Privacy policy

Last updated: January 23, 2026

This Policy is primarily intended to comply with applicable U.S. privacy laws.

We do not intentionally target or offer services to individuals located in the European Union through this Website.

We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the smokybrands-marketing.com website (“Website” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.

This Policy describes how we collect, use, disclose, and safeguard Personal Information in connection with the Website and Services. This Policy does not apply to the practices of third parties that we do not own or control.

Automatic collection of information

When you open the Website, our servers automatically record information that your browser sends. This data may include information such as your device’s IP address, browser type, and version, operating system type and version, language preferences or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, information you search for on the Website, access times and dates, and other statistics.

Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.

Use and processing of collected information

We collect and use Personal Information to operate the Website and Services, communicate with you, provide support, improve our offerings, and comply with legal obligations.

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your non-personally identifiable information with our trusted subsidiaries and joint venture partners, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to your information. We may share Personal Information with trusted third-party service providers solely for the purpose of operating and improving the Website and Services, and in accordance with this Policy.

Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.

We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred.

Some service providers or subcontractors assisting us in providing the Services may be located outside the United States, including in Germany. In such cases, Personal Information is shared solely for operational purposes and processed on our behalf under contractual confidentiality and data protection obligations.

Retention of information

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, to enforce our Policy, resolve disputes, and unless a longer retention period is required or permitted by law.

We may use aggregated data derived from or incorporating your Personal Information, but not in a manner that would identify you personally. Once the retention period expires, Personal Information will be deleted or de-identified, unless we are required or permitted by law to retain it longer.

International Data Transfers

Personal Information may be accessed or processed by authorized service providers or subcontractors located outside the United States, including Germany. Such access is limited to what is necessary to perform services on our behalf and is subject to appropriate safeguards.

U.S. State Privacy Notices

This section describes additional disclosures and rights available to residents of certain U.S. states under applicable U.S. privacy laws.

Disclosures for residents of the USA

If you are a resident of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Utah, or Virginia, you may have certain rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. This supplemental section, together with other relevant sections of the Policy, provides information about your rights and how to exercise them under the California Consumer Privacy Act and the California Privacy Rights Act (collectively, “CCPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Delaware Online Privacy and Protection Act (“DOPPA”), the Iowa Consumer Data Protection Act (“ICDPA”), the Maryland Personal Information Protection Act (“PIPA”), the Utah Consumer Privacy Act (“UCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), and any and all regulations arising therefrom. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the related state laws.

In addition to the rights as explained in this Policy, if you provide Personal Information as defined in the statute to obtain Services for personal, family, or household use, you may submit requests related to your Personal Information as permitted by applicable law. Note that there are circumstances when we may not be able to comply with your request, such as when we are not able to verify your request or when providing a full response conflicts with other legal obligations. You will be notified if that is the case.

(a) Right to know and right to access: You have the right to request certain information we have collected about you. Once we receive and confirm a verifiable request from you, we will disclose to you, to the extent permitted by law:

• The specific pieces of Personal Information we hold about you.
• The categories of sources from which information about you is collected.
• The purposes for collecting, selling, or sharing your Personal Information.

You may request that the Personal Information is delivered in a format that is portable and, to the extent technically feasible, readily usable.

(b) Right to correct: You have the right to request that we correct inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of processing.

(c) Right to delete: You have the right to request deletion of your Personal Information, subject to exceptions permitted by law.

(d) Right to opt-out of the sale and sharing: You have the right to opt out of the sale or sharing of your Personal Information as defined under applicable law.

(e) Right to limit the use of sensitive personal information: Where applicable, you may have the right to limit the use of Sensitive Personal Information. We do not use Sensitive Personal Information for purposes beyond those permitted by law.

(f) Right to non-discrimination: You have the right not to be discriminated against for exercising your rights. We will not deny goods or services, charge different prices, provide a different level or quality of goods or services, or suggest that we would treat you differently because you exercised your rights.

(g) Shine the Light: California residents with an established business relationship with us may have the right to request information about how certain personal information is disclosed to third parties for their direct marketing purposes, as provided by California’s “Shine the Light” law, or the right to opt out of such practices.

To exercise any of your rights, contact us using the details below. After we receive and verify your request, we will process it to the extent required by applicable law.

How to exercise your rights

Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that the authorized representative has valid written authority to submit requests on your behalf.

You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

Cookies

Our Website and Services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services.

We may use cookies to collect, store, and track information for security and personalization, to operate the Website and Services, and for statistical purposes. For further information on the cookies we collect and their purpose, see our cookie policy. Please note that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer.

Data analytics

Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Website and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Website and Services. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.

Privacy of children

We do not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission.

Do not sell or share my personal information

We do not sell your Personal Information. Where applicable U.S. state privacy laws define certain disclosures as “selling” or “sharing,” you may opt out by submitting a request using the link below. We will process verified requests in accordance with applicable law.

Submit a Do Not Sell or Share My Personal Information request

Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from users who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.

Social media features

Our Website and Services may include social media features, such as the Facebook and Twitter buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Website and Services, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Website and Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.

Email marketing

We offer electronic newsletters to which you may voluntarily subscribe at any time. We do not share your email address with third parties for their own marketing purposes, except as needed to use a service provider to send emails on our behalf and as described in this Policy. We will maintain the information sent via email in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all emails sent from us will clearly state who the email is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us.

Links to other resources

The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

Data breach

In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.

In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website. In jurisdictions where required, we may also report the breach to relevant authorities in accordance with applicable data protection regulations.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the top of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy will constitute your acceptance of those changes.

Acceptance of this policy

By using the Website and Services, you acknowledge that you have read and understood this Policy.

Contacting us

If you have any questions regarding the information we may hold about you or if you wish to exercise your rights, you may use the following data subject request form to submit your request:

Submit a data access request

If you have any other questions, concerns, or complaints regarding this Policy, we encourage you to contact us using the details below:

hello@smokybrands-marketing.com

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable U.S. privacy laws.