are those placed directly
by us and are used only by us. We use Cookies to
facilitate and improve your experience of Our Site and to
provide and improve our products and
services. We have carefully chosen these Cookies and have
taken steps to ensure that your privacy and personal data is protected and
respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your
computer or device. Third-party Cookies are those placed by websites,
services, and/or parties other than us.

Our Site uses analytics services provided by Google Analytics & CloudIQ
to collect and analyse anonymous usage information, enabling us to better
understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.

The analytics service(s) used by Our Site use(s) Cookies
to gather the required information. You do not have to allow us to use
these Cookies, however whilst our use of them does not pose any risk to
your privacy or your safe use of Our Site, it does enable
us to continually improve our Site, making it a better and
more useful experience for you.

In addition to the controls that we provide, you can
choose to enable or disable Cookies in your internet browser. Most internet
browsers also enable you to choose whether you wish to disable all Cookies
or only third-party Cookies. By default, most internet browsers accept
Cookies, but this can be changed. For further details, please consult the
help menu in your internet browser or the documentation that came with your

You can choose to delete Cookies on your computer or device at any time,
however, you may lose any information that enables you to access Our Site
more quickly and efficiently including, but not limited to, login and
personalisation settings.

It is recommended that you keep your internet browser and operating system
up-to-date and that you consult the help and guidance provided by the
developer of your internet browser and manufacturer of your computer or
device if you are unsure about adjusting your privacy settings. ]

15. How Do I Contact You?

To contact us me about anything to do with your personal
data and data protection, including to make a subject access request,
please use the following details (for the attention of DPO):

Email address: [email protected]

Telephone number: 01483 861121

Postal Address:
Not Blowing Smoke Limited,
21 Church Street,

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This
may be necessary, for example, if the law changes, or if we change our business in a way that
affects personal data protection.

Any changes will be immediately posted on Our Site and you
will be deemed to have accepted the terms of the Privacy Policy on your
first use of Our Site following the alterations. We recommend that you check this page regularly to keep


In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in the Klarna privacy policy.


UPON PURCHASE OF AN IQOS DEVICE: The personal data (Name, Address, Date of Birth, Email) we obtain from you in connection with your purchase of IQOS devices will be transferred to the UK importer of IQOS “heat-not-burn” (or heated tobacco) products and “HEETS” consumables, Philip Morris Limited (UK number 03619145). They will use your data to create your personal IQOS account on their website HERE, activate the 12-month warranty and for data analysis purposes. Any of your data will be held in accordance with their privacy policy, available HERE. Please contact us before you order your IQOS device should you wish to opt out of this process.