Effective Date: November 20, 2023


We respect your privacy. We are committed to safeguarding the privacy of our website visitors. https//recoovape.com website administration (hereinafter – «Website») is obliged to maintain your privacy on the Internet. Please read this document carefully as it sets out our «Privacy Policy» which informs you what we do with your Personal Data, whether we are providing you with news alerts or using your Personal Data as part of the research that we conduct for or statistical purposes. We pay great attention to securing the Data you provided to us. Our Privacy Policy is based on the Federal Decree Law No. 45 of. 2021 on Personal Data Protection (Law No. 45) (may for certain types of Personal Data processing, be subject to laws from other jurisdictions), General Data Protection Regulation (GDPR) of the European Union and similar laws. The purposes, for which we collect your Personal Data are: improvement of our service, communication with visitors to this site, newsletters, presenting the information requested by the user, and for other actions listed below.

This Privacy Policy applies to the Personal Data of visitors anywhere in the world who access or use this Website.

Personal Data storage and processing

We collect and process your Personal Data only with your willing consent. Depending on the relevant circumstances and the laws and obligations that apply in your location, we may collect some or all of the information below:

• Name and surname;

• Contact details (such as your e-mail address or mobile number);

• Country of residence;

• Category to which you belong (consumer, supplier / company, or other);

• Date of birth;

• Additional information that you provide us voluntarily;

• Technical Data (e.g. the IP address, device information, log information, location information).

We do not knowingly collect information from visitors to this Website under the age of eighteen. If we become aware that a minor has provided information, it will be immediately deleted from ours databases.

How do we collect your Personal Data?

We collect your Personal Data largely in three ways:

1) Personal Data that you provide us with. You can share your Personal Data with us in multiple ways, such as:

• By proactively contacting us, usually by phone, email, through our contact form or through social media; and / or

• Because we contact you, either by phone or by e-mail.

• By collecting information through the intervention of the (your) our representative.

We usually receive Personal Data such as your contact details, your name, the country of residence, your date of birth, etc.

2) Personal Data that we obtain from other sources. We may use other sources to obtain additional information about you, e.g. from third parties. An example of this is the information we via the Google Analytics tool. For example, Google Analytics Opt-out Browser Add-on can be found here. Usually, we so receive Personal Data such as information via a unique identifier (e.g. information about your activity on the Website).

3) Personal Data that we collect automatically. When you visit our Website, we collect technical Data by means of cookies such as the IP address your computer uses to connect to the internet, the type and version of your browser, your time zone setting, types and version of browser plugins, operating system and platform, including the type of mobile device you use, a unique device identifier, traffic Data, weblogs and other communication Data, and the resources that you access, and other technical information is saved in the database when you visit Website.

Why do we collect your Personal Data?

We collect, use and disclose your Personal Data for a number of reasons, including:

• to ensure that we can respond to any queries and contact you if you request us to do so;

• for storing your details (and updating them when necessary) on our database, so that we can contact you in relation to email news alerts or respond to any query you have asked us to answer;

• as part of the research that we conduct for statistical purposes;

• to administer our Website for internal operations, including troubleshooting, Data analysis, testing, research, statistical and survey purposes;

• to ensure the effective operation of software and IT services procured by us (including disaster recovery);

• for other reasons with your consent.

We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.

The Company's Sharing of Personal Data

We will share your Personal Data primarily to ensure we provide you with the most relevant and up to date news, content and events, or to ensure we can respond to any query quickly and expeditiously. The Company may share Personal Data with affiliated companies, service providers who act on our behalf, or others at your direction.

• Service Providers. The Company may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing Data, including Personal Data, in connection with your use of our services and delivering products to customers (including external consultants, investor relations service providers and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems). The Company service providers are obligated to handle Personal Data consistent with this Privacy Policy and according to our instructions.

• Tax, audit, or other authorities, when we believe that the law or other regulation requires us to share this Data (for example, because of a request by a tax authority or in connection with any anticipated litigation) or in order to help prevent fraud or to enforce or protect the rights and properties of the Company or its subsidiaries; or protect the personal safety of the Company employees, third party agents or members of the public.

• If the Company entity merges with or is acquired by another business or company in the future, we may share your Personal Data with the new owners of the business or company (and provide you with notice of this disclosure); and

• Circumstances may arise where, whether for strategic or other business reasons, the Company decides to sell, buy, merge or otherwise reorganise businesses in some countries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it from sellers. It is the Company’s practice to seek appropriate protection for personal information in these types of transactions.

We do not share, rent or trade your information with third parties for marketing or promotional purposes.

We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

Data storage, alteration, and removal

The user, who has provided to the Company with their Personal Data, has the right for their alteration and removal, as well as the right to recall the agreement to Data processing. Time, during which your Personal Data will be stored is: time the Personal Data is used that is necessary for the Website’s main activity. We will not keep your Personal Data for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation). After finishing with the processing of your Personal Data, the Website’s administration will permanently delete it. To access your Personal Data, you can contact the administration on: privacy@recoovape.com. We will be able to pass your Data to a third party only with your willing consent. If the Data was transferred to a third party, which is not associated with our organization, we cannot perform any changes to that Data.

Processing of visiting technical Data

Each time you use our Website, we may and often will automatically record your IP address, time of visit, browser settings, operational system, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting), traffic Data, weblogs and other communication Data, and the resources that you access, and other technical information is saved in the database when you visit Website. This Data is necessary for the correct display of the Website’s content and help us to better understand user behavior. It is impossible to identify the person of the visitor using this Data.

Children’s personal information

If you are a parent or a legal guardian of an underage child, and you know that the child has provided us with their personal information, please contact us on: privacy@recoovape.com. It is forbidden to enter Personal Data of underage users.

Marketing

We may collect your preferences to receive marketing information directly from us by email or SMS in the following ways:

• if you register for an account on the Website, we will ask you if you would like to opt in to receive marketing information directly from us;

• if you click on the link on our Website to sign up to our newsletter.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above at any time. Please see Your rights below for further details on how you can do this.

Cookies processing

We use cookie files for the correct display of the Website’s content and for the convenience of browsing Website. They are small files, that are stored on your device. They help the Website to remember information about you, such as in which language you use the Website and which pages have you already opened. This information will be useful in the next visit. Thanks to cookie files, the Website’s browsing becomes much more convenient. You can set up cookies reception and blocking in your browser yourself. Inability to receive cookie files may limit the functionality of the Website.

Alternatively, you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone, you will need to refer to your handset manual or network operator for advice.

What are the different types of cookies?

• Strictly Necessary.

These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. They allow you to navigate back and forth between pages without losing your previous actions from the same session. Since these cookies are necessary for the functionality of our Website, we do not need to ask for your consent to use them.

• Functional.

These cookies allow a Website to remember your site preferences and choices you make on the site including username, region, and language. This allows the Website to provide personalized features like local news stories and weather if you share your location and boost your overall user experience on our Website. The Data collected via these cookies is anonymous and these cookies do not track browsing activity across other Websites. Similarly, to strictly necessary cookies, we do not need to ask for your consent to use these cookies.

• Performance.

Performance cookies are cookies used specifically for gathering Data on how visitors use our Website, which pages of our Website are visited most often and whether the users get error messages on web pages. These cookies monitor only the performance of the Website as the user interacts with it. These cookies do not collect identifiable information on visitors, which means all the Data collected is anonymous and only used to improve the functionality of our Website. We also use these cookies to gather statistical Data on how our Website is performing in order to make improvements. Despite the anonymity of the Data collected we will seek your consent to the use of these cookies.

• Persistent cookies.

These cookies remain on your device when you close your Internet browser, and they are reactivated each time you visit the Website that originally generated this type of cookie.

• Session cookies.

These cookies are not permanently stored on your device. They are used to enhance your browsing experience on a Website, for example by enabling you to switch between websites without needing to log back in. Closing your Internet browser deletes all session cookies from your computer.

• Flash cookies.

These cookies are installed by websites that feature multimedia content; this requires Adobe Flash to be displayed. These speeds up the rate at which you can download content and save information.

Most browsers accept and maintain Cookies by default. Check the «Help» or «Setting» menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website, but this may limit your ability to access certain areas of the Website.

Links to other websites

Our Website may contain links to other websites, which are not under our control. We are not responsible for the content of these websites. We recommend you familiarize yourself with the privacy policy of every website that you visit, if such policy exists.

If you decide to access the linked third-party websites, you do so at your own risk. We do not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the contents of another website to which you may link from the Website.

Transfer of Personal Data

In order to conduct our operations or fulfil regulatory obligations, we must transfer the Personal Data described in this Privacy Policy to and from, and process and store it in, China and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. In all such cases, and generally for any processing operations, we take appropriate security measures to protect your Personal Data in accordance with this Privacy Policy.

Personal information is typically subject to the laws of the country in which it is held, and sometimes also the laws of other countries that have a connection to its processing, such as the source country. For this reason, your personal information may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of any of the countries where we (or the recipients of disclosures mentioned in Section 5) operate, pursuant to the laws of such countries.

However, this Privacy Policy applies to Company’s operations worldwide. To the extent that personal information is transferred from China, the European Economic Area («EEA») and the UK to any non-EEA members of our group or third-party processors who handle the information solely on our behalf, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with China and other Data protection laws to govern the transfers of such Data. For more information about these transfer mechanisms, please contact us as set out below.

Changes to the Privacy Policy

We may change this Privacy Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Privacy Policy, we will endeavour to provide you notice through the Website or by some other means, such as email. Your continued use of the Website after such notice constitutes your understanding of the changes. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

If your Personal Data, and more specifically, your contact information was entered incorrectly, we will not be able to contact you.

Security Precautions

We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your Personal Data.

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Data transmitted over the internet and we do not warrant the security of any information, including Personal Data, which you transmit to us over the internet.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Please raise your concern by contacting us using the Contact us section of the Website, in the first instance, and we will investigate the matter and update you as soon as possible on next steps.

Your rights

You have several rights regarding the Data that we process about you. These are explained in more detail below.

• Right to object.

You can always inform us of the special reasons why you wish to object to the processing of your Personal Data that is based on the public interests or legitimate interests. If these reasons outweigh these interests, we can stop processing. If we process your Personal Data to send e-mail notifications, you can always ask us to stop doing so without having to provide a special reason.

• Right to withdraw consent.

If the processing of your Personal Data for certain activities is based on your consent, you can withdraw this consent at any time. We will stop using your Data for that purpose.

• Right of access.

You can ask us at any time to obtain information about whether or not to process your Personal Data and, if necessary, request a copy of the relevant categories of Personal Data that we process about you, as well as the other information. Any access request generally comes at no cost to you, and we must respond within 1 (one) month unless provided otherwise by the Law No. 45 or other applicable laws. We may, where permissible, impose a reasonable fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.

• Right to erasure.

In certain circumstances you have the right to request that we "delete" your Personal Data. This is described in more detail in the Law No. 45.

• Right to restriction of processing.

You have the right to request us to restrict your Personal Data in certain circumstances in line with the relevant articles providing for such right set out in the Law No. 45 or other applicable laws, e.g. if you dispute the accuracy of the Personal Data we hold about you. A restriction of processing means that we may only temporarily store your Data unless you give permission to process your Data, in the context of a legal claim or in the public interests and legitimate interests. A restriction can be lifted afterwards. We will of course notify you before we lift any restrictions on the processing of your Personal Data.

• Right to rectification.

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• Right to Data portability.

In some cases, you can legally transfer your Personal Data to other service providers. In essence, this means that you can transfer the Data we hold about you to another third party. To this end, we provide you with your Data in a common and machine-readable format that enables you to transfer the Data. Another option is that we transfer the Data directly for you if this is technically possible. For more information about this right, see the Law No. 45.

• Right to file a complaint.

Feedback and final clauses

You can contact the Website administration regarding any questions related to Privacy Policy on: privacy@recoovape.com, or by filling a contact form specified in a corresponding section of this Website. If you do not agree with this Privacy Policy, you cannot use the Website. In this case you should avoid visiting our Website.

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