Privacy Policy

Privacy Policy

Smartwear Group (“we”, “our”, “us”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share information when you purchase our Products, access our website, and use related mobile applications and services.

1. Data We Collect

We may collect the following categories of personal data:

a. Purchase & Account Information

• Name, date of birth, contact details (email, phone, address)

• Billing and payment details

• Delivery information

• Account login credentials (if you create an account to access our online services)

b. Device & Usage Data (Smart Unit + App)

• Device identifiers (serial number, firmware version)

• Sensor data generated during use (e.g., muscle stimulation settings, session logs, performance metrics)

• Connection data (Bluetooth/Wi-Fi pairing information)

• App usage data (features accessed, preferences, error reports)

c. Website Data:

• IP address, browser type, operating system

• Cookies and similar tracking technologies (see Cookie Policy)

d. Customer Support:

• Communications with us (emails, chat, support tickets)

• Feedback, surveys, complaints

2. Legal Basis for Processing

We process your personal data under the following bases:

• Contractual necessity – to process your purchase, deliver your EMS suit, provide app functionality, and provide customer support

• Legitimate interests – to improve our products/services, prevent fraud, and ensure device security

• Legal obligations – to comply with consumer protection, tax, accounting, and product safety laws

• Consent – where required, e.g., for marketing communications or optional health-related tracking features

3. How We Use Your Data

We use personal data to:

• Process orders, payments, and deliveries

• Register and authenticate app users

• Enable device functionality, updates, and security patches

• Monitor performance and provide analytics for user experience

• Handle customer inquiries and technical support
• Send product updates, warranty, and recall notices
• Conduct marketing (if you consent)
• Comply with regulatory requirements (safety, consumer rights, product testing)

4. Data Sharing

We may share your data with:

• Service providers – payment processors, delivery couriers, IT/cloud hosting providers

• Business partners – app stores, technical support providers

• Regulators/authorities – where legally required (e.g., safety recalls, compliance reporting)

• Affiliates – within our corporate group for operational purposes

We do not sell your personal data.

5. International Transfers

If your data is transferred outside the UK/EU, we will ensure appropriate safeguards (e.g., Standard Contractual Clauses, adequacy decisions).

6. Data Retention

We retain data only as long as necessary for the purposes described:

• Purchase/account data: up to 7 years (legal/tax obligations)
• Device/app usage data: until your account is deleted or after 3 years of inactivity
• Marketing data: until you withdraw consent
• Support communications: 3 years after resolution

7. Security

We use appropriate technical and organisational measures (encryption, access controls, secure servers) to protect your data. However, no system is fully secure.

8. Your Rights

Under GDPR/UK GDPR, you have rights to:

• Access your data
• Rectify inaccuracies
• Erase your data (“right to be forgotten”)
• Restrict or object to processing
• Data portability
• Withdraw consent at any time (where applicable)
• Lodge a complaint with your local Data Protection Authority

9. Children

Our products and services are not directed at children under 16. We do not knowingly collect personal data from minors.

10. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights:

Privacy Team
Email: contact@smartweargroup.com

Last Updated: 22 September 2025