Privacy Policy

Website: www.xohavana.com

Effective Date / Last Updated: April 2026

LIBRENTEZ respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, place an order, or interact with us (collectively, the “Service”).

By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Service.

1. Who We Are – Data Controller

The data controller responsible for your personal data is:

LIBRENTEZ
(CEO – Olivier Girard)
15 rue de la Queue du Renard
86260 Angles-sur-l'Anglin
France
Email: contact@xohavana.fr

We are a French company selling TPD-compliant electronic cigars and related vaping products online. All processing of personal data complies with the EU General Data Protection Regulation (GDPR – Regulation (EU) 2016/679) and the French Data Protection Act.

2. What Personal Data We Collect

We collect the following categories of personal data:

• Identification and contact data: First name, last name, email address, telephone number, date of birth (for age verification).
• Delivery and billing data: Postal address, postcode, city, country, payment information (processed securely by our payment provider – we do not store full card details).
• Account data: Login credentials (if you create an account), order history, preferences.
• Technical and usage data: IP address, browser type, device information, cookies, browsing behaviour on our site.
• Other: Any information you voluntarily provide when contacting customer service or participating in promotions.

We do not intentionally collect sensitive data (special categories) except where required for age verification (you must be at least 18 years old to purchase vaping products).

3. How We Collect Your Data

• Directly from you when you create an account, place an order, contact us, subscribe to newsletters, or fill in forms.
• Automatically through cookies, pixels, and similar technologies when you browse our website.
• From third parties such as payment service providers (e.g. Viva Wallet), shipping carriers, or fraud prevention services.

4. Purposes and Legal Basis for Processing

We process your personal data for the following purposes and on the following legal bases:

Purpose	Legal Basis	Examples
Processing and fulfilling orders	Contract performance (Art. 6(1)(b) GDPR)	Delivery, payment, order confirmation
Age verification & legal compliance	Legal obligation (Art. 6(1)(c) GDPR)	Confirming you are 18+ for vaping products
Customer service & communications	Contract performance / Legitimate interest	Responding to inquiries, after-sales support
Marketing (newsletters, promotions)	Consent (Art. 6(1)(a) GDPR) – you can withdraw at any time	Sending promotional emails (only with your opt-in)
Website improvement & analytics	Legitimate interest (Art. 6(1)(f) GDPR)	Understanding how users interact with the site
Fraud prevention & security	Legitimate interest / Legal obligation	Anti-fraud checks on large orders
Accounting & tax obligations	Legal obligation	Invoicing and regulatory compliance

5. Sharing Your Personal Data

We may share your personal data with:

• Service providers: Hosting provider (123 Reg Limited, Studio 4th Floor, Parts C&D at East West, Tollhouse Hill, Nottingham, NG1 5FW, England), payment processors (including Viva Wallet), shipping carriers (e.g. La Poste / Colissimo), email service providers.
• Legal authorities: When required by law (tax, customs, or judicial requests).
• Professional advisers: Lawyers, accountants, or auditors when necessary.

We do not sell your personal data to third parties. All third-party processors are bound by data processing agreements and must comply with GDPR.

International transfers may occur (e.g., to the UK for hosting). We ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses where required).

6. Cookies and Tracking Technologies

Our website uses cookies and similar technologies for:

• Essential functionality (shopping cart, authentication)
• Analytics and performance (e.g., Google Analytics or similar)
• Marketing and personalisation (only with your consent)

You can manage your cookie preferences at any time via the cookie banner or your browser settings. For more details, see our Cookie Policy (or the relevant section in this policy).

7. Data Retention

We keep your personal data only as long as necessary for the purposes outlined above or as required by law:

• Order-related data: 5–10 years (accounting and legal obligations)
• Marketing consent: Until you withdraw consent
• Technical/usage data: Up to 13–26 months (analytics cookies)

After the retention period, we securely delete or anonymise your data.

8. Your Rights under GDPR

You have the following rights regarding your personal data (subject to applicable law):

• Right to access your data
• Right to rectification (correct inaccurate data)
• Right to erasure (“right to be forgotten”)
• Right to restriction of processing
• Right to data portability
• Right to object to processing (especially for marketing or legitimate interest)
• Right to withdraw consent at any time (where processing is based on consent)

To exercise any of these rights, please contact us at: contact@xohavana.fr

We will respond within one month (extendable in complex cases). You also have the right to lodge a complaint with the French supervisory authority: CNIL (www.cnil.fr).

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure (e.g., secure servers, encryption for payments, access controls).

10. Children’s Privacy

Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a person under 18 without verified parental consent, we will delete it.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised “Last Updated” date. We encourage you to review it periodically.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

Email: contact@xohavana.fr
Postal address: 15 rue de la Queue du Renard, 86260 Angles-sur-l'Anglin, France