Direct Marketing Policy

Last updated: 27 August 2026

1. Purpose

This policy explains how Clayton Leonard Enterprises Ltd (Unit 19, Seatown Business Campus, Swords, Co. Dublin, K67 Y673, Ireland) carries out direct marketing in connection with www.ivapegreatshop.ie, and the rules we follow under:

• the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (S.I. No. 336 of 2011) — the Irish "ePrivacy Regulations";
• the GDPR and the Data Protection Act 2018; and
• the Public Health (Tobacco Products and Nicotine Inhaling Products) Act 2023 and related Irish law restricting the promotion of nicotine inhaling products.

2. Adults only

We market age-restricted products. We only send marketing to people who have identified themselves to us as being 18 or over, and we do not knowingly direct marketing at anyone under 18. Our marketing lists are built solely from age-verified customers and adult subscribers.

3. Electronic marketing (email and SMS)

We send marketing by email or SMS only where one of the following applies:

• You have opted in. You gave us clear consent to receive marketing (for example by ticking an unticked box when subscribing or creating an account); or
• You are an existing customer ("soft opt-in"). As permitted by Regulation 13 of S.I. 336/2011: we obtained your details in the course of selling you a product; the marketing relates to our own similar products; you were given a clear, free and easy way to refuse marketing when we collected your details and are given the same in every message; and the details are used within twelve months of the sale (or of your most recent purchase).

Every marketing message we send includes a working unsubscribe mechanism. Opting out is free and takes effect promptly; once you opt out we keep only a suppression record so that we do not contact you again.

4. Telephone and post

We do not currently market by telephone call or post. If that changes, calls will respect the National Directory Database opt-out register and postal marketing will honour any objection you make.

5. No marketing of third-party products

We do not share your contact details with other businesses for their marketing, and we do not send marketing on behalf of third parties.

6. Content standards for regulated products

Because nicotine inhaling products are age-restricted and their advertising is restricted under Irish law, our marketing:

• is sent only to adults who have opted in or are existing adult customers, as described above;
• contains factual product, price and availability information;
• does not make smoking-cessation, health or medicinal claims;
• does not target, feature or appeal specifically to minors.

7. Your rights

You have the absolute right to object to direct marketing at any time (Article 21(2) GDPR). You can opt out by using the unsubscribe link in any message, adjusting your account preferences, or contacting us via Contact Page. For all other data protection rights, see our Privacy Policy.

8. Complaints

If you believe we have sent you marketing unlawfully, please contact us first so we can put it right. You may also complain to the Data Protection Commission (www.dataprotection.ie), which enforces both the GDPR and the ePrivacy Regulations in Ireland.