Privacy Policy

Personal Data

Personal Data means any data related to a person that allows that person to be identified such as your name, age, telephone number, e-mail and mailing address (“Personal Data").

Smartwell would like to collect, maintain and use your Personal Data to:
- fulfil its obligations under any sale and purchase contract and any other contract between you and Smartwell,
- provide customer care, including services related to Smartwell businesses, such as warranty and after sales services,
- ask your opinions on Smartwell products and services and conduct product surveys,
- facilitate and process your searches and requests for information on Smartwell and its products and services,
- provide you with the latest Smartwell products and services information, including upgrades and special offers in which you may be interested,
- improve Smartwell products and services for you,
- conduct prize draws, contests and other promotional offers,
- consider employing you if these data are requested on one of Smartwell’s job application websites.

For these purposes, Smartwell may share, make available or transmit Personal Data to other Smartwell Group Companies (subject to Smartwell’s strict compliance with applicable data protection laws). Smartwell Group Companies will use your Personal Data only for the purposes outlined above, and they are or will be subject to stringent policies and terms on Personal Data use and protection.

Smartwell collects data about you in several ways. For example, we might ask for your contact information when you correspond with Smartwell, call Smartwell to make a purchase or request service, register your purchased product for after sales service, register to participate in an on-line survey or to any promotional offers, chat rooms, or on bulletin boards.

Here are some of the most typical examples of how Smartwell collects your personal data.
- When you register a Smartwell product or service, we will collect your name, address data and the product or model name, etc.,
- When you ask our customer service for help, we will keep a record of your name, the product(s) you bought, the technical issues at hand, and our advice to you etc.,
- When you buy a product from us, or make a request to purchase, we record your name, contact details, the products you want to buy or bought and your requests to us. If you buy online an account will be created with your payment and shipping preferences. A credit check may have to be done if you decide to purchase a product or a service,
- When you want to participate in online communities, we need to record your account details and preferences. Some of our web sites allow for some personalisation of the content according to your interests, in which case we are recording your preferences,
- Keeping a record of your contact details and any resulting financial transaction in the context of a repair.

Data collected online may also be combined with data you provide to Smartwell at other times. For example, during product registrations, calls to our call centers or at public events such as exhibitions and trade shows. The Personal Data provided to Smartwell in these cases may be consolidated with existing databases and stored, so that our customer data management systems are simplified.

Your Preferences

The personal data we collect may be stored in different databases. Smartwell makes every effort to take into account the various preferences you may have expressed over time in order to process your data in a consistent way. If for any reason you receive incorrect data, Smartwell Customer Service can be contacted to rectify this situation.


Smartwell will not disclose Personal Data to third parties ("3Ps") other than Smartwell Group Companies, without your consent, except in the following cases:
Personal Data may be disclosed to sub-contracting 3Ps to enable the performance of contracts you are party to or for other purposes. Smartwell uses other companies to perform functions on its behalf, such as fulfilling orders, delivering packages, sending postal mail and e-mails, providing marketing assistance, processing credit card payments and providing customer services. Such companies will have access to personal data needed to perform these functions, but may not use it for any other purpose and are required to process the data in accordance with applicable law.
Personal Data may be disclosed to 3Ps to enable compliance with legal obligations to which Smartwell is subject. If Personal Data is disclosed to 3Ps to enable them to provide services for, on behalf of, or at the direction of Smartwell, then Smartwell takes measures to ensure that the 3Ps comply with our own privacy policy, and that such recipients:
- do not use the Personal Data for any other purposes than those permitted,
- obtain and process Personal Data only on condition that they protect that Personal Data from unauthorised use and adopt and comply with similarly stringent policies and terms on Personal Data protection and use,
- comply strictly with applicable laws.

Anonymous or generic data (including "generic" statistics) from which you cannot be identified are excluded from use, processing, disclosure, transmission and other Personal Data use restrictions.

Postings to Forums

Postings on certain Smartwell websites (whether in chat rooms, on message boards or via other methods of communication within the Forums) will generally be available to, and freely accessible by, other users of Smartwell Forums. Therefore, users should not expect any information they post to be kept private or confidential and they are encouraged to exercise discretion when using the Smartwell Forums. Additionally, your member name will always be posted in conjunction with your posting in the Smartwell Forums.

Security of Collected Data

Smartwell intends to protect your Personal Data and to maintain its quality. Smartwell will use all reasonable efforts to take all appropriate technical and organisational measures and precautions to keep Personal Data secure and protected from unauthorised access, use or alteration and unlawful destruction. Measures include using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data, such as credit card details. SSL encryption is designed to make the data unreadable by anyone but us.

How we protect your data
- we limit access to your Personal Data. Only those employees who need to come into contact with that data, to provide products and services to you, will do so,
- we have physical, electronic, and procedural safeguards that comply with regulations to protect your Personal Data,
- we allow for your account data to be password protected.
As general best practice on the internet, it is recommended that individuals do not use trivial login names and passwords. Passwords should contain a combination of letters and numbers, be kept securely and changed periodically.


Certain Smartwell websites may employ an industry-wide technology called "cookies". These are small pieces of data that are placed on your hard disk drive when you access a website or a certain part of a website. Cookies help Smartwell understand which parts of its websites are the most popular, where Smartwell visitors are going, and how much time they spend there.
Smartwell uses cookies to study traffic patterns on its sites in order to improve website performance, to customise the user experience, and to better match the users' interests and preferences. For example, Smartwell keeps track of the domains from which people visit, and also measures visitor activity on Smartwell websites. However, these tracking records are performed and maintained in ways that keep the data non-identifiable.
Cookies may also be used to recognise your computer next time you visit a website. This might save you time (e.g. by ensuring that you don not have to register again) or help you by customising your internet settings.
If you do not wish to accept cookies, they can be disabled by referring to your browser manufacturer’s instructions. Please refer to your browser instructions or help screen to learn more about these functions. For example, in Internet Explorer, you can go to the Tools/Internet options/Security and Privacy Tabs to adapt the browser to your expectations.
Web beacons, also known as single pixel or clear gif technology, or action tags, may be used on our site. This technology show us which visitors clicked on key elements (such as links or graphics) on a Smartwell Web page or a Smartwell e-mail. When you ask us to send you information on a promotion or a newsletter, we may use web beacons to establish which emails are actually opened. We use this information in order to optimise our content and services.

These Web beacons usually work in conjunction with cookies. If you don't want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies.

Access to Your Personal Data

You have the right to access your Personal Data, and to rectify or delete inaccuracies in your Personal Data, and to object to the processing of your Personal Data.
If you would like to view, correct, amend or update your Personal Data stored in Smartwell’s database, contact Smartwell. For privacy protection reasons, you will be asked to provide some proof of identification.
On demand, you can receive an explanation regarding the processing of your Personal Data and also obtain confirmation that all relevant parties have been notified of your request(s) for information, for alteration or for deletion, as appropriate. Smartwell will do its best to comply with such requests.
If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link and/or instructions placed (typically) at the bottom of the mail. If you use more than one e-mail address to shop or contact Smartwell, unsubscribe from each e-mail account you use.

Links to Other Sites

Some Smartwell websites may contain links to other websites that are not operated by Smartwell. Smartwell does not share your Personal Data with those websites. While Smartwell tries to link only to sites that share Smartwell’s high standards and respect for privacy, Smartwell is not responsible for the content, security, or privacy practices employed by other sites and expressly disclaims all liability associated with your use of such other sites and the content found there.

Children’s Privacy

Smartwell does not knowingly solicit or collect Personal Data from or about children (aged 14 and under) without the consent of a parent or guardian, and Smartwell does not knowingly market its products or services to children. If Smartwell becomes aware that the person submitting Personal Data, through any part of Smartwell’s websites, is a child, Smartwell will use reasonable efforts to delete that Personal Data from its files as soon as possible. Smartwell will also use reasonable efforts to ensure that this Personal Data is not used for any purpose, nor disclosed to any 3P. As Smartwell does not seek to collect any Personal Data about children, and Smartwell deletes any data collected inadvertently as soon as it is discovered, Smartwell retains no data about children that could be reviewed or deleted. If a parent requests review or deletion of data about their child before Smartwell has discovered and deleted the data, then Smartwell will of course honour that request.

Industry Standards

The Smartwell Privacy Policy has been established in cooperation with the Federation of European Direct Marketing (FEDMA). FEDMA is the first trade association whose data protection code of practice, which was developed in negotiations with the European Data Protection Authorities and recognized by the EU Commission. For enquiries about your Personal Data please contact us via sending an e-mail to