Privacy Policy

Last updated: 18th November 2021


Smudge Studio (“Smudge Studio”, “we”, “our” or “us”) considers the privacy and protection of its clients’ personal data to be of upmost importance. To ensure that you feel confident about providing us with your personal information when communicating with us and using our services, we outline below our practices in relation to the collection and use of personal data. This policy forms part of our Terms and Conditions of trading.

Through its dealings with you, Smudge Studio (through its website and generally) obtains information about you. By using this website and by submitting your personal information to us, you agree to the use of that information by us as set out in this policy. This policy supersedes any earlier version. Your continued use of the website constitutes your agreement to this policy and any updates.


Respecting your privacy

This policy sets out:

  • the kinds of personal information we collect and hold;
  • how we collect and hold it;
  • the purposes for which we collect, hold, use and disclose it;
  • your right to access and seek correction of it;
  • how you may complain about privacy matters; and
  • our sharing of your personal information overseas.

What kinds of personal information do we collect and hold?

The personal information we collect and hold is that which is reasonably necessary for our business functions and activities. When we collect and hold personal information, it is of the following kinds:

  • your personal details such as your name, business name, addresses, telephone numbers;

You generally have the option of not identifying yourself or of using a pseudonym when dealing with us. However, it is not possible where the law or a court order provides otherwise.


How do we collect and hold personal information?

Collection of personal information: When we collect personal information about you, we do so by making a record of it. We do this when:

  • you communicate with us online;
  • you take part in our promotions, competitions, testimonials, surveys and focus groups.

We may also collect personal information about you by accessing data from other sources and then analysing that data together with the information we already hold about you in order to learn more about your likely preferences and interests.

When you visit our websites, social media pages or mobile applications or click on our advertisements on the online media of other companies, we may collect information about you using technology which is not apparent to you, for example “cookies”.


What are “cookies”?

“Cookies” are small pieces of information sent by a web server and stored by your browser on the hard drive of your computer, tablet or mobile phone so it can later be read back from that browser. This allows your browser to remember some specific information relating to your internet activity. Most web browsers automatically accept cookies, but you can usually change your browser to prevent that. You can find information about how to do this for all the commonly used internet browsers on the website: This website will also explain how you can delete cookies which are already stored on the hard drive of your computer, tablet or mobile phone.

Most of the personal information we collect and hold about you is from your direct dealings with us. We may sometimes collect your personal information other than from you directly. For example, from other suppliers who, in common with us, have a relationship with you.

Holding of personal information: Personal information we hold is generally stored in a computer database. These may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information. We use current industry standard security practices to operate our systems including this website. We use the 128-bit digitally signed SSL certificated security.


Why do we collect, hold, use and disclose personal information?

When we collect, hold and use your personal information, we do so primarily to sell and promote our goods and services to you and to improve on the range of our offerings. For example:

  • to learn of your likely preferences so that we may promote our goods and services to you in a way which may be of most interest to you; and
  • to assist in investigating your complaints and enquiries.

We disclose personal information we collect for purposes which are incidental to the sale and promotion of our goods and services to you. We may disclose your personal information:

  • within our business. Our primary business location is Ireland;
  • to service providers and suppliers who assist us in our day-to-day business operations;
  • in the event that we sell or buy any business or assets, including their goodwill, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if Smudge Studio or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to apply our terms and conditions and any other agreement with you.

When marketing to you, your personal information is only ever used or disclosed for Smudge Studio’s own purposes. You may opt out of our direct marketing to you. Our direct marketing materials will tell you how to do this.

We may de-identify your personal information. We may do this for use and disclosure of the anonymous data to determine preferences and shopping pattern.


How can you enquire about, access and correct your personal information?

Access: The General Data Protection Regulation (GDPR) gives you rights to access information held about you. Your right of access can be exercised in accordance with the Act. If you wish to access your personal information or have an enquiry about privacy, please contact our Data Protection Officer at:

Before we provide you with access to your personal information we may require some proof of identity.

Correction: If you need to correct your personal information, please contact our Data Protection Officer at the above contact points.


How can you complain about our management of personal information?

If you wish to complain about a breach of the privacy rules that bind us, you may contact our Data Protection Officer at the above contact points. We may ask you to put your complaint in writing and to provide details about it.

We may discuss your complaint with our personnel and our service providers and others as appropriate.

Our Data Protection Officer will investigate the matter and attempt to resolve it in a timely way. Our Data Protection Officer will inform you in writing about the outcome of the investigation. If our Data Protection Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Data Protection Officer will inform you that your complaint may be referred to the Information Commissioner’s Office for further investigation and will provide you with the Information Commissioner’s Office’s contact details.


Data retention period

We only retain the personal information collected from a user for as long as a user’s account is active. Personal information gathered from this website will be retained for a period of time as long as we need it to fulfil the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.



We reserve the right to update this policy from time to time. When we do, we will revise the “Last updated” date of this policy.


Other privacy terms and limits of this policy

There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us and on our particular businesses.


More information

More information about privacy law and privacy principles is available from the Information Commissioner’s Office. The contact details of the Information Commissioner’s Office can be found at


Other points on Privacy

Third Party Web Sites

Our Website may contain links to other Websites that are not operated by Smudge Studio. Smudge Studio is not responsible for the privacy practices of Websites that it does not operate so when you link to other websites you should read their privacy policies.