Privacy Policy

INTRODUCTION

REMOS spol. s r.o., Tomášikova 26, 82101 Bratislava, IČO: 35890941 (“REMOS,” “we,” “our,” or “us”) respects your privacy and is committed to protecting it in accordance with this Privacy Policy (“Policy”). We provide our customers (“Customers,” “you,” “your”) with inspiring, informative, and entertaining content as part of our Services, aimed at helping you become better and happier. We are committed to being transparent in the processing and handling of personal data in accordance with applicable privacy and data protection laws.

This Policy outlines our practices regarding the collection, use, storage, protection, and disclosure of your personal data (as defined below) on our website https://www.smolfi.com (“Website”), any related applications, products, and platforms (together with the Website, “Service” or “Services”), or anywhere this Policy is posted, as well as through any offline interactions.

Please read this Policy carefully to understand our practices and procedures regarding your information. If you do not agree with our terms, your choice is not to use our Services. By accessing or using the Services, you agree to this Privacy Policy.

This Policy may change over time (see the section CHANGES TO OUR PRIVACY POLICY). Your continued access to our Services after changes are made constitutes acceptance of those changes. Therefore, please check the date of the last modification of this Policy to ensure that you are reviewing the most current version.

CHILDREN’S PRIVACY

The Service is intended for a general audience and is directed at users aged 18 years and older. We do not knowingly collect personal data from individuals under the age of 18.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information about you and users of our Services, such as personal data when you register for an account on our Website (“Account”) or order our Services. Personal data refers to information that identifies (either directly or indirectly) a specific individual, such as a person’s name, mailing address, email address, and phone number (“Personal Data”).

Other types of information we collect include data regarding how you use our websites and apps, which helps us improve our Services. You expressly consent to receiving communications from REMOS through the information you have provided us. For more details on how to manage your communication preferences, please see the sections YOUR RIGHTS and YOUR CHOICES REGARDING YOUR INFORMATION in this Policy below.

When you provide us with information related to a specific activity, or when you register for our products and Services or provide us with your contact information, including your email address or phone number related to that activity, product, or service, you agree that this step represents a purchase or inquiry, creating a business relationship with us.

INFORMATION PROVIDED BY YOU OR ON YOUR BEHALF

Account/Contact Data: Email address; Name; How/when personal data is collected: You provide your contact details when filling out a questionnaire or web form on our Website; You provide this information when you create an Account. Purpose of collecting personal data: To provide requested Services; To provide you with an Account; To communicate with you about the Services you requested; To provide customer support; To send communications about similar products and services, if appropriate, with the option to unsubscribe at any time.

Payment and Order Information: Name; Email address; Phone number; Mailing address; Banking information (e.g., credit/debit card number, PayPal login details, etc.). How/when personal data is collected: You provide this information when purchasing products or Services on our Website; Please note that we use third parties to process payments to handle your order information. For more information, see the section HOW WE DISCLOSE AND SHARE YOUR INFORMATION. Purpose of collecting personal data: To provide requested Services; To fulfill your purchase; To provide customer support.

AUTOMATICALLY COLLECTED INFORMATION

When you browse and interact with our Services, we and our third-party providers, including analytics and content service providers, may automatically collect certain information about you whenever you access or interact with the Services. We may combine this automatically collected information with other information we collect about you. We do this to improve the services we offer, analyze, and enhance the functionality of the website.

1. Usage Information: Details of your visits to our Website or Services (e.g., links you clicked, content response times, location data, logs, and other similar communication data and statistics about your interactions). How/when personal data is collected: This information is automatically collected when you visit our Website. Purpose of collecting personal data: To analyze your usage of the Services; To improve and develop our Website and Services, and enable us to offer you new features and materials.
2. Device Information: Information about your computer and internet connection, including your IP address, operating system, and browser type. How/when personal data is collected: This information is automatically collected when you visit our Website. Purpose of collecting personal data: To analyze your usage of the Services; To protect the Services, our company, our employees, and users from malicious attacks, hacking, fraud, or other illegal or unauthorized activities; To investigate and take measures to prevent potential fraud or other unfair activities.

Cookies and Other Automatic Data Collection Technologies

REMOS and our partners use cookies or similar technologies that store certain information on your computer and allow us, among other things, to analyze trends, manage the Website, and collect demographic information about our users. The technology used to automatically collect information from REMOS users may include the following:

• Cookies: Like many websites, we and our operating partners, analysts, and service providers use "cookies" to collect information. A cookie is a small data file that we transfer to your computer's hard drive for record-keeping purposes. We use persistent cookies that remain on your computer or similar device, and session identifier cookies that expire at the end of your browser session. We also use cookies to improve the reliability, security, and performance of our Website, including cookies sent by our Web Application Firewall. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit the use of some features or properties of the Website.
• Web Beacons: Web beacons are small graphics with a unique identifier, which may be invisible to you, and are used to track online user activity.
• Embedded Scripts: An embedded script is a programming code designed to collect information about your interactions with the Services, such as links you click. The code is temporarily downloaded to your computer or other device and is deactivated or deleted when you disconnect from the Service.

Third-Party Cookies

REMOS uses third-party tracking cookies, pixels, and other technologies, such as Google Analytics and Meta, to collect data about your activities when you visit our Website, the websites of entities for which we provide advertisements, or websites and online services where we display ads (see the following section for more information about Google Analytics). This information may include the content you view, the date and time you view this content, products you purchase, or location information associated with your IP address. The information we collect is used to provide more relevant ads (sometimes referred to as "retargeting" or "remarketing"). We collect information about where you saw the ads we provided and which ads you clicked on to measure the success of our advertising campaigns. You can generally opt out of receiving personalized ads from third parties, advertisers, and ad networks that are members of the Network Advertising Initiative (NAI) or adhere to the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (DAA). You can learn how to opt out of ads provided through Facebook Custom Audience here: //www.facebook.com/business/help/610516375684216?id=2469097953376494&locale=en_GB

Google Analytics: Google Analytics collects information about how often users visit this Website, which pages they visit, when they do so, and which other websites they used before coming to this Website. The information we obtain from Google Analytics is used solely to improve our Services. Google Analytics only collects the IP address assigned to you on the day you visit this Website, instead of your name or other identifiable information. The information obtained through Google Analytics is not merged with personally identifiable information. While Google Analytics places a persistent cookie in your web browser to identify you as a unique user on subsequent visits to this Website, the cookie can only be used by Google. Google's ability to use and share the information obtained through Google Analytics about your visits to this Website is restricted by Google Analytics Terms of Service and Google Privacy Policy. You can prevent Google Analytics from recognizing you on subsequent visits to this Website by disabling cookies in your browser.

Do Not Track Signal: The "Do Not Track" (DNT) signal is a privacy preference that users can set in some web browsers, allowing them to opt out of being tracked by websites and online services. We do not support "Do Not Track" requests from browsers, but our cookie policy below describes how you can opt out of receiving cookies.

Legal Grounds for Collecting and Processing Personal Data

In this section, we inform you about the legal basis we rely on for each specific processing purpose, where this legal basis is applicable under data protection laws such as the General Data Protection Regulation (GDPR). For processing your personal data, as described above, we rely on the following legal grounds:

• Contractual Necessity: To provide the REMOS Service and Account, communicate with you in relation to your use of the Service, fulfill your order, and perform the contract you have with us.
• Legitimate Interest: It is in our legitimate interests to improve and analyze our Services, promote our products, send you marketing communications, personalize our ads, prevent fraudulent transactions, maintain the security of our Services, enforce our Terms of Use, and provide functionality for our Websites and Services.
• Consent: We may send you marketing communications, store or access information on your devices through cookies and other tracking technologies, and provide you with our Services. In cases where we request consent, you can withdraw your consent at any time following the instructions provided in the sections on Cookies and Other Automatic Data Collection Technologies and Your Options Regarding Your Information in this Notice.
• Legal Obligations: If necessary, we may process personal data for the purpose of establishing, exercising, or defending legal claims or whenever courts are acting in their judicial capacity.

HOW WE DISCLOSE AND SHARE YOUR INFORMATION

We may share the information we collect about you in the following ways or as described in other parts of this Privacy Policy. When we share personal information, the recipient is obligated to maintain the confidentiality of that personal information, ensure its security, and process the personal data only for the specific purpose for which they are engaged:

• Service Providers: We employ third parties and individuals to provide Services on our behalf, carry out operations related to the Services such as website maintenance, database management, web analytics, payment processing, fraud detection, or email marketing. REMOS collaborates with the following service providers to deliver Services to you.
• Corporate Transactions: We may sell, transfer, or otherwise share some or all of our assets, including your personal information, in connection with a merger, acquisition, reorganization, or sale of assets (including as part of the due diligence process with any potential acquirer) or in the event of bankruptcy.
• As Required by Law: REMOS will share personal information with governmental agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and including, but not limited to, in connection with income reporting.
• With Your Consent: You may provide us with personal information through a form on our website and consent to receive communications from us or our business partners and non-partner entities based on the information in the form. You may also leave a review via websites or through our business partners and non-partner entities based on your use of the Services.
• Non-Identifiable Personal Information: We may also use aggregated information or information that cannot be used to identify an individual for further customization of the content of our Services and for research and publication purposes. For example, we may use responses to our survey questions to better understand the goals and habits of our users.

YOUR CHOICES REGARDING YOUR INFORMATION

You have several ways to exercise control over your information:

• Email: You can unsubscribe from receiving marketing emails from us by following the unsubscribe instructions included in these emails. Please note that we reserve the right to send you certain communications regarding your account or use of the Service (such as administrative and service notifications) via email and other means, and these transactional account messages may remain unaffected if you unsubscribe from marketing communications.
• Consent: You can choose whether to receive offers and promotions from us for: our products and services, third-party products or services, or products and services we think may interest you, by providing your consent (such as by ticking an unchecked box).
• Contact Us: You can contact us at info@smolfi.com to learn more about your rights and options regarding your personal information.

YOUR RIGHTS REGARDING YOUR DATA (INFORMATION)

Depending on your location, you may have certain rights regarding your personal information (also known as "personal data" under applicable data protection laws). Citizens of certain jurisdictions may access, modify, update, or delete their personal information; object to our processing of this information, request us to restrict the processing of your personal information, or request the portability of your personal information. For more information on exercising your rights, please review the sections (YOUR RIGHTS REGARDING YOUR INFORMATION) and (YOUR OPTIONS REGARDING YOUR INFORMATION) in this notice.

Upon request, REMOS will provide information on whether we store any of your personal information. You are responsible for maintaining the accuracy of the information you provide to us, such as your contact details. If you submit a request for access to all personal information you have provided to us, we will respond to your request within 30 days or in accordance with legal requirements.

We agree to make commercially reasonable efforts to fulfill your deletion requests; however, certain residual information may persist on the Service even if you close your account. Additionally, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you request the deletion of information that we are required to retain by law or have a legitimate interest in retaining (such as for fraud prevention purposes). Your personal information may remain in our archives, and information that you update or delete, or information in a closed account, may persist internally for administrative purposes, as permitted by law. It is not always possible to completely remove or delete information from our databases. Furthermore, we generally do not remove information that you have publicly posted through or on the Service. Please note that neither you nor REMOS can delete all copies of information previously shared with other users on the Service. If your information is deleted, your account may be deactivated. If your account is deactivated or you request its closure, you will no longer be able to use the Services.

Please note that our Services require a minimum amount of personal information for functionality. Individuals who do not provide personal information (for example, by not completing a profile) may not have access to the full functionality of features available on REMOS.

European Union Citizens

In accordance with the GDPR, REMOS is the data controller. Citizens of the European Union may access, correct, or delete their personal information through the settings of their online account, as outlined above. Additionally, EU citizens may contact the Data Protection Officer at info@smolfi.com to access, correct, update, or delete their personal information; object to the processing of this information, request a restriction on the processing of their personal information, or request the portability of their personal information.

California Residents – Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), which amends the CCPA (collectively referred to as the "California Privacy Laws"), grant you additional rights regarding our collection, use, and disclosure of your personal information, including: 1. The right to know what personal information we have collected about you and how we have used and disclosed that information in the past 12 months prior to your request. 1.1. We have collected the following categories of personal information in the past 12 months: identifiers/contact information, payment card information associated with you, commercial information, internet or other electronic activity information, geolocation data, audio, electronic, visual, or similar information, and inferences drawn from the above. 1.2. The sources of personal information from which we obtained this data include directly from users, analytical tools, social networks, and third parties that update or supplement the information we hold about you. 1.2.1. For a complete list of the categories of personal information we have collected about you, please see the section above in this notice titled "WHAT, WHEN, HOW, AND WHY WE COLLECT YOUR PERSONAL INFORMATION." 2. The right to request the deletion of your personal information. 3. The right to be free from discrimination related to exercising any of your privacy rights. 4. The right to opt out of the sale of your personal information and request information about whether we have sold your personal information in the past 12 months. 4.1. We have not sold personal information in the past 12 months. 5. The right to correct inaccurate personal information. 6. The right to limit the use and disclosure of your sensitive personal information.

For more information on exercising your rights under California's privacy laws: If you would like to learn more about how to exercise your rights under California's privacy laws, please contact us at info@smolfi.com. Please note that we may need to verify your identity by comparing your email address or other account information with the information we have in our systems before you can submit a request to exercise any of these rights. If you designate another person as your authorized agent to submit requests on your behalf, unless you provide the agent with a power of attorney under the California Probate Code, we will ask the agent to submit a written and signed authorization from you, verify with you that you provided the authorization, and verify your identity.

INTERNATIONAL JURISDICTIONS

REMOS and the content available through our website are developed, operated, and distributed by REMOS spol. s r.o., a legal entity established under the laws of the Slovak Republic. Our services are hosted in the Slovak Republic and offered globally. If you access the services from another country, please be aware that your personal data may be transferred to the United States, and by using the services, you consent to the transfer, processing, and storage of your personal data in accordance with this Privacy Notice. You also agree to comply with applicable European Union laws and local laws regarding the use of services and agreements with us. Individuals accessing our services from jurisdictions with laws governing the use of the internet, including the collection, use, or disclosure of personal data, which differ from the laws stated above, may only use the services in accordance with the laws of their jurisdiction. If the use of services in your jurisdiction is unlawful, you may not use our services.

SECURITY

We use physical, technical, and organizational measures designed to protect your information from unauthorized access, theft, and loss. Access to your personal information is restricted to those employees who need it to provide services related to your account or to perform their job functions.
Although we take measures to protect the information we process, no system or electronic data transmission is completely secure. Any transfer of your personal data is at your own risk, and we expect you to use appropriate security measures to protect your personal data. You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of the services without prior notice if we suspect or detect any security breach. You understand and agree that we may send electronic notifications of security breaches to the email address listed in your account records.

DATA RETENTION

Unless you request the deletion of certain information (see YOUR RIGHTS REGARDING YOUR INFORMATION and YOUR OPTIONS REGARDING YOUR INFORMATION), we will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:

• The length of time we have a relationship with you and provide you with services (for example, as long as you have an account with us or continue to use the website);
• Whether we are subject to a legal obligation (for example, some laws require us to retain records of your transactions for a certain period before we can delete them);
• Whether data retention is advisable; and consideration of our legal position (such as statutory limitation periods, legal disputes, or regulatory investigations).

CHANGES TO THIS NOTICE

REMOS may update this Privacy Notice at any time, and any changes will take effect upon publication. If there are significant changes in the way we handle your personal data, we will update the "Last Updated" date upon effectiveness. We may also inform you via email, at our discretion.

If you have any questions regarding this Privacy Notice, please contact us at info@smolfi.com.

Effective Date: February 25, 2025