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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 Data Processing
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 the 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 provider.
Payments may be made through third-party payment services. Such services process payment data in accordance with their own privacy policies and security practices.
2.3. Data Collected Automatically
When you visit the Website, the following data may be collected automatically:
• IP address;
• device type;
• operating system;
• browser type and version;
• information about the pages you visit;
• date and time of your visit;
• source from which you accessed the Website;
• technical information about your use of the Website;
• information stored through cookies and similar technologies.
In certain cases, IP addresses and cookie identifiers may be considered personal data under the GDPR.
3. How We Use Personal Data
We may use personal data for the following purposes:
3.1. Fulfilling Orders
For:
• placing and processing orders;
• confirming purchases;
• providing access to purchased digital materials;
• sending links or other information necessary to access the purchased product;
• processing refunds and handling order-related requests.
3.2. Communicating with Users
We may use contact details to:
• respond to inquiries;
• provide technical support;
• resolve issues related to an order;
• notify 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 in an email or by contacting us at support@smitholga.com.
Unsubscribing from marketing communications does not affect the processing of data necessary to fulfill a purchase already made or to 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 operation of the Website.
Where consent is required by applicable law for the use of certain analytics cookies, such technologies will not be used until 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 Data Processing
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 Website security, prevent fraud, or improve certain processes, where such a basis is permitted by applicable law;
• legal obligation — where processing is necessary to comply with applicable 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 transferred to or made accessible to third-party service providers that help us operate our services.
These may include:
• payment service providers;
• digital product delivery services;
• email and newsletter services;
• hosting providers;
• analytics services;
• Website protection and security services;
• technical and IT service providers;
• government authorities or other parties where such 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 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 for by law.
7. Cookies and Similar Technologies
The Website may use cookies and similar technologies.
They may be used for:
• ensuring the proper operation of the Website;
• operating the shopping cart and checkout process;
• saving user preferences;
• determining language or other settings;
• analytics;
• marketing and advertising functions, where such functions are used.
Necessary Cookies
Some cookies are technically necessary for the operation of the Website. Without them, certain functions, such as the shopping cart or checkout, may not work 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 the user’s preferences and applicable legal requirements.
Where consent is required for their use, users must have the option to:
• accept them;
• reject them;
• change their choice later.
Refusing non-essential cookies should not prevent access to the core functionality of the Website.
8. Data Retention Period
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 its processing.
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 expires, the data are 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 personal 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 is being processed;
• obtain a copy of their personal data;
• request correction of inaccurate or incomplete data;
• request the deletion of personal data;
• request 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 this is provided for by applicable law;
• lodge a complaint with the competent data protection authority.
To exercise these rights, users may contact:
Before fulfilling a request, we may ask the user to verify their identity where necessary to protect personal data against 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 for unsubscribing where technically feasible and required by applicable law.
Unsubscribing from marketing communications does not mean that information we are legally required to retain, or information necessary to fulfill an order already placed, will be deleted.
12. Children’s Data
The Website is not intended for children who are not legally permitted 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 notify us at:
13. Third-Party Websites and Services
The Website may contain links to third-party websites, social media platforms, or other online services.
After you navigate to 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 expressly 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 last update will be indicated at the top of this document.
If the changes are significant, we may also notify users in another manner where required by applicable law.
16. Contacts
If you have any questions regarding this Privacy Policy or the processing of personal data, please contact us:
Smith Olga
Email: support@smitholga.com
Website: smitholga.com