PRIVACY POLICY

OUR PRIVACY POLICY AT A GLANCE

1. WHO WE ARE. We are JSC E.MOTION ROOMS (company code: 302828858, company registration and postal address: Jasinskio st. 16B, LT-01112, Vilnius. E-mail: info@smartwellness.eu), operating BODY & HEALTH website: www.smartwellness.eu We are responsible for processing and protecting your personal data. This means that we are responsible for how we process and protect your data.
2. WHAT WE USE YOUR DATA FOR. We will use your data, collected online to manage your purchases of products or services and to respond to your queries.
3. WHY WE USE YOUR DATA. We have legal standing to process your data for various reasons. The main reason is that we need to process your data to perform the contract that you accept with us when you make a purchase or enjoy any of our services or functionalities. We also use your data for other reasons, for example, to respond to your queries.
4. WHO WE SHARE YOUR DATA WITH. We share your data with service providers who provide us with assistance or support or third party providers inside or outside the European Union.
5. YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In certain cases, you are also entitled to other rights, such as, for example, to object to us using your data, or to transferring your data.

We encourage you to read our full Privacy Policy below to understand in depth the manner in which we will use your personal data and your rights over your data.

OUR PRIVACY POLICY

We are JSC E.MOTION ROOMS (company code: 302828858, company registration and postal address: Jasinskio st. 16B, LT-01112, Vilnius. E-mail: info@smartwellness.eu), operating BODY & HEALTH website: www.smartwellness.eu. We need your personal data to perform the contract that you accept with us when you make a purchase or enjoy any of our services or functionalities. We also use your data for other reasons, for example, to respond to your queries. We are responsible for processing and protecting your personal data. This means that we are responsible for how we process and protect your data.

In this Privacy Policy, you will find all relevant information applicable to our use of our clients personal data, regardless in our website www.smartwellness.eu. When we speak about our Platform, we refer, in general, to our website: www.smartwellness.eu.

We are transparent about what we do with your personal data, to help you to understand the implications of the way in which we use your data, and the rights you are entitled to in relation to your data:

WHY WE PROCESS YOUR PERSONAL DATA

Depending on the purpose for which we process your data from time to time, as explained above, we need to process one or other data, which will in general be, depending on each case, as follows:

• your identity data (for example, your name, surname, language and country from which you interact with us, contact data, etc.);
• economic and transactions information (for example, your payment or card data, information on your purchases, orders, returns, etc.);
• connection, geolocation and/or browsing data (if you interact with us from your mobile phone, for example);
• commercial information (for example, if you have subscribed to our newsletter),
• information about your tastes and preferences.

Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the Platform, we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please take into account that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities.

Depending on how you interact with our Platform, i.e., depending on the services, products or functionalities that you wish to enjoy, we will process your personal data for the following purposes:

PURPOSE

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1. For the development, performance and execution of the purchase or services contract that you executed with Us on the Platform

This purpose includes processing your data, mainly:

▪To contact you for updates or informative notices related to the contracted functionalities, products or services, including quality surveys and to be able to establish the degree of customer satisfaction with the provided service;

▪To manage payment of the products that you purchase, regardless of the payment procedure used. For example:

▪If on purchasing any of our products through the Website www.smartwellness.eu, you opt to activate the functionality of save your card data for future purchases, we need to process the indicated data for activation and development of that functionality. Consent to the activation of this functionality enables your autocompleted payment data to appear in subsequent purchases so that you do not need to introduce them in each new process, and these data will be deemed valid and effective for subsequent purchases. You may change or cancel your cards at any time through the section on payment information, either of your Website registered user account.

2. To meet requests or applications that you make through the Customer Support channels

We only process the personal data that are strictly necessary to manage or resolve your request or application.

3. Analysis of usability and quality to improve our services

If you access our Platform, we inform you that we will treat your browsing data for analytic and statistic purposes, i.e., to understand the manner in which users interact with our Platform and thus be capable of introducing improvements in the Platform. In addition, we occasionally perform quality surveys and actions to know the degree of satisfaction of our customers and users and detect those areas in which we may improve.

HOW WE ARE LEGALLY PERMITTED TO PROCESS YOUR DATA?

The legal terms on which we are permitted to process your personal data also depends on the purpose for which we process them, as explained in the following table:

Purpose

Legal standing

1. Development, performance and making of the purchase or services contract

We process your data because their processing is necessary for us to make the purchase or services contract with you.

Certain processing of data related to the purchase process is activated only because you request or authorise it, as is the case of the storage of payment (card) data for future purchases.In these cases, our processing of your data is supported by your own consent.

We consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud when you make a purchase. We understand that the processing of these data is positive for all the participating parties when a purchase is paid and in particular for you, since this allows us to establish measures to protect you from fraud attempts by third parties.

2. Customer Support

We consider that we have legitimate interest in answering the requests or queries raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the queries raised.

When you get in touch with us, in particular, for the management of incidents related to your order or the product/service acquired through the Platform, the processing of your data is necessary to perform the purchase contract.

When your request is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations.

3. Analysis of usability and quality

We consider that we have a legitimate interest in analysing the Platform usability and the user's satisfaction degree, since we understand that that the processing of these data is also beneficial for your because the purpose is to improve the user experience and provide a higher quality service.

HOW LONG WILL WE KEEP YOUR DATA?

The time for which we will keep your data will depend on the purposes for which we process them, as explained below:

Purpose

Time for which the data are kept

1. Development, performance and execution of the purchase or services contract

We will process your data for the time necessary to manage the purchase of the products or services that you buy, including potential returns, complaints or claims related to the purchase of the product or service in question.

Sometimes, we will only process the data until the time when you decide, as is the case of payment (card) data that you requested us to store for future purchases.

2. Customer Support

We will process your data for the time necessary to meet your request or application.

3. Analysis of usability and quality

We will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymise your browsing data.

Notwithstanding the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time-barred we will proceed to delete the personal data.

DO WE SHARE YOUR DATA WITH THIRD PARTIES?

To achieve the purposes mentioned in this Privacy and Cookies Policy, we must give access to your personal data to third parties that provide us with support in the services that we offer your, i.e.:

▪financial institutions,
▪anti-fraud detection and prevention entities,
▪technological service providers,
▪logistic, transport and delivery partners and service providers,
▪providers of customer support related services,
▪advertising and marketing related partners and service providers.

For service efficiency purposes, some of these providers are located in territories outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union, in other words, the United States of America. In such cases, we inform you that we will transfer your data with adequate safeguards and always keeping your data safe:

WHAT YOUR RIGHTS ARE WHEN MAKING YOUR DATA AVAILABLE TO US

We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, we that you may exercise your rights free of charge by writing us an e-mail to mail address (info@smartwellness.eu), simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.

In particular, notwithstanding the purpose or legal basis we use to process your data, you have the following rights:

• To request access to your personal data that we hold. We remind you that where you are a Platform registered user you may also consult this information in the relevant section of your online account.
• To request that we rectify the personal data that we hold. Please bear in mind that if you are a registered user on the Platform, you may also access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy and Cookies Policy.
• To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.
• To request that we cancel or limit the processing of your personal data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them longer that necessary.

If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time. Some of the circumstances in which you may withdraw your consent are detailed in section 2 where we explain for which purposes we process your data.

When we are legally permitted to process your data due to your consent or to for the purposes of a contract, as explained in section 3, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly without impediments on our part.

In addition, where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.

WHAT HAPPENS WHEN YOU PROVIDE US WITH DATA OF THIRD PARTIES?

We offer functionalities or services that require us to process the personal data of a third party that you must provide, such as in the case of purchase delivery to the third part. If you provide us with personal data of third parties, you confirm that you informed them of the purposes and of the manner in which we need to process their personal data.

CHANGES TO THE PRIVACY POLICY

We may amend the information contained in this Privacy and Cookies Policy when we consider this appropriate. Should we do so, we will notify you by various procedures through the Platform (for example, through a banner, a pop-up or a push notification), or we may even send you a notice to your e-mail address when the change in question is relevant to your privacy, for you to be able to review the changes, assess them and, as the case may be, object or unsubscribe from ay service or functionality. In any case, we suggest you to review this Privacy and Cookies Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website www.smartwellness.eu.

INFORMATION ON COOKIES

We use cookies and similar devices to facilitate your browsing in the Platform, understand how you interact with us and, in certain cases, to be able to show you advertisements in accordance with your browsing habits. Please read our Cookies Policy to understand with greater detail the cookies and similar devices that we use, their purpose and other information of interest.

What is a Cookie? A Cookie is a small text file that a website stores on your PC, telephone or any other device, with information about your navigation on that website. Cookies are necessary to facilitate browsing and to make it more user-friendly, and they do not damage your computer.

While this Policy uses the general term “Cookies”, as they are the main method for storing information used by this website, the browser's "Local Storage" space is also used for the same purposes as the Cookies. All the information included in this section is also applicable to this "Local Storage".

What are Cookies used for on website www.smartwellness.eu? Cookies are an essential part of how our website works. The main purpose of our Cookies is to improve your browsing experience. For example, they are used to remember your preferences (language, country, etc.) while browsing and on future visits.
The information collected by the Cookies also enables us to improve the site by estimating numbers and patterns of use, the suitability of the website to the individual interests of the users, quicker searches, etc. On occasion, if we have obtained your informed consent in advance, we may use Cookies, tags or other similar devices to obtain information that enables us to show you, either from our own website or from third-party websites or any other means, advertising based on the analysis of your browsing habits.

What are Cookies NOT used for on this website?We do not store sensitive personal information, such as your address, your password, your credit or debit card data, etc. in the Cookies we use.

Who uses the information stored in Cookies? The information stored in the Cookies from our website is used exclusively by us, except for those identified below as "third-party cookies", which are used and managed by external entities to provide services requested by us to improve our services and the experience of the user when browsing our website. The main services for which these "third-party cookies" are used are to obtain access statistics and to guarantee the payment transactions that are carried out.

How can I avoid using Cookies on this website? If you prefer to avoid the use of Cookies on this page, taking into account the above-described limitations, you must first disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website.
You may use this option for preventing the use of Cookies at any time.

How do I disable and prevent the use of Cookies? You may restrict, block or delete the Cookies from this website at any time by changing the configuration of your browser following the steps indicated below. While the settings are different in each browser, Cookies are normally configured in the "Preferences" or "Tools" menu. For further details on configuring Cookies in your browser, see the "Help" menu in the browser itself.

QUESTIONS AND FEEDBACK

We welcome your questions, comments and feedback. Please send all questions, comments and feedback to us via the contact information provided on our "Contact Us” webpage.

Last updated June 2021