QOLA Nicotine Pouches - PRIVACY POLICY

Last Updated: 2025/5/7

1. Introduction

Welcome to QOLA Nicotine Pouches. This Privacy Policy explains how Sinovision Trading L.L.C. ("QOLA," "We," "Our," "Us"), a company established under the laws of Iraq, collects, uses, stores, shares, and protects your personal information when you visit or make a purchase from www.qolapouch.com (and any related subdomains), our social media pages, or other technology platforms (collectively, the "Platforms"). We are committed to protecting your privacy and handling your personal data in an open and transparent manner, in compliance with applicable Iraqi laws and regulations. By accessing or using our Platforms, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Platforms. This Privacy Policy should be read in conjunction with our Terms & Conditions of Use.

2. Information We Collect

We may collect and process the following types of personal information about you:

Information You Provide Directly: Your full name, email address (e.g., when you contact us at [email protected]), shipping address, billing address, and phone number. Account information (if you create an account), transaction information (details about purchases, payment information, order history), communications (information from customer service inquiries), and age verification information.
Information We Collect Automatically: When you access our Platforms, we may automatically collect certain information about your device and your interaction with our Platforms. This may include your IP address, browser type, operating system, referring URLs, pages viewed, links clicked, time spent on pages, and other usage statistics.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

To Provide and Manage Our Services: To process and fulfill your orders, including managing payments, shipping, and handling returns. To create and manage your user account (if applicable). To verify your age to ensure compliance with legal requirements. To communicate with you about your orders, account, and our services, including responding to your inquiries and providing customer support.
To Improve Our Platforms and Services: To understand how users interact with our Platforms to improve usability and customer experience. To develop new products and services. For data analysis, research, and auditing purposes.
For Marketing and Promotional Purposes: To send you information about new products, special offers, and other updates that we think may be of interest to you, provided you have opted-in to receive such communications. You can opt-out at any time.
To Comply with Legal Obligations and Protect Our Rights: To comply with applicable Iraqi laws, regulations, court orders, or other legal processes. To prevent fraud, misuse of our services, and ensure the security of our Platforms. To enforce our Terms & Conditions and other policies. To protect the rights, property, or safety of Sinovision Trading L.L.C., our customers, or others.

4. Legal Basis for Processing

While Iraqi law may not have a singular comprehensive data protection framework like GDPR that explicitly requires detailing legal bases for all processing, we generally process your personal data based on:

Your Consent: Where you have given us explicit consent to process your personal information for a specific purpose (e.g., for direct marketing).
Contractual Necessity: To perform our contractual obligations to you (e.g., to process your order and deliver products).
Legal Obligations: To comply with our legal and regulatory obligations under Iraqi law.
Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., for fraud prevention, improving our services).

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may share your personal information in the following circumstances:

Service Providers: We may share your information with trusted third-party service providers who perform services on our behalf, such as payment processing, order fulfillment and shipping, data hosting, website analytics, IT support, and customer service. These providers are contractually obligated to protect your information and are only permitted to use it for the specific services they provide to us.
Legal Requirements and Law Enforcement: We may disclose your information if required to do so by Iraqi law or in response to valid requests by public authorities (e.g., a court or a government agency).
Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Platforms of any change in ownership or uses of your personal information.
Protection of Rights: We may disclose information when we believe it is necessary to protect our rights, property, or safety, or that of our users or others, and to enforce our Terms & Conditions.

6. Cookies and Tracking Technologies

Our Platforms may use cookies (small text files placed on your device) and similar tracking technologies (like web beacons or pixels) to collect information about your browsing activities. This helps us:

Remember your preferences and settings.
Understand how you use our Platforms.
Improve our Platforms and provide a more personalized experience.
For analytics and advertising purposes (where applicable and with consent).

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of our Platforms. For more detailed information, please see our [Link to Cookie Policy, if you have a separate one, otherwise expand here].

7. Your Rights and Choices

Depending on applicable Iraqi law and your jurisdiction, you may have certain rights regarding your personal information. These may include:

Right to Access: The right to request access to the personal information we hold about you.
Right to Rectification: The right to request correction of inaccurate or incomplete personal information.
Right to Erasure: The right to request the deletion of your personal information under certain conditions.
Right to Restrict Processing: The right to request the restriction of processing of your personal information under certain conditions.
Right to Object to Processing: The right to object to our processing of your personal information under certain conditions, particularly for direct marketing purposes.
Right to Data Portability: The right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Right to Withdraw Consent: If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, or if you have questions about your rights, please contact us at [email protected]. We will respond to your request within the timeframes required by applicable law. We may need to verify your identity before processing your request.

You can opt-out of receiving promotional emails from us by following the unsubscribe instructions provided in those emails or by contacting us directly.

8. Data Security

We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, use, alteration, and disclosure. These measures are implemented in accordance with applicable Iraqi cybersecurity regulations and best practices. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

9. Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, and in compliance with Iraqi laws.

The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide services to you.
Whether there is a legal obligation to which we are subject.
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

When your personal information is no longer needed, we will securely delete or anonymize it.

10. International Data Transfers

If we transfer your personal information outside of Iraq (e.g., if our servers or third-party service providers are located in other countries), we will ensure that appropriate safeguards are in place to protect your personal information in accordance with applicable Iraqi legal requirements for such transfers. This may include relying on adequacy decisions, standard contractual clauses, or your explicit consent.

11. Children's Privacy

Our Platforms and products are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at [email protected].

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our Platforms after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

13. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data handling practices, or if you wish to exercise your rights, please contact us at:

Sinovision Trading L.L.C.

Email: [email protected]

Website: www.qolapouch.com