Legal Disclaimer: This privacy policy is designed to comply with the CCPA, as amended by the CPRA (effective January 1, 2023), and related state privacy laws. This is a template and not a substitute for legal counsel. Please consult a qualified privacy attorney to ensure full compliance with applicable laws in your jurisdiction.
Smitle respects the privacy of our users and is committed to transparency regarding our data practices. This Privacy Policy explains how Smitle collects, uses, discloses, and otherwise processes personal information in connection with our website, mobile application, and related services. By accessing or using Smitle, you acknowledge that you have read and understood this Privacy Policy.
Personal Information We Collect
Smitle collects personal information in several ways — directly from you, automatically through your use of the platform, and from third parties. Below are the specific categories collected during the 12-month period preceding this policy's effective date:
- Contact & Identification: Name, email address, phone number, postal address, account username, and other identifiers.
- Preferences & Activity: Gift preferences, wishlists, saved items, reminders, event details, group gifting activities, product ratings, and platform interactions.
- Commercial Transactions: Purchase history, transaction amounts, payment method info (via secure third-party providers), order status, and delivery details.
- Device & Technical: Device type, OS, browser type, IP address, device identifiers, mobile network info, and pages visited.
- Location Data: Approximate location from IP address, or precise geolocation if permitted by your device.
- Professional Info: Job title or employment status, if voluntarily provided during registration.
- Analytics & Usage: Clickstream data, search queries, pages visited, time spent, referral sources, and feature interactions.
Categories of Sources
We obtain personal information from the following sources:
- Directly from you when interacting with our platform
- Automatically through cookies, pixels, and analytics tools
- Third parties such as data brokers, social media platforms (if linked), or affiliate partners
- Publicly available sources
- Business partners who refer or share data with us
How We Use Your Information
We collect and use personal information for the following specific business purposes:
- Providing our services and fulfilling your requests
- Creating and managing your account
- Personalizing your experience and providing tailored recommendations
- Communicating with you about orders, account updates, and service changes
- Processing transactions and payments
- Measuring and improving platform performance
- Developing new features
- Preventing fraud and protecting against security threats
- Complying with legal obligations and responding to law enforcement requests
- Enforcing our terms of service
- Analyzing user behavior to improve our offerings
Data Minimization
We limit collection, use, and retention of your information to what is reasonably necessary and proportionate to serve these purposes. If we intend to use your information for materially different purposes, we will provide you with notice and, where required, obtain your consent.
Your Consumer Rights (LOCK)
Under the CCPA and similar state laws, California and other state residents have the following rights. You can exercise these rights at any time by submitting a verifiable request through the methods described in the Contact Us section. We will respond to verified requests within 45 days.
- Right to Delete: You have the right to request deletion of personal information we have collected from you, subject to certain exceptions including when the information is necessary to complete a transaction or comply with legal obligations.
- Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights — no denial of goods, different pricing, or different service quality.
Sale and Sharing of Personal Information
Under CCPA/CPRA, "sale" means selling, renting, releasing, disclosing, or otherwise communicating personal information to another business for monetary or other valuable consideration. "Sharing" includes disclosing personal information to third parties for cross-context behavioral advertising.
Our Policy
Smitle may share user information with advertising partners and analytics providers in ways that may constitute "sharing" for cross-context behavioral advertising under CCPA/CPRA definitions. You have the right to opt-out of this sharing at any time. To exercise this right, please visit our "Do Not Sell or Share My Personal Information" link or contact us using the methods in the Contact Us section.
During the 12-month period preceding this policy's effective date, Smitle has shared the following categories of personal information for cross-context behavioral advertising or affiliate purposes: contact information, preferences and activity information, device and technical information, and analytics data. These disclosures have been made to advertising networks, analytics providers, and affiliate marketing partners.
Sensitive Personal Information
We handle certain categories of sensitive personal information with additional care, including social security numbers, financial account information, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, genetic information, biometric data, health information, sex life information, and personal information of minors under 16.
We limit our use and disclosure of sensitive personal information to purposes you would reasonably expect or that are necessary to provide services you request. We do not use sensitive information for profiling or automated decision-making that produces legal effects, or sale without your explicit opt-in consent.
Right to Limit
You may submit a request to limit our use of your sensitive personal information at any time by clicking the "Limit Use of My Sensitive Personal Information" link, or contacting us through the methods in the Contact Us section.
Data Retention and Deletion
We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and protect against fraud. Specific retention periods:
- Account Information: Retained for the duration of your account and for two years after account closure, unless longer retention is required by law.
- Transaction Information: Retained for at least seven years for tax and legal compliance purposes.
- Marketing Preferences: Retained as long as necessary to honor your preferences, typically for the duration of your relationship with us.
- Analytics & Device Data: Retained for 12–24 months from collection unless anonymized.
You may request deletion of your personal information at any time. We will delete your information within 45 days of a verified deletion request, subject to applicable law exceptions.
Automated Decision-Making Technology
Smitle may use automated decision-making technology (ADMT) including artificial intelligence and algorithmic processing to make certain decisions affecting you, such as personalized recommendations, content moderation, fraud detection, and eligibility determinations.
When we use ADMT for significant decisions that have legal or similarly significant effects, we will provide you with notice of the right to opt-out of such processing, human review options, and information about the logic, significance, and consequences of the decision.
Do Not Sell or Share My Personal Information
If you are a California or other applicable state resident and wish to opt-out of the sharing or sale of your personal information, you have the right to submit an opt-out request.
Submit an opt-out request by emailing us or submitting a form through our website. Once verified, we will honor your opt-out preference for at least 12 months. We also recognize and honor valid Global Privacy Control (GPC) signals as opt-out requests.
Children and International Users
Children's Privacy: Smitle is not intended for users under 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected information from a child under 13 without verifiable parental consent, we will delete it promptly. For users ages 13–15, we provide enhanced protections for sensitive information.
International Users: Our platform is operated in the United States. If you are located outside the U.S., your information may be transferred to, processed in, and stored in the United States. By using Smitle, you consent to this transfer and processing.
Contact Us and Exercising Your Rights
To exercise any of your privacy rights, submit a verifiable request through one of the following methods:
Smitle Privacy Inquiries
- Email[email protected]
- Websitewww.smitle.com/privacy
- ResponseWe aim to respond to all verifiable requests within 45 days.
This Privacy Policy is effective as of May 19, 2026, and will be updated at least annually or as required by law. Material changes will be posted on this page with an updated effective date. Your continued use of Smitle after updates constitutes your acceptance of the revised policy.
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