Ecomnio Operations UG (in foundation), Domänenweg 1c, 31171 Nordstemmen (hereinafter referred to as "provider" or "we") is the developer and operator of "SmileSecret". We take the protection of your personal data very seriously and observe the provisions of the European General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and the German Telemedia Act (TMG) when collecting, processing and using your data. The following statement gives you an overview of how we guarantee data protection and what type of data is collected and for what purpose.

1. collection, processing and use of personal data

"Personal data" is all individual details about your personal or factual circumstances. This includes all information that allows conclusions to be drawn about your identity (e.g. name, address, email address, bank details, etc.)

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The collection, storage and processing of personal data is governed exclusively by applicable law. We undertake to handle the data you provide responsibly and with the utmost care.

The "SmileSecret" website and our systems are protected by technical and organizational measures against loss, destruction, access, modification or dissemination of your data by unauthorized persons. However, despite regular checks, complete protection against all risks is not possible.

2. Purposes of processing your personal information

We process personal information in order to operate, provide and improve the services we offer to our customers. We use the data we receive from you to:

- provide you with our services, including to grant you access to your profile and our website,
- identify you as a registered user when you log in to and revisit our website,
- process payments,
- provide logistics services including shipment tracking,
- improve the website and our services,
- answer your questions and provide appropriate customer services,
- send you our newsletters,
- recommend personalized offers on the website,
- enable our social sharing features; This includes providing you with the option to connect with members of your network who are customers of both SmileSecret and one or more social networks,
- perform various internal business actions, such as B. analyzing data, monitoring, surveillance and preventive measures to protect against fraud, develop new products and services, improve or revise the Site or our services, identify usage trends, determine the effectiveness of our promotional campaigns, and conduct and expand our business activities,
- ensure compliance with legal requirements and procedures, public and governmental authorities, applicable industry standards and our internal policies,
- enforce our terms and conditions,
- protect our business or that of our affiliates,
- protect our business and our affiliates from fraud,
- protect our affiliates from fraud,
- protect our affiliates from fraud,
- protect our affiliates from fraud,
- protect our affiliates from fraud,
- protect our affiliates from fraud,
- protect our affiliates from fraud, and
- protect our rights, privacy, safety or property and/or those of our affiliates, you or others,
- allow us to pursue possible legal remedies and limit any damages we may incur.

We will also use this information in other ways for which we will provide separate information at the time of collection.

3. data collection when visiting our website

When using our website for information purposes only, i.e. if the user does not register or otherwise provide us with information, we only collect the data that the browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:

- Our visited website
- Date and time at the time of access
- Amount of data sent in bytes
- Source/reference from which you accessed the page
- Browser used
- Operating system used
- IP address used (in anonymized form if applicable)
The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if there are concrete indications of illegal use.

4. Newsletter / Revocation of consent for newsletter

On the SmileSecret website, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted to the controller when the newsletter is ordered

SmileSecret GmbH & CO. KG informs its customers regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if
a) the data subject has a valid e-mail address and
b) the data subject registers for the newsletter shipping.

For legal reasons, a confirmation email is sent to the email address entered by a data subject for the first time for the newsletter mailing using the double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the data subject has authorized the receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject's email address at a later date and therefore serves as legal protection for the controller.

The personal data collected when subscribing to the newsletter is used exclusively to send our newsletter. Furthermore, subscribers to the newsletter may be informed by email if this is necessary for the operation of the newsletter service or a registration in this regard, as could be the case in the event of changes to the newsletter offer or changes to the technical circumstances. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be canceled by the data subject at any time. The consent to the storage of personal data, which the data subject has given us for the newsletter dispatch, can be revoked at any time. There is a corresponding link in every newsletter for the purpose of revoking consent. It is also possible to unsubscribe from the newsletter at any time directly on the controller's website or to inform the controller of this in another way.

You can revoke your consent to receive the newsletter at any time with effect for the future by declaring your revocation to the provider using the following contact details:

E-mail: info@smilesecret.de

SmileSecret GmbH & Co KG
Domänenweg 1C
D - 31171 Nordstemmen

You will not incur any costs for revoking your consent to receive the newsletter, except for the transmission costs according to the respective basic tariff of your telephone/internet provider.

SMS notification

Text marketing and notifications: By subscribing to text notifications, you agree to receive recurring automated marketing messages from all companies belonging to the SECRET BRANDS umbrella brand at the phone number provided. Consent is not a condition of purchase. Reply STOP to unsubscribe. HELP for help. Message and data rates may apply. For more information, see the privacy policy and terms of use

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5. data processing when opening a customer account and for contract processing

In accordance with Article 6(1)(b) GDPR, personal data will continue to be collected and processed if you provide it to us for the performance of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. You can delete your customer account at any time by sending a message to info@smilesecret.de. We store and use the data you provide to process the contract. After completion of the contract or deletion of your customer account, your data will be blocked with regard to tax and commercial law retention periods and deleted after these periods have expired, unless you have expressly consented to further use of your data or we have reserved the right to further use of your data as permitted by law, about which we will inform you accordingly below.

In order to process your order, we work together with service providers who support us in whole or in part in the execution of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information. The personal data collected by us will be passed on to the transport company commissioned with the delivery as part of the contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment data to the commissioned credit institution as part of payment processing, insofar as this is necessary for payment processing. The legal basis for the transfer of data is Art. 6 para. 1 lit. b GDPR.

6. Integration of Facebook

We offer you the opportunity to recommend offers, products, promotions and messages via Facebook. We use social plugins from Facebook for this purpose. These services are offered by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (Facebook).

If you are logged in to Facebook during your visit to smilesecret.de, Facebook can assign the pages you visit to your Facebook account. By interacting with the social plugins (clicking, etc.), the information generated by the interaction is transmitted to Facebook and stored there. You can prevent this by logging out of Facebook before visiting our website.

It is also possible to block social plugins from Facebook in general. For this purpose, there are extensions for the respective browser (e.g. the Facebook Blocker), which you must install and activate for your respective browser.

Facebook's privacy policy and other privacy settings options can be retrieved from Facebook (http://de-de.facebook.com/about/privacy/).

7. YouTube plugin

This website uses plugins from YouTube. These services are provided by Youtube, LLC, Cherry Ave, United States (Youtube), represented by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (Google).

When you open the website in your browser, the code for the "YouTube" button is retrieved directly from a YouTube/Google server by your browser and integrated into the "SmileSecret" website that appears in your browser. We therefore have no influence on the scope of the data retrieved by YouTube/Google.

According to its own information, Google collects information about the page you viewed when you clicked on the YouTube button, i.e. the Internet address, as well as your IP address and other browser-related information. Google standardized its privacy policy on 1 March 2012. The current privacy policy no longer contains any information on the use of the YouTube button.

If you are logged in to YouTube with your account, the information collected will be assigned to your account/Google account. By interacting with the YouTube plugins (clicking, etc.), the information generated by the interaction is transmitted to YouTube/Google and stored there. You can prevent this by logging out of YouTube before visiting our website.

According to its own information, Google does not record your visits to the Internet or your browsing history permanently and does not evaluate your visit to a page with a YouTube button in any other way. However, Google does store some data about your visit for a short time, usually for about two weeks, for system maintenance and troubleshooting purposes. However, this data is not structured according to individual profiles, usernames or URLs.

Further information on the purpose and scope of the collection, storage and processing of your data by YouTube/Google as well as settings can be found here: https://policies.google.com/privacy?hl=de&gl=en.

Please also inform yourself there, as the privacy policy of Google products is regularly updated and adapted due to extended functionalities.

8. Instagram plugin

This website uses plugins from Instagram. These services are provided by Instagram, LLC, 1601 Willow Rd. Menlo Park, CA 94025, United States.

When you open the website in your browser, the Instagram plugin code is retrieved directly from an Instagram server by your browser and integrated into the "SmileSecret" website that appears in your browser. We therefore have no influence on the scope of the data retrieved by Instagram.

Further information on the purpose and scope of the collection, storage and processing of your data by Instagram as well as settings can be found here: https://help.instagram.com/519522125107875?helpref=page_content.

Please also inform yourself there, as the privacy policy of the Instagram products is regularly updated and adapted due to extended functionalities.

9. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. The IP address is anonymized by us (anonymi-zeIp() so-called IP masking), therefore your IP address will be shortened by Google within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the provider, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the provider. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You can prevent the storage of cookies by selecting the appropriate settings in your browser software; however, please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link (http://tools.google.com/dlpage/gaoptout?hl=de).

Further information on Google Analytics is provided here: https://support.google.com/analytics/answer/6004245?hl=de.

10. use of Google AdWords

The ''SmileSecret'' website uses the online advertising program "Google AdWords" and, as part of Google AdWords, the conversion tracking of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use the Google AdWords service to draw attention to our attractive offers with the help of advertising material (so-called Google AdWords) on external websites. We can determine how successful the individual advertising measures are in relation to the advertising campaign data. In this way, we pursue the interest of showing you advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs.

The conversion tracking cookie is set when a user clicks on an ad placed by Google. Cookies are small text files that are stored on your computer system. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page. Each Google AdWords customer receives a different cookie. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users. If you do not wish to participate in tracking, you can object to this use by easily deactivating the Google Conversion Tracking cookie via your Internet browser under user settings. You will then not be included in the conversion tracking statistics.

You can find more information about Google's privacy policy at the following Internet address: https://policies.google.com/privacy?gl=de.

11. cookies

Cookies are small pieces of information that the website stores on the hard disk of your computer, tablet or smartphone. Please note that HTML5 has introduced the Web Storage feature, which is comparable to cookies and which we therefore consider a cookie below.

Cookies contain information that the website uses to improve the efficiency of communication between you and your web browser. Cookies identify your computer or device and not you as a specific user.

We set session cookies, permanent cookies, session cookies for HTML5 sessionStorage and HTML5 localStorage as well as HTML5 sessionStorage objects, which are temporary and are deleted after you close your internet browser. Permanent cookies are stored for a longer period of time and remain on your computer until they are deleted. Permanent cookies expire or delete themselves after a certain period of time, which is determined by the cookie, but are renewed each time you visit the website. HTML5 localStorage objects are permanent and remain on your computer until they are deleted.

You can prevent the setting of a cookie by configuring your Internet browser so that all cookies are deleted when you close the browser window. You can also delete the cookies stored on your computer at any time. You can find more information about cookies, including the question of the dangers of cookies, at the following link on the website of the German Federal Office for Information Security.

Cookies are used for the following purposes:

Generating statistics: for measuring website traffic, such as the number of website visitors, which domain the visitors come from, which pages they visit on the website and in which geographical areas the visitors are located.

Monitoring website performance and your use of our website: for monitoring website performance, our applications and infrastructure and how you use our website.

Login procedures and improving the functionality of our website: to optimize the user experience on the website, which includes a reminder function for your username and password when you visit the website again, as well as a reminder function for your browser and preferred settings (e.g. your preferred language).

We also use cookies to display relevant advertisements on the website, including interest-based advertisements that we think may be of interest to you. We use third parties to deliver these advertisements when you visit the Website and other websites. These third parties may use cookies alone or in conjunction with web beacons and other tracking technologies to collect information about your use of our Website and other websites.

12. legal basis of the processing

Art. 6(1)(a) GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service or consideration, the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 para. 1 lit. c) GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. Processing would then be based on Art. 6 (1) (d) GDPR. Ultimately, processing operations could be based on Art. 6 (1) (f) GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal bases if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

13th Legal obligation to disclose personal data to third parties

We would like to point out that we are legally obliged to pass on your personal data to third parties in certain cases (e.g. in the event of law enforcement measures)

14. your rights

We would like to briefly inform you about the data protection rights that you can exercise against us:

Right to information and access

You have the right to receive information about the personal data stored by us at any time. Please send us an email to info@smilesecret.de.

Right to rectification

SmileSecret GmbH & Co KG may only process accurate personal data about you. If you discover - for example by exercising your right to information - that a data about you is incorrect or has become incorrect, we are generally obliged to correct it immediately.


Right of deletion

If you wish to delete your account, please send us an email to info@smilesecret.de from the email address you used to register with us. Please also tell us your full name.

Right to object

Insofar as you have a legal right to object to the data processing described in this privacy policy, we will inform you of this at the appropriate point. You also have the option of conveniently exercising your right to object at the relevant points.

In principle, you have the right to object to (further) data processing for processing based on the legal basis of "legitimate interest" and for processing based on consent.

Right to lodge a complaint with the supervisory authorities

You have the right to lodge a complaint with a data protection authority. You can do this, for example, by contacting the data protection authority responsible for your place of residence or your federal state or the data protection authority responsible for us. This is the Berlin Commissioner for Data Protection and Freedom of Information.

Data portability

You also have the right to receive data that you have provided to us in a structured, commonly used and machine-readable format or - if technically feasible - to request that the data be transferred to a third party.

15. further information on data protection at "SmileSecret"

Your trust in the protection of your personal data when you visit our websites is very important to us. We are therefore always available to answer any questions you may have regarding the collection, storage and processing of your personal data. If you have any questions that are not answered by this privacy policy, you can contact us at any time at info@smilesecret.de.

16th Messengerpeople

By sending a start message, I agree to the validity of the internal data protection regulations of (SmileSecret Medical) .
In particular, I consent in accordance with Art. 6 para. 1 lit. a GDPR that my personal data (surname and first name, telephone number, messenger ID, IP address, profile picture and message history) will be stored, processed and used in the context of the use of the respective messenger in order to transmit messages to me. An active account with the respective provider is required to use the Messenger service.
I am also aware that (SmileSecret Medical) uses MessengerPeople GmbH, Seidlstraße 8, 80335 Munich as a technical service provider and processor to provide this service.
My consent to the processing of personal data can be freely revoked at any time; a corresponding notification to (SmileSecret Medical)is sufficient for this purpose. Further information can be found in the respective privacy policies of (SmileSecret Medical), the messenger services and MessengerPeople GmbH.

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As of 01 November 2022