Privacy Policy


Upswing – Privacy Notice


We collect and manage customer data as an essential part of our business. This notice explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, and how we keep it secure.


Privacy Policy – We do not store credit card details, nor do we share financial details with any 3rd parties


About Upswing


Founded in 2021, COOLLAB LTD, trading as Upswing, is an electronic company. We are a Limited Company registered in England and Wales, Company Registration Number 13542455.

We observe data protection legislation and are committed to protecting and respecting privacy and rights. Specifically, we act as a Data Controller regarding the information we gather and process.


We are registered with the Information Commissioners Office under registration number 13542455. If you have any comments or queries regarding the use of your data, they can be contacted as follows:


Address: Ground Floor, 26 Skylines Village, Limeharbour, London, United Kingdom, E14 9TS




What Information Do We Collect About You?


The information we will request from you includes but may not be limited to your:

Date of Birth
Telephone Number
Email Address


This information is required if you wish to join our membership scheme. It is also required to verify your age. You may provide us with this information verbally or in writing.

Please also be advised that when you visit our website, cookies will be used to collect information about you, such as your Internet Protocol (IP) address which connects your computer or mobile device to the Internet, and information about your visit, such as the pages you viewed or searched for, pages response times, and download errors for example. We do this so that we can measure our website’s performance and make improvements in the future. Cookies are also used to enhance our website’s functionality and personalization, including sharing data with third-party organizations. You can control this by adjusting your cookies settings.


Children and Minors Under 16

Our services are not aimed at children and minors under 16. As we deal with age-restricted products, we will not hold any data for a minor.


Collecting Your Personal Data

We collect your personal data in a number of ways, including but not limited to:


Submitting an online enquiry;
Following/liking or subscribing to our social media channels;
Taking part in any competition or promotion run on our website or through our social media channels;
By completing a questionnaire or survey via our website;
Asking a question or submitting your query or complaint via our website, email, or social media channels;
Posting information on our website or social media channels, for example, commenting or joining in discussions;
When you leave a review about us on, Google Reviews, or other media platforms.


How We May Use Your Details

Data Protection says that we are allowed to use and share your personal data only where we have a proper reason. The law says we must have at least one of these reasons:


Contractyour personal information is processed in order to fulfill a contractual arrangement
Consent – where you agree to us using your information in this way
Legitimate Intereststhis means the interests of Upswing managing our business to allow us to provide you with the best products and services in the most secure and appropriate
Legal Obligation – where there are statutory or other legal requirements to share the information


Here is a list of the ways we may use your personal information and the reasons we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.


  What We Use Your Personal Information For

 Our Reasons (Legal Basis)

 Our Explanation of Upswing Legitimate Interests


  Contacting you about your subscription to the Upswing Membership




  Contacting you with news and offers if you have subscribed to our mailing list through our website




  Contacting you in the event that you have a problem with a product purchased from us or other customer services functions regarding a purchase

Fulfilling a contract



  Process your orders

Fulfilling a contract



  To detect, investigate and report financial crime and fraud

Legal Obligation



  Contacting customers with news, offers, and new products that we think they might be interested in

Legitimate Interests

Developing and stocking products and services that attract and retain customers


  Conduct customer satisfaction surveys or invite you to provide product reviews

Legitimate Interests

Developing and stocking products and services that attract and retain customers and ensuring our customers have the best possible experience


  Ensuring our customers are above the legal age limit to purchase e-cigarette products

Legal Obligation



  Logistics planning, demand forecasting, management information, and research

Legitimate Interests

We use information about shopping habits and products bought to help us plan ahead and ensure we have the right products in the right place at the right time for our customers.


  Maintaining network and data security

Legitimate Interests

To maintain the security of our network and systems, this helps us keep your information safe



Who Has Access to My Personal Data?

Upswing operates a data protection regime to oversee the effective and secure processing of your personal data. Ordinarily, we will only use your information within Upswing; we will not share your information with third parties. However, we do hold all customer information in a cloud-based service with (EPOS NOW Ltd company no. 07666961). We also work with selected IT partners who help keep our website and systems up and running.


How Do We Protect Your Personal Data?

We will only ever use personal information to target individuals with marketing materials. We may use personalization to collect analytics to inform marketing and produce relevant content for the marketing strategy to enable it to enhance and personalize the customer experience.


We recognize that your information is valuable, and we take all reasonable measures to protect it whilst it is in our care.


We have exceptional technology and operational security standards to protect personally identifiable data from loss, misuse, alteration, or destruction. Similarly, we adopt a high threshold when it comes to confidentiality obligations; both internal and external parties have agreed to protect the confidentiality of all information, to ensure all personal data is handled and processed in line with our stringent confidentiality and data protection policies.


We use computer safeguards such as firewalls, data encryption, and other industry-standard security approaches. We also enforce physical access controls to our buildings and files to keep data safe.


All of our staff are trained on data protection best practices in line with GDPR; we also undertake regular refresher training to ensure staff understands their duty of care in maintaining trust, privacy, and security of your data.


How Long Do We Keep Your Data?

Your personal information will be retained, usually in computer or manual files, only for as long as necessary to fulfil the purposes for which the information was collected; or as required by law; or as long as is set out in any relevant contract you may hold with us; or until you opt-out of receiving news and updates.


Your Rights

Legal rights protect your personal data under the GDPR, which includes:


Right of access – to request access to your personal information and information about how we process it
Right to rectification – to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased
Right to restriction of processing – to restrict processing of your personal information
Right to data portability to electronically move, copy or transfer your personal information in a standard form
Right to object to object to the processing of your personal information
Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making, including profiling


For more information or to exercise your data protection rights, please get in touch with us using the contact details at the beginning of this notice.



If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer, who will investigate further. and you can contact them as follows:


Address: Ground Floor, 26 Skylines Village, Limeharbour, London, United Kingdom, E14 9TS



If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO). You can contact the ICO as follows:

Telephone: 0303 123 1113