Introduction
Personal Data Policy describes the personal data processing practices of VIRAGE SMILE International SRL and complements the Terms and Conditions on the site. This applies for the website https://smilevirage.com, social media pages of VIRAGE SMILE International SRL (including blogs and vlogs), and online/offline events organized by VIRAGE SMILE.
This document is intended to inform you of what kind of personal data we collect from you, how and where we may use this data, how we protect it, who has access to it and what rights you have. All is in accordance with EU Regulation 2016/679 and applicable national law (referred to in this document as the GDPR).
VIRAGE SMILE International SRL addressees to all potential consumers. Our services are made for legal entities or individuals. We apply the principle of minimizing the collected data according to GDPR.
Also, the entire activity of attracting visitors on the website https://smilevirage.com is addressed for individuals and legal entities or their representatives.
Purpose of data collection and legal basis
2.1. The purpose of collecting personal data is:
- sending information to potential consumers;
- selling and providing the services of VIRAGE SMILE International SRL (such as order processing, payment, invoicing, etc.) to all interested people;
- marketing activities for clients and former clients of VIRAGE SMILE International SRL and for attracting legal entities who will purchase our services.
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2.2. The legal grounds for processing this data are:
- execution of the contract and preliminary steps for this contract (art. 6 (1) b GDPR) – for the collected data through the order form. This includes the necessary information related directly with the provision of services and the necessary data for the agreement with the terms of use of the web platform VIRAGE SMILE International SRL;
- legal obligations (art. 6 (1) c GDPR) for the required data for ordering or invoicing;
- consent (art. 6 (1) of the GDPR) for data used for marketing for website visitors (newsletter subscription or information by other methods, etc.);
- the legitimate interest (art. 6 (1) f GDPR) for the data used for marketing for current clients (according to art. 12 (2) law 506/2004) of VIRAGE SMILE International SRL, the data used for marketing to legal entities, security of VIRAGE SMILE International SRL (recital 49 GDPR) and data used internally to optimize the web platforms of VIRAGE SMILE International SRL.Â
2.3. If you register on the web platform VIRAGE SMILE International, we will inform you and ask your permission to send you push notifications. We do not collect personal data from, but these permissions are required for the following purpose:
- push notifications, in order to be able to send you messages related to the events of VIRAGE SMILE International SRL.
What personal data do we collect and how much do we keep?
We collect information that in certain circumstances may constitute personal data in three ways:
3.1. Direct
We ask for your personal data directly through the order form (name, address, e-mail, telephone) which are used for order, account and invoicing, as well as for the sending information related to VIRAGE SMILE International SRL after the event. The order and billing data is kept for 10 years, in accordance with the legal obligations and the account data is used for the entire period when the account is active. If you do not provide us with this information, we will not be able to honor your order or help you with the services you required.
For those who attend our offline events, we usually ask for a name, so that we can make badges and other personalized materials with your name exclusively for the purpose of attending the event and facilitating networking with other participants. They are only used during the event.
During all our offline events for B2B or B2C we make quality photos and videos, which we publish on VIRAGE SMILE International platforms, in order to promote our company’s services.
Also, when you subscribe to our methods of communication, please provide us with certain information, such as an e-mail address and a name, and sometimes other information necessary to personalize your communication. For the registration on the company’s website, as well as for our other web platforms, we may ask you for an email address and/or a phone number, as well as your name.
We may also use our methods of communication to send you commercial information if you are a customer of VIRAGE SMILE International SRL and you took part in any of our events. This data is retained until you revoke your consent, activate the automatic unsubscribe option, or until your activity indicates that you are no longer interested of our news.
3.2. Indirect through traffic data
When you visit a website, regardless of the device used, you disclose certain traffic data that may contain certain personal data about you, such as your IP address, time of visit, place of entry. our sites. They can only identify you in extreme situations and we will never do that anyway due to the fact that we are interested only in statistical information to improve our site or apps. VIRAGE SMILE International SRL uses external traffic analysis services – Google Analytics. The IP address is anonymized to this service and personal information can only be kept for a maximum of 50 months.
We do not collect any traffic data information to access our social networking pages. However, the operating system provider (Windows, Linux, Android, or iOS) or the platform through which you access pages on social networks may have access to such information.
3.3. Indirectly, through cookies or similar technologies and how to block them.
Due to the nature of our site and our services, we only track legal representatives through marketing cookies. VIRAGE SMILE International SRL places cookies (third party) or similar technologies when browsing our sites. Basically they are only from a few platforms – Google, Facebook, Instagram – and their purpose is marketing, traffic analysis or other customizations, according to the details below:
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Name of service                      Purpose
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Facebook Connect                    Marketing
Facebook Social Plugins / Google+ Â Â Â Â Social media
Google Analytics                     Traffic analysis
Google Tag Manager                  Tag Management System
Doubleclick (Google) Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Marketing
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Who else has access to personal data? The data is processed exclusively by VIRAGE SMILE International SRL for the purposes written above. We do not sell or give your data to third parties (as defined in the GDPR), unless you give your express consent to this. However, we need to process your personal data with the help of third parties as authorized entity. These companies can only use the data sent by us, exclusively for the express purpose and cannot use them for their own purposes. This data is sent for the purposes mentioned above through services such as:
- Hosting services
- Email sending services
- Marketing services
- Accounting services
- Online payment services
All authorized people who we work with are companies from the European Union or any state with an adequate protection conditions or other basis established according to Chapter V of the GDPR. With obligations of confidentiality, security and protection of commercial interests, we prefer to publish the list with the categories of recipients.
We do not process personal data that would have legal or other significant importance. For data collected by consent, you have the right to withdraw your consent at any time.
To exercise these rights, you can email us a request to our e-mail address, posted on the site, regarding the specific right you wish to exercise, as well as your identification details. We may request additional data to identify you only to ensure that we do not pass personal data on to another user who is not allowed to access it. You also have the right to lodge a complaint with a supervisory authority or to take legal action.
The personal data policy was adopted today, 11.04.2022 and in the future, whenever we change it, we will publish the new version on the first page of the site and send information regarding this.