Penthouse ‘Fine traditions’

_{Smartline Design (referred to as “our,” “us,” or “we”) respects and values your privacy. As part of our commitment to use the information you share with us responsibly, we want you to be familiar with how we collect, use, and disclose information relating to you, your computer, or your device and that enables your identification (“Personal Information”).}

_{This Privacy Statement describes our practices with respect to Personal Information that we (or our service providers) collect from you through our Websites (“Online Information”) that link to this Privacy Statement (collectively, the “Site”).  The statement also covers our practices with respect to Personal Information collected from you, our customer, other than directly through or from the Site, such as from telephone, facsimile, postal mail, personal delivery, electronic mail, or any other or additional offline means or media (“Offline Information”). Offline Information also includes information collected with respect to our customers during their visits to one of our showrooms or their interactions with us during sales or offline events.}

_{This Privacy Statement is incorporated into our Website's Terms and Conditions by reference, as if set forth fully therein.  By using the Site, you agree and consent to the Terms and Conditions, and by using the Site or services provided by us offline, you agree and consent to this Privacy Statement.}

_{We can be contacted at elenatushina@smartline.design.}

1. What Information Do We Collect From You?

_{When you interact with us, we may collect information from you as described below.}

_{In addition to information that we collect from you directly, we may also receive information about you from other sources, including third parties such as our business partners and designers.}

Sensitive Information

_{We ask that you not send or otherwise disclose to us through the Site, or while using our offline services, your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. Where you provide us with such information, we reserve the right to erase any such information at our discretion.}

Information About Minors

_{The Site is not intended for persons under the age of 18. We do not knowingly collect Personal Information online or offline from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion.}

2. How We Use the Information We Collect

_{We use Personal Information submitted by you or otherwise collected through the Site and through other sources for the purposes described in this Privacy Statement and as otherwise described to you at the point of collection. Generally, we use the information you provide to us for the reason for which it was provided.  For example, if you sign up to receive email notifications about our collections, we will contact you by email.  If you provide us with information to inquire about a material or a collection, we will use the information to process your inquiry. Specifically, we may use Personal Information from or about you:}

1. _{to respond to your inquiries and fulfill your requests;}
2. _{to complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase, and provide you with related customer service;}

_{iii.      to send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies, and other administrative information;}

1. _{to notify you about upcoming events that may be of interest to you or register you for an event, contest or sweepstakes if you request it;}
2. _{to send you surveys regarding your experience;}
3. _{in accordance with your preferences, to promote our products and services; and}

_{vii.     for our business purposes, such as data analysis, audits, recordkeeping, developing new products or services, enhancing the Site, improving our services, identifying Site usage trends, and personalizing your experience on the Site.}

_{We may use any information that does not personally identify you, your computer, or your device, for any purpose.}

3. Our Disclosure of Your Information

_{We do not sell your Personal Information. We may share your Personal Information with third parties only as described in this Privacy Statement or as otherwise described at the point where we collect the information from you, including:}

1. _{to our affiliates for the purposes described in this Privacy Statement;}
2. _{to the companies or individuals that we hire to provide services to us, such as Website hosting services or our third-party payment processor;}

_{iii.   we share client data with our product vendors where such information is required to place a quote/order for their product;}

1. _{to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).}
2. _{in other circumstances, with your consent.}

4. Uses and Disclosures to Comply with Laws

_{In addition, we use and disclose Personal Information collected through online or offline as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.}

5. Links to Third Party Sites

_{The Site may contain links to other Web sites for the convenience of users in locating information, products, or services that may be of interest. If you access a third party Website from a link on this Site, any information you disclose on that Website is not subject to this Privacy Statement. It is possible that these links may be used by third parties or others to collect personal or other information about you.}

_{We are not responsible for the privacy practices of such Websites, advertisers, or third parties or the content of such Websites and it is your sole obligation to review and understand the privacy practices and policies of these other Websites. We do not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other Websites, advertisers and any third parties.}

6. Where Your Information is Processed

_{We are based in the United States. No matter where you are located, you consent to the processing and transfer of your Personal Information in and to the United States and other countries.  The laws of the United States and other countries governing data protection may not be as comprehensive or as protective as the laws in the country where you live. We rely on Standard Contractual Clauses approved by the European Commission for the transfer of data. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction, you can contact us using the contact information below.}

7. Security

_{We will take reasonable steps to protect the information collected and provided online or offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  However, you should understand that no transmission over the Internet is ever fully secure.  Also, We use reasonable efforts to ensure that the Site is generally available. However, there will be occasions when access to the Site will be interrupted or unavailable. We will use reasonable efforts to minimize such disruption where it is within its reasonable control. You agree that we shall not be liable to you for any modification, suspension or discontinuance of the Site. In the event that we are required by law to inform you of a breach to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.}

8. Data Retention

_{We generally retain Personal Information for so long as it may be relevant for the purposes identified in this Privacy Statement or at the time the information is collected, unless a longer period of time is required by law or unless you ask us to delete it sooner.}

9. Your Data Rights and Choices

_{Where required by law, you may be able to make the following choices regarding your personal information:}

1. _{Access to Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.} 
2. _{Changes to Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.} 
3. _{Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.} 
4. _{Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.} 
5. _{Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.}
6. _{Promotional Emails. At any time, you can unsubscribe from certain emails by clicking on the “unsubscribe” link they contain. You can also opt-out of the use of certain cookie-related processing by following the process enabled by your web browser.  Please note that due to email production schedules, you may receive an email message from us after you have provided but before we have processed your opt-out notice.}
7. _{Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with "NO PROMO MAILINGS" in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.}
8. _{Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”}
9. _{Revocation of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.}

10. Information for California Residents

_{California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose”(as those terms are defined under California law). You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the "Contacting Us" section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.}

11. Our Right to Change Privacy Statement

_{We reserve the right at any time to modify, alter, or update this Privacy Statement. Any changes we may make to our Privacy Statement in the future will be posted on this page.}

_{Your use of the Site or service provided by us offline following any changes means that you agree to follow and be bound by the Privacy Statement as changed, subject to limitations under applicable law. If you do not agree with such changes, you should stop using our Site or services.}

_{To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. The Privacy Statement was last updated on the date indicated above.}

12. Contacting Us

_{Please feel free to contact us if you have any questions or concerns about this Privacy Statement or our information practices. You may contact us as follows: elenatushina@smartline.design}