Privacy Policy

 

Last Updated: March 2026

Data Controller: FriLar AB, Sweden (Org. nr: 5594993676)

 

1. Introduction and Scope

This Privacy Policy describes how FriLar AB (the "Company", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from pouchfix.com (the "Site") or otherwise communicate with us regarding the Site (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

 

2. Legal Basis for Processing

Operating from Sweden, we process your personal data in accordance with the EU General Data Protection Regulation (GDPR). Our legal bases include:

 

• Contractual Necessity: To process and deliver your orders.

• Legal Obligation: To comply with the Swedish Act on Tobacco-Free Nicotine Products (2022:1257) regarding mandatory age verification and the Swedish Accounting Act (1999:1078) for record-keeping.

• Legitimate Interest: To maintain site security and provide customer support.

 

3. Personal Information We Collect

We collect information directly from you, through cookies, and from third parties:

• Contact & Shipping: Name, shipping address, billing address, email, and phone number.

• Age Verification Data: To comply with global nicotine regulations, we use AgeChecker.net. This may include you providing your date of birth and, if required, a government-issued ID during checkout.

• Technical Data: IP address, browser type, and usage data collected via cookies.

4. Disclosure to Third Parties and International Transfers

To provide our Services, we disclose your information to specific third parties:

• Age Verification: Your data is shared with AgeChecker.net to verify your eligibility to purchase nicotine. This transfer is protected by EU Standard Contractual Clauses (SCCs).

• Logistics: We share your contact details with UPS and other carriers to facilitate global delivery and physical age verification upon arrival.

• Payment Processing: We use encrypted payment gateways; we do not store your credit card details on our servers.

 

5. Data Retention and Security

We retain your personal information only for as long as necessary to fulfill the purposes described herein.

• Accounting: Transaction records are kept for 7 years per Swedish law.

• Age Logs: Verification status is stored to prove compliance with sales laws, while raw ID images are deleted by our partner, AgeChecker.net, as soon as verification is complete.

 

6. Your Rights (GDPR)

Depending on your location, you have rights including:

•           Access and Portability: Requesting a copy of your data.

•           Correction and Deletion: Updating or removing your information.

•           Right to Human Intervention: If an automated age verification via AgeChecker.net fails, you have the right to request a manual review by our staff. Please contact us at hello@pouchfix.com to perform a manual review.

 

7. Contact

For questions or to exercise your rights, please contact us at hello@pouchfix.com. If you are in the EU and have concerns, you have the right to lodge a complaint with the Swedish Authority for Privacy Protection (IMY).