Privacy Policy
SIA “Smartandplay.com”, registration number: 40103883506, legal address: Zemgales iela 43-38, Olaine, Olaines Municipality, LV-2114 (hereinafter referred to as Smartandplay.com) is committed to protecting the privacy of its clients.
Accordingly, we have prepared the principles of the Privacy Policy related to the collection, use, publication, transfer, and storage of customer personal data.
Our online activities are carried out in accordance with the laws of the Republic of Latvia and relevant European Union regulations. Please take a few minutes to familiarize yourself with the principles of our Privacy Policy.
Legal basis for personal data processing
1. Smartandplay.com processes the Client’s personal data based on the following legal grounds:
- for concluding and executing the contract – to conclude the contract upon the Client’s request and ensure its execution;
- for compliance with regulations – to fulfill the obligations set out in applicable external regulations;
- in accordance with the Client’s – data subject’s consent;
- legitimate interests – to realize Smartandplay.com’s legitimate interests arising from the existing obligations between Smartandplay.com and the Client, or the contract concluded, or arising from the law.
2. Smartandplay.com legitimate interests are:
- conduct commercial activities;
- verify the Client’s identity before signing the contract;
- ensure the performance of contract obligations;
- store Client product and service orders, as well as notes about them (e.g., oral or written);
- analyze Smartandplay.com website activity;
- manage Smartandplay.com Client account;
- advertise its products and services by sending commercial messages;
- send messages about the progress of the application and purchase agreement execution;
- prevent fraud;
- manage purchases, payments, and orders;
- inform the public about its activities.
Purposes of personal data processing
3. Smartandplay.com processes personal data for the following purposes:
- for customer identification;
- for preparing and concluding contracts;
- for product delivery and provision of services (to fulfill contract obligations);
- for advertising and distributing products or for commercial purposes;
- for customer service;
- for handling and processing complaints;
- for payment administration;
- for improving website operations.
Data processing
4. Smartandplay.com processes the Client’s data using the capabilities of modern technology, taking into account the existing privacy risks and available organizational, financial, and technical resources.
5. In order to ensure the high-quality and efficient execution of the obligations under the contract concluded with the Client, Smartandplay.com may authorize its partners to perform certain tasks related to the delivery of goods or provision of services, such as goods delivery, sending commercial messages, and similar activities. In performing these tasks, Smartandplay.com’s partners process the Client’s personal data and are considered data processors of Smartandplay.com, and Smartandplay.com has the right to transfer the necessary personal data of the Client to the partners only to the extent necessary for carrying out these activities.
6. Smartandplay.com partners (in the role of data processors) will ensure the fulfillment of personal data processing and protection requirements in accordance with the signed Data Processing Agreement and applicable laws, and will not use personal data for any other purposes than fulfilling the obligations under the contract concluded with the Client on behalf of Smartandplay.com.
7. Smartandplay.com does not disclose the Client’s personal data to third parties except in the following cases:
- if the data must be provided to the relevant third party within the framework of a concluded contract (e.g., goods delivery);
- if the Client has given clear and unambiguous consent;
- to the persons specified in external regulations, upon their justified request, in the manner and scope provided by external regulations;
- in cases specified in external regulations, for the protection of Smartandplay.com’s legitimate interests.
Personal data storage takes place for as long as:
- while the contract concluded with the Client is in effect;
- while in accordance with the procedure specified in external regulatory acts, Smartandplay.com or the Client can exercise their legitimate interests;
- while there is a legal obligation to store the data;
- while the Client’s consent for the relevant personal data processing is valid, unless there is another legal basis for data processing.
Access to personal data and other Client rights
8. The client has the right to receive the information specified in regulatory acts regarding the processing of their data. Most of the client’s information is already available on www.smartandplay.com in the “My Account” section, where the client can verify the accuracy of their data, correct it, and withdraw consent for receiving commercial messages.
9. The client has the right to request the termination of the processing of their personal data, request information on the purposes for which their personal data is being used, as well as request the transfer of their personal data in a widely used format to themselves or to third parties. To prevent the misuse of the client’s data and rights, the application can only be submitted in a form that allows identifying the person submitting the request (the application must be signed digitally or submitted in person to Smartandplay.com). We have the right to respond to such requests within 30 days.
A request to terminate data processing is considered a request to terminate the permanent client contract.
The customer’s consent to data processing and the right to withdraw it
The client can give consent for the processing of personal data, where the legal basis is consent (e.g., receiving commercial notifications, etc.), on the www.smartandplay.com website in the “My Account” section, by calling +371 28 725 777, or by writing to info@smartandplay.com.
10. The Client has the right to withdraw the consent given for data processing at any time in the same manner in which it was given.
11. The withdrawal of consent does not affect the data processing carried out during the time when the Client’s consent was valid.
12. Revoking consent does not affect the processing of data carried out based on other legal grounds.
Communication with the Client and Commercial Notifications
13. Smartandplay.com communicates with the Client using the contact information provided by the Client (phone number, email address).
14. Communication regarding the fulfillment of service contract obligations by Smartandplay.com is carried out based on the concluded contract (for example, coordinating delivery times, information about purchases and invoices, etc.).
15. Communication regarding commercial notifications from Smartandplay.com is carried out in accordance with the regulatory acts or with the Client’s consent.
16. The Client’s consent to receive commercial notifications is valid until it is revoked (even after the termination of the service agreement). The Client can refuse to receive further commercial notifications at any time.
17. Smartandplay.com stops sending commercial notifications as soon as the Client’s request is processed, which may take up to three days.
Website Visits and Cookie Processing
18. Smartandplay.com website uses cookies to improve the services available to users. Cookies are files placed on users’ computers by websites to recognize the user and make it easier for them to use the site. Internet browsers can be configured to alert the user about the use of cookies and allow the user to choose whether they agree to accept them. Refusing cookies will not prevent the user from using the Website, but it may limit some features of the Website’s functionality.
19. Smartandplay.com websites may contain links to third-party websites, which have their own terms of use and privacy policies, for which Smartandplay.com is not responsible.
Other terms
We assume that before using our website or filling out the request to become a registered client, you have read our Privacy Policy principles and terms and have accepted them. We reserve the right to make changes to the main provisions of the Privacy Policy, informing all regular customers about this. However, we do our best to ensure that the Privacy Policy is always updated and available to you on our website.
For any questions or issues related to the Privacy Policy or data processing, as well as in cases where the customer wishes to unsubscribe from commercial notifications or completely delete their data from their profile, please contact us using the email address info@smartandplay.com or by phone at +371 28 725 777. You have the right to contact the Data Protection Inspectorate or the court at any time to protect your personal data. The Data Protection Inspectorate is a state institution where you can also turn to for consultations or assistance regarding personal data protection.