Legal Documentation

Privacy Policy

This document describes how Smart Mining S.r.l. collects, processes, and protects personal data in compliance with EU Regulation 2016/679 (GDPR) and applicable Italian law (D.Lgs. 196/2003, as amended by D.Lgs. 101/2018).

Last updated: 16 June 2025 GDPR – Reg. (EU) 2016/679 D.Lgs. 196/2003 (Codice Privacy) D.Lgs. 101/2018

 
01

Data Controller

Pursuant to Art. 13 and Art. 4(7) of Regulation (EU) 2016/679 (“GDPR”), the Data Controller is:

Smart Mining S.r.l.

Via Lucchese 579, 51034 Serravalle Pistoiese (PT), Italy

Email: support@smartmining.com

PEC: admin@pec.smartmining.com

Website: www.smartmining.com

For any questions regarding the processing of your personal data, or to exercise your rights, you may contact us at the address or email above.

02

Categories of Personal Data Processed

Depending on how you interact with our website and services, we may collect and process the following categories of personal data:

2.1 — Identification & Contact Data

  • First name and last name
  • Email address
  • Telephone number (optional)
  • Billing and shipping address
  • Fiscal code or VAT number (for invoicing purposes)

2.2 — Payment Data

  • Payment card details (processed exclusively by our certified third-party payment processors; we do not store full card numbers)
  • Transaction identifiers and payment confirmation references

2.3 — Order & Commercial Data

  • Purchase history, order details, and product preferences
  • Delivery and tracking information
  • Warranty registrations and product serial numbers
  • Customer service correspondence and support tickets

2.4 — Browsing & Technical Data

  • IP address and approximate geolocation derived from it
  • Browser type, version, and operating system
  • Pages visited, time spent, referring URLs, and navigation paths
  • Device identifiers and session data
  • Cookie identifiers (see Section 6)

2.5 — Account Data

  • Username, encrypted password, and account preferences
  • Saved addresses and wishlist items

2.6 — Marketing & Communication Data

  • Newsletter subscription status and communication preferences
  • Responses to surveys or promotional campaigns (where applicable)

We do not intentionally collect special categories of personal data (Art. 9 GDPR), such as health data, political opinions, racial or ethnic origin, or biometric data. Should you inadvertently provide such data in free-text fields, we will delete it promptly upon becoming aware.

03

Purposes and Legal Bases for Processing

We process your personal data for the following purposes, each based on a specific legal ground under Art. 6 GDPR:

Purpose Data Used Legal Basis (Art. 6 GDPR)
Processing and fulfilling your orders (including shipping, invoicing, and after-sales support) Identification, contact, payment, order data Art. 6(1)(b) – Performance of a contract
User account creation and management Account data, identification data Art. 6(1)(b) – Performance of a contract
Legal and fiscal obligations (invoicing, accounting, tax records) Identification, payment, order data Art. 6(1)(c) – Legal obligation
Customer support and handling of complaints or warranty claims All relevant data provided in context Art. 6(1)(b) – Performance of a contract
Sending transactional emails (order confirmations, shipping updates) Email address, order data Art. 6(1)(b) – Performance of a contract
Sending marketing communications, newsletters, and promotional offers Email address, preferences Art. 6(1)(a) – Consent (withdrawable at any time)
Website analytics and improving the browsing experience Browsing and technical data Art. 6(1)(f) – Legitimate interests / Consent (for non-essential cookies)
Fraud prevention, security monitoring, and abuse detection Technical data, IP address, transaction data Art. 6(1)(f) – Legitimate interests
Compliance with court orders or law enforcement requests Relevant data as required Art. 6(1)(c) – Legal obligation
Profiling for personalised product recommendations (optional) Purchase history, browsing data Art. 6(1)(a) – Consent (withdrawable at any time)

Where processing is based on your consent (Art. 6(1)(a) GDPR), you have the right to withdraw that consent at any time without prejudice to the lawfulness of processing carried out prior to withdrawal.

Where processing is based on our legitimate interests (Art. 6(1)(f) GDPR), we have carried out a balancing test and determined that our interests do not override your fundamental rights and freedoms. You may object to such processing at any time (see Section 7).

04

Recipients and International Data Transfers

4.1 — Categories of Recipients

Your personal data may be disclosed to the following categories of recipients, who act as Data Processors under Art. 28 GDPR or as independent Data Controllers:

  • Payment service providers (e.g., Stripe, PayPal, or equivalent) – to process transactions securely
  • Shipping and logistics companies (e.g., BRT, GLS, DHL, Poste Italiane) – to deliver your orders
  • E-commerce platform and hosting providers – to operate the website and store data
  • Email marketing and CRM platforms – only where you have given consent to marketing
  • Analytics providers (e.g., Google Analytics with IP anonymisation enabled)
  • Accounting and ERP software providers – for fiscal and administrative obligations
  • Customer support tools – to manage support tickets and communications
  • Legal and fiscal advisors – bound by professional confidentiality obligations
  • Public authorities and law enforcement bodies – when required by applicable law

We do not sell, rent, or otherwise trade your personal data to third parties for their own marketing purposes.

4.2 — International Transfers

Some of our service providers may be established outside the European Economic Area (EEA). Where personal data is transferred to a third country, we ensure that an appropriate safeguard is in place, in accordance with Chapter V GDPR, such as:

  • An adequacy decision by the European Commission (Art. 45 GDPR)
  • Standard Contractual Clauses (SCCs) approved by the European Commission (Art. 46(2)(c) GDPR)
  • Binding Corporate Rules (BCRs) where applicable

You may obtain a copy of the relevant safeguards by contacting us at support@smartmining.com.

05

Retention Periods

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, in compliance with applicable legal obligations. The following retention periods apply:

Data Category Retention Period Basis
Order, invoice, and transaction data 10 years from date of transaction Art. 2220 Italian Civil Code; D.P.R. 633/1972 (VAT obligations)
Customer account data Duration of account + 2 years after last activity Contractual necessity; legitimate interests
Customer support communications 3 years from closure of the request Legitimate interests (legal defence); Art. 2946 Civil Code
Marketing consent and preferences Until withdrawal of consent, + 2 years thereafter Documentation obligation (Art. 7 GDPR)
Website logs and technical data 12 months (or as required by law) Legitimate interests; D.Lgs. 196/2003
Analytics data (anonymised/aggregated) Up to 26 months Legitimate interests (anonymised – not personal data)
Cookie consent records 12 months Garante Privacy guidelines

At the end of the applicable retention period, data is securely deleted or anonymised. Where you request earlier deletion (see Section 7), we will comply unless a legal obligation requires us to retain the data.

06

Cookies and Tracking Technologies

SmartMining.com uses cookies and similar tracking technologies in accordance with the Italian Data Protection Authority (Garante per la protezione dei dati personali) Cookie Guidelines of 10 June 2021, and the EU ePrivacy Directive (2002/58/EC as amended by 2009/136/EC).

6.1 — Technical / Essential Cookies

These cookies are strictly necessary for the website to function and cannot be switched off. They include session management, shopping cart functionality, and security tokens. No consent is required for these cookies.

6.2 — Analytics Cookies

We use analytics cookies (such as Google Analytics with IP anonymisation) to understand how visitors use our website, measure performance, and improve the user experience. These cookies are installed only with your prior consent, obtained through our cookie consent banner.

6.3 — Marketing and Profiling Cookies

Marketing cookies may be used to deliver personalised advertisements and measure the effectiveness of campaigns. These are set only with your explicit prior consent. You may withdraw your consent at any time via our cookie settings panel.

6.4 — Managing Your Cookie Preferences

When you first visit our website, a cookie banner will allow you to accept, refuse, or customise non-essential cookies. You may change your preferences at any time by accessing the cookie settings link in the website footer. You may also manage or delete cookies directly from your browser settings.

For more information about cookies and how to manage them, visit www.allaboutcookies.org.

Note on the Garante Cookie Guidelines (2021): In line with the Italian supervisory authority’s requirements, we do not use “cookie walls” or dark patterns to influence your choices. Scrolling or continued navigation does not constitute consent. Consent is collected via a clearly labelled banner with genuine accept/reject options.

07

Your Rights as a Data Subject

Under Chapter III of the GDPR (Arts. 15–22), you have the following rights with respect to your personal data. You may exercise any of these rights free of charge by contacting us at support@smartmining.com. We will respond within 30 days (extendable to 90 days for complex requests, with prior notice).

Art. 15 — Right of Access

You may obtain confirmation as to whether we process your personal data and, if so, receive a copy of it along with supplementary information about the processing.

Art. 16 — Right to Rectification

You may request correction of inaccurate or incomplete personal data we hold about you, without undue delay.

Art. 17 — Right to Erasure

You may request deletion of your personal data where it is no longer necessary for its original purpose, or where you withdraw consent, subject to legal retention obligations.

Art. 18 — Right to Restriction

You may request that we restrict processing of your data in certain circumstances, such as while we verify the accuracy of data you have contested.

Art. 20 — Right to Portability

Where processing is based on consent or contract and carried out by automated means, you may receive your data in a structured, machine-readable format or ask us to transmit it to another controller.

Art. 21 — Right to Object

You may object at any time to processing based on legitimate interests (Art. 6(1)(f)), including profiling, and to direct marketing processing.

Art. 7(3) — Withdraw Consent

Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of prior processing.

Art. 22 — Automated Decisions

You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce significant effects on you.

Right to Lodge a Complaint

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the Italian supervisory authority:

Garante per la protezione dei dati personali

Piazza Venezia 11, 00187 Roma (RM), Italy

Website: www.garanteprivacy.it

Email: garante@garanteprivacy.it

PEC: protocollo@pec.gpdp.it

You may also lodge a complaint with the supervisory authority of your country of habitual residence or place of work within the EEA.

08

Processing of Minors’ Data

Our website and services are intended exclusively for adults aged 18 and over. We do not knowingly collect personal data from minors under the age of 18. In Italy, pursuant to Art. 2-quinquies of D.Lgs. 196/2003 (as amended), the minimum age for consent to information society services is 14 years; however, given the nature of our products (home cryptocurrency mining hardware), we restrict access to adults only.

If we become aware that we have inadvertently collected personal data from a minor under 18, we will delete such data promptly. If you believe a minor has provided us with their data, please contact us at support@smartmining.com.

09

Security Measures

We implement appropriate technical and organisational security measures in accordance with Art. 32 GDPR to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

  • TLS/SSL encryption for all data transmitted between your browser and our servers
  • Encryption of sensitive data at rest (including payment-related identifiers)
  • Access controls and role-based permissions for internal staff
  • Regular security assessments and vulnerability testing
  • Pseudonymisation of data where appropriate
  • Data breach detection, response, and notification procedures in compliance with Art. 33–34 GDPR
  • Staff training on data protection and security obligations

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay, in accordance with Art. 34 GDPR.

10

Links to Third-Party Websites

Our website may contain links to external websites and services operated by third parties. This Privacy Policy applies only to SmartMining.com. We are not responsible for the privacy practices of third-party websites and recommend that you review their privacy policies before providing any personal data. Linking to an external site does not imply endorsement by Smart Mining S.r.l.

11

Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or regulatory guidance. The date of the most recent revision appears at the top of this page. Where changes are material, we will notify you by email (if you have an account) or by displaying a prominent notice on our website prior to the change taking effect.

We encourage you to review this page periodically. Continued use of our website following notification of changes constitutes acceptance of the revised policy, to the extent permitted by applicable law.

12

How to Contact Us

For any questions, requests, or concerns relating to your personal data or this Privacy Policy, please contact us using any of the following channels:

Smart Mining S.r.l. — Data Controller

📍 Via Lucchese 579, 51034 Serravalle Pistoiese (PT), Italy

✉️ Email: support@smartmining.com

📠 PEC: admin@pec.smartmining.com

🌐 Website: www.smartmining.com

We aim to respond to all legitimate privacy-related requests within 30 calendar days of receipt. If your request is complex or you have submitted multiple requests, we may extend this period by a further two months and will inform you accordingly, in line with Art. 12(3) GDPR.

If you are not satisfied with our response, you retain the right to lodge a complaint with the Garante per la protezione dei dati personali (see Section 7).