PRIVACY POLICY

Effective Date: September 29, 2026

This Privacy Policy explains how Savvy Smart Ecomm Ltd. (“Savvy”, “we,” “us,” or “our”) collect, use, disclose, retain, and protect information about you when you visit or use our websites, landing pages, sales funnels, and related online services (collectively, the “Site”), or purchase our products.

By accessing or using the Site, you acknowledge that you have read and understood this Privacy Policy and acknowledge the privacy practices described herein. Your use of the Site is also subject to our Terms of Service. 

1. INFORMATION WE COLLECT

We collect information you provide to us, information collected automatically when you use the Site, and information we receive from certain third parties.

Information You Provide

Depending on how you interact with us, we may collect:

When you visit or interact with the Site, we and our service providers may automatically collect:

We may collect this information through cookies, pixels, web beacons, tags, log files, SDKs, and similar technologies.

When you choose to purchase a product or service offered by one of our business clients through an upsell or other offer, you may be directed to that business client's checkout or order page. You may be asked to provide your information again to complete the purchase. Information you provide for that purchase may be processed through our technology and CRM systems and made available to the business client to process, fulfill, and support your order.

We may receive information from payment processors, fulfillment providers, advertising and analytics providers, social-media platforms, business partners, data providers, and other third parties.

For example, third parties may provide information that helps us understand advertising performance, prevent fraud, communicate with customers, or improve our products and Site.

We may also combine information collected from these sources with information we collect directly from you or automatically through the Site, subject to this Privacy Policy and applicable law.

2. CATEGORIES OF PERSONAL INFORMATION

Depending on how you use the Site, we may collect the following categories of personal information:

We may collect these categories from you, automatically through the Site and your device, or from third parties such as payment processors, fulfillment providers, advertising and analytics providers, social-media platforms, business partners, and other service providers.

We do not intentionally collect sensitive personal information unless reasonably necessary for a specific business purpose and permitted by applicable law.

We do not intentionally collect health information, biometric information, precise geolocation, genetic information, or other sensitive personal information merely because it may be available through a device or third-party service. We will collect such information only if our actual business operations require it and applicable law permits or requires the collection.

The Site is not intended for individuals under the age of 18. We do not intentionally collect personal information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the email address below to request deletion.

3. HOW WE USE YOUR INFORMATION

We may use personal information to:

We may combine information collected from different sources for these purposes.

We may also use personal information to administer customer accounts or requests, verify transactions, screen orders for fraud or security risks, maintain the security and functionality of the Site, and understand the effectiveness of our products, advertising, and marketing.

Where we use personal information for analytics, research, or business planning, we may use aggregated or de-identified information where reasonably appropriate.

4. LEGAL BASES FOR PROCESSING

If the GDPR applies to your personal information, we process it on one or more of the following legal bases:

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that occurred before withdrawal.

5. CONSENT AND MARKETING

When you provide information to complete a transaction, request information, or otherwise interact with the Site, we may use that information for the purpose for which you provided it and for other purposes permitted by law.

Where applicable law requires consent for marketing, cookies, or other processing, we will request that consent in the manner required by law.

You can withdraw marketing consent at any time.

We may send promotional emails about our products, offers, promotions, and Site.

Marketing emails will include an unsubscribe mechanism. You may unsubscribe at any time by using the unsubscribe link in the email or contacting us at support@savvysmartdeals.com.

Transactional and service-related communications, such as order confirmations, shipping notices, security notices, and responses to your requests, are not marketing communications and may continue when reasonably necessary.

Commercial emails will comply with applicable requirements concerning accurate sender information, non-deceptive subject lines, identification, physical address requirements, and opt-out mechanisms.

Where permitted by law, we may contact you by telephone or SMS for marketing purposes if you provide the required consent. Where required, your consent may include express written consent to receive calls and text messages using automated technology, artificial or prerecorded voice, or other automated dialing technology. Consent to receive marketing calls or text messages is not a condition of purchasing any product or service. Message frequency may vary. Message and data rates may apply.

You may opt out of marketing text messages at any time by replying STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. You may also contact us using the information in the Contact section below. For assistance, reply HELP where supported or contact us directly. A reasonable request to revoke consent through an available method will be honored in accordance with applicable law.

6. COOKIES AND TRACKING TECHNOLOGIES

We may use cookies, pixels, web beacons, tags, SDKs, and similar technologies.

We may use these technologies to:

Some technologies are operated by third parties. Those third parties may collect information about your activity on our Site and, where permitted, across other websites or services. You can control cookies through your browser settings and, where available, through privacy or cookie controls provided on the Site. Disabling certain cookies may affect Site functionality.

Where required by applicable law, we will obtain consent before using non-essential cookies or tracking technologies. If you disable or reject cookies, we may continue to use information that was lawfully collected before the change, but we will not use a disabled cookie to collect additional information where applicable law requires us to stop doing so.

7. ADVERTISING, RETARGETING, AND ANALYTICS

We may work with advertising, analytics, and technology providers to understand Site activity, measure advertising, improve our marketing, and show advertisements that may be relevant to you. These providers may use cookies, pixels, identifiers, and similar technologies. Depending on the technology used and applicable law, sharing information with advertising partners may constitute “selling” or “sharing” personal information under certain state privacy laws, even when we do not receive money in exchange for the information.

We do not sell personal information for monetary consideration. We may share the categories of personal information described in Section 2 with advertising, analytics, and marketing providers for purposes such as measuring campaigns, understanding Site activity, delivering or measuring advertising, and improving our marketing, subject to applicable law. Where applicable law gives you the right to opt out of targeted advertising or the sale or sharing of personal information, you may exercise that right as described below. We do not intentionally use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects on you.

8. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information to the following categories of recipients:

Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.

We may share information with companies that perform services for us, including:

These providers generally receive only the information reasonably necessary to perform their services. Depending on the service provided, these companies may process personal information on our behalf or process information under their own privacy policies and legal obligations.

We may disclose information to advertising, analytics, social-media, and marketing partners to measure campaigns, provide advertising, understand Site activity, and improve our marketing.

We may share information with companies that are affiliated with us or with business partners that offer products or services through our Site where reasonably necessary to provide products, services, promotions, or other activities described to you. If you purchase an upsell or other offer from one of these businesses, the information you provide to complete that purchase may be shared with that business to process, fulfill, and support your order. The business may also use that information in accordance with its own privacy policy and applicable law.

We may disclose information when reasonably necessary to:

If Savvy or substantially all of its assets are acquired, sold, reorganized, financed, merged, or transferred, personal information may be transferred as part of that transaction.This may include disclosure to prospective purchasers, investors, lenders, advisers, and successor entities as reasonably necessary for due diligence or completion of the transaction, subject to applicable law. We may disclose the categories of personal information described in Section 2 to the categories of recipients described in this Section 8.

9. THIRD-PARTY SERVICES AND WEBSITES

Our Site may use third-party services for payment processing, advertising, analytics, hosting, communications, shipping, customer support, security, fraud prevention, and other business functions. Those providers may process information on our behalf or, depending on their role, may process information under their own privacy policies. When you interact directly with a third-party service or leave our Site for a third-party website, that third party's privacy policy may apply. We encourage you to review the privacy policies of third-party services you use.

We are not responsible for privacy practices of third parties that we do not own or control. Our Site may also contain links or integrations with social-media platforms or other third-party websites. If you interact directly with those third parties, their privacy policies and terms may apply to that interaction.

10. AGGREGATED AND DE-IDENTIFIED INFORMATION

We may aggregate or de-identify information so that it cannot reasonably be used to identify you.

NL - EN speaking only: 085 4001159

We may use and disclose aggregated or de-identified information for lawful business purposes, including research, analytics, marketing, product development, and business planning.

We will not attempt to re-identify information that has been de-identified except as permitted by applicable law.

11. AUTOMATED DECISION-MAKING

We may use automated tools to detect fraud, abuse, suspicious transactions, or security threats.

If the GDPR applies to you, we do not intentionally use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects on you.

If this changes, we will provide the information and rights required by applicable law.

12. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

The appropriate retention period depends on factors such as:

We may retain information for different periods depending on the type of information, the purpose for which it was collected, our relationship with you, our legal and regulatory obligations, and the need to prevent fraud, resolve disputes, enforce agreements, or protect our business. When information is no longer reasonably necessary, we may delete it, de-identify it, or securely dispose of it, subject to applicable law.

13. SECURITY

We maintain reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, alteration, loss, destruction, or disclosure. Our safeguards are designed to be appropriate to the nature of the information we maintain and the reasonably foreseeable risks associated with our business. They may include access controls, authentication, encryption where appropriate, monitoring, vendor controls, security procedures, and other reasonable safeguards. Our security measures may include access controls, authentication, encryption where appropriate, monitoring, vendor controls, and other safeguards appropriate to the nature of the information and reasonably foreseeable risks. No system or transmission over the Internet is completely secure, so we cannot guarantee absolute security.

14. SECURITY INCIDENTS AND DATA BREACHES

If we become aware of a security incident involving personal information, we will investigate and take commercially reasonable steps to contain, mitigate, and remediate the incident. Where applicable law requires notification to affected individuals, regulators, law enforcement, or other parties, we will provide the required notice within the applicable time period and in the manner required by law. For individuals protected by the GDPR, where we are required to notify a supervisory authority of a personal-data breach, we will do so without undue delay and, where required, within 72 hours after becoming aware of the breach. Where the GDPR requires notification to affected individuals because the breach is likely to result in a high risk to their rights and freedoms, we will provide that notification as required.

15. CHILDREN'S PRIVACY

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you are under the age required to provide valid consent under applicable law, you should use the Site only with the involvement and permission of a parent or legal guardian where required. We do not knowingly use the Site to solicit personal information from children.

If you believe a child has provided personal information to us, contact support@savvysmartdeals.com. We will take reasonable steps to investigate and delete the information when required by law.

16. YOUR U.S. PRIVACY RIGHTS

Depending on where you live and subject to applicable law, you may have the right to:

Depending on applicable law, you may also have rights concerning certain automated decision-making technologies, including rights to access information about such processing or opt out of certain uses. Because we do not intentionally use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects on you, these rights may not apply to our current practices. These rights vary by state, and exemptions may apply.

California Residents

If you are a California resident, the California Consumer Privacy Act, as amended (“CCPA”), provides additional rights, subject to applicable exceptions.

These may include the right to:

California law also recognizes qualifying opt-out preference signals, including Global Privacy Control (“GPC”), for applicable sale and sharing opt-outs. Where required, we will process a qualifying signal in accordance with applicable law.

If we engage in activities that constitute a sale or sharing under the CCPA, we will provide the applicable opt-out mechanism required by law, including an appropriate “Your Privacy Choices,” “Your California Privacy Choices,” or “Do Not Sell or Share My Personal Information” mechanism, as applicable. If we use or disclose sensitive personal information for purposes that give California consumers a right to limit that use or disclosure, we will provide the applicable mechanism required by the CCPA.

17. EXERCISING U.S. PRIVACY RIGHTS

To submit a privacy request, contact: support@savvysmartdeals.com

Please provide enough information for us to reasonably verify your identity and process your request. We may request additional information where reasonably necessary to verify that the request is legitimate and relates to you. We will respond within the time required by applicable law.

Where applicable law requires multiple methods for submitting a privacy request, we will provide the required methods. If the law permits an online business to use email as a request method, you may submit your request by contacting support@savvysmartdeals.com. Where applicable law provides an appeal right, you may appeal our decision by contacting us at support@savvysmartdeals.com and identifying the decision you wish to appeal.

Where permitted by law, an authorized agent may submit a request on your behalf. We may require proof of the agent's authority and reasonable verification of your identity. We will not discriminate against you for exercising privacy rights provided by applicable law. Where required by applicable law, we will honor qualifying opt-out preference signals, including Global Privacy Control (“GPC”), in accordance with applicable requirements.

18. EEA / GDPR PRIVACY RIGHTS

If you are located in the European Economic Area (“EEA”) and the GDPR applies to our processing of your personal information, you may have the right to:

These rights are subject to applicable GDPR conditions and exceptions.

To exercise an applicable right, contact support@savvysmartdeals.com

We will generally respond within one month as required by the GDPR, subject to permitted extensions for complex or numerous requests.

19. INTERNATIONAL DATA TRANSFERS

Savvy and our service providers may process and store personal information in the United States and other countries where we or our service providers operate. If you are located outside the United States, your information may therefore be transferred to and processed in a country that may have different data-protection laws from your country of residence.

20. DO NOT TRACK

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser. As such, we cannot promise that we respond to all “Do Not Track” signals, but do recognize and respond when required by applicable privacy laws.

21. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business, technology, services, or legal obligations. When we update it, we will post the revised policy on the Site and update the Effective Date. If we make a material change that requires additional notice under applicable law, we will provide that notice in the manner and within the timeframe required by law. If applicable law requires additional notice for a material change, we will provide that notice in the manner required by law.

22. CONTACT US

If you have questions about this Privacy Policy, our privacy practices, or your privacy rights, contact us at:

Savvy Smart Ecomm Ltd.

Email: support@savvysmartdeals.com

Website: https://savvysmartdeals.com/

Last Updated: September 29, 2026