Effective Date: July 6, 2022   Scroll to the bottom of the page to review any material modifications and their effective dates. Smobya OÜ owns and operates website business. All references to “we”, “us”, this “website” or this “site” shall be interpreted to mean Smobya OÜ. This privacy policy will explain how our organisation uses the personal data we collect from you when you use our website and services. This Privacy Policy describes how we collect, use, and share information, including the sharing of information with our marketing partners for purposes of serving personalised ads based on your interests. Our marketing partners might include third party service providers, advertisers, advertising networks and platforms, advertising agencies, and data brokers and aggregators. (See below, PERSONALIZED ADS.) Our Privacy Policy applies to all of the services offered by us including services accessed by mobile devices and application programming interface (API), but excludes services that have separate privacy policies which do not incorporate this Privacy Policy. Our Privacy Policy does not apply to other companies and organisations who advertise our services, and who may use cookies, web beacons (pixel tags), and other methodologies to serve personalised ads.   HOW WE MODIFY THIS PRIVACY POLICY Without any prior notice, we reserve the right to modify this Privacy Policy at any time, by uploading an amended Privacy Policy that is always accessible by clicking on the “Privacy Policy” link on this site’s home page. Your continued use of this site shows that you have accepted the amended Privacy Policy. If any materially less restrictive modification is made in our Privacy Policy, especially regarding the use or disclosure of your Personal Information, other than as it was previously disclosed to you, we will obtain your consent once again, with respect to such information.   THE TYPES OF INFORMATION WE COLLECT   PERSONAL INFORMATION “Personal Information” includes any information regarding a natural person that may be used directly to identify the person. Personal Information that we collect may vary with each separate purpose for which you provide it, and it may include one or more of the following categories: name, physical address, and email address, phone number, credit card information including credit card number, expiration date, and billing address, location data, and delivery address.   PASSIVELY OR AUTOMATICALLY COLLECTED DATA (“Data Usage”). We and our marketing partners including third-party service providers, advertisers, advertising networks and platforms, advertising agencies, and data brokers and aggregators may use automated means to collect various types of information about you, your computer or other device used to access this site or its services. This information is based on your usage of this site, including information collected automatically from this site (or by our marketing partners working along with us on this site). A representative, non-exhaustive list of the types of passively or automatically collected information may include: network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system you are using, (e.g., Microsoft Windows or Mac OS), the name of your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers, mobile network, device identifiers (such as an Apple IDFA or an Android Advertising ID), device settings, browser settings, the web pages of this site you have visited, pages or service visited before and after you visit a page or service, the type of handheld or mobile device used to view the page or service (e.g., iOS, Android), location information, and the content and advertisements you have accessed, seen, forwarded and/or clicked on, the various time details per visit (e.g., the time spent on each page or service within the site) and the details about the path followed within the site with special reference to the sequence of pages visited, other parameters about the device operating system and/or the user’s IT environment, and conversion rates and marketing and conversion data and statistics, reports and analytics, including without limitation your interactions to emails we send, and reviews and surveys regarding this site or any products listed on this site. Usage Data is essentially anonymous when collected, but could be used indirectly to identify a person.   HOW AND WHEN WE COLLECT INFORMATION You directly provide us with most of the data we collect. We collect and process data when you:   SIGN UP OR PLACE AN ORDER We collect personal information at the time you directly provide it to us. We collect personal information through our Sign-Up Form by submitting the “Join our journey” form on our website and when you Place An order / preorder on . Personal information that we collect may vary with each sign-up and with each order placed. We also collect personal information from all communications with site visitors including without limitation, text messages, telephone calls, and regular mail, as well as from third-party outside sources including data brokers and aggregators.   YOU DIRECTLY COMMUNICATE WITH US We collect Personal Information that we receive from you as you communicate with us. If you complete our “Join our journey” and/ or “Contact us” contact form subscribing to newsletter or requiring more information via chat or to participate in our mailing list activities, we will receive your personal information from our email services and/ or autoresponder service.   USAGE DATA We collect Usage Data as you use this site, including your interactions with emails we send, and via third-party platforms, third-party websites, applications, integrations, and services of our marketing partners. This data may be automatically or passively collected (that is, gathered without your actively providing the information) using various analytics like Google Analytics and reporting technologies, such as cookies, web beacons, locally stored objects, and mobile device identifiers and SDKs, and other similar methodologies as well as similar technologies developed in the future. (See below, SPECIFIC INFORMATION ABOUT COOKIES AND OTHER DATA COLLECTION METHODOLOGIES.)   VOLUNTARILY COMPLETE A CUSTOMER SURVEY OR PROVIDE FEEDBACK VIA EMAIL We collect personal data and information from any survey on our website that you voluntarily complete. By completing such documents, you are helping us to learn more about our partners and customers, so we can provide a better and better service and product for you.   HOW WE USE YOUR INFORMATION We may use your Personal Information and Usage Data for the performance of the services or transaction for which it was given and for the basic purpose of this site like eg.: finding you new products or processing your order. We may use your Personal Information in connection with other products, services, promotions, personalised ads, or contests we may offer, and our private, internal reporting for this site, and security assessments for this site. We may also send you messages related to certain features or your activity on this site. We may also send you news or updates about changes to our site or services. By default, you will receive these messages via email. We may make full, unrestricted use of Usage Data for any purpose in our sole discretion, including without limitation, to customise or personalise ads, offers and content made available to you based on your visits to and/or usage of this site or its services, and to analyse the performance of those ads, offers and content, as well as your interaction with them. We may combine and use the personal information and usage data we collect from all services and products offered by us over various websites to provide, protect, and improve them, and to develop and offer new services and products. We will treat you as a single user of these combined services and products. We may also use this information to provide you with personalised ads.   INFORMATION SHARING AND DISCLOSURE   GENERAL DISCLOSURE POLICY We may share and disclose your personal information as described below. We may share and disclose usage data without restriction, including without limitation, as described below.   SERVICE PROVIDERS We may provide access to your Personal Information and Usage Data to our trusted service providers that assist us with the operation and maintenance of this site. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfilment, optimization, analytics, reporting, and software maintenance and development services. In addition, our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.   SUCCESSORS & BUSINESS TRANSFERS In case we sell or otherwise transfer part or all of our business or substantially all of our assets to another organisation, such as in the course of an acquisition, merger, or in the unlikely event that Smobya OÜ goes out of business or enters bankruptcy, user information like personal information and usage data would be one of the assets that are transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of Smobya OÜ may continue to use your personal information as set forth and agree to our commitments provided in this Privacy Policy.   LEGAL PROCESS, ENFORCEMENT, SECURITY NOTICE We may disclose your personal information and usage data if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as, for instance, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity, and (iii) to investigate, respond to, or enforce violations of our rights or the security of this site.   JOINT VENTURE PARTNERS We may decide to participate with another company or individual for purposes of jointly promoting our products, services, promotions or contests or their products, services, promotions, or contests. In this case, we reserve the right to disclose your personal information and usage data to them for purposes of (i) compensation, transaction processing, fulfilment, and support, and (ii) for purposes of offering you other products, services, promotions, and contests. These joint venture marketing partners may also contact you regarding other products, services, promotions, or contests.   MARKETING PARTNERS We may also share your personal information and usage data with our marketing partners including third-party service providers, advertisers, advertising networks and platforms, advertising agencies, and data brokers and aggregators to serve and offer personalised ads.   GENERAL CONTEST OR PROMOTION REGULATION When you choose to enter a contest or other promotion, and in accordance with the terms and conditions of the promotions, your personal information and usage data may be disclosed to our sponsors and to third parties who help administer the promotion, including in connection with winner selection, prize fulfilment and aggregated data analysis. Your personal information and usage data also may be disclosed as required by law, such as on a winners list. Further, by entering a promotion, you are agreeing to the official rules that govern that promotion, including allowing our sponsors to use your name, voice, and likeness in advertising and marketing associated with the promotion in accordance with applicable law. All terms applicable to the particular promotion will be made available to you at the time you enter the promotion.   SHARING YOUR PERSONAL DATA WITH YOUR CONSENT We may share your Personal Information with other parties with your consent.   CALIFORNIAN PRIVACY RIGHTS If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. Under California Law, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and disclosing the categories of personal information shared. To make such a request, please send an email to the email address provided ( and put “California Privacy Request” in the subject line, and the domain name of the website you are inquiring about, please also include your name, address and email address. We will get back to you within thirty days (30) of receiving such a request. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content.   SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS   COOKIES Our goal is to provide the best service for our site, to achieve that we and our marketing partners may use cookies and other data collection methodologies discussed below to collect usage data to store your preferences and information about what pages you visit and past activity at our site and other websites. This information helps us and our marketing partners display personalised ads, compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operations of our site. For information about cookies from the FTC website visit –> “Cookies” are tiny pieces of information stored by your browser on your computer’s hard drive. Cookies are also used to customise content based on your browser. Most browsers are initially set to accept cookies. If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies. Please remember, however, that cookies may be required to allow you to use certain features of our site.   FLASH COOKIES Flash Cookies – third party cookies that use an Adobe Flash Media Player local shared object (LSO) – may be used along with other third party cookies for purposes of crediting any purchase you may make on this site to one of our joint venture partners that may have referred you to us. These cookies will be used for purposes of crediting sales to the referring joint venture marketing partner. Flash cookies are not the same as “browser cookies”. The Adobe Flash Media Player is software that enables users to view content on their computers. Flash cookies are also accompanied by a browser cookie. If you delete the browser cookie, the Flash cookie may automatically create (or re-spawn) a replacement for the browser cookie.   WEB BEACONS Web Beacons (sometimes called single-pixel gifs or clear gifs) are used to assist in delivering cookies, and they allow us to count users who have visited pages of our site. We may include Web Beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.   LOCALLY STORED OBJECTS We may use locally stored objects (“LSOs”) and other client-side storage tracking technologies in certain situations where they help to provide better user experience, such as to remember settings, preferences and usage similar to browser cookies, or in order to target or help our Partners target ads, analyze ad performance, or perform user, website or market analytics. For LSOs utilized by Adobe Flash you can access Flash management tools from Adobe’s website: –> . In addition, some, but not all browsers, provide the ability to remove LSOs, sometimes within cookie and privacy settings.   PERSONALIZED ADS We may collaborate with our marketing partners for the purposes of providing personalised ads based on your interests. This activity is performed by collecting usage data and by using cookies and other tracking and data collection methodologies discussed above to transfer information to our marketing partners which manage advertising activities. Our marketing partners may also use cookies and other tracking and data collection methodologies discussed above to measure advertisement effectiveness and for other purposes that are disclosed in their own privacy policies. We have no access or control over these cookies and other tracking and data collection methodologies that may be used by our marketing partners, and we have no responsibility or liability for the privacy policies and practices of these sites. AdWords (Google) – We may participate in AdWords program which is a personalised ad service provided by Google Inc. that connects the activity of this site with the Adwords advertising network and the Doubleclick cookie. Information collected: cookie and Usage Data. For the opt-out, visit –>   GOOGLE ANALYTICS Google Analytics for Display Advertising (Google) – We may participate in any and all of the following Google Analytics Advertising Features provided by Google: Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. These features use first-party cookies (such as the Google Analytics cookie) for connecting the tracking activity performed by Google Analytics and its cookies with the Adwords advertising network and the DoubleClick cookie (a third-party cookie). Information collected: cookie and Usage Data, including audience data such as age, gender, and interests. For the opt-out, visit –> You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at –> For information in general about Google’s personalised ad campaigns, and specifically about information regarding DoubleClick cookies and how to control and manage Google’s advertising cookies for these campaigns, visit –> For another Google resource for opting out of Google’s use of cookies, visit –> For information regarding how Google uses data when you use Google’s partners’ sites or apps, visit –> For an additional resource recommended by Google for opting out of a third-party vendor’s use of cookies, visit –>   FACEBOOK ADS Custom Audience (Facebook). We may participate in’s Custom Audience program which enables us to display personalised ads to persons on our email lists when they visit We provide Personal Information such as your email address and phone number to Facebook to enable Facebook to determine if you are a registered account holder with Facebook. You may opt-out of participation in our Facebook Custom Audience by sending an email, from the email address you are opting out of, to the email address provided in our contact information below. For your opt-out to be effective, you must: (i) place the following text in the subject line of the email – “Opting Out of Website Custom Audience Ads”, and (ii) in the body of the email, include your name and email address. We will forward your name and email address to with a request to delete you from all of our Facebook Custom Audience Ads.   TWITTER ADS Tailored Audiences/Conversion Tracking Programs (Twitter). We may participate in’s Tailored Audiences/Conversion Tracking Programs which enable us to display personalised ads. You may opt-out of participation in these programs by visiting .   OTHER SIMILAR SERVICES (PERSONALISED AND BEHAVIOURAL ADS) We may participate in additional retargeting and behavioural advertising services that will be similar to the services described above.   MANAGE YOUR PERSONALISED ADS You can control the placement of cookies and other data collection methodologies for purposes of opting out.   MANAGE COOKIES VIA YOUR BROWSER Please note that although most browsers are initially set up to accept cookies, you may be able to change your browser settings to cause your browser to refuse first-party or third-party cookies or to indicate when a third-party cookie is being sent. However, disabling or limiting cookies may cause certain features of this website to not function properly or optimally. Check your browser’s “Help” files or other similar resources to learn more about handling cookies on your browser. In addition, visit –>   MANAGE FLASH COOKIES Flash cookies, or also called local shared objects (LSOs) (already mentioned above), are functioning similarly to standard cookies except that they are often larger and are downloaded to a computer or mobile device by the Adobe Flash Player. In some cases, these Flash cookies can be managed through browser settings. Adobe also provides a means of controlling Flash cookies on its Flash Player: Setting Manager page.   NETWORK ADVERTISING INITIATIVE (NAI) Many companies that use cookies to collect information about your online activities are members of NAI, which offers a single location to opt-out of receiving personalised ads from member companies. To opt-out of information collection by NAI member companies, or to obtain information about the technologies they use or their own privacy policies, please visit the NAI consumer opt-out page: –> .   DIGITAL ADVERTISING ALLIANCE (DAA) DAA member advertising associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customised based on their online behaviour across different websites. To make choices about interest-based ads from participating third parties, please visit DAA Consumer Opt-Out page –> .   ANALYTICS We reserve the right to participate with third party analytics partners to monitor and analyse Web traffic and can be used to keep track of user behaviour on this site. Google Analytics (Google) – Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. Information collected: cookie and Usage Data. Visit Privacy Policy at –> You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at –> .   DO NOT TRACK REQUESTS Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honour each and every request correctly. In order to alleviate any communication error between browsers and websites, we do not respond to “Do Not Track” signals at this time. As the technology and communication between browser and website improve, we will reevaluate the ability to honour “Do Not Track” signals and may make changes to our policy.   HOW DO WE STORE YOUR DATA? DATA SECURITY We will implement reasonable and appropriate security procedures consistent with prevailing industry standards to protect data from unauthorised access by physical and electronic intrusion. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Information by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive at this site. When you transmit Personal Information through our sign up process via our “Join our journey” form or when you confirm your product purchase, we encrypt that information in transit using secure socket layer technology (SSL).   ONWARD TRANSFER OUTSIDE YOUR COUNTRY OF RESIDENCE Any Personal Information which we may collect on this site may be stored and processed in our server at A2 hosting. By using this site, you consent to any such transfer of Personal Information outside your country of residence to any such location.   UPDATING PERSONAL INFORMATION Upon request, we will permit you to request or make changes or updates to your Personal Information for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others.   LINKS TO JOINT VENTURE MARKETING PARTNER SITES This site may contain links to other websites operated by our joint venture marketing partners. If you do click on any of the links to their websites or accept any of their promotional offers, your click-through information and any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should be careful to review any privacy policies posted on any of these sites before providing information to them.   CHILDREN’S ONLINE POLICY We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site. Consistent with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact our site as provided below under “Contact Us”, and be sure to include in your message the same information that your child submitted.   CONTACT US If you have any questions regarding this Privacy Policy, please contact the owner and operator of this website business at: Smobya OÜ Business registration number: 16509852 Email: ,