Privacy Policy

Your privacy matters. Here’s how we keep your data safe

Pouch Aware Privacy Policy 

Pouch Aware is a website maintained by Nicotine Database Limited. The website will contain two databases; the public Pouch Aware database for producers and the private Pouch Aware database which will only be accessible to Nicotine Database Limited, Inter Scientific Limited, Trading Standards Bodies, Medicines & Healthcare products Regulatory Agency (MHRA), Office for Product Safety & Standards (OPSS), Health and Safety Executive (HSE), The Advertising Standards Authority (ASA), His Majesty’s Revenue and Customs (HMRC), and Border Force. Nicotine Database Limited will not own the data shared on the database nor will they obtain the background intellectual property rights to the data and information as set out in Clause 11 of the Terms of Business. 

Nicotine Database Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www. Pouch-aware.com (Our Site) and we will only collect and use personal data in a way that is consistent with our obligations and your rights under the Data Protection Legislation. 

Please read this Privacy Policy carefully and ensure that you understand it. 

Your acceptance of this Privacy Policy is requested via our contact form page at http://www.pouch-aware.com/contact-us and membership pages (registration, sign up, sign in, access denied).   

1.Definition and Interpretation 

In this Policy the following terms shall have the following meanings: 

Account means an account required to access and/or use certain areas and features of Our Site. 

Cookiemeans a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; 

Cookie Lawmeans the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; 

Data Protection Legislation means all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulation (EU) 2016/679; the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy Electronic Communications Regulations 2003 (SI 2003/2426) as amended. Therefore, means any UK and EU legislation relating to data and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of Data, including without limitation, the privacy of electronic communications.  

Nicotine Database means Nicotine Database Limited 

Our Site means www.pouch-aware.com 

Privacy Policy means this Privacy Policy document that outlines how Pouch Aware collects, uses and protects personal information obtained from users of Our Site. It details the types of data collected, the purposes for processing the data and the rights of users in compliance with the applicable Data Protection Legislation. 

 

  1. Information about Pouch Aware

Our Site is owned and operated by Nicotine Database Limited, a company registered in England. 

Registered Address:Unit 29, Spindus Road, Compass West Industrial Estate, L24 1YA 

Company Number: 15734373. 

VAT number: GB 473460583. 

  1. What does this policy cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them. It also covers the information and use of data within the database. 

  1. What is personal data?
    Personal data is defined by the UK GDPR and the Data Protection Act 2018, collectively, the Data Protection Legislation, defines personal data as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier
  2. What are your rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold: 

1.        The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15. 

2.        The right to access the personal data we hold about you. Part 13 will tell you how to do this. 

3.        The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more. 

4.        The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more. 

5.        The right to restrict (i.e. prevent) the processing of your personal data. 

6.        The right to object to us using your personal data for a particular purpose or purposes. 

7.        The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time. 

8.        The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. 

9.        Rights relating to automated decision-making and profiling. Pouch Aware does not use your personal data in this way. 

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. 

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed, if we have that data. 

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. 

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. However, we would welcome the opportunity to resolve your concerns ourselves, so please contact us first, using the details in Part 15. 

  1. What data does Pouch Aware collect and how?
    Depending upon your use of Our Site, we may collect and hold some or all the personal and non-personal data set out in the table below. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children.
Identity Information Method of Data Collection 
Name Form on www.pouch-aware.com/contact-us 
Contact Number 
Email Address 

 

Contact Information Method of Data Collection 
Name Form on www.pouch-aware.com/contact-us 
Contact Number 
Email Address 

 

Business Information Method of Data Collection 
Business Name 

Form on www.pouch-aware.com/contact-us 

By our office team via; 

Email 

Telephone 

Meetings 

Contact Number 
Email Address 
Business Address 
Business Category/Type 
Employee Name 

 

  1. How does pouch Aware use your personal data?
    Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The table below describes how we may use your personal data, and our lawful bases for doing so.
Action Information Collected Reason 
Registering you on Our Site. Name, email, telephone number, message. 

 

 

 

 

 

 

 

 

 

 

 

Legitimate interests – Supplying services to you and updates to these services. 

Providing and managing your Account. Name, email address, emails telephone number, company details, company financial / invoicing details 
Providing and managing your access to Our Site. Name, email address, emails, telephone number telephone number, message. 
Personalizing and tailoring your experience on Our Site. Name, email address, emails, telephone number telephone number, message. 
Administering Our Site. Name, email address, emails, telephone number telephone number, message. 
Supplying Our services to you. Name, email address, emails telephone number, company details, company financial / invoicing details 
Managing payments for Our services Name, email address, emails telephone number, company details, company financial / invoicing details 
Personalizing and tailoring Our services for you. Name, email address, emails telephone number, company details, company financial / invoicing details 
Communicating with you. Name, email address, emails telephone number, company details, company financial / invoicing details 
Supplying you with information by email that you have opted-in-to you may opt-out at any time by clicking onto the relevant links in each email communication. Name, email address, emails telephone number, company details, company financial / invoicing details 

 

 

  1. How long will pouch Aware keep your personal data?

We will not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): 

Information Type Particulars Time Period (Years) 
Identity Information 

Name 

Contact Number 

Email Address 

5 
Contact Information 

Name 

Contact Number 

Email Address 

5 
Business Information 

Business Name 

Contact Number 

Email Address 

Business Address 

Business Category/Type 

Employee Name 

5 
Payment Information 

Name 

Company Name 

Card Type 

Total Amount 

10 
Profile Information 

Preferences and Interests 

Username 

Purchase History 

Testing Credits 

5 
Technical Information 

Data collected (IP address, browser type and version) 

Operating System 

5 

 

  1. How and where do pouch Aware store or transfer your personal data?

For further information on how Pouch Aware store or transfer your personal data, please contact us by using the details in Part 15. 

  1. Does pouch Aware share your personal data?

We will not share any of your personal data with any third parties for any purposes,subject to the following exceptions: 

       If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy. 

       In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. 

  1. How can you control your data?

In Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes, including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details. 

You may also wish to sign up to one or more of the preference services operating in the UK: The Mailing Preference Service (“the MPS”). This may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving. 

  1. Can you withhold your information?

You may access all areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14. 

  1. How can you withdraw your information?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. 

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. 

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. 

We will respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress. 

  1. How does pouch Aware use cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. 

All Cookies used by and on Our Site are used in accordance with current Cookie Law. 

Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. 

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them. 

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. 

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings. 

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings. 

  1. How can you contact pouch Aware?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: 

Email address: info@pouch-aware.com 

Telephone number: +44 (0) 333 0156177 

Postal Address: Unit 29, Spindus Road, Compass West Industrial Estate, L24 1YA 

  1. Changes to this policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. 

Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This 

Privacy Policy was last updated on 22/10/24. 

  1. Database and Membership Data

Any data that you are privy to after being accepted as a member is strictly confidential and for your access only. 

We ask that you under no circumstances share your login details with anyone even if they have been provided with access. You must not allow anyone else to access your account or provide them access to view the database. 

For those who request to be a member to access the database, the only information stored on you will be your first name, surname and email addresses. We do not have access to your passwords through hashed encryption used and card details. 

Should you forget your password, please use the forgotten password functionality on the sign in page or contact info@pouch-aware.com for support. 

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OVERVIEW

Non-destructive Testing

Non-destructive tests assess key physical properties of nicotine pouches without altering or damaging the product. These tests are essential for evaluating consistency, quality, and shelf stability, and are often the first indicators of potential formulation issues.

 

Non-destructive testing is fast, reliable, and helps maintain the integrity of samples for further analysis if needed.

1. Pouch Mass (Average of 10 Pouches)

This test calculates the average mass of 10 individual pouches from a single product batch.

Why it matters

Consistent pouch mass is essential for uniform dosing, user experience, and trust in product quality. Fluctuations in pouch mass may suggest poor manufacturing controls or undeclared formulation changes.

2. Water Activity (Single Pouch Sample)

This test measures how much free moisture is present in the pouch (as opposed to bound water).

Why it matters

Elevated water activity can promote microbial growth and shorten shelf life. Monitoring water activity helps predict product stability and ensures safety during storage and transport—especially critical in a largely unregulated category.

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Overview

Destructive Testing

Destructive tests break open or chemically alter pouches to assess their internal composition. These in-depth analyses provide essential insights into nicotine levels, chemical content, and potential contaminants that cannot be observed from the outside. These tests are necessary for verifying claims, identifying health risks, and supporting regulatory readiness.

 

Each test typically uses 10–12 pouches per batch to ensure accurate and representative results.

1. Nicotine Assay

(Average of 3 Pouches)

Determines the actual nicotine content in each pouch.

Why it matters

Accurate nicotine delivery is essential for user safety and dosage reliability. Mismatches between labelled and tested values can raise legal, ethical, and health concerns.

2. Major Components – Glycerol & Propylene Glycol

Quantifies common additives that affect moisture retention and texture.

Why it matters

Overuse of these components can negatively impact product safety and sensory experience. Identifying unexpected or excessive amounts can flag poor formulation or undeclared additives.

3. TSNAs – NNN & NNK (Average of 3 Pouches)

Measures two tobacco-specific nitrosamines known to be carcinogenic.

Why it matters

Even in “tobacco-free” products, these harmful compounds may appear due to contaminated raw materials or manufacturing residues. This test identifies potential long-term health risks and supports harm reduction claims.

4. Water Content (Derived from NNN/NNK Sample Set)

Measures total water content (not just active moisture).

Why it matters

Total moisture levels affect chemical stability and microbial resistance. This deeper look supports claims around product freshness and shelf life.

5. Heavy Metals – Chromium, Nickel & Lead (Average of 3 Pouches)

Tests for toxic heavy metals that may be introduced during production.

Why it matters

These metals are harmful even at trace levels and are under increasing scrutiny by health authorities. Testing helps identify contamination sources and promotes safe sourcing practices.

6. pH (1–3 Pouches)

Measures the acidity or alkalinity of the pouch material.

Why it matters

pH affects nicotine absorption and user comfort. Extremes in pH can cause irritation or make the product less effective. This test ensures a balanced, tolerable experience for users.

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