Privacy Policy

Published 22/12/2025, version: 2.0

1. WHO ARE WE AND WHY PRIVACY POLICY MATTERS?

Please take a few minutes to read the following text. At Freesmo Limited (we) we consider the protection of personal data of our visitors and customers (you) as an important and necessary part of our systems and processes. Safeguarding and preserving your privacy is one of our priorities.

This Privacy Policy explains how we process your data that you provide to us or that we collect about you while you visit our websites or use any other Freesmo tools, like AI Chatbot. All abbreviations that are used in Terms and Conditions are also applicable here.

We may amend this Privacy Policy from time to time, so please check back regularly. If we make significant changes, we will notify you in a manner commensurate with those changes, for example by email or through a notification on our websites. All changes are summarized in the last section.

2. WHO PROCESS YOUR PERSONAL DATA

The Controller of your personal data is our company Freesmo Limited, company number: 15249787, registered with Companies House and whose registered office is at 12 Palmyra Road, Bristol BS3 3HU, United Kingdom.

You can contact us by email at customers@freesmo.co.uk.

3. WHAT DATA WE PROCESS AND FOR WHICH PURPOSE?

3.1. Information that you provide to us:

We collect your personal data from order forms and other forms available on our websites and through your account registrations.

• Identification and administration data
  Name, date of birth, login, password, shipping and billing address, phone number and email address.

• Communication and order data
  Personal data that you provide to us when you order products on our websites or communicate with us or the AI Chatbot.

• Product preferences and habits
  Within the AI Chatbot and Freesmo Recommendation Model you will fill in some personal data on your smoking preferences and habits. We do not consider medical suitability.

• Marketing preferences
  Your marketing choices, such as consent or opt-out from marketing communications.

3.2. Information that we process about you / Cookies:

Please see the Cookies Policy.

• Technical information
  IP address, browser type and version, operating system and platform.

• Information about your visit
  Pages viewed, interactions, timestamps and referral URLs.

We use Hotjar to better understand user experience. Hotjar processes pseudonymised usage data. For details see Hotjar Support.

4. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The legal basis for the processing of your personal data includes:

• Performance of a contract
• Legitimate interests
• Legal obligations
• Your consent

You can revoke consent at any time via info@freesmo.co.uk.

5. HOW WE PROTECT YOUR PERSONAL DATA

We apply technical and organizational security measures including secure servers, access control and internal policies.

6. TO WHOM CAN WE SHARE YOUR DATA?

• IT vendors
  Creative OpCo s.r.o. (Czech Republic)

• Fulfillment
  IndeDrop and delivery partners (Royal Mail, FedEx)

• Payment processor
  Worldpay (UK) Limited

• Other
  Mailchimp, Twilio, Microsoft Azure, WhatsApp, Experian

7. WHERE YOUR DATA ARE STORED

Data are stored within the European Economic Area.

8. HOW LONG DO WE KEEP YOUR DATA?

9. YOUR RIGHTS

You may request access, correction, deletion, restriction, objection or portability of your data.

Contact us at customers@freesmo.co.uk.

You may complain to the Information Commissioner’s Office: https://ico.org.uk/

10. CHANGES TO PRIVACY POLICIES

Last update: 22.12.2025
Changes: 22.12.2025

Cookies Policy

Published 10/01/2024, version: 1.0

This Cookies Policy explains what cookies are and how we use them.

1. WHAT ARE COOKIES?

Cookies are small text files downloaded to your device.

2. HOW DO WE USE COOKIES?

Essential cookies are required for site operation. Other cookies require consent.

3. HOW CAN I DISABLE COOKIES?

You can manage cookies via the Cookies Banner or browser settings.

4. THE COOKIES USED ON THE WEBSITES

a) Essential cookies:

b) Analytics and marketing cookies:

5. OUR CONTACTS

Contact us at customers@freesmo.co.uk.