Privacy Policy – Smart Giftly

Smart Giftly is operated by PoriZma B.V. We value your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you use our platform to purchase or redeem digital gift vouchers ("optionalities").

1. Who is responsible for your data?

Smart Giftly, operated by PoriZma B.V., is the data controller responsible for processing your personal data.
Company Name: PoriZma B.V.
Platform Name: Smart Giftly
Email: info@smartgiftly.com
KvK Number: 86250434
VAT Number: NL863910026B01
Website: www.smartgiftly.com

2. What data do we collect?

3. Why do we collect your data?

• To fulfill the purchase and redemption of optionalities
• To issue invoices to Gift Givers after voucher redemption, in accordance with Dutch VAT law applicable to multi-purpose vouchers
• To deliver physical gifts via third-party shipping providers
• To provide customer service and support
• To comply with legal obligations (e.g., tax and accounting)
• To improve our platform and user experience

4. Legal basis for processing

• Contractual necessity: To fulfill the agreement with the Gift Giver
• Legal obligation: For compliance with Dutch law
• Legitimate interest: To improve services and prevent fraud
• Consent: Where required, e.g., for marketing communications

5. Sharing your data

• Third-party payment providers (for secure transactions)
• Third-party shipping providers (for delivery of physical gifts)
• IT service providers (for platform hosting and maintenance)
• In certain cases—such as when a large number of orders need to be fulfilled—we may also share your shipping information with our supplier partners who handle delivery on our behalf.

We do not sell or rent your personal data to third parties.

6. Data retention

• Purchase and redemption data: up to 2 years (voucher validity period)
• Invoice data: retained for 7 years in accordance with Dutch tax law (even if issued after voucher redemption)
• Shipping data: retained for 6 months after delivery
• Legal and accounting records: retained per statutory requirements

7. Your rights

• Access your personal data
• Request correction or deletion
• Object to processing
• Withdraw consent (where applicable)
• Lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

To exercise your rights, contact us at: info@smartgiftly.com

8. Security

Smart Giftly implements appropriate technical and organizational measures to protect your data, including:

• Secure payment processing
• Encrypted data transmission
• Access controls

9. Cookies and Tracking Technologies

Smart Giftly uses cookies and similar technologies to ensure the proper functioning of our website and to understand how visitors interact with it.

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites function properly, improve user experience, and provide information about how the site is used.

Types of Cookies We Use

We use the following categories of cookies:

1. Strictly Necessary Cookies
   These cookies are essential for the website to function properly and cannot be switched off in our systems.
2. Analytics Cookies
   With your consent, we use Google Analytics 4 to collect information about how visitors use our website. This includes information such as:
   • Pages visited
   • Time spent on pages
   • Device type and browser
   • General geographic location (country/region level)
   This data helps us improve the website and user experience.
3. Marketing Cookies (Meta Pixel)
   With your consent, we use Meta Pixel to measure ad performance and improve how we show relevant ads. Meta Pixel may collect information such as pages viewed, actions taken on our website (for example purchases), device and browser information, IP address, and referrer data.

Google Analytics may process data in accordance with Google's Privacy Policy: https://policies.google.com/privacy

We have configured Google Analytics to respect user consent and to limit data collection until consent is granted.

Meta Pixel is also activated only after your consent for marketing cookies has been provided through our cookie banner.

Meta may process personal data in accordance with Meta's Privacy Policy: https://www.facebook.com/privacy/policy/

Legal Basis (EEA Users)

For users located in the European Economic Area (EEA), analytics cookies are used only with your prior consent, in accordance with the GDPR and ePrivacy Directive.

Marketing cookies, including Meta Pixel, are also used only with your prior consent.

Strictly necessary cookies are processed on the basis of our legitimate interest in operating a functional website.

Consent Management

We use Clickio as our consent management platform (CMP). When you first visit our website, you are presented with a cookie banner allowing you to:

• Accept cookies
• Reject non-essential cookies
• Manage your preferences

Analytics cookies are not set unless you provide consent.

You may withdraw or modify your consent at any time by clicking the "Cookie Settings" link available on our website.

You can also manage ad preferences in your Meta account settings: https://www.facebook.com/adpreferences/ad_settings

Data Retention

Analytics data collected through Google Analytics is retained for a limited period in accordance with our configured retention settings and Google's policies. Data is aggregated and used for statistical purposes.

Changes to This Section

We may update this Cookies section from time to time to reflect changes in legal requirements or our use of cookies. Any updates will be posted on this page with a revised effective date.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Changes will be published on our platform. Continued use of Smart Giftly after updates constitutes acceptance of the revised policy.