Privatumo politika

General provisions

We, the private limited liability company SmartWay Europe Limited established in accordance with the laws of the United Kingdom, in this Privacy Policy (hereafter the Privacy Policy), establish the main guidelines and provisions that we undertake to comply with and enforce in the processing of Personal Data to individuals entrusted to us through our online reservation management program – the Booking Program), available on (hereafter referred to as the Website).

Anyone willing to use the Booking Program (hereinafter referred to as the Visitor) must provide us with their personal details (depending on the purpose and scope of the use). A Visitor who uses the Booking Program automatically agrees that we process the Personal Data submitted to us further for the purposes indicated in this Privacy Policy. A Visitor, who does not provide the requested Personal Data or opposes the processing of his or her Personal Data, may not use the Booking Program.

This Privacy Policy was prepared on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal data and other legal acts applicable to the protection of personal data.

We reserve the right to change this Privacy Policy at any time, unilaterally at our discretion, by posting its new text on its website.

In this Privacy Policy, the Visitors can find answers to the following questions:

  • how do we collect Personal Data?

  • what data and for what purposes we process?

  • how long do we process data?

  • how do we ensure the security of our processed Personal Data?

  • what rights do data subjects have?

  • how to enforce your right to file a complaint about data processing?

how do we collect Personal Data?

We collect Personal Data directly from the Visitors by providing them with relevant information during their visits to the Website and/or the registration in the Booking Program, as well as by subsequent using the Booking Program (by filling in the corresponding boxes of the Booking Program).

what data and for what purposes we process?

We are guided by the provisions of Article 6 (1) of the General Data Protection Regulation, and we process the following data.

Visitor contact details

We collect and process the contact information of Visitors with the purpose of enabling them Visitors to use the Booking Program for booking the time of the relevant service provider for the Visitors, also for sending notifications to Visitors about the booked time.

To do this, we process the following contact details of the Visitors:

  • first name and surname;

  • telephone number;

  • e-mail address.

Data recipients

The above Personal Data of Visitors are disclosed (transferred) to the relevant service provider, whose time is booked by the Visitor.

The service provider, having received the above Visitor’s details from us, processes them independently for the determined purposes. In order to learn more about the processing of Personal Data by service providers, the Visitor must contact the relevant service provider (on its website).

Consequences of non-provision or withdrawal of consent to the processing of data

Disclosing Personal Data of the above-mentioned Visitors is a prerequisite for us to allow them for using the Booking Program. I.e. by failing to provide Personal Data or providing inaccurate or incorrect Personal Data, as well as withdrawing the consent to process the Personal Data, the Visitor will not be able to access the Booking Program or its corresponding individual functions.

Using cookies

We use our cookies on our Website to improve the quality of our Website browsing, to collect statistics and marketing data.

To this end, by visiting our Website, we collect the following Visitor data:

  • frequency of visits to the Website;

  • the IP address of the device that connects to the Website.

Data recipients

The above Personal Data may be disclosed to our partners, which we will use for the maintenance and development of the Booking Program.

Consequences of denial of consent or refusal to process the data

Each Visitor may disagree with the use of cookies for him, and, once such consent is issued, to withdraw it at any time. This can be done by changing your Internet browser settings and deleting the saved cookies.

Disabling or deleting cookies may increase the time it takes to browse the Website, and the Visitor may no longer have access to some features of the Website.

Third-party websites, services and products on our Website

Our Website may contain third-party advertising panels, links to their websites and services that we do not control. We are not responsible for the safety and privacy of data collected by third parties. The privacy of such data must be protected by the data subject with relevant third parties whose sites or services they use.

Direct marketing

We are constantly developing and updating the Booking Program, and expanding its functions. We will be able to inform the Visitor about all the innovations and new functions of the Booking Program if he has given his consent to use his email and/or telephone number for direct marketing purposes.

Consequences of denial of consent or refusal to process the data

If you do not agree to use your data for direct marketing purposes or cancel your consent, the Visitor will not lose the possibility of using the Booking Program.

How long do we process THE data?

We will keep and process the specific Visitor's Personal Data as long as this Visitor uses the Booking Program and for another twenty years after the last use, but in any case no longer than the Visitor withdraws his consent to process his data.

In case of any likelihood of a dispute between us and the Visitor regarding the use of the Booking Program, we will keep the Personal Data of such Visitor necessary for the resolution of such a potential dispute (full name, contact details, data of the use of the Booking Program), for all relevant limitation periods set by the applicable laws (depending on possible nature of the claim) if it is longer than the above time limit.

After the expiration of the data processing deadlines, we delete the data so that they cannot be reproduced or replaced and cannot be linked to a specific individual.

How do we ensure the security of our processed Personal Data?

In order to protect our processed Personal Data from loss, unauthorized use or alteration, we have implemented the appropriate organizational and technical means. However, we want to point out that no organizational and/or technical means can ensure complete data security.

what rights the Visitors have as Data Subjects?

We undertake to respect the rights of Data Subjects as they are provided in the General Data Protection Regulation:

  • to know (be informed) about the processing of your personal data (right to know);

  • to have an access to your personal data and to be informed of how they are processed (right to access);

  • to request to correct or supplement the incomplete personal data (right to rectify), taking into account the purposes for the processing of personal data;

  • to require to destroy your personal data or suspend the processing of your data (except for storage) (right to destroy and right to “be forgotten”);

  • to request to restrict the processing of personal data;

  • To data transfer;

  • to object against the processing of personal data;

  • other legal rights applicable to the processing of Personal Data.

Any application related to the processing of Personal Data may be submitted by the Visitor to us by e-mail or by sending an application.

We are obliged to respond to all requests for the processing of Personal Data, within one month from receipt of the request, in accordance with the procedure established by the General Data Protection Regulation.

how can you enforce your right to file a complaint about data processing?

Every person has the right at any time to appeal against our processing of his data by submitting a complaint to the State Data Protection Inspectorate. On the other hand, we value each of our clients, so we want to encourage Visitors to contact us first without hesitation in the event of any questions or doubts regarding their processing.

Our contacts

SmartWay Europe Limited

Reg. Number 8898147

71-75 Shelton Street

Covent Garden



E-mail address

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