Data Protection Officer
The provider and person responsible for the collection and processing of your personal data on this website, within the scope of the General Data Protection Regulation (GDPR) and other national data protection laws of the EU Member States, as well as other data protection regulations, is
Smile Nutrition, Inc.
1430 Ventura Canyon Dr.
The data protection officer at Smile Nutrition, Inc. is: Gabriel Rodriguez Roca Any interested party who has questions and suggestions regarding data protection may contact the above-mentioned data protection officer.
2. General information on personal data and their processing
2.1. How do we handle personal data?
The use of our internet pages is, in principle, possible without entering any personal data. However, if the person concerned wishes to use certain services on our website (such as contact forms, newsletter subscriptions), the processing of personal data may be required.
If the processing of personal data is required and there is no legal basis for such processing, e.g. fulfilment of a contract or fulfilment of a legal obligation, we generally obtain the consent of the data subject. In addition, the processing of personal data will be in accordance with the provisions of the General Data Protection Regulations (hereinafter referred to as GDPR) and under each country's own privacy policies.
2.3. Technical and organisational measures
As data controllers, we have implemented numerous technical and organizational measures to ensure the highest possible protection for the personal data processed through this website. Our websites and our blog include an SSL certificate to increase the security of the website. The SSL certificate is used for the encryption of data transmitted via HTTP. However, data transmissions over the Internet can, in principle, have security flaws, so that absolute protection cannot be guaranteed.
2.4. Legal basis
Provided that we obtain your consent for the processing of personal data, Article 6(1)(a) of the EU General Data Protection Regulation (GDPS) serves as the legal basis for the processing.
If the processing of personal data is necessary to fulfil a contract with you, as is the case, for example, for processing operations necessary for the supply of goods and any service or consideration, the processing is based on Article 6(1)(b) of the RGPD. The same applies to processing operations necessary to carry out pre-contractual measures, for example, in cases of queries about our products or services.
If we were subject to the legal obligation that requires the processing of personal data, such as compliance with tax obligations, the processing would be based on Article 6, paragraph 1, lebra c) of the RGPD.
In rare cases, the processing of personal data may be required to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if someone visiting our company were injured and their name, age, health insurance or other vital information would have to be transmitted to a doctor, hospital or other third party. In this case, the data processing would be based on Article 6(1)(d) of the RGPD.
2.5. Data retention and deletion
Your personal data must be deleted or deactivated when the purpose of the processing of your personal data has expired. However, the data may be kept for longer if European legislation and national law, to whose laws and regulations we as a company are subject, so provide.
3. Online marketing and digital communication with ActiveCampaing
We use the marketing automation software ActiveCampaing from the US company ActiveCampaing, LLC, 1 North Dearborn Street, 5th floor Chicago, IL 60602, hereinafter "ActiveCampaing". ActiveCampaing is an integrated software service that covers various aspects of our digital marketing, sales and customer relationship management. We also use this tool to analyze our websites in order to optimize them and to provide you with the best, most effective service possible. We use ActiveCampaing for:
- a contact form to provide users with an easy way to contact us
- subscription to the newsletter and sending the newsletter
- the content management of our NutriGrow blog
- posting comments on our blog and subscribing to blog updates
- the creation of landing pages, which are used as part of an advertising campaign
- linking to social networks or social sharing
- the analysis of the use of our newsletters (opening rate, click rate, unsubscriptions, etc.)
For detailed information on the scope of data processing, the legal basis, the purpose, the time limits for data retention, as well as the possibilities for objection, please refer to points 3.1. to 3.6.
The content of this website is based on your personal data, which is provided by you, for example, when using our contact form or registering for our newsletter.
3.1. Contact form
The landing pages of our specific products have a contact form by which visitors to our website can contact us. Article 6(1)(f) of the RGPD (legitimate interest) is the legal basis for the handling of contact requests. In this case, our legitimate interest in the processing of personal data extends to the ability to respond to your inquiry. If you provide us with your personal data via the contact form, the disclosure of this data by you is expressly voluntary. In this case, the legal basis for data processing is Article 6(1)(a) of the GPRS. If we process your data for the purpose of carrying out pre-contractual measures, the legal basis is Article 6(1)(b) of the GPRS.
When using the contact form, the following data is collected:
- Both your email address and the query itself are required fields that allow us to process the query and respond to it.
- Your last name, first name, form of address and the name of your company are optional fields. The information is voluntary and serves to address you in a correct and more personal way.
Your personal data will be used exclusively for the processing of the conversation and will not be communicated to unauthorized third parties. The data is kept in our Hubspot marketing automation tool until your inquiry, or all relevant facts associated with it, are finally resolved. Subsequently, the data will be deleted, unless the contact request results in a contract. In this case, we can and must keep your data according to the statutory deadlines. You have the opportunity to revoke your consent to the processing of your data at any time. All personal data stored during the course of the contact will be deleted immediately in this case.
3.2. Marketing subscription forms
As part of the subscription process to our newsletter, we collect the following data from you.
Data you entered in the form:
- Surname and first name
- E-mail address
- Declaration of consent
Technical data collected at registration:
- IP address
- Time of registration and declaration of consent
- Web form used for registration
- Data for the double opt-in (DOI) process
- Other data that may be collected in the course of the subscription for marketing purposes
- Each newsletter contains a link to a preference page, where you can specify your interests (e.g. marketing information, events), so that we can provide you with relevant information.
Your consent to the processing of your data is obtained during the registration process. When you register for our newsletter, you will receive a confirmation email with a link. The link will verify your email address. This is a double opt-in process and protects you and us against misuse of your email address; it also helps to verify that the consent actually comes from the owner of the email address that provided the data at the time of subscription.
If you provide us with your personal data when registering, the disclosure of this data by you is expressly voluntary. The legal basis for processing is Article 6(1)(a) of the GPRS. Your personal data will be used exclusively to send you our newsletter, and will not be communicated to unauthorized third parties. The data is stored in our HubSpot marketing automation tool as long as the subscription remains active. You have the opportunity to revoke your consent to the processing of your data at any time. Each newsletter contains a link to unsubscribe. In addition, you can always send an e-mail to our data protection officer (firstname.lastname@example.org) and inform us of the cancellation of your subscription. All personal data stored during the newsletter subscription will be deleted immediately in the event of a revocation of consent to data processing and a simultaneous request for deletion of data.
We regularly generate downloads such as technical reports, computer graphics, e-books, presentations, brochures, etc. Creating a complete technical report or a computer graphic requires a lot of preparation time and the use of valuable resources. By subscribing to our newsletter, you will also gain access to this exclusive and high quality content. With regard to the scope and purpose of the processing, as well as its legal basis, retention, revocation and deletion deadlines (as described in section 3.2.) we will collect further specific data for marketing purposes according to the download. These data include, for example, the level of knowledge or experience on the relevant topic, the use of systems, etc. Evaluating this data helps us to create more content.
3.4. "Comments" function
Our blog has a comment function that allows you to make comments on blog posts. The use of this feature requires you to enter your email address. Other information such as your first name, last name and website is optional. The specification of the email address is necessary so that any objections or questions related to your comments can be forwarded to you. If you enter your first and/or last name when posting a comment, this information will be published. Your e-mail address and other voluntary information, as well as the time the comment was created, are retained on Hubspot but are not published or disclosed to any third party. This data is processed solely for the purpose of providing comments.
We reserve the right to delete comments with offensive, threatening or racist content. If you provide us with your personal data via the comment function form, the disclosure of this data by you is expressly voluntary. The legal basis for the processing is Article 6(1)(a) of the RGPD.
The data is stored in our Hubspot marketing automation tool until you want to revoke your consent to the processing of the data. You have the opportunity to revoke your consent to the processing of your data at any time. All personal data that you have entered in the comment function will be deleted immediately in the event of a revocation. This requires that all comments you made on our blog are also deleted.
3.5. Blog updates
You can register to receive updates from the blog with your email address, first and last name. That means we'll send you an email as soon as there's a new NutriGrow Club blog post. If you register for blog updates, you will receive a confirmation email with a link. The link will verify your email address. This corroborated subscription procedure is called double-opt-in (DOI) consent, and it protects you and us from the misuse of your email address; it also helps verify that the consent actually comes from the owner of the email address that provided the data at the time of subscription.
If you provide us with your personal data when registering for blog updates, the disclosure of this data by you is expressly voluntary. The legal basis for processing is Article 6(1)(a) of the RGPD.
Your e-mail address and other voluntary information, as well as the date of registration, will not be disclosed to third parties and will be processed only for the purpose of informing you about a new publication. You have the option of revoking your consent to the processing of your data via e-mail. Until the revocation, we keep your data on Hubspot. In the event of a revocation of data processing and a simultaneous request for deletion of data, your personal data will be deleted immediately.
3.6. Data analysis and reporting
Hubspot allows us to carry out the following reports, analyses and evaluations:
- Activity on our websites and blog
- Number of page views and time each visitor stays on each page
- Click path of each visitor
- Downloading files from the website
- Landing page report
- Opening rates for newsletters and campaigns
By using the website, you consent to the collection of data for analysis. You may refuse, at any time, to allow HubSpot to track your visits by clicking the "Reject" button in the cookie message.
Cookies are small text files that are stored on your computer or mobile device and saved to your browser. Cookies allow us to automatically recognize that you have visited our website again. Cookies do not cause any damage to your device and do not contain any viruses. Cookies serve to make our website more user-friendly, more effective and safer. In addition, cookies allow us to analyse how visitors use the website (see 3.6. and 5.).
There are differences between own and third party cookies. Own cookies are those that are set for our website. All other cookies are from third parties. Our websites use their own and third-party cookies.
Not all cookies collect personal data.
Among others, the following personal data may be collected through cookies:
- IP address
- Start data
Non-personal data collected by cookies may include
- Browser language
- Session Information
Most of the cookies we use are so-called "session cookies". They are automatically deleted at the end of your visit. Other cookies are kept on your device until you delete them. These cookies allow us to recognize your browser the next time you visit our website. We also use analysis cookies. These cookies are used to anonymously monitor user behaviour on the website, for example by recording the number of visits per page. The data collected will only be used to optimize the performance and design of this website. These cookies are third-party cookies (such as Google Analytics, HubSpot). This data is collected anonymously and used exclusively by us.
The legal basis for the processing of personal data by means of technically necessary cookies is Article 6(1) of the RGPD. The legal basis for the processing of personal data by means of cookies that are not technically necessary (analysis cookies) is Article 6(1)(a) of the GDPR.
5. Google Analytics
Our website uses Google Analytics. This is a service provided by Google Inc. ("Google") for the analysis of accesses to Internet pages that allow us to improve our Internet offers. Cookies (see above) allow us to analyse your use of our website. The information collected by means of a cookie (IP address, time of access, duration of access) is transmitted to a Google server in the United States and stored there. The evaluation of your activities on our website will be transmitted to us via reports. Google may disclose the information collected to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google's tracking codes in our internet offer use the function "_anonymizeIp ()", therefore IP addresses are only processed in a shortened form to exclude possible direct personal references. You can also prevent the installation of cookies by Google Analytics by selecting the appropriate settings in your browser software. In this case, you may not be able to use the functions of our website in full. Google Analytics can also be disabled and controlled by means of browser extensions, e.g. via the Google Browser Opt-out Plug-in: tools.google.com/dlpage/gaoptout. By using our online offer, you agree to the processing of your data by Google.
6. Google Maps
On our website we use the "Google Maps" map application server from Google Inc. 1600 Amphitheater Parkway, Mountain View, CA 94043 USA, hereinafter "Google". Each time you enter Google Maps, Google sets a cookie to store your preferences when you are viewing the page on which Google Maps is displayed. As a general rule, this cookie is not deleted when you close your browser, but expires after a certain period of time unless you first manually delete it. If you do not agree with this data processing, it is possible to deactivate the "Google Maps" service and thus prevent the transfer of data to Google. To do this, the Java Script function of the browser must be deactivated. However, it should be noted that in this case you will not be able to use "Google Maps", or only to a limited extent. The use of "Google Maps" and information obtained via "Google Maps" is subject to the Google Terms of Service and the additional terms of service of "Google Maps".
7. Social Media
Our website links to our Facebook page, as well as our profiles on Twitter, Google+, LinkedIn and Xing. No data is sent to Facebook, Twitter, Google+, LinkedIn or Xing just by linking to the corresponding page through the icons.
We remind you that you use our Facebook, Twitter, Google+, LinkedIn and Xing pages and their functions voluntarily and under your responsibility. The same applies to the use of interactive features such as "comments", "sharing" and rating. Please note that data collected by Facebook Ltd., Twitter Inc., Google LLC, LinkedIn Inc. and Xing SE are processed by these companies and may be transferred to other countries outside the European Union. The data received by Facebook, Twitter, Google, LinkedIn or Xing, and how it is used by such providers, are described in their respective data use policies. You can also find information about contact possibilities and ad settings. You can view the data usage guidelines here:
8. YouTube videos
In order to include videos on our website, we use YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, represented by Google Inc, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Usually, when you visit a page with a video inserted, your IP address will be sent to YouTube and cookies will be installed on your device.
Some of our internet offers contain hyperlinks to other websites which are not operated by us. We do not monitor these websites and are neither responsible for their content nor their handling of personal data.
10. Log files for web servers
The hosting service provider of our web pages collects and records information in so-called log files and this information is automatically sent to us by browsers every time someone accesses our web pages. Among other things:
- Visited website
- Date and time of website visit or server request
- Amount of data transferred
- Notification of successful download
- Browser type and version
- Operating system used
- Referral URL (the previously visited page)
- Hostname of the computer you are accessing
- IP Addresses
The temporary preservation of the IP address by the system is necessary to allow our web pages to reach your computer. That is why the IP address must be saved at least for the duration of the session. The data in the log files also serves to optimize our websites and to ensure the security of our websites. Log files are not used to evaluate the behaviour of website visitors or for marketing purposes, and are not associated with other data collected by us. The retention of IP addresses empowers the competent authorities in the event of cyber attacks or in the event of illegal use, since IP addresses, assigned to a user via the provider, can identify that user. For this reason, log files are kept at our hosting service provider for a period of 6 months and then deleted. The legal basis for the retention of data in the log files is Article 6(1)(f) of the GDPR. The collection of data for the provision of the web pages and the retention of the data in log files is essential for the operation of our website. There is no possibility for you to object.
11. Rights of information, rectification, erasure, restriction of processing, data portability, objection and complaints
At any time, the European Directive and the regulatory body give you the right to:
- obtain free of charge information on their own data, their origin and recipients, or the categories of recipients to whom the data were disclosed or transmitted; the purpose of the processing; the duration of the retention of the data or, if this is not possible, the criteria for determining the retention periods; as well as information on whether their personal data were transmitted to a third country or to an international organisation. If this is the case, you have the right to obtain information on the appropriate safeguards in the framework of the transmission.
- the rectification, i.e. the correction, completion or immediate deletion of your data
- limit data processing
- not be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects or similarly affects him
- to complain to the supervisory authorities
In addition, you may revoke your consent to the collection and retention of data with future effect at any time.
We may, at your request, provide you with your stored personal data, in a common format, or transfer it to another person in charge.
Notification and contact
If you have any questions regarding this data protection declaration or the storage of your data, please contact us at
Last update: 06/06/2019