Privacy policy

This document was last updated on March 9, 2020

This privacy policy ("Policy") describes how HT Global A.S. ("HT Global A.S.", "we", "us" or "our") collects, protects and uses the personally identifiable information ("Personal Information") you ("User", "you" or "your") may provide on the smilecase.com website and any of its products or services (collectively, "Website" or "Services"). It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Definitions

We use the term “personal data” to refer to any information collected or processed by, or in connection with, this website or the platform, that directly, or indirectly, identifies you or factors specific to you, such as your name, IP address or user preferences. Below we describe “lawful grounds” for processing your personal data. These lawful grounds (sometimes also referred to as “legal basis”) are the justification under GDPR for the processing of your personal data. If there are no lawful grounds for processing your personal data neither we, nor anyone else, is permitted to access or process your personal data.

Collection of data

We process personal data that we receive from you as part of your use of our website and, if applicable, our business relationship. In the case of purely informative use of the website, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. When you visit our website, we collect the following access data that we technically require to display our website and to ensure stability and security. The access data include the IP address, date and time of the visit, time zone difference compared to Greenwich mean time (GMT), content of the request (i.e. name of the specific visited web page), access status/HTTP status code, respective amount of transmitted data, referrer URL (previously visited page), browser type and version, operating system and its interface, language and version of the browser software, message about successful retrieval. In addition, we obtain your personal data if you contact us by using our contact form or by e-mail. Personal data here include e.g. name, company, e-mail, phone number, subject, message text (hereinafter called "contact information").

Use and processing of collected information

Any of the information we collect from you may be used to personalize your experience; improve our Website; improve customer service and respond to queries and emails of our customers; process transactions; send newsletters; send notification emails such as updates, news etc; run and operate our Website and Services. Non-Personal Information collected is used only to identify potential cases of abuse and establish statistical information regarding Website usage. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

We may process Personal Information related to you if one of the following applies: (i) You have given your consent for one or more specific purposes. Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. This, however, does not apply, whenever the processing of Personal Information is subject to European data protection law; (ii) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) Süreçing is necessary for compliance with a legal obligation to which you are subject; (iv) Süreçing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) Süreçing is necessary for the purposes of the legitimate interests pursued by us or by a third party. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Information transfer and storage

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.

The rights of users

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

The right to object to processing

Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Privacy of children

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our Website or Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website or Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through our Website or Service, please contact us. You must also be at least 16 years of age to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf).

Newsletters

We offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

Cookies

The Website uses "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services. To learn more about cookies and how to manage them, visit internetcookies.org

In addition to using cookies and related technologies as described above, we also may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These companies may deliver ads that might also place cookies and otherwise track user behavior.

Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. Our Website does not track its visitors over time and across third party websites. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

Links to other websites

Our Website contains links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third-parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information.

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.

Data breach

In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website.

Legal disclosure

We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and personal data will likely be among the assets transferred.

Changes and amendments

We reserve the right to modify this Policy relating to the Website or Services at any time, effective upon posting of an updated version of this Policy on the Website. When we do we will revise the updated date at the bottom of this page. Continued use of the Website after any such changes shall constitute your consent to such changes.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Google Analytics

Based on our legitimate interests, i.e. our interest in optimizing and economic operation of our Website, we use the web analytics service Google Analytics of Google Inc. ("Google"). The web analytics service Google Analytics uses cookies. The data generated by these cookies about the use of our Website usually are transmitted to a Google server in the USA and stored there. Google is certified under the EU-US Privacy Shield Agreement and therefore guarantees compliance with European data protection law (https://www.privacyshield.gov). Google uses such data on our behalf to evaluate the use of our Website by our users, to compile reports on the activities on this Website and to provide us with further services related to the use of this Website. The processed data can be used to generate pseudonymous usage profiles. We use Google Analytics with activated IP anonymization. This means that the users' IP address is shortened by Google within the States that are party to the Agreement on the European Economic Area. The full IP address is sent to a Google server in the USA and shortened there in exceptional cases only. The IP address transmitted by the user's browser is not merged with other data provided by Google. Users may prevent the storage of cookies by setting their browser software accordingly; in addition, users may also prevent the collection of the data generated by the cookie and their transfer to Google as well as the processing of such data by Google, by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de. For more information about data processing by Google, settings and options to object, please visit the websites of Google at: https://www.google.de

Facebook Custom Audience Re-Targeting

Our website uses Facebook’s re-targeting technology Website Custom Audience operated by Facebook Inc., 1601 S. California Avenue, Palo Alto, CA 94394, USA („Facebook“). This tool permits our online visitors, who are Facebook members, to view relevant advertisement and offers for our services on the Facebook website. For this purpose our website contains Facebook re-targeting pixels, which permit Facebook to identify a member as a visitor of our website on the basis of pseudonymous date and use such information in order to display our advertisement or offers in the Facebook Ads network. This does not involve the collection of personally identifiably information and does therefore not enable us to identify you on Facebook. The pseudonymous data collected through the re-targeting pixels will not be connected with your Facebook user data. More information can be found on Facebook “Custom Audience” re-targeting and how you can adjust your settings at: https://www.facebook.com/settings/?tab=ads and https://www.facebook.com/about/privacy You can refuse Facebook Custom Audiences at: https://www.facebook.com/settings/?tab=ads= and http://www.youronlinechoices.com/de/praferenzmanagement/

Other services

On our website, we use third-party services as part of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, i.e. our interest in an optimal Website. The user's IP address is transmitted to such third-party providers. The IP address is technically required for the contents to be displayed. Third party providers may use so-called web pixels (invisible graphics, also referred to as "web beacons") for evaluation or marketing purposes. The web pixels can be used to evaluate information, such as the traffic of the Website. The third parties may store information in cookies on users' devices. We use the following third-party providers on our website:

Google Maps, provided by third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Its privacy policy is available at https://www.google.com/policies/privacy and an opt-out option is available at https://www.google.com/settings/ads/.

YouTube videos provided by third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. For its privacy policy, visit https://policies.google.com/privacy and an opt-out option is available at https://adssettings.google.com/authenticated.

We include functions of Twitter in our Website. Twitter is offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the presentation of our contributions within Twitter on our Website, the link to our Twitter profile, and the ability to interact with Twitter posts and features. Twitter is certified under the Privacy Shield Agreement and therefore guarantees compliance with European data protection law (https://www.privacyshield.gov). For Twitter's privacy policy visit https://twitter.com/de/privacy and an opt-out option is available at https://twitter.com/personalization.

Functions of the Instagram service are integrated into our online offering. These functions are provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged in to your Instagram account, you can connect the contents of our site with your Instagram profile by clicking on the Instagram button. This allows Instagram to associate the visit to our site with your user account. Please note that as the website providers, we receive no information about the content of the transferred data or their uses regarding Instagram. Data protection declaration: http://instagram.com/about/legal/privacy/.

Contacting us

HT GLOBAL AS.

Esentepe, 23 Temmuz Sk. No:9, 34394 Sisli/Istanbul

If you have any questions about this Policy, please contact us.

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