DATE OF LAST UPDATE: 19 June 2020
Thank you for your interest in Smacircle. Smacircle LMT Ltd. operates http://www.smacircle.com. Here we describe the privacy practices for our devices, applications, software, websites, APIs, products, and services (the “Services”). You will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.
Specifically, we’ll cover:
When you use our Services, we collect the following types of information.
Some information is required to create an account on our Services, such as your name, email address, password, and in some cases your mobile telephone number. This is the only information you have to provide to create an account with us. You may also choose to provide other types of information, such as country information.
When you place an order with Smacircle, or contact us for customer service, you may provide us with your contact information including your name, email address, shipping address, billing address, and phone number(s).
When you place an order with Smacircle or engage in financial transactions by using Smacircle Products and Services, you provide your payment information, including your name, credit or debit card number, card expiration date, CVV code, and billing address. We do not store this payment information. We store your delivery address to fulfill your order. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms.
When you contact us, we may collect information about your communications with us, including your contact information, and the time, topic, and content of your communications.
When you activate Smacircle products, request for after-sales service, you may provide us with information about your Smacircle device, including model and serial number. Our after-sales team may ask for your product information to provide the service you requested.
When you activate the Smacircle app, you may provide us with geolocation information. In order to provide your location, you may be required to enable certain features of your mobile phone (such as Wi-Fi, and Bluetooth).
When you access or use our Services, we receive certain usage or network activity information. This includes information about your interaction with the Services, for example, when you view or search content, install applications or software, create or log into your account, pair your device to your account.
websites and online services. Cookies are used to collect information, including
personal data, from you. Cookies are small files which, when placed on your
device, enable us to provide certain features and functionality.
We also collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, operating system, or mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.
We use the information we collect for the following purposes:
We will not disclose your information that we collect through Smacircle Products and Services to third parties except as described in this Policy or as we disclose to you at the time the information is collected. We may disclose information to third parties in the following circumstances:
You may update, correct, or delete certain Smacircle account information and
preferences by accessing your account-preferences page, available through
certain Smacircle Products and Services, including the smacircle.com websites
and various mobile applications. If you receive commercial email or text
messages from us, you may unsubscribe at any time by following the instructions
contained within the email or text message. You may also opt-out from
receiving commercial email or text messages from us by sending your request to
us by email at email@example.com.
If you are located in the European Economic Area, you may also have the right to request access to additional information, including the right to request access to and receive certain information we maintain about you; to update or correct inaccuracies in the information we maintain about you; to receive a copy of the information which you provided for its transmission to another company; to object to the processing on grounds relating to your particular situation; and to have the information blocked, deleted, or erased, as appropriate. When we process personal data on the basis of your consent, you can also withdraw your consent. If you withdraw your consent, we will apply your preferences going forward, and this will not affect the lawfulness of the processing before you withdraw your consent.
Note, however, that if you exercise your right to object or your rights of blocking, deletion or to be “forgotten,” or if you decline to share certain information with us, or if you withdraw your consent to our processing of information about you, we may not be able to provide to you some, or any, of the features and functionality of Smacircle Products and Services.
Likewise, if you close your Smacircle account, you will not be able to sign in to Smacircle Products or Services or access any of your information. However, you can open a new account at any time. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit, as authorized under applicable law, for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information will be subject to those third parties’ policies.
If you wish to exercise any rights you have under applicable data protection law, including the right to access, amend or delete any information we hold about you, you may contact us at firstname.lastname@example.org.
We retain your information to provide service to you, or as required by applicable laws or regulations. We aim to retain your information only for the period necessary to fulfill our obligations under this Policy, unless otherwise required or permitted by law. We will carefully assess the need to collect data, the type of data collected, relevant legal framework, and the statute of limitations when determining the retention period.
Except for certain products that are marked as “14+” or “for customers over the age of 14,” Smacircle Products and Services are not directed to children under the age of 14. We do not knowingly collect information from children under the age of 14 without obtaining parental consent. If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at email@example.com.
We work hard to keep your data safe. We use certain physical, organizational, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards. If you have a security-related concern, please contact Customer Support.
We operate internationally and your information collected by Smacircle may be
transferred to and accessed by Smacircle entities and business partners
We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and Swiss-US Privacy Shield, and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us. Smacircle complies with the Privacy Shield principles regarding the collection, use, sharing, and retention of personal information as described in our Privacy Shield certifications.
Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a Smacircle account and click “I agree” to data transfers, irrespective of which country you live in. If you later wish to withdraw your consent, you can delete your Smacircle account by contacting the customer support.
If you live in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please review these additional privacy disclosures under the European Union’s General Data Protection Regulation (“GDPR”).
Smacircle is your data controller and provides the Services if you live in the EEA, UK or Switzerland.
For personal data subject to the GDPR, we rely on several legal bases to process
the data, including:
In addition to the various controls that we offer, in certain circumstances, you
can seek to restrict our processing of your data or object to our processing of
your data based on our legitimate interests, including as described in the How
We Use Information section. Under the GDPR, you have a general right to object
to the use of your information for direct marketing purposes. Please see your
notification settings to control our marketing communications to you about
Smacircle products. Please note that you can always delete your account at
If you need further assistance regarding your rights, please contact us at firstname.lastname@example.org, and we will consider your request in accordance with applicable laws.
If you are a California resident, please review the following additional privacy disclosures under the California Consumer Privacy Act ("CCPA").
You have the right to understand how we collect, use and disclose your
personal information, to access your information, to request that we delete
certain information, and to not be discriminated against for exercising your
privacy rights. You may exercise these rights using your account settings and
tools as described in the Your Rights To Access and Control Your Personal Data
section, for example:
By logging into your account and using your account settings, you may exercise your right to access your personal information and to understand how we collect, use, and disclose it. Your account settings also let you exercise your right to delete personal information. Learn more here. If you need further assistance regarding your rights, please contact us at email@example.com, and we will consider your request in accordance with applicable laws.
As described in the Information We Collect section, we collect the categories of
personal information listed below. We receive this information from you, your
device, your use of the Services, third parties, and as otherwise described in this
policy. We use and disclose these categories of information for the business
purposes described in the How We Use Information and How Information Is
Shared sections, respectively. The categories are:
Identifiers, like your name or username, email address, postal address, phone number, IP address, account ID, device ID, cookie ID, and other similar identifiers.
Commercial information, including your payment information and records of the Services or devices you purchased, obtained or considered (for example, if you added them to your shopping cart on the Smacircle site but did not purchase them).
Internet or other electronic network activity information, such as the usage data we receive when you access or use our Services. This includes information about your interactions with the Services and about the devices and computers you use to access the Services.
Geolocation data, including GPS signals, device sensors, Wi-Fi access points, and mobile mast IDs, if you have granted us access to that information.
Electronic,, visual, or similar information, such as your profile photo or other photos.
Other information that you provide, including account information. We never sell the personal information of our users.
time at this page.
If you have questions about this policy or need help exercising your privacy rights, please contact us at firstname.lastname@example.org.