Personal data protection

This policy applies to "Smile Holding" (SIA "Smile Holding") Ltd, and its companies (collectively referred to as E100) and the websites they operate. E100 ensures user privacy. We are committed to protecting the privacy of individuals who provide us with their contact and personal information. This policy sets out the types of personal information we collect, how we use it, who we may share it with, and your choices about how we may use it. We also describe here the steps we take to safeguard this information and how to contact us about our privacy practices.

E100 observes the principles set out in the Regulation of the European Parliament and the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Regulation on Data Protection) - GDPR

Data collection

As a service provider, we may form a direct relationship with you and, in turn, you may choose to provide us with your personal information as part of that relationship.

Personal data of website users are controlled by "Smile Holding" (SIA "Smile Holding") Sp. z o.o., with its registered office in Latvia, 4A Gredu Street, Riga, LV-1019.

This data may be provided when for example you apply for a product offered through E100, subscribe to an E100 information list, participate in promotions or surveys, apply for a job with E100. As soon as you provide this data to us, the data subject is no longer anonymous. When you apply to create a business relationship and during the course of that relationship, we receive personal transaction information about you from financial institutions and other entities. We may also receive information about you from payment transaction processing companies, publicly available information systems, credit reporting agencies and commercial information services.

When you submit a request to E100 for products or services through our website or through one of our sales representatives, you may choose to provide us with your company information and/or your personal information.

Here are the types of personal information we may receive:

  • Contact information (such as name, postal and e-mail address, telephone and fax numbers)
  • Business contact information (such as position, department and organization name)
  • Information about the applicant and co-applicant (such as name, mailing and e-mail addresses, telephone and fax numbers, date of creation or date of birth, and identification numbers)
  • User name and password
  • Financial information
  • Contact details of other people you allow us to contact
  • User-submitted content (for example, comments)
  • Details on employment:
  • Unique mobile device identifier
  • Geographical location data
  • Other information
Anonymous data collection

E100 collects certain information such as cookies and web beacons when you visit our site. The collection of cookies and beacons is subject to consent of E100 website visitor and is only collected if the "I agree" option is ticked. If you select the "I do not agree" option, no cookies will be collected. The data we collect in this way includes, but is not limited to, IP address, browser type, operating system, URL of pages which users have been redirected from, information about actions taken while visiting the site, and dates and times of site visits. "Cookie" is a text file placed on your computer's hard drive or mobile device's memory by a website or server. "Web beacon", also referred to as a web bug, pixel tag, or clear GIF, is used to transmit feedback to a server. We use cookies and other Internet technologies to enhance your experience by managing our website and contact programs.

The cookie, in itself, does not contain any data leading to personal identification.


If your browser settings allow for cookies collection and you have given E100 your consent to cookies collection directly on the website, we can store a small amount of information on your computer about a part of the website you have visited and which features you like best. This allows us to tailor the content you view to your interests. We may also use cookies to identify authorized users so that they do not have to re-enter their username and password. By allowing us to better understand how you use our site, cookies can help us provide you with a better and more relevant online experience. No third party websites can see the cookies we store on your computer.

Most web browsers allow users to modify their security settings to accept or decline cookies. You do not need to have cookies enabled to visit our site, but without them your access to some areas may be limited and customized navigation may not be available. For more information about the cookies we use and the purposes which we use them for, please see our Cookie Policy.

Web beacons

E100, like many other websites, may use web beacons. Web beacons help us better understand web traffic and user behavior when they visit our site, as well as their response to promotions we offer. This information does not identify individual users and is only used to create an overall picture of how users use our site. Users can, if they wish, deactivate pixel tags by setting their web browser to bypass images, and deactivating JavaScript.

Phone calls

As part of some transactions, you will contact us by telephone or we will call you. For these purposes, we may also contact each other via web chats. Please be aware that it is common practice for E100 to monitor and in some cases record such interactions for the purpose of staff training or quality control, or to preserve evidence of a particular transaction or interaction.

Data sharing

We do not sell or otherwise disclose your personal information that we collect, except as described herein or as otherwise disclosed to you at the time of collection. We share data in order to conduct transactions or other activities related to our business relationship. We may share the personal information we collect with our companies, commercial affiliates, subsidiaries, traders, suppliers and other entities involved in the process of contracting with E100 Group Customers. We may also share this data with our service providers who perform services on our behalf. We do not authorize these service providers to use or disclose this data except as necessary to perform certain services on our behalf or to comply with legal requirements. We require these service providers, as part of their contract, to adequately protect your privacy and the personal information they process on our behalf.

We may share data with business partners whom we do business with. Business partners may contact you about products or services which you may be interested in. Third parties may use personal information in accordance with their own privacy policies. We suggest that you review the privacy policies of third parties if you use these features. We reserve the right to share your personal information, if we sell or transfer all or part of our business or assets. If such a sale or transfer occurs, then we will make every effort to instruct the recipient to use the personal information received from you in a manner consistent with our privacy policy. Upon completion of such sale or transfer, you may contact the entity that received your personal information regarding any questions you may have regarding the processing of your personal information.

User rights and choices

You may have certain rights regarding the personal information we hold about you. We offer you the right to choose which personal information we collect.

You may choose not to share your personal information with the E100 Group by refusing to provide the consents you give when you do business with E100. You may choose not to have a unique cookie identification number assigned to your computer to avoid aggregation and analysis of data collected on our websites.

You may stop receiving marketing materials from us by mail by following the unsubscribe instructions included in the contents of a specific promotion. You may also opt out of receiving promotional materials. You may withdraw any consent you have previously given us or prohibit us from processing your personal information at any time for legitimate reasons. From then on, we will start to follow the preferences expressed by the user. In some cases, withdrawing your consent to our use or disclosure of your personal information will mean that you will not be able to use certain products or services offered by us.

If you are located in the European Economic Area, you may prohibit us from sharing your personal information with third parties, except: (i) service providers we have engaged to provide services on our behalf, (ii) if we sell or transfer all or part of our business or assets, (iii) if disclosure is dictated by the requirements of law or legal process, or (v) if we believe that such disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of alleged fraud or other illegal activity. If you are located in the European Economic Area, we will only use your personal information for the purposes set out in the terms of this privacy policy and any other terms and conditions we have notified you of, unless we have a legal basis, such as your consent to use it for other purposes. If required by law, E100 obtains your prior consent when collecting for processing your (i) personal data for marketing purposes and (ii) personal data deemed relevant under applicable law.

Information security

The registered office of Smile Holding is in Latvia. All user information may be transferred to and stored in a secure database in Latvia or in databases belonging to E100. If we transfer your information to other countries, we will protect it as described in this privacy policy. The data we collect may be transferred outside of your country of origin. They may also be processed by employees operating outside your country of origin who work for us or for any of our suppliers. These employees may, for example, be involved in processing an order placed by you, processing payment information, and providing support services. By providing your personal data, you consent to this transfer, storage or processing. If you give us details of other employees or people in your organisation, it is your responsibility to ensure that you have their permission to do so. We will take all reasonable steps to secure your information and protect it in accordance with this privacy policy. E100 has a data protection program designed to (i) safeguard and maintain the confidentiality of your personal information; (ii) protect against anticipated threats and risks to the security or integrity of your personal information; (iii) protect against unauthorized access to or use of your personal information that could result in serious harm or inconvenience to you or your entity if a breach were to occur; and (iv) comply with applicable law. Our agreements with our suppliers and service providers similarly oblige them to protect your personal information. Unfortunately, transmitting information over the internet is never completely safe. While we will do our best to protect your personal information, we cannot guarantee the security of any data submitted to our websites. The user submits this data at his/her own risk. We take all reasonable precautions, including appropriate technical, administrative and physical procedures, to protect your personal information from loss, misuse or alteration. The information you provide to us is stored on our secure servers.

Under applicable law, you may have the right to request access to and information about your personal details that we hold about you, to update and correct inaccuracies in your personal details, and to request that we block or delete your information. Your right to access your personal data may be restricted by local law in some circumstances. To update your preferences, request that your details be removed from our contact list, or to make the request, please contact us by email.

Rules of use

By using the E100 website and services, you consent to the use of your personal data as set forth in this privacy policy and any other terms and/or conditions which you shall be notified of. E100 reserves the right to access and disclose personal and contact information in compliance with applicable laws, lawful government requirements, and court orders. [For good reason], such as [introduction of new services, discontinuation of existing services, or a material change in the laws which we are required to comply with], we may need to change the content of our privacy policy. In that case, we will notify you of the changes on this page. Users are encouraged to visit this page to find out about any changes. Your continued use of this site therefore means that you agree to this privacy policy; your use of this site once modified privacy policy has been posted means that you agree to the modified privacy policy.

Our contact information

If you wish to opt out of receiving email, fax or telephone notifications from E100, or if you wish to update your details, request that your details be deleted, or wish to enquire about details of the data we hold, please email us at This email address is being protected from spambots. You need JavaScript enabled to view it.. If you have any further questions about this privacy policy, or if you have a complaint, please contact us by e-mail at This email address is being protected from spambots. You need JavaScript enabled to view it.

Amendments to the Privacy Policy

We will update this privacy policy from time to time to reflect changes in our business operations. If we change the way we use your personal data, or if the purposes or entities to which we disclose your personal information change, we will post a notice of those changes on our website and your continued use of this website following the posting of the modified privacy policy will mean that you agree to the modified policy.