PRIVACY POLICY

Smiley Bones recognizes the importance of privacy, security and data protection for its customers and for all data holders who may have their Personal Data (as defined below) or otherwise processed through Smiley Bones’s systems. Smiley Bones makes every effort to provide adequate protections throughout its operations and to implement the most consistent and stringent policies and procedures.

This Privacy Policy hereby informs you, visitor of Smiley Bones website or mobile application, or who provides data, irrespective of its nature (“You”), of Smiley Bones’s privacy practices and indicates the choices that You may make within the scope of the collection and use of data related to You.

For the purposes of this Privacy Policy, personal data (“Personal Data”) means any data that refers to an identified or identifiable individual. Personal Data shall be Personal Data in nature, whenever there is a possibility that You are identified, either directly or indirectly, by reference to a unique identifier such as your name, an identification number, location data, or other specific factors of your identity. With respect to Smiley Bones, Partners’ Personal Data is not, in principle, considered Personal Data.

  1. SCOPE
    This Privacy Policy describes the processing – which includes the collection or access, use and storage of your Personal Data by Smiley Bones.
    By agreeing to this Privacy Policy, You represent and agree that Smiley Bones may process your Personal Data pursuant to the terms set forth herein.
  2. THIRD-PARTY APPLICATIONS
    This Privacy Policy does not apply to third-party applications, products, services, websites or social media features that may be accessed through links we provide for your convenience and information (“Third-Party Applications”). Access to these links will cause You to leave Smiley Bones’s virtual environment and may result in the collection or sharing of information about You by third parties. Smiley Bones does not control, endorse or provide any warranties with respect to Third Party Applications or their privacy practices, which may be different from those of Smiley Bones. In this regard, we encourage You to read carefully the privacy policies of any Third-Party Application with which You interact before agreeing to the collection and use of your Personal Data.
  3. PERSONAL DATA COLLECTED BY THE WEBSITE AND APPLICATION
    Smiley Bones collects your Personal Data when You access the Website or Smiley Bones’s application. When contacting Smiley Bones for buying purposes, You must provide us your name, your contact details, such as e-mail address.
    If and when your Personal Data is collected in another environment or for other purposes (e.g., registration for employment), You will be duly notified and consequently will have the opportunity to exercise your right of choice.
    Whenever You visit Smiley Bones website, Smiley Bones also receives and saves in our servers your Web browser’s logs, including the type and version of your computer’s or mobile device’s operating system, Web browser type and language, IP address, and geographical areas derived from your IP address, Smiley Bones’s cookie data, file data, access timestamps, and the length of the visits, and the Websites you visited before accessing Smiley Bones Websites. We may map this data to the Personal Data You provide for the purposes detailed in the present Privacy Policy.
    When you use our applications (Websites) for mobile devices, we also automatically collect information about the mobile device and its use and activity in our mobile applications. For example, we collect the type and version of your device’s mobile operating system, Web browser type, device type, geo-location data, Wi-Fi network connection data, Internet Protocol (IP) address, device identifiers, access timestamp, and length of the visits, as well as other data.
  4. PERSONAL DATA COLLECTED BY THIRD PARTIES
    We may collect your Personal Information when You provide it to a third party for purposes of buying at Smiley Bones. In this process, third parties use their own means to collect data related to You and, through an Agreement, allow Smiley Bones to also have access to such data for buying to take effect.
    The data-collecting third parties have a legal obligation to obtain the respective consents and authorizations (the “Consents”) that You freely and unequivocally want to grant for processing of your Personal Data. Smiley Bones relies on the content and scope of these Consents to properly process your Personal Data. Although Smiley Bones contractually requires the Consents obtained by third parties to be suitable, i.e., compliant with the applicable regulations and, especially, reflect the Personal Data processing purposes, Smiley Bones disclaims any liability arising from the potential inappropriateness of such Consents.
    With respect to Personal Data obtained through third parties, Smiley Bones’s commitment is limited, in principle, to provide You as much transparency as possible regarding how Smiley Bones accesses, stores and uses your Personal Data. Smiley Bones does this as a way to establish a trust relationship with You. No legal obligation requires Smiley Bones to do so.
  5. PERSONAL DATA COLLECTED AUTOMATICALLY
    Cookies are text files containing small amounts of data that are downloaded by your device, or, more precisely, to by Web browser you use on your device when You visit a Website. The entity that installs cookies in your Web browser can, then, read the information contained in the cookie. Cookies are usually categorized as “session cookies,” which do not remain on your device after you close the Web browser, or “persistent cookies,” which will normally remain on your device until You delete them or, alternatively, until they expire.
    When You visit our Website, we place information on your computer in the form of a cookie, which is automatically recognized the next time You visit us. Cookies allow us, e.g., to customize our website to suit your interests. If You do not want Smiley Bones to recognize your computer again at a later time, set your Web browser to delete cookies from your computer, block all cookies, or notify You before a cookie is saved. Note that, once You request such deletion, You may be unable to take advantage of all the functionalities of Smiley Bones’s Website. In this regard, note that Smiley Bones uses certain cookies that are not related to on-line advertising: (i) account access security cookies; (ii) functional cookies, which preserve the functionality of navigation elements; and (iii) language or regional setting cookies.
    Smiley Bones may also track IP addresses for purposes of managing its systems, reporting aggregate information, Website tracking, preventing our servers from being hacked, and for other purposes detailed in the present Privacy Policy.
  6. HOW WE USE YOUR PERSONAL INFORMATION
    Smiley Bones uses your Personal Data to offer online shop services.
    Smiley Bones also uses your Personal Data to enhance its relationship with You and to provide You with better services, including customizing your interaction and experience with us. For example, we may use your Personal Information to:
    1. run our regular business, including to verify your identity, complete transactions and orders for our products or services, manage your account, process payments, and conduct business surveys and analysis;
    2. for staff training and quality assurance purposes (which may include monitoring or logging of calls to our customer support service) and to improve our internal operations and the performance of our systems, products and services, including innovation activities such as the creation of new products , features and services using research and development tools, and embedding data analysis activities.
    3. improve your experience with Smiley Bones by maintaining accurate contact and registration data, by providing appropriate and improved products, services and features that may interest You and enable You to participate in contests and surveys;
    4. respond to your comments, questions and complaints;
    5. send You service-related information, including confirmations, invoices, technical notices, updates, security alerts, and administrative and support messages;
    6. inform You of promotions, future events and news about products and services offered by Smiley Bones and our Partners;
    7. relate or combine information about You with other data we receive from third parties to help us understanding your needs and provide You with a better, more customized service;
    8. enforce our terms and conditions or protect our business, Partners or customers;
    9. prevent, investigate and avoid fraudulent, unauthorized or illegal activities.
  7. Smiley Bones may transfer your Personal Data to third parties. Based on your unequivocal Consent, Smiley Bones may also combine your Personal Data with data that Smiley Bones collects automatically and with Personal Data that Smiley Bones receives from third parties.
  8. SHARING AND TRANSFERRING PERSONAL DATA
    We do not share Personal Data with third parties unless You have previously agreed to it or unless permission or requirement based on law is provided.
    We may transfer Personal Data to other Smiley Bones entities. In order to ensure that your Personal Data remains secure, Smiley Bones is contractually required to comply with the present Privacy Policy and our internal conduct practices relating to privacy. Our internal policies and standards are also shared annually with our employees as part of our specific compliance program. By accessing this Website, You agree to the transfer and sharing of your Personal Data between Smiley Bones entities.
    Like any other company, Smiley Bones relies on service providers to manage and support, on behalf of and by order of Smiley Bones, certain aspects of our operations. Such service providers may be located in England or in other countries, and may provide services such as data hosting, IT and cloud computing services, debt collection, fraud management services, customer support, and advertising and marketing activities. Our service providers are under the contractual obligation to adequately safeguard any Personal Data they receive from Smiley Bones and are prohibited from using Personal Data for any purpose other than providing the services under their responsibility, as instructed by Smiley Bones.
    We may also share your Personal Information when we believe in good faith that we have the obligation to: (i) comply with a law, regulation or court order; (ii) respond to requests for information from a regulatory agency, law enforcement agency and other public authorities, including in cases related to national security; (iii) enforce and/or protect Smiley Bones’s property or rights, including to investigate fraud and help preventing security threats – including information security threats – or other criminal or malicious activity; or (iv) protect the legitimate interests of third parties, including the personal safety of Smiley Bones employees.
    Smiley Bones may, for strategic reasons, among others, decide to sell, buy, merge or reorganize its business. In such cases, Smiley Bones may share or transfer your Personal Data with/to any interested parties or buyers.
    Smiley Bones may also share your Personal Information with: (i) credit assessment and fraud prevention agencies; (ii) debt collection agencies (for outstanding debts with us); (iii) other third parties, including our business partners – in this case, upon prior notice and after the relevant consent. If You choose to provide your Personal Information to such third parties, your Personal Data will be processed pursuant to their privacy policy, which may differ from Smiley Bones’s policies and practices.
  9. ADVERTISING AND MARKETING
    You agree that we may collect, process and use your Personal Data for advertising or market research purposes, and, in particular, improve Smiley Bones’s services. We may collect, classify and use your Personal Data together with that of other Personal Data holders in order to improve our services. Furthermore, Smiley Bones may use your Personal Data to provide You unique services and special opportunities that are compatible with your characteristics and preferences.
  10. CHILDREN’S PRIVACY
    Smiley Bones collects or processes data from children only with the due authorization of their parents or guardians, and strictly for the purpose of checking in and providing the necessary services during the stay. Except as provided above, Smiley Bones does not knowingly collect or treat Personal Data associated with children.
  11. COMMUNICATIONS VIA E-MAIL AND INSTANT COMMUNICATORS
    We shall use your e-mail address and phone number only for the purposes for which You have authorized such use (e.g., responding to messages sent by You through Smiley Bones website). You will receive advertising from Smiley Bones by email only if You have agreed to this or if Smiley Bones is endorsed by law to do so without your consent.
    If You have expressly agreed to receive mail marketing or newsletters (e.g., at the time You register or at a later time), You will have agreed to receive communications with content selected or drafted by Smiley Bones, or advertising e-mails at the e-mail address You provided. Smiley Bones communications may be issued at regular or irregular intervals. In addition to information pertaining to Smiley Bones, such communications may contain offers from Smiley Bones or third-party business partners. You may cancel the subscription to Smiley Bones’s communications at any time at [email protected] or, when available, through the link in the messages themselves.
  12. SECURITY OF PERSONAL DATA – PROTECTION OF YOUR PERSONAL DATA
    Smiley Bones adopts the usual procedures and standards for physical, electronic, and managerial security, including encryption and passwords, in an effort to protect your Personal Data from unauthorized access and disclosure, as well as to prevent unwanted communication (spam). However, be advised that no company, including Smiley Bones, can completely eliminate the security risks associated with Personal Data processing.
    The Personal Data we collect may be withheld for the time required to meet Smiley Bones’s legitimate business purposes, including the purposes described in the present Privacy Policy, or for a period of time specifically required or allowed by the applicable law or regulation.
  13. EXERCISING YOUR RIGHTS
    Smiley Bones respects the rights that You hold as the holder of personal data and makes it possible to exercise them under the applicable law.
    Thus, You have the right to confirm that Smiley Bones handles Personal Data relating to You, and to access the Personal Information that You have provided to us or that we keep about You.
    Smiley Bones strives to ensure that the processing of Personal Data complies with the law, and that such processing respects the rights and interests of the holders of personal data. If You note that Smiley Bones keeps incomplete, inaccurate or outdated Personal Data, You have the right to request the correction thereof. Likewise, if You find that Smiley Bones processes unnecessary or excessive Personal Data, or that such processing is in violation of the law, You have the right to request the anonymization, blocking or deletion of the Personal Data subject to such inconsistency.
    In addition, You have the right to request information about the possibility of not giving consent and the consequences of such refusal. If You have previously granted your consent, You have the right to revoke it and to request the deletion of the Personal Data whose processing has been authorized by such consent.
    Further, You have the right to request clarification on how Smiley Bones processes your Personal Information. Likewise, You have the right to request information about the entities with which Smiley Bones has shared your Personal Data.
    If You want the Personal Data maintained by Smiley Bones to be shared with another provider of goods or services, You have the right to request that Smiley Bones provides such portability.
    The foregoing rights shall be exercised through the e-mail address [email protected], and your request will be reviewed by those responsible for the protection of privacy and personal data at Smiley Bones. In certain, your request may be denied based on legitimate grounds, such as when the fulfillment of the request could lead to exposure of Personal Data relating to other holder of personal data; in cases where Smiley Bones is legally prevented to disclose such information; or, furthermore, when Smiley Bones is prevented from fulfilling your request by reason of an agreement with third parties. In all cases of refusal by Smiley Bones, the appropriate justification shall be submitted to You.
  14. AMENDMENTS
    As technology and our services advance, we will also adjust our Privacy Policy. Whenever this happens, we shall publish the new version, which shall indicate the date of the review. If You deem it necessary, You may request by other means the most up-to-date version of our Privacy Policy. Anyway, You should check this page regularly to learn more about the status of this Privacy Policy.
  15. REVOCATION
    If the processing of your Personal Data is, for the most part, based on your consent, please be aware that it may be revoked at any time. In general, the revocation applies, however, to the future use of Personal Data. You may revoke your consent by means of an e-mail sent to Smiley Bones. Consent revocation may mean that certain services shall no longer be available to You, or that You will become subject to restrictions or limitations. Smiley Bones reserves the right to exercise our data activities on a legal basis at any time.
  16. CONTACT US
    If You have any questions or concerns about this Privacy Policy, or about our Personal Data collection and use practices, or about a potential or breach of confidentiality of Personal Data or privacy, You may contact us by e-mail at [email protected]
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