General Privacy Policy

At smartphoto we attach great importance to your privacy. To fully benefit from our service, we need certain information from you. In this General Privacy Policy you can read what we do with this information and what are the legal grounds on which this use is based.

This “General Privacy Policy” governs the processing of your personal data by those persons responsible for the processing: smartphoto Nordic AB, with registered office at Östergatan 39, 211 22 Malmö, Sweden, and registered in the Swedish Central Database under the corporate registration number 556334-8100 (hereinafter: “smartphoto”).

This General Privacy Policy contains your rights and obligations with regard to smartphoto and can be revised or updated. We would advise you to read through them carefully and to review them regularly.

Article 1 - General information

1.1. By means of this General Privacy Policy, smartphoto is also in line with the European Regulation 2016/679 of 27 April 2016 regarding the protection of personal data (hereinafter referred to as the General Data Protection Regulations or as the “GDPR”) and any specific local data privacy regulation.

Article 2 - Personal data

2.1. Personal data that you share with us:

- Category 1: without registration: your IP-address;
- Category 2: at registration on the website when creating an account: Your e-mail address and password; any supplementary personal data you voluntary provided in your profile;
- Category 3: your first name & name and address details in order to make a delivery, your payment and invoicing data when placing an order;
- Category 4: when you subscribe to our newsletter: your e-mail address;
- Category 5: images that you save on your account or upload for the delivery of the goods;
- Category 6: via cookies: see Article 9.

2.2. Smartphoto can collect data from you (personal data) in various ways:

a. by using cookies (see below);
b. during your registration and use of the website.

Article 3 – Purposes of the processing

3.1. General purposes:

smartphoto will only make use of the personal data collected from you for the following purposes:

- Category 1: your IP address for the purpose of maintaining and improving this website and the inclusion of personal data in anonymous statistics from which the identity of specific persons or companies cannot be deduced, with the legal grounds being the legitimate interests of smartphoto to continually improve its website and services. Using the IP address, the geographical information is also processed via Google. Furthermore, we also remember your preferences, in order to be able to give you suitable advice.
- Category 2: your e-mail address and password (and any supplementary personal data you voluntary provided in your profile) for the purpose of managing your account on this website, with the legal basis being the implementation of an agreement that was requested by you, and, if indicated by you, for the sending of direct marketing, with the legal basis being your explicit, prior consent.
- Category 3: your first name, name and address details for the delivery, payment and invoicing of the products ordered by you, with the legal basis being the provision of a service that was requested by you. At each order you have the option to either allow to store your payment details or not. These are stored as an additional service for you.
- Category 4: your e-mail address for the purpose of sending you direct marketing, newsletters, special offers and promotions, with the legal basis being your explicit prior permission.
- Category 5: images that you save on your account or upload for the delivery of the goods.
- Category 6: cookies, see Article 9 for more information.

You are not obligated to release your personal data, but you must understand that the provision of certain services becomes impossible if you refuse to allow the processing.

3.2. Direct marketing:

TThe personal data will also be used for direct marketing, if you gave your consent.

If you have already been included in our mailing list for receiving marketing materials in electronic form, smartphoto may use your personal data for sending you direct marketing with regard to smartphoto and its services.

This consent can be withdrawn simply at any time, without justification and free-of-charge, for example by clicking on the opt-out link provided for this at the bottom of each promotional e-mail message or in your profile. You can also contact us by e-mail via contact@smartphoto.co.uk or by letter to the following address:

smartphoto Nordic AB
Östergatan 39,
211 22 Malmö, Sweden

3.3. Transfer to third parties:

Smartphoto will never pass on your personal data to third parties without your consent, with the exception of companies that are directly or indirectly connected with smartphoto for carrying out the requested services (such as the delivery of the ordered goods).

Smartphoto will make reasonable efforts to inform you in advance of the fact that smartphoto discloses your data to the above-mentioned third parties, but you should also recognise that this is not technically or commercially feasible under all circumstances.

Smartphoto will not sell, rent or distribute your personal data, or make it otherwise commercially available to third parties, except in the cases described above, or with your prior consent.

3.4. Legal requirements:

In rare cases, it may occur that smartphoto is obliged to disclose your personal data pursuant to a court order, or in order to comply with other mandatory laws or regulations. Smartphoto will make reasonable efforts to inform you accordingly in advance, unless this is subject to legal restrictions.

Article 4 – Duration of the processing

We retain and process personal data for a period that is necessary to fulfil the purposes of the processing, depending on the contractual relationship between you and smartphoto.

- Category 1: without registration: your IP address for the duration of your visit to the website.
- Category 2: your e-mail address and password (and any supplementary personal data you voluntary provided in your profile) will be retained for the duration of the customer relationship.
- Category 3: after you have placed an order, your first name, name and address details will be retained for the duration of the customer relationship.
- Category 4: your e-mail address will be retained for the duration of the customer relationship.
- Category 5: all images uploaded by using your account will be retained for 24 months. If a (new) order has been placed, your images will be kept for another 24 months. If images have been uploaded or used for an order without using your account, these will be kept for one month.
- Category 6: cookies, see Article 9.

Article 5 - Your rights

5.1. Right of access and inspection:

You have the right to access your personal data at any time and free of charge, as well as to be informed about the use smartphoto makes of your personal data.

5.2. Right of correction, deletion and limitation:

You are free to communicate your personal data to smartphoto, or not to do so. In addition, you have the right to ask us to correct, supplement or delete your personal data at any time. You acknowledge that the delivery of certain services and products will not be possible if you refuse to communicate personal data, or if you ask us to delete your personal data.
You may also request that the processing of your personal data be restricted.

5.3. Right of objection:

You also have the right to oppose the processing of your personal data for serious and legitimate reasons.
In addition, you always have the right to oppose the use of personal data for purposes of direct marketing; in this case, you do not need to give any reasons.

5.4. Right of free data transfer:

You have the right to obtain your personal data that is processed by smartphoto in a structured, standard and machine-readable form and/or to have your personal data transferred to other data processors.

5.5. Right of withdrawal of consent:

Insofar as the processing is based on your prior consent, you have the right to withdraw this consent.

5.6. Exercising your rights:

You can exercise your rights by contacting us, either by e-mail to contact@smartphoto.co.uk or by letter to (provided you can identify yourself as a customer):

smartphoto Nordic AB
Östergatan 39,
211 22 Malmö, Sweden

5.7. Right to submit complaints:

You have the right to lodge a complaint to the Information Commissioner’s Office (ICO): Information Commissioner’s Office, 3rd floor, 14 Cromac Place, Belfast, BT7 2JB Phone: 029 2067 9400, Fax: 0292 067 8399 e-mail: registration@ico.org.uk.
A claim for compensation from the civil court will still be possible afterwards in the event you were to suffer damage as a result of the processing of your personal data.

Article 6 - Security and confidentiality

6.1. We have developed technical and organisational security measures of personal data protection to prevent the destruction, loss, falsification, modification, unauthorised access or inadvertent notification to third parties of personal data by error, as well as to prevent any other unauthorised processing of this data.

6.2. Under no circumstances can smartphoto be held liable for any direct or indirect damage that arises from the incorrect or unlawful use of the personal data by a third party. You guarantee that you have lawfully obtained permission from the people who are included in the images you submitted or uploaded, and if there is copyright or any other right on the images, that you have these rights; and that you will fully compensate and indemnify smartphoto against any claim by a third party against smartphoto as a result of unlawful processing of that third party’s personal data.

6.3. You must comply with the security regulations at all times, for example by preventing any unauthorized access to your login. You are therefore solely responsible for the use made of the website from your computer, IP address and for your identification data, as well as for the confidentiality thereof.

Article 7 – Access by third parties

7.1. In order to be able to process your personal data, we grant access to your personal data to our employees to the extent that is necessary for one of the described purposes of the processing.

7.2. We guarantee a similar level of protection by making contractual obligations that are similar to this Privacy Policy enforceable against the employees and appointees.

7.3. In order to guarantee an optimal service, our customer service department has access to your account, and this only in the context of providing our services to you.

Article 8 – Privacy Commission declaration

A declaration of the processing of personal data was made to the Belgian Data Protection Authority.

Article 9 - Cookies

9.1. What are cookies?

A “cookie” is a small file sent out by the smartphoto server and placed on the hard drive of your computer. The information stored in these cookies can only be read by us, and only during the duration of the visit to the website.

9.2. Why do we use cookies?

Our website uses cookies and similar technologies to distinguish between your usage preferences and those of other users of our website. This helps us to offer you an even better user experience when you visit our website and also allows us to optimize our website. This helps us to offer you a better user experience, for example by filling in certain information without asking you to do this each time when you visit our website, and also allows us to optimize it.

As a result of recent legislative changes, all websites aimed at certain parts of the European Union are obliged to ask your permission for the use or storage of cookies and similar technologies on your computers or mobile devices. This Cookie Policy gives you clear and complete information about the cookies we use and their purpose.

9.3. Types of cookies:

Although there are different types of cookies that differ in terms of functionality, origin or retention period, the legislation mainly distinguishes between functional or technically necessary cookies on the one hand, and all other cookies on the other.

Our website only uses the following cookies:

Functional cookies
Name Function
Authentication cookies
'Remember me’
The identification of the user while he is logged in.
User input cookies
‘Lifestyle Identifier’
The remembering of user actions on a website.
User interface customization cookies Are used to remember user preferences.
Tracking cookies Google AnalyticsAre used to record the browsing behaviour of visitors.



Non-functional cookies
Name Function
Tracking cookiesAre used to record the browsing behaviour of visitors.
Social plug-in tracking cookiesAre used to offer social media modules on a website, such as a Facebook Like button, Pinterest button or the possibility of re-tweeting a message.


For cookies placed by third parties (including but not limited to Google Analytics, Google Plus, Google Maps, Google Adwords, Bing Search Marketing, Facebook), we refer to the statements made by these parties on their respective websites. Please note: We do not exert any influence on the content of these statements, nor on the content of the cookies of these third parties. For more information about Google Analytics cookies, please visit the official Google Analytics Privacy Policy (https://support.google.com/analytics/answer/6004245?hl=en).

9.4. Your agreement:

In the near future you will be asked, at your first visit to our website, to accept our different types of cookies. You will be able to accept or reject the cookies by category then. From that moment on, you will be able to change the cookie settings for our website at any time via the hyperlink at the bottom of our website and thereby revoke your consent.
At the first use of the website, you will also be able to refuse to allow the installation of these cookies by selecting “Refuse cookies” in the pop-up screen provided for this purpose.
Additionally, you can also refuse or block cookies by changing the configuration parameters of your browser. The disabling of cookies can mean that you may not be able to make use of certain functionalities of the website.
If you have any further questions or comments regarding the processing of your personal data, please feel free to contact us, either by e-mail to contact@smartphoto.co.uk,

or by letter to
smartphoto Nordic AB
Östergatan 39,
211 22 Malmö, Sweden

or by phone to +46 525 170 00.

You can also find more information about cookies on: http://www.allaboutcookies.org
You can find more information about online behavioural advertising and online privacy here: http://www.youronlinechoices.eu/

Article 10 – Applicable law and competent court

This General Privacy Policy is governed, interpreted and implemented in accordance with Swedish law, which is exclusively applicable.
The courts that have jurisdiction over the company responsible for the processing of personal data have exclusive jurisdiction over any dispute that may arise from the interpretation or implementation of this General Privacy Policy.
In the case of any contradiction between the English General Privacy Policy with the Dutch version, the Dutch version will take precedence.