Vape & E-Cig Terms & Conditions
VAPESDIRECT WEST MIDLANDS LIMITED TERMS AND CONDITIONS
YOU MUST BE OVER 18 TO PURCHASE GOODS FROM OUR SITE. WE RESERVE THE RIGHT TO REQUEST EVIDENCE OF AGE BEFORE WE FULFIL YOUR ORDER.
1.1 What these terms cover. These are the terms and conditions on which we supply e-cigarette and related products to you.
1.2 Why you should read them. Please read these terms carefully before you submit your order to us. These terms tell you who we are, how we will provide products to you, how you and we may change or end the contract, what to do if there is a problem and other important information. If you think that there is a mistake in these terms, please contact us to discuss.
INFORMATION ABOUT US AND HOW TO CONTACT US
2.1 Who we are. We are VAPESDIRECT WEST MIDLANDS a company registered in England and Wales. Our company registration number is 11503708 and our registered office is at 9 Brindley Street, Stourport on Severn DY13 8JA. Our registered VAT number is GB344479379.
2.2 How to contact us. You can contact us by telephoning our customer service team at 0800 4880205 or by writing to us at VAPESDIRECT WEST MIDLANDS, 9 Brindley Street, Stourport on Severn DY13 8JA or emailing us at email@example.com.
2.3 How we may contact you. If we have to contact you we will do so by telephone or by writing to you at the email address or postal address you provided to us in your order.
2.4 "Writing" includes emails. When we use the words "writing" or "written" in these terms, this includes emails.
OUR CONTRACT WITH YOU
3.1 How we will accept your order. Our acceptance of your order will take place when we email you to accept it, at which point a contract will come into existence between you and us.
3.2 If we cannot accept your order. If we are unable to accept your order, we will inform you of this by email and will not charge you for the product. This might be because the product is out of stock or because we have identified an error in the price or description of the product or because there is a safety issue or because we reasonably believe you are not aged over 18 years of age or resident in the UK.
3.3 Your order number. We will assign an order number to your order and tell you what it is when we accept your order. It will help us if you can tell us the order number whenever you contact us about your order.
3.4 We cannot sell some goods within the EU. Due to the Tobacco Products Directive (2014/40/EU) we cannot sell certain electronic cigarette products to consumers resident in countries of the EU. We are however able to sell all of our products to consumers resident in the UK and in non-EU countries.
3.5 For non UK residents. If you're resident outside of the UK then it is your responsibility to ensure that the products that you order from us comply with the local laws that apply in your country and to take responsibility for importing the goods into your country. We will have no responsibility for products which are stopped at customs or which do not meet the legislation which applies in your country.
3.6 We only sell to people over 18. By law we cannot sell e-cigarettes or related products to anyone who is under 18 years of age. If we reasonably believe that you are not over 18 we reserve the right to require you to provide proof of your age before we fulfil your order.
4.1 Products may vary slightly from their pictures. The images of the products on our website are for illustrative purposes only. Although we have made every effort to display the colours accurately, we cannot guarantee that a device's display of the colours accurately reflects the colour of the products. Your product may vary slightly from those images.
4.2 Product packaging may vary. The packaging of the product may vary from that shown in images on our website. You may not return the product because the packaging does not match the image shown on our website.
4.3 Product safety. There are some safety risks associated with using e-cigarettes and we strongly recommend that you read the instructions for your product before you start using it. Further information on product safety can be found in our Blog pages, if not please email us or manufacturer for further information.Disposable Devices
We will no longer cover by any warranty for the following reasons:
- Disposable devices are a consumable, oral products therefore for purposes of hygiene we cannot accept them back in returns for inspection.
- Claims for dead on arrival or lack of taste cannot be validated by ourselves due to the hygiene reasons mentioned above and will no longer be covered by any warranty.
- All Puff Counts are a guide from the manufacturer.
YOUR RIGHTS TO MAKE CHANGES
If you wish to make a change to the product you have ordered, please contact us. We will let you know if the change is possible. If it is possible we will let you know about any changes to the price of the product, the timing of supply or anything else which would be necessary as a result of your requested change and ask you to confirm whether you wish to go ahead with the change. If we cannot make the change or the consequences of making the change are unacceptable to you, you may want to end the contract (see clause 8- Your rights to end the contract).
- OUR RIGHTS TO MAKE CHANGES
6.1 Minor changes to the products. We may change the product:
(a) to reflect changes in relevant laws and regulatory requirements, for example, where it is necessary to changing packaging or change the design of products to meet changes in the law; and
(b) to implement minor technical adjustments and improvements, for example to address a safety issue. These changes will not materially affect your use of the product.
PROVIDING THE PRODUCTS
7.1 Delivery costs. The costs of delivery will be as displayed to you on our website.
7.2 When we will provide the products. During the order process we will let you know when we will provide the products to you. We will deliver the goods to you as soon as reasonably possible and in any event within 30 days after the day on which we accept your order.
7.3 We are not responsible for delays outside our control. If our supply of the products is delayed by an event outside our control then we will contact you as soon as possible to let you know and we will take steps to minimise the effect of the delay. Provided we do this we will not be liable for delays caused by the event, but if there is a risk of substantial delay you may contact us to end the contract and receive a refund for any products you have paid for but not received.
7.4 If you are not at home when the product is delivered. If no one is available at your address to take delivery and the products cannot be posted through your letterbox, the carrier will leave you a note informing you of how to rearrange delivery or collect the products from their local depot.
7.5 If you do not re-arrange delivery. If, after a failed delivery to you, you do not re-arrange delivery or collect the products from a delivery depot within 14 days the products will be returned to us. Once we receive the products back we will contact you for further instructions and may charge you for storage costs and any further delivery costs. If, despite our reasonable efforts, we are unable to contact you or re-arrange delivery or collection we may end the contract and clause 10 will apply.
7.6 When you become responsible for the goods. The product will be your responsibility from the time we deliver the product to the address you gave us.
7.7 When you own goods. You own the product when we dispatch it to you.
YOUR RIGHTS TO END THE CONTRACT
8.1 You can always end your contract with us. Your rights when you end the contract will depend on whether there is anything wrong with the product you've bought, how we are performing and when you decide to end the contract:
(a) If what you have bought is faulty or mis-described you may have a legal right to end the contract (or to get the product repaired or replaced or a service re-performed or to get some or all of your money back), see clause 11;
(b) If you want to end the contract because of something we have done or have told you we are going to do, see clause 8.2;
(c) If you have just changed your mind about the product, see clause 8.3. You may be able to get a refund if you are within the cooling-off period, but this may be subject to deductions and you will have to pay the costs of return of any goods.
8.2 Ending the contract because of something we have done or are going to do. If you are ending a contract for a reason set out at (a) to (c) below the contract will end immediately and we will refund you in full for any products which have not been provided and you may also be entitled to compensation. The reasons are:
(a) we have told you about an error in the price or description of the product you have ordered and you do not wish to proceed;
(b) there is a risk that supply of the products may be significantly delayed because of events outside our control;
(c) you have a legal right to end the contract because of something we have done wrong.
8.3 Exercising your right to change your mind (Consumer Contracts Regulations 2013). For most products bought online if you are resident in the UK you have a legal right to change your mind within 14 days and receive a refund. These rights, under the Consumer Contracts Regulations 2013, are explained in more detail in these terms.
8.4 Our goodwill guarantee. Please note, these terms reflect the goodwill guarantee offered by Vapesdirect West Midlands Limited to its UK customers, which is more generous than your legal rights under the Consumer Contracts Regulations as it applies to all customers and allows you to return the goods within 15 days of delivery. This goodwill guarantee does not affect your legal rights in relation to faulty or misdescribed products (see clause 11.2):
8.5 When you don't have the right to change your mind. You do not have a right to change your mind in respect of products (e.g. vape kits) sealed for health protection or hygiene purposes, once these have been unsealed after you receive them.
8.6 How long do I have to change my mind? You have 15 days after the day you (or someone you nominate) receives the goods, unless your goods are split into several deliveries over different days. In this case you have until 15 days after the day you (or someone you nominate) receives the last delivery to change your mind about the goods.
HOW TO END THE CONTRACT WITH US (INCLUDING IF YOU HAVE CHANGED YOUR MIND)
9.1 Tell us you want to end the contract. To end the contract with us, please let us know by calling customer services on 0800 4880205 or emailing us at firstname.lastname@example.org. Please provide your name and order number or your name and home address.
9.2 Returning products after ending the contract. If you end the contract for any reason after products have been dispatched to you or you have received them, you must return them to us. You must return the goods by posting them back to us at Vapesdirect West Midlands Limited, 9 Brindley Street, Stourport on Severn, DY13 8JA, United Kingdom. Please either include the returns slip or a note with your name and order number or, if you can't find your order number, your name and address and the reason why you're returning the goods. If you are exercising your right to change your mind you must send off the goods within 14 days of telling us you wish to end the contract. We strongly recommend that you send the goods by Special Delivery or Signed for First Class to avoid the goods being lost in the post. We will not be able to refund you the price of the goods until you can prove that they were posted to us or we have received them.
9.3 When we will pay the costs of return. We will pay the costs of return:
(a) if the products are faulty or misdescribed;
(b) if you are ending the contract because we have told you of an upcoming change to the product, an error in pricing or description, a delay in delivery due to events outside our control or because you have a legal right to do so as a result of something we have done wrong.
In all other circumstances (including where you are exercising your right to change your mind) you must pay the costs of return.
9.4 How we will refund you. We will refund you the price you paid for the products including delivery costs, by the method you used for payment. However, we may make deductions from the price, as described below.
9.5 Deductions from refunds if you are exercising your right to change your mind. If you are exercising your right to change your mind:
(a) We may reduce your refund of the price (excluding delivery costs) to reflect any reduction in the value of the goods, if this has been caused by your handling them in a way which would not be permitted in a shop. See our Refunds & Returns Policy for information about what handling is acceptable and examples. If we refund you the price paid before we are able to inspect the goods and later discover you have handled them in an unacceptable way, you must pay us an appropriate amount.
(b) The maximum refund for delivery costs will be the costs of delivery by the least expensive delivery method we offer. For example, if we offer delivery of a product within 1-3 days at one cost but you choose to have the product delivered within 24 hours at a higher cost, then we will only refund what you would have paid for the cheaper delivery option.
9.6 When your refund will be made. We will make any refunds due to you as soon as possible. If you are exercising your right to change your mind then your refund will be made within 14 days from the day on which we receive the product back from you or, if earlier, the day on which you provide us with evidence that you have sent the product back to us. For information about how to return a product to us, see clause 9.2.
OUR RIGHTS TO END THE CONTRACT
We may end the contract if you break it. We may end the contract for a product at any time by writing to you if you do not, within a reasonable time, allow us to deliver the products to you or arrange collection of the products.
IF THERE IS A PROBLEM WITH THE PRODUCT
11.1 How to tell us about problems. If you have any questions or complaints about the product, please contact us. You can do this by telephoning our customer service team at 0800 488 0205 or by writing to us at Vapesdirect West Midlands Limited, 9 Brindley Street, Stourport on Severn, DY13 8JA emailing us at email@example.com.
11.2 Summary of your legal rights. We are under a legal duty to supply products that are in conformity with this contract. See the box below for a summary of your key legal rights in relation to the product. Nothing in these terms will affect your legal rights.
11.3 Your obligation to return rejected products. If you wish to exercise your legal rights to reject products you must post them back to us. We will pay the costs of postage. Please see clause 9.2 on how to return the products to us.
PRICE AND PAYMENT
12.1 Where to find the price for the product. The price of the product (which includes VAT where applicable) will be the price indicated on the order page when you placed your order; regardless of the VAT rate applicable for sales to your country. We take all reasonable care to ensure that the price of the product advised to you is correct. However please see clause 12.3 for what happens if we discover an error in the price of the product you order.
12.2 We will pass on changes in the rate of VAT. If the rate of VAT changes between your order date and the date we supply the product, we will adjust the rate of VAT that you pay, unless you have already paid for the product in full before the change in the rate of VAT takes effect.
12.3 What happens if we got the price wrong. It is always possible that, despite our best efforts, some of the products we sell may be incorrectly priced. We will normally check prices before accepting your order so that, where the product's correct price at your order date is less than our stated price at your order date, we will charge the lower amount. If the product's correct price at your order date is higher than the price stated to you, we will contact you for your instructions before we accept your order. If we accept and process your order where a pricing error is obvious and unmistakable and could reasonably have been recognised by you as a mispricing, we may end the contract, refund you any sums you have paid and require the return of any goods provided to you.
12.4 When you must pay and how you must pay. We accept payment by credit card (VISA, MasterCard) or debit card (VISA and MasterCard). You must pay for the products before we dispatch them.
12.5 What to do if you think an invoice is wrong. If you think an invoice is wrong please contact us promptly to let us know and we will not charge you interest until we have resolved the issue.
- OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU
13.1 We are responsible to you for foreseeable loss and damage caused by us. If we fail to comply with these terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breaking this contract or our failing to use reasonable care and skill, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time the contract was made, both we and you knew it might happen, for example, if you discussed it with us during the sales process.
13.2 We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors; for fraud or fraudulent misrepresentation; for breach of your legal rights in relation to the products as summarised at clause 11.2.
13.3 We are not liable for business losses. We only supply the products for domestic and private use. If you use the products for any commercial, business or re-sale purpose we will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
- HOW WE MAY USE YOUR PERSONAL INFORMATION
14.1 How we will use your personal information. We will use the personal information you provide to us:
(a) to supply the products to you;
(b) to process your payment for the products; and
(c) if you agreed to this during the order process, to give you information about similar products that we provide, but you may stop receiving this at any time by contacting us.
14.2 We will only give your personal information to third parties where the law either requires or allows us to do so.
OTHER IMPORTANT TERMS
15.1 We may transfer this agreement to someone else. We may transfer our rights and obligations under these terms to another organisation. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under the contract.
15.2 You need our consent to transfer your rights to someone else. You may only transfer your rights or your obligations under these terms to another person if we agree to this in writing.
15.3 Nobody else has any rights under this contract. This contract is between you and us. No other person shall have any rights to enforce any of its terms.
15.4 If a court finds part of this contract illegal, the rest will continue in force. Each of the paragraphs of these terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.
15.5 Even if we delay in enforcing this contract, we can still enforce it later. If we do not insist immediately that you do anything you are required to do under these terms, or if we delay in taking steps against you in respect of your breaking this contract, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.
15.6 Which laws apply to this contract and where you may bring legal proceedings. These terms are governed by English law and you can bring legal proceedings in respect of the products in the English courts. If you live in Scotland you can bring legal proceedings in respect of the products in either the Scottish or the English courts. If you live in Northern Ireland you can bring legal proceedings in respect of the products in either the Northern Irish or the English courts.
Information Security Policy
This Policy document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and fully understand this policy. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and re-distributed to all employees and contractors where applicable.
Vapesdirect Premier Newtown Stores handles sensitive cardholder information daily. Sensitive Information must have adequate safeguards in place to protect the cardholder data, cardholder privacy, and to ensure compliance with various regulations, along with guarding the future of the organisation.
Vapesdirect Premier Newtown Stores commits to respecting the privacy of all its customers and to protecting any customer data from outside parties. To this end management are committed to maintaining a secure environment in which to process cardholder information so that we can meet these promises.
Employees handling sensitive cardholder data should ensure:
- Handle Company and cardholder information in a manner that fits with their sensitivity and classification;
- Limit personal use of Vapesdirect Premier Newtown Stores information and telecommunication systems and ensure it doesn’t interfere with your job performance;
- Vapesdirect Premier Newtown Stores reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;
- Do not use e-mail, internet and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;
- Do not disclose personnel information unless authorised;
- Protect sensitive cardholder information;
- Keep passwords and accounts secure;
- Request approval from management prior to establishing any new software or hardware, third party connections, etc.;
- Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;
- Always leave desks clear of sensitive cardholder data and lock computer screens when unattended;
- Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.
We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use. If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.
A high-level network diagram of the network is maintained and reviewed on a yearly basis. The network diagram provides a high level overview of the cardholder data environment (CDE), which at a minimum shows the connections in and out of the CDE. Critical system components within the CDE, such as POS devices, databases, web servers, etc., and any other necessary payment components, as applicable should also be illustrated.
In addition, ASV should be performed and completed by a PCI SSC Approved Scanning Vendor, where applicable. Evidence of these scans should be maintained for a period of 18 months.
Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Vapesdirect Premier Newtown Stores established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and the Company from illegal or damaging actions, either knowingly or unknowingly by individuals. Vapesdirect Premier Newtown Stores will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.
- Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
- Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.
- Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts.
- All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature.
- All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
- The List of Devices in Appendix B will be regularly updated when devices are modified, added or decommissioned. A stocktake of devices will be regularly performed and devices inspected to identify any potential tampering or substitution of devices.
- Users should be trained in the ability to identify any suspicious behaviour where any tampering or substitution may be performed. Any suspicious behaviour will be reported accordingly.
- Information contained on portable computers is especially vulnerable, special care should be exercised.
- Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of Vapesdirect Premier Newtown Stores , unless posting is in the course of business duties.
- Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.
- All sensitive cardholder data stored and handled by Vapesdirect Premier Newtown Stores and its employees must be securely protected against unauthorised use at all times. Any sensitive card data that is no longer required by Vapesdirect Premier Newtown Stores for business reasons must be discarded in a secure and irrecoverable manner.
- If there is no specific need to see the full PAN (Permanent Account Number), it has to be masked when displayed.
- PAN'S which are not protected as stated above should not be sent to the outside network via end user messaging technologies like chats, ICQ messenger etc.,
It is strictly prohibited to store:
- The contents of the payment card magnetic stripe (track data) on any media whatsoever.
- The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
- The PIN or the encrypted PIN Block under any circumstance.
Data and media containing data must always be labelled to indicate sensitivity level.
- Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to Vapesdirect Premier Newtown Stores if disclosed or modified. Confidential data includes cardholder data.
- Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure.
- Public data is information that may be freely disseminated.
All Access to sensitive cardholder should be controlled and authorised. Any job functions that require access to cardholder data should be clearly defined.
- Any display of the card holder should be restricted at a minimum to the first 6 and the last 4 digits of the cardholder data.
- Access to sensitive cardholder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information.
- No other employees should have access to this confidential data unless they have a genuine business need.
- If cardholder data is shared with a Service Provider (3rd party) then a list of such Service Providers will be maintained as detailed in Appendix C.
- Vapesdirect Premier Newtown Stores will ensure a written agreement that includes an acknowledgement is in place that the Service Provider will be responsible for the for the cardholder data that the Service Provider possess.
- Vapesdirect Premier Newtown Stores will ensure that a there is an established process, including proper due diligence is in place, before engaging with a Service provider.
- The Company will have a process in place to monitor the PCI DSS compliance status of the Service provider.
Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.
- Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.
- Media containing sensitive cardholder information must be handled and distributed in a secure manner by trusted individuals.
- Visitors must always be escorted by a trusted employee when in areas that hold sensitive cardholder information.
- Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where cardholder data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on Vapesdirect Premier Newtown Stores sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to physically enter the premises for a short duration, usually not more than one day.
- A list of devices that accept payment card data should be maintained.
- The list should include make, model and location of the device.
- The list should have the serial number or a unique identifier of the device
- The list should be updated when devices are added, removed or relocated
- POS devices surfaces are periodically inspected to detect tampering or substitution.
- Personnel using the devices should be trained and aware of handling the POS devices
- Personnel using the devices should verify the identity of and=y third party personnel claiming to repair or run maintenance tasks on the devices, install new devices or replace devices.
- Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices to the appropriate personnel. Vapesdirect Premier Newtown Stores sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
- Strict control is maintained over the external or internal distribution of any media containing card holder data and has to be approved by management
- Strict control is maintained over the storage and accessibility of media
- All computer that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.
All sensitive cardholder data must be protected securely if it is to be transported physically or electronically.
- Card holder data (PAN, track data, etc.) must never be sent over the internet via email, instant chat or any other end user technologies.
- If there is a business justification to send cardholder data via email or by any other mode then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, IPSEC, etc.).
- The transportation of media containing sensitive cardholder data to another location must be authorised by management, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location.
- All data must be securely disposed of when no longer required by Vapesdirect Premier Newtown Stores , regardless of the media or application type on which it is stored.
- An automatic process must exist to permanently delete on-line data, when no longer required.
- All hard copies of cardholder data must be manually destroyed when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-electronic cardholder data has been appropriately disposed of in a timely manner.
- Vapesdirect Premier Newtown Stores will have procedures for the destruction of hardcopy (paper) materials. These will require that all hardcopy materials are crosscut shredded, incinerated or pulped so they cannot be reconstructed.
- Vapesdirect Premier Newtown Stores will have documented procedures for the destruction of electronic media. These will require:
- All cardholder data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped using military grade secure deletion processes or the physical destruction of the media;
- If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.
- All cardholder information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” - access to these containers must be restricted.
The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.
- Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice.
- Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A).
- All employees that handle sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with the Company.
- All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
- Company security policies must be reviewed annually and updated as needed.
- Vapesdirect Premier Newtown Stores PCI Security Incident Response Team (PCI Response Team) is comprised of the Information Security Officer and Merchant Services. Vapesdirect Premier Newtown Stores PCI security incident response plan is as follows:
- Each department must report an incident to the Information Security Officer (preferably) or to another member of the PCI Response Team.
- That member of the team receiving the report will advise the PCI Response Team of the incident.
- The PCI Response Team will investigate the incident and assist the potentially compromised department in limiting the exposure of cardholder data and in mitigating the risks associated with the incident.
- The PCI Response Team will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary.
- The PCI Response Team will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.
Vapesdirect Premier Newtown Stores PCI Security Incident Response Team (or equivalent in your organisation):
Information Security Officer
Collections & Merchant Services
Information Security PCI Incident Response Procedures:
- A department that reasonably believes it may have an account breach, or a breach of cardholder information or of systems related to the PCI environment in general, must inform Vapesdirect Premier Newtown Stores PCI Incident Response Team. After being notified of a compromise, the PCI Response Team, along with other designated staff, will implement the PCI Incident Response Plan to assist and augment departments’ response plans.
Incident Response Notification
Escalation Members (or equivalent in your company):
Escalation – First Level:
Information Security Officer Controller
Executive Project Director for Credit Collections and Merchant Services Legal Counsel
Director of Vapesdirect Premier Newtown Stores Communications
Escalation – Second Level:
Vapesdirect Premier Newtown Stores President
Auxiliary members as needed
External Contacts (as needed)
Merchant Provider Card Brands
Internet Service Provider (if applicable)
Internet Service Provider of Intruder (if applicable) Communication Carriers (local and long distance) Business Partners
External Response Team as applicable (CERT Coordination Center 1, etc) Law Enforcement Agencies as applicable inn local jurisdiction
In response to a systems compromise, the PCI Response Team and designees will:
- Ensure compromised system/s is isolated on/from the network.
- Gather, review and analyze the logs and related information from various central and local safeguards and security controls
- Conduct appropriate forensic analysis of compromised system.
- Contact internal and external departments and entities as appropriate.
- Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
- Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.
The credit card companies have individually specific requirements that the Response Team must address in reporting suspected or confirmed breaches of cardholder data. See below for these requirements.
Incident Response notifications to various card schemes
- In the event of a suspected security breach, alert the information security officer or your line manager immediately.
- The security officer will carry out an initial investigation of the suspected security breach.
- Upon confirmation that a security breach has occurred, the security officer will alert management and begin informing all relevant parties that may be affected by the compromise.
If the data security compromise involves credit card account numbers, implement the following procedure:
- Shut down any systems or processes involved in the breach to limit the extent, and prevent further exposure.
- Alert all affected parties and authorities such as the Merchant Bank (your Bank), Visa Fraud Control, and the law enforcement.
- Provide details of all compromised or potentially compromised card numbers to Visa Fraud Control within 24 hrs.
- For more Information visit: http://usa.visa.com/business/accepting_visa/ops_risk_management/cisp_if_ compromised.html
Visa Incident Report Template
This report must be provided to VISA within 14 days after initial report of incident to VISA. The following report content and standards must be followed when completing the incident report. Incident report must be securely distributed to VISA and Merchant Bank. Visa will classify the report as “VISA Secret”*.
- Executive Summary
- Include overview of the incident
- Include RISK Level(High, Medium, Low)
- Determine if compromise has been contained
- Initial Analysis
- Investigative Procedures
- Include forensic tools used during investigation
- Number of accounts at risk, identify those stores and compromised
- Type of account information at risk
- Identify ALL systems analyzed. Include the following:
- Domain Name System (DNS) names
- Internet Protocol (IP) addresses
- Operating System (OS) version
- Function of system(s)
- Identify ALL compromised systems. Include the following:
- DNS names
- IP addresses
- OS version
- Function of System(s)
- Timeframe of compromise
- Any data exported by intruder
- Establish how and source of compromise
- Check all potential database locations to ensure that no CVV2, Track 1 or Track 2 data is stored anywhere, whether encrypted or unencrypted (e.g., duplicate or backup tables or databases, databases used in development, stage or testing environments, data on software engineers’ machines, etc.)
- If applicable, review VisaNet endpoint security and determine risk
- Compromised Entity Action
- Contact(s) at entity and security assessor performing investigation
*This classification applies to the most sensitive business information, which is intended for use within VISA. Its unauthorized disclosure could seriously and adversely impact VISA, its employees, member banks, business partners, and/or the Brand.
- Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-636-722-4100.
- Provide a detailed written statement of fact about the account compromise (including the contributing circumstances) via secured e-mail to firstname.lastname@example.org.
- Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers.
- Within 72 hours of knowledge of a suspected account compromise, engage the services of a data security firm acceptable to MasterCard to assess the vulnerability of the compromised data and related systems (such as a detailed forensics evaluation).
- Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
- Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request.
- Provide finding of all audits and investigations to the MasterCard Merchant Fraud Control department within the required time frame and continue to address any outstanding exposure or recommendation until resolved to the satisfaction of MasterCard.
Once MasterCard obtains the details of the account data compromise and the list of compromised account numbers, MasterCard will:
- Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs.
- Distribute the account number data to its respective issuers.
Employees of the company will be expected to report to the security officer for any security related issues. The role of the security officer is to effectively communicate all security policies and procedures to employees within the company and contractors. In addition to this, the security officer will oversee the scheduling of security training sessions, monitor and enforce the security policies outlined in both this document and at the training sessions and finally, oversee the implantation of the incident response plan in the event of a sensitive data compromise.
Discover Card Steps
- Within 24 hours of an account compromise event, notify Discover Fraud Prevention at (800) 347-3102
- Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
- Prepare a list of all known compromised account numbers
- Obtain additional specific requirements from Discover Card
American Express Steps
- Within 24 hours of an account compromise event, notify American Express Merchant Services at (800) 528-5200 in the U.S.
- Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
- Prepare a list of all known compromised account numbers Obtain additional specific requirements from American Express
- All third-party companies providing critical services to Vapesdirect Premier Newtown Stores must provide an agreed Service Level Agreement.
- All third-party companies providing hosting facilities must comply with the Company’s Physical Security and Access Control Policy.
- All third-party companies which have access to Card Holder information must
- Adhere to the PCI DSS security requirements.
- Acknowledge their responsibility for securing the Card Holder data.
- Acknowledge that the Card Holder data must only be used for assisting the completion of a transaction, supporting a loyalty program, providing a fraud control service or for uses specifically required by law.
- Have appropriate provisions for business continuity in the event of a major disruption, disaster or failure.
- Provide full cooperation and access to conduct a thorough security review after a security intrusion by a Payment Card industry representative, or a Payment Card industry approved third party.
- Access to Vapesdirect Premier Newtown Stores is controlled through a formal user registration process beginning with a formal notification from HR or from a line manager.
- Each user is identified by a unique user ID so that users can be linked to and made responsible for their actions. The use of group IDs is only permitted where they are suitable for the work carried out.
- There is a standard level of access; other services can be accessed when specifically authorized by HR/line management.
- The job function of the user decides the level of access the employee has to cardholder data
- A request for service must be made in writing (email or hard copy) by the newcomer’s line manager or by HR. The request is free format, but must state:
Name of person making request;
Job title of the newcomers and workgroup;
Services required (default services are: MS Outlook, MS Office and Internet access).
- Each user will be given a copy of their new user form to provide a written statement of their access rights, signed by an IT representative after their induction procedure. The user signs the form indicating that they understand the conditions of access.
- Access to all Vapesdirect Premier Newtown Stores systems is provided by IT and can only be started after proper procedures are completed.
- As soon as an individual leaves Vapesdirect Premier Newtown Stores employment, all his/her system logons must be immediately revoked.
- As part of the employee termination process HR (or line managers in the case of contractors) will inform IT operations of all leavers and their date of leaving.
- Access Control systems are in place to protect the interests of all users of Vapesdirect Premier Newtown Stores computer systems by providing a safe, secure and readily accessible environment in which to work.
- Vapesdirect Premier Newtown Stores will provide all employees and other users with the information they need to carry out their responsibilities in an as effective and efficient manner as possible.
- Generic or group IDs shall not normally be permitted, but may be granted under exceptional circumstances if sufficient other controls on access are in place.
- The allocation of privilege rights (e.g. local administrator, domain administrator, super-user, root access) shall be restricted and controlled, and authorization provided jointly by the system owner and IT Services. Technical teams shall guard against issuing privilege rights to entire teams to prevent loss of confidentiality.
- Access rights will be accorded following the principles of least privilege and need to know.
- Every user should attempt to maintain the security of data at its classified level even if technical security mechanisms fail or are absent.
- Users electing to place information on digital media or storage devices or maintaining a separate database must only do so where such an action is in accord with the data’s classification.
- Users are obligated to report instances of non-compliance to Vapesdirect Premier Newtown Stores
- Access to Vapesdirect Premier Newtown Stores IT resources and services will be given through the provision of a unique Active Directory account and complex password.
- No access to any Vapesdirect Premier Newtown Stores IT resources and services will be provided without prior authentication and authorization of a user’s Vapesdirect Premier Newtown Stores Windows Active Directory account.
- Password issuing, strength requirements, changing and control will be managed through formal processes. Password length, complexity and expiration times will be controlled through Windows Active Directory Group Policy Objects.
- Access to Confidential, Restricted and Protected information will be limited to authorised persons whose job responsibilities require it, as determined by the data owner or their designated representative. Requests for access permission to be granted, changed or revoked must be made in writing.
- Users are expected to become familiar with and abide by Vapesdirect Premier Newtown Stores policies, standards and guidelines for appropriate and acceptable usage of the networks and systems.
- Access for remote users shall be subject to authorization by IT Services and be provided in accordance with the Remote Access Policy and the Information Security Policy. No uncontrolled external access shall be permitted to any network device or networked system.
- Access to data is variously and appropriately controlled according to the data classification levels described in the Information Security Management Policy.
- Access control methods include logon access rights, Windows share and NTFS permissions, user account privileges, server and workstation access rights, firewall permissions, IIS intranet/extranet authentication rights, SQL database rights, isolated networks and other methods as necessary.
- A formal process shall be conducted at regular intervals by system owners and data owners in conjunction with IT Services to review users’ access rights. The review shall be logged and IT Services shall sign off the review to give authority for users’ continued access rights.