Privacy Policy

Last updated: 15 September 2026

The website smitholga.com (hereinafter referred to as the “Website”) respects users’ right to privacy and the protection of personal data.

This Privacy Policy explains what personal data we may collect, the purposes for which we use it, with whom we may share it, how we protect it, and what rights users have.

We strive to process personal data lawfully, transparently, and only to the extent necessary for the relevant purposes.

1. Who Is Responsible for Processing Your Data

The owner and administrator of the Website is Smith Olga.

For questions regarding the processing of personal data, the exercise of users’ rights, or this Privacy Policy, you may contact us at:

Email: support@smitholga.com

Website: smitholga.com

If applicable law requires the appointment of a specific representative or data protection officer for particular cases, the relevant information will be provided separately.

2. What Personal Data We May Collect

Depending on how you use the Website, we may process the following categories of data.

2.1. Data You Provide Directly

This may include:

• first and last name;
• email address;
• contact details;
• information necessary to place an order;
• information about purchased digital products;
• messages and requests that you send to us;
• information that you voluntarily provide through contact forms, comments, or when communicating with us through social media.

We do not ask users to provide more personal data than is necessary for the relevant purpose.

2.2. Order and Payment Data

When placing an order, we may receive information necessary to process and confirm your purchase.

Payment card details, such as the full card number or security code, are not stored on the Website if they are processed directly by the relevant payment service provider.

Payments may be processed through third-party payment services. Such services process payment data in accordance with their own privacy policies and security rules.

2.3. Data Collected Automatically

When you visit the Website, the following information may be collected automatically:

• IP address;
• device type;
• operating system;
• browser type and version;
• information about pages visited;
• date and time of the visit;
• referral source;
• technical information about the use of the Website;
• information stored through cookies and similar technologies.

An IP address and cookie identifiers may, in certain circumstances, be considered personal data under the GDPR.

3. How We Use Personal Data

We may use personal data for the following purposes:

3.1. Order Fulfillment

For:

• placing and processing orders;
• confirming purchases;
• providing access to purchased digital materials;
• sending links or other information necessary to receive purchased products;
• processing refunds and handling order-related inquiries.

3.2. Communication with Users

We may use contact details for:

• responding to inquiries;
• providing technical support;
• resolving order-related issues;
• informing users about important changes related to purchased products or the operation of the Website.

3.3. Marketing and Newsletters

If a user has separately agreed to receive promotional or informational communications, their email address may be used to send:

• news;
• information about new products;
• special offers;
• promotions;
• other marketing information.

Users may unsubscribe from marketing communications at any time by using the unsubscribe link provided in the email or by contacting us at support@smitholga.com.

Unsubscribing from marketing communications does not affect the processing of data necessary to fulfill an existing purchase or comply with legal obligations.

3.4. Analytics and Website Improvement

We may use analytics tools, including Google Analytics, to understand how users interact with the Website.

This may include information about:

• pages visited;
• referral source;
• device and browser;
• general user behavior on the Website;
• technical characteristics of the visit.

Analytics tools are used to improve the structure, functionality, and performance of the Website.

If applicable law requires user consent for the use of certain analytics cookies, such technologies must not be used before the required consent has been obtained.

3.5. Security

Data may be processed for:

• protecting the Website;
• preventing fraud;
• detecting suspicious activity;
• preventing unauthorized access;
• protecting the rights and property of the Website and its users.

3.6. Compliance with Legal Obligations

We may retain and process certain data where necessary to comply with legal requirements, accounting or tax obligations, resolve disputes, or establish, exercise, or defend legal claims.

4. Legal Bases for Processing Personal Data

Depending on the specific circumstances, we may process personal data on the following legal bases:

• performance of a contract — for example, to process and fulfill an order;
• user consent — for example, for certain marketing communications or non-essential cookies;
• legitimate interests — for example, to ensure the security of the Website, prevent fraud, or improve certain processes, where such a legal basis is permitted by applicable law;
• legal obligation — where processing is necessary to comply with legal requirements.

Where processing is based on consent, the user has the right to withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

5. Who We May Share Data With

We do not sell users’ personal data.

For the operation of the Website and the fulfillment of orders, certain data may be shared with or made available to third-party service providers that assist us in operating our services.

These may include:

• payment service providers;
• digital product delivery services;
• email and newsletter services;
• hosting providers;
• analytics services;
• Website security and protection services;
• technical and IT service providers;
• government authorities or other parties where disclosure is required by applicable law.

Such service providers may process personal data only to the extent necessary to provide the relevant services and in accordance with applicable law and their own privacy policies.

6. Transfers of Data Outside the European Economic Area

Some service providers used to operate the Website may be located outside the European Economic Area (EEA) or may process data in other countries.

Where personal data is transferred outside the EEA, such transfers are carried out in accordance with the requirements of applicable data protection laws.

Depending on the specific service provider, this may include an adequacy decision of the European Commission, Standard Contractual Clauses, or other safeguards provided by law.

7. Cookies and Similar Technologies

The Website may use cookies and similar technologies.

They may be used for:

• ensuring the operation of the Website;
• enabling the shopping cart and checkout functionality;
• saving user preferences;
• determining the language or other settings;
• analytics;
• marketing and advertising functions, where such functions are used.

Essential Cookies

Some cookies are technically necessary for the operation of the Website. Without them, certain features, such as the shopping cart or checkout, may not function properly.

Such cookies may be used without separate consent where permitted by applicable law.

Analytics and Marketing Cookies

Non-essential analytics or marketing cookies are used in accordance with user preferences and applicable legal requirements.

Where consent is required for their use, users must have the ability to:

• accept them;
• reject them;
• change their choice at a later time.

Refusing non-essential cookies should not prevent access to the core functionality of the Website.

8. Data Retention

We retain personal data only for as long as necessary for the relevant purpose.

The retention period depends on the type of data and the reason for processing it.

For example:

• data necessary to fulfill an order may be retained for the period required to complete the order and resolve related matters;
• accounting and tax data are retained for the periods required by applicable law;
• data used for marketing communications may be processed until consent is withdrawn or the user unsubscribes, unless another legal basis exists for retaining such data;
• technical and analytics data are retained in accordance with the settings of the relevant services and the necessity of their use.

After the relevant retention period has expired, the data will be deleted, destroyed, or anonymized unless further retention is required by law.

9. Protection of Personal Data

We implement reasonable technical and organizational measures to protect personal data against:

• unauthorized access;
• unlawful processing;
• accidental loss;
• alteration;
• disclosure;
• destruction.

However, no method of transmitting or storing information over the Internet can guarantee absolute security.

If a data security breach is identified, we will take appropriate measures in accordance with applicable legal requirements.

10. Users’ Rights

Depending on applicable law, users may have the right to:

• obtain information about which of their personal data are being processed;
• receive a copy of their personal data;
• request the correction of inaccurate or incomplete data;
• request the deletion of personal data;
• request the restriction of processing;
• object to certain types of processing;
• withdraw consent where processing is based on consent;
• receive personal data in a structured format and, where provided by law, transfer it to another service provider;
• not be subject to a decision based solely on automated processing where such protection is provided under applicable law;
• lodge a complaint with the competent data protection authority.

To exercise these rights, users may contact us at:

support@smitholga.com

Before processing a request, we may ask the user to verify their identity where necessary to protect personal data from unauthorized access.

11. Marketing Communications

If a user has subscribed to marketing communications, they may unsubscribe at any time.

Each marketing email will include a method of unsubscribing where technically possible and required by applicable law.

Unsubscribing from marketing communications does not mean that we will delete information that we are legally required to retain or that is necessary to fulfill an existing order.

12. Children’s Data

The Website is not intended for children who are not legally able to independently make the relevant purchases or provide consent for the processing of personal data.

We do not knowingly intend to collect personal data from children without an appropriate legal basis.

If you become aware that a child has provided us with personal data in circumstances where such processing is not permitted by law, please contact us at:

support@smitholga.com

13. Third-Party Websites and Services

The Website may contain links to third-party websites, social media platforms, or other online services.

Once you access a third-party resource, its own privacy policy may apply separately.

We do not control the privacy policies of third-party services and recommend reviewing them before providing any personal data.

14. Automated Decision-Making

We do not use personal data to make decisions that produce legal effects concerning users or similarly significantly affect them solely on the basis of automated processing, unless otherwise explicitly communicated to the user in accordance with applicable legal requirements.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example, due to changes in the functionality of the Website, the services we use, or legal requirements.

The current version will always be published on this page.

The date of the latest update will be indicated at the top of this document.

If the changes are significant, we may also notify users by additional means where required by applicable law.

16. Contacts

If you have any questions regarding this Privacy Policy or the processing of personal data, please contact:

Smith Olga

Email: support@smitholga.com

Website: smitholga.com