We are STAR LATITUDE (BVI) LIMITED
If you have any questions about this policy, including any requests to exercise your legal rights, please contact us at [marketing@elfpouches.com].
This policy was last updated on 29 April 2026.
Who is this policy for?
We do not sell products or provide services to children, nor do we market to children. If you are under the age of 18 you are not permitted to use our website, or access our products or services through any other available channel.
This policy covers consumers who are part of the ELF Nicotine Pouch User Survey.
How do you use my data?
When you fill in the survey questionnaire, we will collect your email address and your product feedback of ELF nicotine pouch. We collect and use this informationto:
- Administer the survey and follow up with you regarding your submissions, including follow-up communication and clarification of your product feedback where necessary.
- Conduct product category research, market insight analysis, product review and iteration, existing product optimisation, flavour tuning and upgrading, and new product R&D; to evaluate, iterate and enhance our products, formulas and overall user experience.
- Carry out data analytics and statistical reporting to analyse consumer preferences, collect professional user insights and optimise product and brand operation strategies.
- Generate aggregated, anonymised and non-identifiable survey findings for internal reporting, business decision-making and brand archiving.
- For legal brand marketing and promotional purposes: develop secondary content based on overall survey data and conclusions; reference the participant group as professional football athletes; use aggregated survey insights and product supporting materials across social media, media coverage, official website, blog and brand case showcases, without disclosing any personal identifiable information.
When you contact us either by phone, email, via our 'contact us' page or via social media, we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query. To send you marketing information. Where you have previously expressed an interest in our products (and not opted-out of marketing) we will use your name and email address to send you updates because it is in our legitimate interests to promote our other products and services we think you might be interested in.
Where you are a new customer and have opted in via our website to receive updates on our products including offers and promotions, we will process your personal data to provide you these updates in line with the preferences you have provided and will only use your personal data in this way with your consent.
You can withdraw your consent to marketing at any time by contacting us at [marketing@elfpouches.com] or, where relevant, by following the unsubscribe link in any marketing communication you receive from us.
Who do you share my data with?
Business partners, suppliers and subcontractors for the performance of the contract we enter into with them or you.Promotional events and marketing organisations, we do not sell data for marketing purposes, but may share your data with an event organiser or collaboration brand including where we run workshops with co-presenters and offer a promotion alongside a partner brand. We will always tell you before (usually on the event registration form) and you will be given the chance to opt-out before we do this.Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging your personal data with other companies and organisations for the purposes of fraud protection.Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.
Where do you store my data?
Your responses and data are collected through Google Forms, a service provided by Google LLC ("Google"). As stated in Google’s Privacy Policy, Google processes and stores data globally, including in the United States and other locations outside the UK and European Economic Area (EEA). For details on Google’s data practices, see their Privacy & Terms.
In addition, when working with third parties we may need to transfer your personal data outside of the UK and / or EU. Whenever we transfer your personal data outside of the UK and the EU, we ensure it receives additional protection as required by law. To keep this policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at support@ebclub.com for more information about this.
How long do you keep my data for?
We will only retain your personal data for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.
In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve our products and marketing.
What are my rights under data protection law?
You have various other rights under applicable data protection laws, including the right to:
- access your personal data;
- correct incomplete or inaccurate data we hold about you;
- ask us to erase the personal data we hold about you;
- ask us to restrict our handling of your personal data;
- ask us to transfer your personal data to a third party;
- object to how we are using your personal data; and
- withdraw your consent to us handling your personal data.
You also have the right to lodge a complaint with us or the Information Commissioner's Office, the supervisory authority for data protection issues in England and Wales. If you are based in the EU you can find your relevant supervisory authority here.
Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.