Unikos Global Limited trading as smilerex® of 128 City Road, London, United Kingdom, EC1V 2NX, www.smilerex.com, (hereinafter “Smilerex”, “we” or “us”) appreciates your interest in our company and our products and your visit to our website.
The protection of your privacy when processing personal data as well as the security of all business data is an important concern for us, which we take into account in our business processes. We process personal data collected during your visit to our online offers confidentially and only in accordance with the legal requirements set out in the UK`s Data Protection Act 2018 (DPA) and the EU`s General Data Protection Act (GDPR).
Personal data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.
All personal data that we obtain from you via the website will only be processed for the purposes described in more detail below. This is done within the framework of the respective legal regulations mentioned or only with your consent.\
In particular, Art. 6 GDPR specifies when data processing is permitted. smilerex® collects personal data if:
- you have given your consent (Art. 6 para. 1 lit. a GDPR),
- the data is necessary for the fulfilment of a contract / pre-contractual measures (Art. 6 para. 1 lit. b GDPR),
- the data is necessary for the fulfilment of a legal obligation (Art. 6 para. 1 lit. c GDPR) or
- the data is necessary to protect the legitimate interests of our company, provided that your interests worthy of protection are not overridden (Art. 6 para. 1 lit. f GDPR). Storage duration or criteria for determining the duration
smilerex® processes and stores your personal data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
As a data subject, you have the right to assert your data subject rights against us. There is more information on each right on the Information Commissioners (ICO) website, and you can simply follow the links provided to learn more.
Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the ICO, their contact details can be found on their website.
Please direct all requests for information, requests for information or objections to data processing to us.
When you visit our website, we collect information that you yourself provide. In addition, during your visit to the website, we automatically collect certain information about your use of the website. In data protection law, the IP address is also generally considered to be a personal data. An IP address is assigned to every device connected to the Internet by the Internet provider so that it can send and receive data.
Visiting our website may involve the transfer of certain personal data to third countries, i.e., countries where the GDPR or the DPA is not applicable law. Such a transfer is permissible if the European Commission or the ICO has determined that an adequate level of data protection is warranted in such third country.
In the absence of such an adequacy decision by the European Commission or the ICO, a transfer of personal data to a third country will only take place if appropriate safeguards pursuant to Art. 46 GDPR are in place or if one of the conditions of Art. 49 GDPR is met.
Unless otherwise stated below, we use standard contractual clauses for the transfer of personal data to processors in third countries as appropriate safeguards.
We use the shop system Shopify for the purpose of hosting and displaying our website. Shopify is offered by the service provider Shopify International Limited (Ireland). Unless otherwise stated in the following information, all data collected on our website is processed on our behalf on the servers of Shopify International Limited.
As part of the aforementioned services, data may be transferred to Canada to the company Shopify Inc. For the data transfer to Canada as a third country, i.e., a country in which the GDPR is not applicable law, an adequacy decision of the European Commission is available. The European Commission has thus decided that an adequate level of protection exists in Canada and that the transfer can take place in a permissible manner.
For more information about Shopify's privacy practices, please visit: https://www.shopify.com/legal/privacy
During the purely informative use of our website, general information that your browser transmits to our server is initially stored automatically (i.e., not via registration). This includes by default: browser type/version, operating system used, page accessed, the previously visited page (referrer URL), IP address, date and time of the server request and HTTP status code. The processing is carried out to protect our legitimate interests and is based on the legal basis of Art. 6 (1) f) GDPR. This processing serves the technical administration and security of the website.
The stored data is deleted after 30 days unless there is a justified suspicion of unlawful use based on concrete indications and further examination and processing of the information is necessary for this reason. We are not able to identify you as a data subject from the stored information. Articles 15 to 22 of the GDPR therefore do not apply pursuant to Article 11 (2) of the GDPR, unless you provide additional information that enables you to be identified in order to exercise your rights set out in these articles.
Contact and enquiries
Our website contains a contact form through which you can send us messages. The transfer of your data is encrypted (recognisable by the "https" in the address line of the browser). All data fields marked as mandatory are required to process your request. Failure to provide this information will result in us not being able to process your request. The provision of further data is voluntary. Alternatively, you can send us a message via the contact e-mail address.
If your request is directed towards the conclusion or implementation of a contract with us, Article 6 (1) (b) of the GDPR is the legal basis for data processing. Otherwise, we process the data on the basis of our legitimate interest in contacting persons making enquiries. The legal basis for data processing is then Art. 6 (1) f GDPR.
Data processing for the processing of purchases
If you order a product via our website, we process personal data to process the contract or to provide you with the ordered product. Within the scope of the ordering process, we only process the data that you yourself have entered in the input mask. In order to be able to deliver the ordered products to you, we transmit your data required for the delivery to one of our shipping service providers as specified in the order. You also have the option of creating a customer account. The legal basis for the processing is in each case Article 6 (1) b) GDPR. All data fields marked as mandatory are required for processing your order. Failure to provide this data will result in us not being able to process your order. The provision of further data is voluntary.
We use the payment service provider "Shopify Payments", 3rd Floor, Europa House, Harcourt Building, Harcourt Street, Dublin 2. If you choose a payment method offered via the payment service provider Shopify Payments, the payment processing is carried out by the technical service provider Stripe Payments Europe Ltd, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to whom we pass on the information you provided during the ordering process, together with information about your order (name, address, account number, bank sort code, credit card number if applicable, invoice amount, currency, and transaction number) in accordance with Art. 6 Para. 1 lit. b GDPR. Your data will only be passed on for the purpose of processing payments with Stripe Payments Europe Ltd. and only to the extent necessary for this purpose.
If you choose to use PayPal payment will be processed through the payment system of PayPal. If you have selected PayPal Express as your method of payment, it is necessary for PayPal to transmit the following personal data to PayPal (Europe) S.á.r.l. & Cie, S.C.A. in order to process your payment:
Total amount of the order, Reference on the PayPal account, your e-mail address of the PayPal account, Encrypted PayPal account number. The legal basis for the processing of your personal data is the establishment and implementation of the user contract for the use of the service in accordance with Art. 6 (1) b) GDPR.
On our website you have the possibility to create a customer account. The required information can be found in the registration form. The provision of the information marked as mandatory is mandatory in order for the registration to be completed. Via the customer account, you can use the advantages of shipment tracking and order history as well as ready-made forms during checkout for subsequent orders. The data provided is processed for the purpose of providing the service. The processing is based on the legal basis of Art. 6 (1) b) GDPR.
We offer the possibility to sign up to receive marketing emails such as our newsletter. Once you have signed up, we will send you regular updates on our offers and events and, where applicable, remind you of shop items in your shopping basket. A valid email address is required to sign up. To verify the e-mail address, you will first receive a registration e-mail, which you must confirm via a link (double opt-in). If you subscribe to the newsletter on our website, we process personal data such as your e-mail address and name on the basis of your consent.
The processing is based on the legal basis of Art. 6 (1) a) GDPR. You can revoke your consent at any time with future effect, for example via the "unsubscribe" link in the newsletter or by contacting us via the above-mentioned channels. The legality of the use of the data that has already taken place remains unaffected by the revocation. When you register for the newsletter, we also store the IP address and the date and time of registration. The processing of this data is necessary in order to be able to prove that consent has been given. The legal basis results from our legal obligation to document your consent (Art. 6 para. 1 lit. c) in conjunction with Art. 7 para. 1 GDPR).
The newsletters contain a so-called "web beacon", i.e., a pixel file that is retrieved when the newsletter is opened. When you open the newsletter, technical information such as your browser and system information, IP address and the time of opening are collected. This data and information is used to technically improve our service based on your reading behaviour. This also includes recording when an email or newsletter was opened and whether a link was clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. It is not our intention to observe individual users. The statistical collection and evaluation of the data serves us to recognise the reading habits of our users and thus to better adapt our content to the users. This also serves to send users different content according to the interest of our users.
The legal basis for statistical collection and analysis is Art. 6 (1) f GDPR. We are interested in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of our users.
You can object to the statistical collection and analysis by unsubscribing from the newsletter. Unfortunately, a separate revocation of the statistical evaluation is not possible.
Analysis of our website
We use the Shopify Statistics feature on our website. This allows us to measure the reach of our website and provides us with statistical analysis of visitor behaviour on our website. The data is processed on servers of Shopify International Limited (Ireland), which we have commissioned with the processing.
The legal basis for the data processing in connection with the Shopify statistics function is Art. 6 (1) f GDPR and the processing serves our legitimate interest in the analysis of user behaviour on our website and the possible design according to requirements. You can object to this processing at any time in the cookie settings.
Shopify will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Shopify may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Shopify's behalf.
We only use Google Analytics with IP anonymisation activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by the user's browser is not merged with other data from Google.
We use the Google Universal Analytics variant. This enables us to assign interaction data from different devices and from different sessions to a unique user ID. This allows us to put individual user actions in context and analyse long-term relationships.
The data on user actions is stored for a period of 14 months and then automatically deleted. Data whose storage period has expired is automatically deleted once a month.
The setting of cookies and the further processing of personal data described here takes place with your consent. The legal basis for data processing in connection with the Google Analytics service is therefore Art. 6 (1) a) GDPR. You can revoke your consent at any time under "Cookie settings".
You can also prevent the storage of cookies by Google Analytics by selecting the appropriate settings in your browser software. You can also prevent the collection of information generated by the cookie by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout. If you are visiting our website via a mobile device, you can deactivate Google Analytics by clicking on this link. Please also note that we document your consent in order to comply with our obligation to provide evidence under Article 7 (1) of the GDPR. As we are obliged to do so, this storage is based on the legal basis of Art. 6 para. 1 lit. (c) GDPR).
Tracking & Retargeting
Within our website, so-called "Facebook pixels" of the social network Facebook, which is operated by Meta Platforms Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), are used. With the help of the Facebook pixel, it is possible for Facebook to determine the visitors to our offer as a target group for the display of advertisements, so-called "Facebook ads". Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our website. This means that with the help of the Facebook pixel we want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad.
You can object to the collection by the Facebook pixel and use of your data for the display of Facebook ads. To do so, you can visit the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads or declare the objection via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The legal basis for this processing is Art. 6 para. 1 letter f) GDPR, our legitimate interest.
Processing of data provided to us via our social media pages
We maintain presences in the "social media". Insofar as we have control over the processing of your data, we ensure that they comply with applicable data protection regulations. However, you use these platforms and their functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g., commenting, sharing). With your consent, data may be transferred to a third country outside the EU, which may have a lower level of data protection than the EU (Art. 49 para. 1 p. 1 lit. a GDPR). We maintain our social media profiles in order to communicate with visitors to these profiles es and to inform them about our offers in this way.
In addition, we collect data for statistical purposes in order to be able to further develop and optimise the content and to make our offer more attractive. The data required for this purpose (e.g., total number of page views, page activities and data provided by visitors, interactions) are processed and made available by the social networks. We have no influence on the generation and presentation of this data.
In addition, your personal data is used by the providers of the social media, but also by us for market research, communication and advertising purposes. It is possible, for example, that usage profiles are created based on your usage behaviour and the resulting interests. This allows, among other things, advertisements to be placed within and outside the platforms that presumably correspond to your interests. Cookies are usually stored on your computer for this purpose. Independently of this, data that is not directly collected from your end devices may also be stored in your usage profiles. The storage and analysis also takes place across devices; this applies in particular, but not exclusively, if you are registered as a member and logged in to the respective platforms.
We do not collect or process any other personal data.
The processing of your personal data by us is based on our legitimate interests in effective information and communication pursuant to Art. 6 (1) sentence 1 lit. f GDPR.
If you are asked for consent to data processing, i.e., if you declare your consent by confirming a button or similar (opt-in), the legal basis of the processing is Art. 6 (1) sentence 1 lit. a., Art. 7 GDPR.
If you are a member of a social network and do not want the network to collect data about you via our website and link it to your stored membership data with the respective network, you must
- log out of the respective network before visiting our fan page
- delete the cookies on your device and
- close and restart your browser
After logging in again, however, you will once more be recognisable to the network as a specific user.
For a detailed description of the respective processing and the opt-out options, please refer to the information linked below:
Opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com
Opt-Out: http://www.networkadvertising.org/managing/opt_out.asp and http://www.youronlinechoices.com
Since we do not have complete access to your personal data, you should contact the providers of the social media directly if you wish to assert your rights, as they each have access to the personal data of their users and can take appropriate measures and provide information.
In order to establish or implement the contractual relationship with our customers, it is regularly necessary to process the personal master, contract and payment data provided to us. The legal basis for this processing is Art. 6 (1) b) GDPR. We also process customer and prospect data for evaluation and marketing purposes. This processing is carried out on the legal basis of Art. 6 (1) f GDPR and serves our interest in further developing our offer and informing you specifically about smilerex® offers. Further data processing may take place if you have consented (Art. 6 para. 1 letter a) GDPR) or if this serves the fulfilment of a legal obligation (Art. 6 para. 1 letter c) GDPR).
Use of e-mail address
We may use the email address you provide when registering or ordering to inform you about smilerex®' own similar products and services. The legal basis is Art. 6 para. 1 lit. f) GDPR. You can object to this at any time without incurring any costs other than the transmission costs according to the basic rates. To do so, you can unsubscribe by clicking on the unsubscribe link contained in each mailing or by sending an e-mail to us.
Queries and Complaints
Any comments or queries on this policy should be directed to us. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.