1. Data Controller

The data controller for information collected through the United Cigar Influencer Association ("UCIA") platform and services is:

Cigar Holdings Ltd.
Registered in England and Wales
Email: [email protected]

This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our website, platform, and services (collectively, the "Services").

2. What Data We Collect

We may collect the following categories of personal data:

Account Information: Email address, password (stored as a hash), display name, and date of registration.

Profile Information: Full name, country, biography, avatar image, social media handles, website URLs, follower counts, years of experience, and cigar interests.

Application Data: Information submitted in your membership application, including social media links, content descriptions, and reason for joining.

User Content: Posts, comments, messages, images, and other content you create or share on the platform.

Usage Data: IP address, browser type, device information, pages visited, time spent on pages, referring URLs, and other analytics data collected automatically when you use the Services.

Communications: Correspondence with us, including support requests and feedback.

3. How We Use Your Data

We use your personal data for the following purposes:

Providing the Services: Creating and managing your account, processing membership applications, enabling platform features, and facilitating member communications.
Communications: Sending you important updates about the Association, your membership status, events, and platform changes. We may also send promotional communications with your consent.
Analytics & Improvement: Understanding how the Services are used, identifying issues, and improving the platform experience.
Safety & Security: Detecting and preventing fraud, abuse, and violations of our Terms of Service and Constitution.
Legal Compliance: Complying with applicable laws, regulations, and legal processes.
Collective Opportunities: Facilitating advertising, sponsorship, and promotional deals negotiated on behalf of members (aggregate/anonymized data only unless you specifically opt in).

4. Data Sharing

We do not sell your personal data to third parties.

We may share your data with:

Service Providers: Trusted third-party companies that help us operate the Services (hosting, analytics, email delivery). These providers are contractually bound to protect your data and use it only for the purposes we specify.
Other Members: Your profile information and User Content are visible to other members as part of the platform's functionality. Your private messages are only visible to recipients.
Legal Requirements: We may disclose your data if required by law, court order, or government regulation, or if we believe disclosure is necessary to protect the rights, property, or safety of Cigar Holdings Ltd., our members, or the public.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction.

5. Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Services. If your membership is terminated or your account is deleted, we will retain your data for a reasonable period necessary to:

Comply with legal obligations
Resolve disputes
Enforce our agreements
Maintain security and fraud prevention records

After the retention period, your personal data will be securely deleted or anonymized.

6. Your Rights (GDPR)

If you are located in the European Economic Area, United Kingdom, or other jurisdictions with applicable data protection laws, you have the following rights:

Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate or incomplete personal data.
Right to Erasure: Request deletion of your personal data, subject to legal obligations and legitimate interests.
Right to Restrict Processing: Request that we limit how we use your data in certain circumstances.
Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format.
Right to Object: Object to processing of your personal data for direct marketing or based on legitimate interests.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

You also have the right to lodge a complaint with your local data protection authority (in the UK, this is the Information Commissioner's Office — ico.org.uk).

7. Cookies & Tracking

We use essential cookies and similar technologies to:

Maintain your session and authentication state
Remember your preferences
Understand usage patterns and improve the Services

We do not use third-party advertising cookies. Analytics data is collected in aggregate form. You can control cookies through your browser settings, but disabling essential cookies may affect the functionality of the Services.

8. International Transfers

Our Services are hosted on Cloudflare's global network. Your data may be transferred to and processed in countries outside your country of residence, including countries that may not provide the same level of data protection. When we transfer data internationally, we implement appropriate safeguards including standard contractual clauses and reliance on adequacy decisions where applicable.

9. Children's Privacy

The Services are intended for individuals aged 21 years and older. We do not knowingly collect personal data from anyone under 21. If we become aware that we have collected data from a person under 21, we will promptly delete that information and terminate the associated account.

10. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include encryption of passwords, secure hosting infrastructure, and access controls. However, no system is completely secure, and we cannot guarantee the absolute security of your data.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to members via the platform or email with at least fourteen (14) days' notice. Your continued use of the Services after changes take effect constitutes your acceptance of the revised policy.

12. Contact

For questions, concerns, or requests regarding your personal data, please contact:

Cigar Holdings Ltd.
Data Protection Enquiries
Email: [email protected]