Privacy Policy

Smilo Holding knows the importance of your data and is committed to protecting the privacy and security of your data. Therefore, it is important for us to provide you in an integrated and practical manner with information related to the processing of your personal data as data subjects (users of the Smilo Holding website, customers, potential customers, consumers, potential consumers) in this Personal Data Processing Policy, applicable for the purposes listed below. Please review this Policy and address any requests for details to us at the contact details below. Also, this Policy promoted by Smilo Holding applies to all devices used for the purpose of accessing the website, smartphone, tablet, TV devices. If you do not agree with the terms and conditions related to their use (set out in this document in terms of personal data protection but also in the general terms and conditions, in terms of confidential information, copyright, etc.), please do not use the website. By ticking that you agree to the Terms and Conditions/Personal Data Processing Policy or as the case may be, by continuing to use our website and services after going through these Policies, you agree to this Personal Data Processing Policy.

1. The purposes for which we collect and process your personal data

Smilo Holding collects and processes your personal data for the following processing purposes: 1. Administration, improvement, and realization of the services provided by the website 2. Commercial sales activities, including sales implementation, administration, and development, including online sales on the website, customer account management, market research/studies, statistics. 3. Advertising, marketing, and publicity, promotion of Smilo Holding products and services, sending newsletters, tracking and monitoring of sales and consumer behavior. 4. For evidentiary purposes in connection with the above activities and archiving.

2. Categories of personal data we process

We process the following categories of personal data for the above purposes: For the administration, improvement and performance of the services provided by the website The purpose of data collection is:
  • For billing and order delivery. Refusal to provide data will result in the cancellation of the order.
  • We deliver the products for which we have accepted your order via a shipping company selected by us. We deliver to the address you have provided for delivery.
  • We do not accept responsibility for cases where the address is given incorrectly or incompletely.
  • Contact form and newsletter – we have a newsletter to inform you about our products and/or services. Your e-mail address will be added to the subscriber list only with your explicit consent.
  • For commercial sales activities, including sales implementation, administration and development, including online sales on the website customer account management, market research/studies, statistics: name, surname, address (home/residence), personal number code, ID card series and number, bank details for payment purposes, delivery address or advertising, marketing and publicity, activities for promotion of Smilo Holding products and services, running promotional companies, sending newsletters, tracking and monitoring of sales and consumer behaviour.  

    Also, some of this data is required as a unique identifier of the person depending on the type of contest/promotion/simulation or game in which they participate.

    The provision of personal data is necessary for Smilo Holding to perform the activities listed above. A refusal on your part to provide us with this data may make it impossible for Smilo Holding to provide you with the services, information, to respond to your requests or to carry out any of the other activities listed above.

    3. To whom we disclose your personal data

    In order to achieve one or more of the purposes mentioned above, Smilo Holding may disclose your personal data to the following categories of recipients:

    Smilo Holding’s contractual partners (such as companies with which Smilo Holding has a partnership relationship, but only on the basis of a confidentiality commitment from them, guaranteeing that this data is kept secure and that the provision of this personal information is done in accordance with the legislation in force, other companies with which we may develop joint programs to offer our products and services on the market), service providers (marketing, courier, payment/banking, telemarketing or other services), including entities assisting Smilo Holding in processing data as authorised agents, insurers, public authorities (Public Prosecutor’s Office, Police, courts and other authorised state bodies), on the basis and within the limits of legal provisions and following expressly formulated requests, other companies in the same group as Smilo Holding as well as you. as a data subject in the context of exercising your right of access.

    4. Transfer of Personal Data abroad

    For the fulfilment of one or more of the above purposes, some or all of your personal data mentioned above may be transferred to countries within the European Union and outside the European Union/European Economic Area. For a full list of countries to which your personal data is transferred, please contact us at the contact details below.

    Smilo Holding takes all necessary steps to ensure that your personal data is adequately protected regardless of where it is transferred.

    By submitting your personal data to Smilo Holding you agree (to the extent that your consent is required by law) that your personal data: 

    To be included in the Smilo Holding database and that all such personal data will be stored, used and processed by Smilo Holding, including its affiliates and collaborators for the performance and/or conduct of activities that fall within the above processing purposes; this consent also includes the processing of data related to the location of your equipment as mentioned above.

    may be transferred by Smilo Holding to its affiliates as well as to other entities in the country or abroad, according to the above information, for the performance by them of their own activities related to promotion and marketing and other related activities.

    5. By reading this Policy you are aware that you are guaranteed your rights under the law, namely:

    • to be informed about the processing of your personal data in accordance with the law;
    • to have access to your personal data;
    • to intervene on your personal data;
    • not to be subject to an automated individual decision;
    • to object to the processing of your personal data and to request rectification, updating or erasure of your data in accordance with the law – in the case of personal data processed for direct marketing purposes, this right may be exercised at any time, free of charge and without justification;
    • to take legal action in the event of violations of the relevant legislation.


    You can exercise these rights by sending an e-mail to Smilo Holding by accessing the contact form at or you can write to us at the following e-mail address:

    On the basis of a written request, dated and signed, sent to the address Calea Baciului nr. 2F-2G, Cluj-Napoca email, you can exercise, free of charge, the following rights:

    • once a year, to have it confirmed to you, according to the law, whether or not your personal data are processed;
    • to access and intervene on the transmitted data;
    • to object to the processing of your data for justified and legitimate reasons related to your particular situation (with the exception of direct marketing processing, in which case you may object at any time free of charge and withoutjustification)
    • to request the deletion of data, except in situations provided for by law. 

    6. Special provisions relating to minors

    Smilo Holding does not, in its data processing activities, process personal data of minors. Special attention is paid by Smilo Holding to ensure that any processing of personal data of minors is carried out in accordance with legal requirements and in strictly defined cases.

    Smilo Holding does not carry out promotional marketing activities directly towards minors.

    Minors who have not reached the age of 14 are not allowed to request services or any communications on the Smilo Holding website otherwise from Smilo Holding, or to participate in contests or campaigns of Smilo Holding, unless this is done on behalf of the minor by the legal representative or guardian of the minor in question, according to the law.

    Minors who have reached the age of 14 may purchase products or services and request and receive communications from Smilo Holding only if they have the consent of their legal representative or guardian, according to the law.

    Also, any person who provides us with personal data through the Website or other applications or devices covered by this Policy warrants that he/she is of legal age, i.e. has full legal capacity.

    Any collection or processing of personal data of minors will be carried out only in accordance with the law, and having regard to the above.