Privacy Policy

1. General provisions

1.1. This data protection declaration was developed by Aeddon Ltd., Eustrasse 8B, 6313 Menzingen, Switzerland, CHE-276.287.823 and regulates the procedures for receiving, collecting, storing, processing, using, protecting and disclosing users' personal data in connection with the use of the Smilodo platform and its eShops.

1.2 In this Privacy Policy the designations of the Terms and Conditions are used as defined at https://www.smilodo.com/en/general-terms-and-conditions.

1.3 The "user" mentioned in this Privacy Policy can be: 

  • eShop Operator
  • eShop Owner
  • eShop User 
  • End Customer 

If the respective regulation applies to a specific user group, it is explicitly mentioned. Otherwise the regulation applies to all user groups.

1.4 Personal data means any information directly or indirectly related to a particular user. This can be: 

  • Name 
  • Surname 
  • e-mail address 
  • Phone number Address, Lieu, ZIP, Country, Canton, State, Province 
  • Company identification number (UID) 
  • IP-address 
  • data on the devices used by the user (computer, browser type, mobile device operating system) 
  • messages that are contained in the correspondence between users with Smilodo (usually from eShop Owners or eShop Users) 
  • messages that are contained in the correspondence between End Customers with an eShop 
  • other communication information, which at the request of the user, is provided to them through the registration form and/or by filling out their profile on the platform, writing a message and/or review 
  • information obtained by oral communication 

1.5 Data processing means any action on the personal data, including but not limited to: access, provision, distribution, collection, systematization, storage, accumulation, recording, transmission, blocking, deletion, clarification, update and/or modification, depersonalization and others ways of using the personal data by the Aeddon Ltd. or by the eShops.

1.6 The Data Manager is therefore the Aeddon Ltd. or the eShop Owner.

1.7 The user expresses his consent to the provisions of this Privacy Policy, by 

  • registering on Smilodo and/or 
  • registering on an eShop and/or 
  • entering his personal data and/or 
  • providing his personal date in another way and/or 
  • performing any actions within Smilodo or an eShop and/or 
  • using any part of the Site and/or 
  • by expressing another explicit consent 

1.8 Users may provide the data independently by 

  • posting it on Smilodo or an eShop and/or
  • communicating through telephone channels and/or
  • the electronic address of Aeddon Ltd. or of the eShop Operator and/or 
  • the postal address of Aeddon Ltd. or of the eShop Owner or 
  • Data may be provided from other sources (in accordance with clause 3 of this Privacy Policy) 

1.9 The user has no right to use Smilodo nor its eShops if he does not agree with the terms of this Privacy Policy.

The user acknowledges that in the event of his negligence in the security and protection of his personal data and authorization data (password, login), third parties may gain unauthorized access to the account and user data. Neither Aeddon Ltd. nor the eShop Owners shall be liable for damages caused by such access.

2. What personal data may be collected?

2.1 Aeddon Ltd. or the eShop Owners may collect the following Data: 

  • name, surname, patronymic, date of birth, sex, marital status, data of the authorized person of the company, company name, company details, contact telephone numbers, e-mail address, address of the company location, other communication data at the request of the user 
  • information about the user's account, including telephone number, e-mail address, login and password, other personal data required for the service of the Platform users, communication with the users, including when the user contacts the Platform support service 
  • information that users provide to Aeddon Ltd. when concluding contracts for the provision of services by accepting a public offer posted on the Platform and/or concluding contracts for the provision of additional services on the Platform 
  • information necessary for the implementation of communications between Users of the Platform, including for the implementation and confirmation of transactions between sellers and buyers, receiving and sending messages, posting feedback, comments, making payments 
  • data obtained as a result of Aeddon Ltd. and/or third parties authorized by the Aeddon Ltd., various surveys related to improving the provision of services to users 
  • information received by Aeddon Ltd. as a result of marketing activities; information posted by users on the results of their service, reviews, comments, appeals to the support service, complaints, claims, other appeals 

2.2 Aeddon Ltd. or the eShop Owners may also process the personal data using the following technologies: 

  • Cookies (a small piece of data that is sent to the user's computer when going to a web page and/or when viewing an advertising module on a web page and stored on the user's computer and/or in his mobile device); 
  • Pixels (digital images, an element of the matrix of displays that form the image) 

These technologies allow the platform to track, how often the user uses the web page, to identify the user's browser and provide services such as storing data in the basket between visits. It is also used for the purpose of elimination of errors of work of the Platform initiated by the user thus all information is processed "as is" and does not change in the course of data collection.  

3. Use and purpose of data processing 

3.1 Aeddon Ltd. or the eShop Owners use and process the personal data: 

  • for implementation of the functions, powers and responsibilities assigned to Aeddon Ltd. in accordance with the respective local legislation, as well as ensuring the implementation of civil, economic and tax relations. 
  • to identify the client as a user of the Platform, in order to communicate with users, including for the provision of services, payment processing, sending, settlement operations, reporting, accounting and management accounting, creation and implementation of bonus programs, loyalty programs, sending mailings, by e-mail, to a mobile phone number, including for the purpose of sending commercial offers, notifications about promotions and news of Smilodo, quality improvement provision of services, formation of ratings, analysis of user activity, search by keywords, traffic management on the Platform, analysis and forecasting of preferences, interests of users; conducting research and analytical activities, as well as ensuring compliance with the terms of the users of the Terms and Conditions and its integral annexes.  

3.2 Neither Aeddon Ltd. nor the eShop Owners do process any personal data of special categories like racial, national affiliation, political views, religious and other beliefs, membership in public associations. 

3.3 The terms of data processing and storage are determined based on the purposes of the processing of personal data, as well as based on the conditions specified in the agreements concluded with users in accordance with the requirements of current legislation of the respective country. 

4. Conditions for granting access to the Data

4.1 Disclosure of personal data is made between eShops and Smilodo and vice versa when the End Customer explicitly allows it in his personal profile or in a respective dialog. The amount personal data transferred is limited to the data required to opening an account on an eShop. This saves the End Customer from entering the most basic data again. 

4.2 In some cases, in order to demonstrate the effectiveness of Smilodo and improve the image of the Platform, Aeddon Ltd. may disclose statistics on the users, without disclosing personal data and information that is a trade secret. 

4.3 The Smilodo eShops, among other things, provide the opportunity to use the YouTube API services. The personal data of users using the YouTube API is processed, stored and transmitted in accordance with the YouTube API Terms of Use, available at: https://www.youtube.com/t/terms, and in accordance with the Google Privacy Policy available at https://policies.google.com/privacy 

4.4 The Platform may contain links to other web resources when entered by eShop Owners or eShop Users, which are not covered by this Policy. 

4.5 Aeddon Ltd. processes Data on a lawful and fair basis: Data is not disclosed to third parties and is not distributed without the consent of the user, except as provided by current legislation of the respective country and only in the interests of national security, economic welfare and human rights, in particular, but not limited to:  

  • at the substantiated requests of respective state bodies having the right to demand and receive such data. 
  • if, in the opinion of Aeddon Ltd., the user violates the terms of this Privacy Policy and/or other contracts and agreements concluded between Aeddon Ltd. and the User, as well as the provisions of the Terms and Conditions and its annexes.  

4.6 Aeddon Ltd. reserves the right in accordance with the requirements of current legislation of the respective state to exchange Data with government agencies in order to:

  • prevent fraud on the Platform, 
  • resolve disputes
  • clarify the circumstances that may cause or have caused violations of applicable law.

5. How to change or delete Personal Data or revoke consent 

5.1 Users may at any time change or delete personal information or refuse to send, or withdraw their consent to the processing of Personal Data through their personal account or by sending a notification to support@smilodo.com or postal address Eustrasse 8B, 6313 Menzingen, Switzerland. 

5.2 Upon receipt of such notification, the processing of the user's Personal Data will be terminated and his Personal Data will be deleted, unless such processing may be necessary in accordance with the current legislation of the respective country. 

5.3 The operation of some features of Smilodo or its eShops, which require the availability of information about the User, may be suspended from the moment of changing / deleting the Personal Data. 

5.4 Aeddon Ltd. processes and stores the Personal Data for the implementation of the purposes specified in this Privacy Policy for the entire period necessary for this, but not more than ten (10) years from the date of the last interaction of the User with the Portal. 

6. Data protection 

6.1 Aeddon Ltd. takes all necessary technical, organizational and legal measures during the processing of personal data in order to protect personal data from unauthorized access, including alterations, deletions, provision, dissemination and other illegal acts. 

6.2 Aeddon Ltd. constantly monitors the security measures taken. 

7. Additional Conditions 

7.1 Aeddon Ltd. reserves the right to change the terms of this Privacy Policy at any time. In this case, the updated version will be posted on the page at: https://www.smilodo.com/privacy-policy. If the user does not agree with the changes, he undertakes to immediately terminate any interaction with the Platform. 

7.2 Aeddon Ltd. is not responsible for damage or loss incurred by the user or third parties as a result of misunderstanding or misunderstanding of the terms of this Privacy Policy. 

7.3 If any provision of this Privacy Policy, including any proposal, paragraph or part thereof, is found to be contrary to the applicable law of the respective country, or invalid, it shall not affect the remaining provisions, they shall remain in full force and effect, and any invalid provision, or provision which cannot be enforced without further action by the Parties, shall be deemed amended, corrected to the extent necessary to ensure its validity and enforceability. 

7.4 The terminology used in this Privacy Policy has the same meaning as in the Terms and Conditions, unless otherwise stated. 

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