Privacy Policy

About us and our website

Owner: SABB General Holding S.L.U (hereinafter, “Smile Vintage”)
Address: Av. Tarragona, 51, Edifici Alfi, 1ª planta, despacho 2, estación 2.3 en Andorra la Vella
VAT Number: L-715100-V

Our guiding principles

We take protecting your information very seriously. Your data is therefore processed with great care and in strict compliance with applicable data protection law. Organisational and technical security measures have been taken to protect all of our websites against the risks present in processing personal data. Our partners who support us in the provision of this website must comply with these provisions as well.

What we log as standard

You can use all the areas of our website that are not access-protected without disclosing your identity. We log every use of our website as standard in order to prevent attacks, remedy faults and investigate security incidents. You can find more about our log data in the section “How we process your data”.

Permissions we have to process your data

We respect your privacy. Consequently, we only process your data when we are permitted to do so.

You will find a summary of the relevant statutory authorisations, on which we base the data processing, at the end of this information.

Of course you can also give us permission to process your data by opting in to the corresponding data processing on our website. In other cases, we process your data because we are permitted to do so by law. If, for example, you place an order through our website, we are permitted to process your data in order to fulfil that contract.

The same applies when you make use of other services on our website that require your data to be processed. We are also permitted to process your data when we have a legitimate interest in doing so. One example of this is the log data that we collect in order to ensure that e.g. our website can be operated without defects(indcluding the technical provision of the website). In any case, we will inform you about the corresponding processing of your personal data and, of course, your interests will always be taken into account in any such processing. In case that you have questions to your personal data, you can find your rights regarding the processing of your personal data in the latter section of this Data Protection Information.

The permissions we make use of, and when, are outlined in the following section. You can find more detailed information on how your data is collected, processed and used on our website (i.e. the type, scope and purpose of data processing) in the same section.

Presentation of the website log data

In order to display the website on your internet browser, we use various technical devices to ensure that all content (text, images, video, etc.) is always up to date. The data collected in this way will only be used to display the contents of the website in your internet browser and will be deleted immediately after intermediate storage within the scope of delivery.

For technical reasons, each time your internet browser accesses our website it automatically sends information to our web server (i.e. log data). We store some of this information in log files, such as:

Date of the access
Time of the access
URL of the website
Version of the HTTP protocol used.
Files accessed
Volume of data transferred
Internet browser type and version
Type of the operating system
IP address (anonymised)

Log data does not contain personal data. We only analyse log data event-driven when required, especially in order to remedy faults in the operation of our website or clarify security incidents. We store this log data indefinitely.

It may be necessary for us to collect additional the IP address of the device as well as log data in order to remedy faults or preserve evidence relating to security incidents. We delete this data once the fault has been remedied or the security incident has been clarified in full, or if the original purpose of the processing no longer exists due to other factors. In the event of a security incident, we will transmit log data to the investigating authorities on a case-by-case basis, to the extent permitted and necessary.

We store such log data separately from other data collected that relates to the use of our website.

Registering on our website

Required details:

First and last name
Full postal address
E-mail address
Mobile number
VAT number / ID number
Payment type

We store registered users’ data until the user deletes their account. Registered users can delete their accounts at any time via the settings of their user account. The user account also allows users to change or delete specific information provided at the time of registration at any time.

Purchasing on our website

You can also use our website to access services requiring payment (e.g. orders in the accessories store). We collect and process the following order information when services are ordered:

First and last name
Full postal address
E-mail address
Mobile number
VAT number / ID number
• Payment type
Billing information

As a registered user, you also benefit from the fact that the time and scope of all purchases (display of the history of purchases made in the user account) is displayed for you in your customer account, so that you can track your orders directly there.

We use state-of-the-art encryption techniques (e.g. SSL) via HTTPS to guarantee the security of your data during transmission.

When you place an order, we use your information for the sole purpose of processing that order and to display the history of purchases. We store order information at least until the expiry of the statutory retention periods. We store data provided when registering until the user deletes their account.

Contacting us

If you contact us outside of a concrete contractual relationship (e.g. for an order) or a registration, we provide various, also purely technical contact possibilities via our websites, including the possibility to contact us e.g. via (automated) chat.

In order to be able to process your specific request when making such contact, we may ask you to provide personal data. This includes, for example, your name and email address and other information such as the subject of your request and your message. Optional postal address and/or telephone number can be given. We collect the information requested in order to be able to deal with your request in an appropriate way.

The personal data transmitted to us in this way are used exclusively for the purpose for which you provide them to us when contacting us – in particular the processing of your request. The data will not be used for other purposes or passed on to third parties without your express consent. Excluded from this are – insofar as it is necessary to fulfil your request – the persons and companies (e.g. local service company) involved in carrying out the communication and answering the request. If there are no legal storage obligations, your personal data will be deleted after the request has been processed.


Our website provides the option of subscribing to our newsletter. We use a double opt-in process to verify whether the owner of an e-mail address has actually registered to receive the newsletter. The newsletter is only successfully subscribed to if the owner of the e-mail address has expressly confirmed the activation of the newsletter by clicking on the link in the confirmation e-mail. We log the completion of the individual stages of the double opt-in process for evidence purposes.

As part of our newsletter campaigns, we use analysis tools to tailor our newsletter to your needs, for advertising purposes and for market research. For this purpose, we collect and process data about your use of our email newsletter. When you open an email newsletter from us, a file contained in the email (so-called web beacon) connects to our servers. This enables us to determine whether an email newsletter has been opened and, if so, which content has been clicked. In addition, we collect technical information about your end device with which the contents of the email newsletter are retrieved (e.g. time of retrieval, browser type and operating system). We use this data exclusively for statistical analysis of our newsletter campaigns.

If you subscribe to receive our newsletter, and therefore consent to it being sent to you, your details are solely used in order to send you the newsletter and analyse your use of the email newsletter. You can withdraw this consent at any time. The relevant link is included in each copy of our newsletter. We will make a note of the fact that you have unsubscribed from the newsletter in our database.

Our social media pages

The protection of your privacy when processing personal data is important to us. We process personal data transmitted to us, which is collected during your visit to our respective social media page (e.g. Facebook Fanpage, Instagram, etc.), confidentially and only in accordance with the statutory provisions.

Responsible for the processing of your data via our social media site is the respective operator of the social media site (see examples below) together with us. As far as the processing of these data takes place within our area of responsibility, we are available to you in all questions concerning data protection and the exercise of your rights in accordance with the information in this data protection information.

Data processing by the Social Media Service

The social media service processes your personal data as soon as you use our respective social media site. Processing is linked, for example, to the following usage processes:

• Subscribe or unsubscribe to a page
• Mark a page or post with “I like” or “I don’t like anymore” or similar functions
• Recommend a page in a post or comment
• Comment on, share or respond to a page post (including the type of response)
• Hide a page contribution or report as spam
• Use functions of the social media provider, such as the website, phone number, “plan route” button or any other button on a page.
• The information whether the login is made via a computer or a mobile device.

You can find out which personal data is collected by the social media provider, how it is processed and which data protection rights you have vis-à-vis the social media provider in the following data protection guidelines of the social media provider. We have no influence on the data processing by the social media provider following the survey.

Data processing by us

On the website provided by us via the social media provider, the social media provider grants us access to the following data categories:

• The social media provider grants us access to statistical analyses that provide information about the use of our social media website. The analyses visible to us do not allow us to individually analyze the usage behavior of individuals. We can only view aggregated data (such as number of hits, likes, followers, region of origin, age group, gender, etc.) that tells us about our audience and the use of our social media site. The data of the respective user on which the analyses are based are not transmitted to us.
• We can set the target group to be reached for the social media website or for individual published articles. The setting is based on general parameters (e.g. age group, language, region, interests) that can be used to align our content with specific groups. It is not possible for us to address or identify individual persons on the basis of the data provided to us by the social media provider.
• If you contact us directly via the social media provider or interact with us in any other way and consciously transmit personal data (e.g. direct networking with our social media website), we store and process this personal data for the purposes for which you transmitted it to us.
• We process this data exclusively for the purpose of making content on our social media website known to the target group and to better understand and optimise the use of our social media website.

In addition, we cannot influence the data processing (for the provision of this data upstream) by the social media provider.

Which personal data is collected from the respective social media provider in detail, how these are processed and which data protection rights you have vis-à-vis the respective social media provider, please refer to the following data protection guidelines of the respective social media provider:

Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA;; Facebook has submitted to the EU-US Privacy Shield.
Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; Twitter has submitted to the EU-US Privacy Shield.
Instagram, provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland,
LinkedIn for countries of the European Union (EU), the European Economic Area (EEA) and Switzerland: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland and url For all other countries: LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA. The LinkedIn Corporation has submitted to the EU-US Privacy Shield.

Information on the EU-US Privacy Shield can be found at

Cookies we use and how they work

You can check our Cookies Policy

Cases where we transmit your data

We work together with a number of service providers to implement and operate our website. We have chosen these service providers carefully and concluded a data protection agreement with each individual service provider to keep your information safe.

The service providers we use to implement and operate our website are:

• Service provider for hosting services including associated technical services (e.g. performance control and measurement, content delivery networks)
• Service provider for the provision of additional functionalities for our website (e.g. product videos, flip catalogue Issu)
• Service provider for programming services
• Service provider for sales and marketing services
• Service provider for hotline services

We only transmit your data to other recipients where necessary to fulfil a contract with you, where we or the recipient has a legitimate interest in the disclosure of your data, or where you have given your consent to that transmission. In such cases, your data will be processed in accordance with the data protection regulations of the recipient of your data concerned. These recipients include service providers and other companies within our corporate group. Furthermore, data may be transmitted to other recipients in the event that we are obliged to do so due to legal provisions or enforceable administrative or court orders.

Other recipients of your data are:

• Forwarding agents for delivering/collecting products
• Payment processing service providers
• Receivables management service providers

Contact about Data Processing and Data Privacy

If you have any questions relating to data protection or exercising your rights, you can use the following contact information to get in touch with our data protection officer directly:

Address: Av. Tarragona, 51, Edifici Alfi, 1ª planta, despacho 3, estación 2.3
Andorra la Vella, Pincipat D’Andorra

Changes to this Information

This Data Protection Information reflects the current state of data processing on our website. In the event of changes to data processing, this Data Protection Information will be updated accordingly. We always provide the latest version of this Data Protection Information on our website so that you can find out about the scope of data processing on our website.

Legal basis for data processing

We base the above data processing operations on

> A legal permit in accordance with Art. 6 para. 1 lit. b of Regulation (EU) 2016/679:
• Registration on our website
• Shopping on our website

> A legal permit in accordance with Art. 6 para. 1 lit. f of Regulation (EU) 2016/679:
• Technical providing for the presentation of the website
• Additional website functions
• Log data
• Contact us
• Session cookies and persistent cookies for convenience features
• Web Analysis & Marketing

> Your consent pursuant to Article 6(1)(a) of Regulation (EU) 2016/679:
• Search our place with Google Maps
• Newsletter
• Persistent cookies for recording usage behavior
• Web Analysis & Marketing Channel Sight
• Facebook Pixels and Custom Audiences
• Google Ads & Remarketing

Your rights

If you have any questions about your personal data, you will find a description of your rights below:

Exercise of your data protection rights

Please use the following contact channels for your requests:

Address: Av. Tarragona, 51, Edifici Alfi, 1ª planta, despacho 3, estación 2.3
Andorra la Vella, Pincipat D’Andorra

• Your right to information about your data: We will provide you with information about the data we hold about you on request.
• Your right to correct and complete your data: We will correct inaccurate information about you if you notify us accordingly. We will complete incomplete data if you notify us accordingly, provided this data is necessary for the intended purpose of processing your data.
• Your right to delete your data: We will delete the information we hold about you on request. However, some data will only be deleted subject to a defined period of retention, for example because we are required to retain the data by law in some cases, or because we require the data to fulfil our contractual obligations to you.
• Your right to have your data blocked: In certain legally determined cases, we will block your data if you would like us to do so. Blocked data is only further processed to a very limited extent.
• Your right to withdraw consent: You can withdraw consent given for your data to be processed with effect for the future at any time. The legality of processing your data remains unaffected by this up to the point at which your consent is withdrawn.
• Your right to object to the processing of your data: You can object to the processing of your data with effect for the future at any time, if we are processing your data on the basis of one of the legal justifications set out in article 6(1e or 1f) of Regulation (EU) 2016/679. In the event that you object we will cease processing your data, provided that there are no compelling and legitimate grounds for further processing. The processing of your data for the purposes of direct marketing never constitutes compelling and legitimate grounds for us.
• Your right to data portability: At your request, we can make certain information available to you in a structured, commonly used and machine-readable format.
• Your right to appeal to a regulatory authority: You can lodge an appeal pertaining to data protection with a data protection authority. To do so, contact the data protection authority responsible for your place of residence or the data protection authority under whose jurisdiction we fall (named below).

Agencia de Protección de Datos del Principado de Andorra.

  • Address Edifici del Consell General C/ Doctor Vilanova, 15-17 (planta -5) AD500 Andorra la Vella. Principat d’Andorra
  •  (+376) 808 115
  •  (+376) 808 118