Legal
Privacy Policy
How SURPASSION LLC handles personal data when you use our website — including GDPR rights and U.S. privacy expectations.
SURPASSION LLC, operating as SURPASSION Cigars, is committed to protecting your privacy. This policy explains how we collect, use, and safeguard your information when you visit surpassioncigars.com or this site, in compliance with the EU General Data Protection Regulation (GDPR), the UK GDPR, and applicable U.S. privacy laws.
Data controller
The data controller responsible for your personal data is SURPASSION LLC (SURPASSION Cigars), located at 320 St Johns Ave, Suite 103, Palatka, FL 32177, United States.
Information we collect
Depending on how you interact with us, we may collect:
- Contact and inquiry data — name, email address, phone number, company or lounge name, and message content when you contact us, request information, or apply to become an authorized retailer (Quartermaster).
- Application materials — files or details you submit through forms (for example, business or licensing information), where applicable.
- Technical and usage data — IP address, browser type, general device or log information, and similar data collected automatically through cookies or similar technologies where used. If you consent to analytics, we may collect anonymized usage data (such as page views and referrers); we only load non-essential analytics after you opt in, where required.
- AI concierge messages— if you choose to use our optional AI concierge, the messages you type are processed to generate replies. Please don’t share sensitive personal information in the chat. See the “AI concierge” section below.
Legal basis for processing (GDPR)
Where GDPR applies, we rely on:
- Consent — when you opt in to optional cookies or marketing, or explicitly agree to specific processing;
- Legitimate interests — to respond to inquiries, operate and secure our website, and improve our services, where not overridden by your rights;
- Contract — when processing is necessary to perform a contract with you or take steps before entering a contract (for example, evaluating a wholesale or partnership request).
- Legal obligation — where we must process data to comply with the law.
Cookies and similar technologies
We use cookies, local storage, or similar technologies as needed to run the site, remember your choices (including age verification where used), and, only with your consent where required, for analytics. You can adjust preferences through our cookie controls where available and your browser settings. See our Cookie Policy for details.
How we use information
We use personal data to:
- Respond to questions, partnership requests, and customer inquiries;
- Operate, maintain, and improve the website and our brand experience;
- Comply with law and protect our rights, users, and the public;
- Send marketing communications only where permitted by law and your preferences.
We do not sell your personal information for money. We do not share personal data with third parties for their own marketing unrelated to SURPASSION without appropriate legal basis or consent.
AI concierge
Our website may offer an optional AI concierge that answers questions about our cigars, brand, and where to buy. To generate replies, the messages you send are transmitted to our AI provider, Anthropic, which processes them on our behalf as a service provider. Under Anthropic’s commercial API terms, your conversations are not used to train their models, and we do not store your concierge conversations on our servers. The concierge is informational only — it does not provide medical, health, or professional advice, and it is intended for adults of legal age. Please avoid entering sensitive personal information into the chat.
Data retention
We retain personal data only as long as needed for the purposes above, including to resolve inquiries, manage retailer relationships, and meet legal, tax, or regulatory requirements. Typical retention for routine contact messages may be up to several years unless a longer period is required by law. Aggregated or anonymized analytics, where used, is retained in a form that does not identify you.
International transfers
We are based in the United States. If you access our site from the EEA, UK, or elsewhere, your information may be processed in the U.S. or other countries. Where GDPR requires, we use appropriate safeguards (such as Standard Contractual Clauses or an adequacy decision or the Data Privacy Framework, as applicable) for transfers to countries not recognized as adequate.
Data security
We implement reasonable technical and organizational measures designed to protect personal data, including encryption in transit (such as HTTPS / TLS) where appropriate and access controls aligned with the sensitivity of the data. No online transmission or storage is completely secure; we cannot guarantee absolute security.
Your rights (GDPR and similar laws)
Depending on your location, you may have the right to access, correct, delete, or restrict processing of your personal data; to data portability; to object to certain processing; to withdraw consent where processing is consent-based; and to lodge a complaint with a supervisory authority.
To exercise these rights, contact us at [email protected]. We will respond within a reasonable time and as required by law (typically within 30 days where GDPR applies).
Age and tobacco products
Our website and products are intended for adults who meet the legal age to purchase and use tobacco products in their jurisdiction (for example, 21+ in many U.S. jurisdictions). We do not knowingly collect personal information from anyone below that age. If you believe we have collected data from someone who does not meet the legal age, please contact us and we will take appropriate steps to delete it.
Children
This site is not directed at children under 16. We do not knowingly collect personal data from children as defined under applicable law.
Changes to this policy
We may update this policy from time to time. We will post the revised version on this page and update the "Last updated" date. Material changes may be highlighted on the site where appropriate.
Contact
SURPASSION LLC · SURPASSION Cigars
320 St Johns Ave, Suite 103, Palatka, FL 32177, United States
Phone: (703) 300-1348
Email: [email protected]