Privacy Policy EU

This Privacy Policy describes how https://www.smile-therapy.co/ (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Personal information we collect 

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information. 

• Device information
• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimise our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose: shared with our processor Shopify and any other softwares we may use to better operate our business including but not limited to sales channels, payment gateways, shipping and fulfilment apps.
• Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Order information
• Purpose of collection: to provide products or services to you to fulfil our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
• Source of collection: collected from you.
• Disclosure for a business purpose: shared with our processor Shopify and any other softwares we may use to better operate our business including but not limited to sales channels, payment gateways, shipping and fulfilment apps.
• Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers and accounts used to make a payment), email address, and phone number.

Text Marketing and notifications: By subscribing to text notifications you agree to receive recurring automated marketing messages at the phone number provided. Consent is not a condition of purchase. Reply STOP to unsubscribe. HELP for help. Msg & Data rates may apply. More info view Privacy Policy and ToS.

Marketing data is collected.

We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address above to request deletion.

How do we use your personal information? 

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfilment of your order, and keeping you up to date on new products, services, and offers.

We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to: 

- Communicate with you; 

- Screen our orders for potential risk or fraud; and 

- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. 

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). 

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Sharing you personal Information 

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. 

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. 

Behavioural advertising 

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

You can opt out of targeted advertising by using the links below (Please note that these opt-out links may change over time): 

- Facebook: https://www.facebook.com/settings/?tab=ads 

- Google: https://www.google.com/settings/ads/anonymous 

- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads 

- Amazon: https://www.amazon.com/gp/help/customer/display.html?nodeId=201909010

- LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

- Twitter: https://twitter.com/personalization

- Instagram: https://www.instagram.com/about/legal/privacy/ad-settings/

- Pinterest: https://help.pinterest.com/en/articles/personalization-and-data

- Snapchat: within the app settings

- TikTok - within the app settings

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. 

Data retention 

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We MAY engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
• Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.

Selling personal information

Our Site sells Personal Information, as defined by the California Consumer Privacy Act of 2018 (“CCPA”).

We may sell or disclose the personal information of California residents to third parties. If you wish to opt-out of the sale of your personal information, please click on the [Do Not Sell My Personal Information] link on our website and follow the instructions provided.

We may also share your personal information with service providers who perform services on our behalf, such as payment processors, shipping companies, and marketing partners. We require our service providers to use your personal information only as necessary to provide services to us and to maintain the confidentiality and security of your personal information.

California residents have the right to request that we disclose the categories and specific pieces of personal information that we have collected about them, as well as the categories of sources from which we collected the information, the purpose for which we collected the information, and the categories of third parties with whom we shared the information. To exercise your right to know or your right to delete your personal information, please contact us.

We do not discriminate against California residents who exercise their privacy rights under the CCPA. However, we may offer financial incentives or charge different prices or rates for goods or services based on the value of the personal information that we collect from you. If we offer such incentives or different prices or rates, we will provide you with a notice and obtain your opt-in consent before doing so.

Your rights 

GDPR - If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. 

Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

CCPA - If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above.

If you would like to designate an authorised agent to submit these requests on your behalf, please contact us.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimise your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Name	Function	Duration
_ab	Used in connection with access to admin.	2y
_secure_session_id	Used in connection with navigation through a storefront.	24h
_shopify_country	Used in connection with checkout.	session
_shopify_m	Used for managing customer privacy settings.	1y
_shopify_tm	Used for managing customer privacy settings.	30min
_shopify_tw	Used for managing customer privacy settings.	2w
_storefront_u	Used to facilitate updating customer account information.	1min
_tracking_consent	Tracking preferences.	1y
c	Used in connection with checkout.	1y
cart	Used in connection with shopping cart.	2w
cart_currency	Used in connection with shopping cart.	2w
cart_sig	Used in connection with checkout.	2w
cart_ts	Used in connection with checkout.	2w
cart_ver	Used in connection with shopping cart.	2w
checkout	Used in connection with checkout.	4w
checkout_token	Used in connection with checkout.	1y
dynamic_checkout_shown_on_cart	Used in connection with checkout.	30min
hide_shopify_pay_for_checkout	Used in connection with checkout.	session
keep_alive	Used in connection with buyer localization.	2w
master_device_id	Used in connection with merchant login.	2y
previous_step	Used in connection with checkout.	1y
remember_me	Used in connection with checkout.	1y
secure_customer_sig	Used in connection with customer login.	20y
shopify_pay	Used in connection with checkout.	1y
shopify_pay_redirect	Used in connection with checkout.	30 minutes, 3w or 1y depending on value
storefront_digest	Used in connection with customer login.	2y
tracked_start_checkout	Used in connection with checkout.	1y
checkout_one_experiment	Used in connection with checkout.	session
checkout_session_lookup	Used in connection with checkout.	3w
checkout_session_token_<<token>>	Used in connection with checkout.	3w
identity-state	Used in connection with customer authentication.	24h
identity-state-<<token>>	Used in connection with customer authentication.	24h
identity_customer_account_number	Used in connection with customer authentication.	12w

Reporting and Analytics

Name	Function	Duration
_landing_page	Track landing pages.	2w
_orig_referrer	Track landing pages.	2w
_s	Shopify analytics.	30min
_shopify_d	Shopify analytics.	session
_shopify_s	Shopify analytics.	30min
_shopify_sa_p	Shopify analytics relating to marketing & referrals.	30min
_shopify_sa_t	Shopify analytics relating to marketing & referrals.	30min
_shopify_y	Shopify analytics.	1y
_y	Shopify analytics.	1y
_shopify_ga	Shopify and Google Analytics.	session
customer_auth_provider	Shopify analytics.	session
customer_auth_session_created_at	Shopify analytics.	session

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences'' menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do not track 

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

 

Changes 

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. 

Complaints

 If you would like to make a complaint, please contact us by e-mail or by mail using the details provided under “Contact”

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://ico.org.uk/make-a-complaint/

CONTACT US

Business Address: AJ Sells LTD, Smile Therapy, Prenzlauer Promenade 87, 13089 Berlin, Germany

Email Address: support@smile-therapy.co