Privacy Policy

Last Updated: 1 October 2026

This Privacy Policy describes how OLO Pouch Mart (“OLO Pouch Mart”, “we”, “us” or “our”), collects, uses, stores and discloses personal information when you visit our website, create an account, place an order, communicate with us or otherwise use our website, products and related services (collectively, the “Services”).

We are committed to protecting your privacy and handling personal information responsibly and in accordance with applicable privacy laws.

We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances, and with your knowledge and consent, except where otherwise permitted or required by law.

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy.

Nothing in this Privacy Policy limits any rights available to you under applicable data protection or consumer protection laws.

1. PERSONAL INFORMATION WE COLLECT

“Personal information” means information that identifies you or can reasonably be linked to you.

Depending on how you interact with us and the Services you use, we may collect or process the following categories of information:

Contact Information

Including:

  • name;
  • email address;
  • telephone number;
  • billing address; and
  • shipping address.

Account Information

Including:

  • username;
  • password or authentication credentials;
  • account preferences;
  • saved addresses; and
  • account settings.

Passwords are generally stored in encrypted or hashed form through our website or authentication service providers.

Order and Transaction Information

Including:

  • products viewed or purchased;
  • shopping-cart contents;
  • order history;
  • returns, cancellations or refund information;
  • transaction amounts; and
  • delivery information.

Payment Information

Payments may be processed by third-party payment service providers.

Depending on the payment method used, payment-related information may include:

  • payment method;
  • billing information;
  • transaction reference;
  • payment status; and
  • limited payment-card information provided to us by our payment processor.

We generally do not directly store complete payment-card details where payments are processed by an independent payment provider.

Age and Identity Verification Information

Because we sell age-restricted products only to persons aged 21 or older (or the legal age in their jurisdiction, whichever is higher), we may process information reasonably necessary to confirm that you are at least 21 years of age.

This may include:

  • date of birth;
  • age confirmation;
  • verification status; and
  • where required, identification information processed for age or identity verification.

Where we use a third-party age-verification provider, that provider may process verification information on our behalf or in accordance with its own privacy notice.

We aim to collect only the information reasonably necessary to complete age verification.

Communications

We may collect information contained in communications between you and OLO Pouch Mart, including:

  • customer-service requests;
  • complaints;
  • refund or replacement requests;
  • email correspondence; and
  • other information you voluntarily provide.

Device and Technical Information

When you access our Services, we may automatically collect information including:

  • IP address;
  • browser type;
  • device type;
  • operating system;
  • device identifiers;
  • approximate location derived from IP address;
  • referring website; and
  • other technical information.

Website Usage Information

We may collect information about how you interact with our website, including:

  • pages viewed;
  • products viewed;
  • searches;
  • links clicked;
  • shopping-cart activity;
  • session information; and
  • date and time of website activity.

2. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

Directly From You

For example, when you:

  • create an account;
  • place an order;
  • enter billing or delivery information;
  • contact customer service;
  • subscribe to marketing communications;
  • submit a review; or
  • participate in a promotion.

Automatically

We may collect information automatically when you access or use our website through cookies, pixels, log files and similar technologies.

From Service Providers

We may receive information from third parties that assist us with:

  • payment processing;
  • age verification;
  • hosting;
  • fraud prevention;
  • order fulfilment;
  • shipping;
  • customer support;
  • analytics; and
  • marketing.

From Other Third Parties

Where permitted by applicable law, we may also receive information from business partners, advertising platforms, social-media platforms and other lawful sources.

3. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes.

Providing Our Services

We use information to:

  • process and fulfil orders;
  • process payments;
  • arrange delivery;
  • create and maintain customer accounts;
  • provide order notifications;
  • process cancellations, refunds or replacements;
  • remember preferences; and
  • provide customer support.

Age and Eligibility Verification

We may use personal information to:

  • confirm that customers are at least 21 years of age;
  • prevent purchases by minors;
  • comply with laws governing age-restricted products; and
  • investigate suspected attempts to circumvent age restrictions.

Security and Fraud Prevention

We may use personal information to:

  • authenticate accounts;
  • detect fraudulent transactions;
  • prevent unauthorized activity;
  • protect our website and systems;
  • enforce our Terms of Service; and
  • protect customers and our business.

Marketing and Advertising

Where permitted by applicable law, and only with your consent where required (for example, when you tick a box to subscribe to our newsletter), we may use personal information to:

  • send promotional emails;
  • send marketing communications;
  • inform you about products, promotions or offers;
  • measure advertising effectiveness; and
  • display relevant advertising.

Every promotional email we send identifies OLO Pouch Mart, includes our contact information and contains a working unsubscribe link. You may unsubscribe or withdraw your consent to promotional emails at any time, free of charge, using that link or by contacting us. We will give effect to your request promptly, and in any event within 10 business days.

Opting out of promotional communications does not prevent us from sending transactional or service-related messages, such as order confirmations, delivery notices or important account information.

Improving Our Services

We may use personal information and aggregated information to:

  • understand website usage;
  • analyse customer preferences;
  • improve website functionality;
  • improve our products and services; and
  • troubleshoot technical issues.

Legal and Regulatory Compliance

We may process personal information where reasonably necessary to:

  • comply with applicable laws and regulations;
  • respond to lawful requests from authorities;
  • establish, exercise or defend legal claims;
  • comply with tax and accounting requirements;
  • investigate suspected violations of our policies; and
  • meet regulatory obligations relating to age-restricted products.

4. COOKIES AND TRACKING TECHNOLOGIES

We may use cookies, pixels and similar technologies to operate and improve our website.

These technologies may be used for purposes including:

  • keeping the website functioning;
  • maintaining shopping-cart sessions;
  • remembering preferences;
  • security and fraud prevention;
  • website analytics;
  • measuring website performance; and
  • advertising and marketing.

Some cookies are necessary for the operation of the website, while others may be optional depending on applicable law.

Where required by law, we will request your consent before using non-essential cookies.

You may be able to control cookies through our cookie-consent tools or your browser settings. Disabling certain cookies may affect the functionality of the website.

For additional information, please refer to our Cookie Policy, where available.

5. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information where reasonably necessary to operate our Services.

Recipients may include:

Service Providers

Including companies that provide:

  • website hosting;
  • payment processing;
  • payment fraud prevention;
  • age verification;
  • analytics;
  • email services;
  • customer support;
  • IT and cybersecurity services;
  • fulfilment;
  • logistics; and
  • shipping.

These providers may process information only as permitted by applicable law and their contractual obligations.

Payment Providers

Payment information may be provided directly to payment processors, banks or other financial service providers in order to complete transactions and prevent fraud.

Delivery and Logistics Providers

We may share information such as your name, shipping address, telephone number and order-delivery information with couriers, postal operators and fulfilment providers.

Marketing and Analytics Partners

Where permitted by law, we may share limited information with analytics, advertising or marketing providers to measure website activity and advertising performance.

Where applicable law provides an opt-out or consent right, we will provide the appropriate mechanism.

Legal Authorities

We may disclose information where reasonably necessary to:

  • comply with applicable law;
  • respond to valid legal process;
  • cooperate with regulatory or governmental authorities;
  • investigate fraud or unlawful activity; or
  • protect our legal rights or the rights and safety of others.

Business Transactions

Personal information may be disclosed as part of a merger, acquisition, restructuring, financing, sale of assets, insolvency or similar business transaction, subject to applicable law.

6. THIRD-PARTY WEBSITES AND SERVICES

Our Services may contain links to websites or services operated by third parties.

We do not control the privacy or security practices of third-party websites.

If you follow a link to a third-party service, we encourage you to review that party’s privacy policy before providing personal information.

The inclusion of a third-party link does not necessarily constitute our endorsement of that service.

7. AGE-RESTRICTED SERVICES AND MINORS

Our Services and nicotine products are intended exclusively for adults who are at least 21 years of age, or the legal age in their jurisdiction, whichever is higher.

We do not knowingly sell nicotine products to minors or to anyone under 21 years of age.

We may use age-verification procedures and may refuse or cancel transactions where we cannot reasonably verify eligibility.

If we become aware that we have collected personal information from a person who is not legally eligible to use our Services, we may delete or restrict that information where appropriate and subject to applicable legal-retention requirements.

Parents or guardians who believe that a minor has provided personal information to us may contact us using the details below.

8. SECURITY

We use reasonable administrative, organisational and technical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration or disclosure.

However, no internet transmission, website, database or storage system can be guaranteed to be completely secure.

You should not send passwords, complete payment-card information or other highly sensitive information through unsecured communication channels.

You are responsible for maintaining the confidentiality of your account credentials.

If a breach of security safeguards involving personal information under our control creates a real risk of significant harm to you, we will notify you and, where required, the privacy regulator in your jurisdiction as soon as feasible, and we will keep a record of such breaches as required by applicable privacy laws.

9. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Retention periods may depend on factors including:

  • the duration of your customer relationship with us;
  • whether you maintain an account;
  • order and transaction records;
  • tax and accounting requirements;
  • legal and regulatory requirements;
  • fraud prevention;
  • dispute resolution; and
  • the establishment or defence of legal claims.

When personal information is no longer reasonably required, we may delete, anonymise or securely dispose of it, subject to applicable law.

10. DATA TRANSFERS OUTSIDE YOUR COUNTRY OF RESIDENCE

OLO Pouch Mart may use service providers located in jurisdictions other than the one in which you reside.

As a result, your personal information may be stored or processed outside your country of residence.

When we transfer personal information to a service provider for processing, we use contractual or other means designed to provide a comparable level of protection while the information is being processed.

Depending on the circumstances, these measures may include:

  • contractual safeguards;
  • obtaining consent where legally appropriate;
  • transfers necessary to perform a contract with you; or
  • another transfer mechanism permitted by applicable law.

Personal information stored or processed outside your country of residence is subject to the laws of the jurisdiction in which it is held, and may be accessible to the courts, law-enforcement and national-security authorities of that jurisdiction.

11. YOUR PRIVACY RIGHTS

Under applicable privacy laws, you have rights concerning your personal information.

These may include the right to:

  • request access to personal information we hold about you;
  • challenge the accuracy and completeness of your information and request correction of inaccurate information;
  • request deletion of personal information;
  • request restriction of certain processing;
  • object to certain processing;
  • request portability of certain personal information;
  • withdraw consent where processing relies on consent; and
  • opt out of certain marketing communications.

These rights are not absolute and may be subject to legal exceptions.

For example, we may be required to retain certain transaction records to comply with legal, accounting, tax, fraud-prevention or regulatory obligations.

12. EXERCISING YOUR RIGHTS

You may submit a privacy request by contacting us using the information provided in the Contact Us section below.

We may ask you to provide information reasonably necessary to verify your identity before processing your request.

Where permitted by law, an authorised representative may submit a request on your behalf. We may request evidence that the representative is authorised to act for you.

We will respond within the timeframe required by applicable law, and generally within 30 days of receiving your request. If we refuse a request, we will explain why and tell you how you can challenge our decision.

We will not unlawfully discriminate against you for exercising a privacy right.

13. MARKETING PREFERENCES

You may unsubscribe from marketing emails at any time using the unsubscribe link contained in our emails.

You may also contact us to request removal from marketing communications.

Even after opting out of marketing, we may continue to send necessary non-promotional communications relating to:

  • orders;
  • transactions;
  • account security;
  • delivery;
  • legal notices; and
  • customer-service matters.

14. COMPLAINTS

If you have a concern about how we handle your personal information, please contact us first so that we can review the matter.

If you are not satisfied with our response, you have the right to file a complaint with the privacy regulator in your jurisdiction.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in:

  • our business practices;
  • our website or technology;
  • service providers;
  • applicable laws; or
  • regulatory requirements.

When we update this Privacy Policy, we will publish the revised version on this page and update the Last Updated date.

Where required by law, we will provide additional notice regarding material changes.

16. CONTACT US

If you have questions about this Privacy Policy, our privacy practices, or wish to exercise a privacy right, please contact the person responsible for our compliance with this Privacy Policy:

OLO Pouch Mart – Privacy Officer
Email: [email protected]