PRIVACY NOTICE

Last updated: 15 July 2026

1. About This Privacy Notice

Smerilli Design Manufacturing Pty Ltd (“SDM”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Notice explains how we collect, use, store, share and protect personal information when you:

• visit our website;
• contact us or submit an enquiry;
• request information about our services;
• book a consultation or online meeting;
• create or use a website account;
• submit a project brief or supporting material;
• communicate with our team; or
• otherwise interact with Smerilli Design Manufacturing.

We process personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”) and other applicable data protection requirements.

2. Responsible Party

The responsible party for personal information processed through this website is:

Smerilli Design Manufacturing Pty Ltd
Shop 1, 10 Industrial Street
George Industria
George, South Africa

Telephone: +27 72 132 3048
Email: info@smerillidm.co.za

Information Officer email: admin@smerillidm.co.za

3. Personal Information We Collect

The information we collect depends on how you interact with us.

3.1 Information You Provide Directly

When you contact us, submit a form, request assistance or book a consultation, we may collect:

• your name and surname;
• company or organisation name;
• job title or professional role;
• email address;
• telephone number;
• country or location;
• preferred meeting date and time;
• time zone;
• information included in your enquiry or booking notes;
• details about your footwear, leather goods or manufacturing project;
• project briefs, reference images, technical information or files voluntarily provided by you;
• correspondence between you and Smerilli Design Manufacturing;
• account or login information, where an account is created; and
• any other information you choose to provide.

Please do not submit personal information that is not reasonably necessary for your enquiry or project.

3.2 Website and Device Information

When you visit our website, certain information may be collected automatically, including:

• your Internet Protocol address;
• browser type and version;
• device type and operating system;
• approximate location derived from your IP address;
• date and time of access;
• pages visited;
• referring website;
• website interactions;
• cookie preferences; and
• diagnostic, performance and security information.

This information helps us operate the website, maintain its security, understand general website usage and improve its performance.

4. Consultations, Meetings and Zero-Value Bookings

Our website allows visitors to book consultations or online meetings with Smerilli Design Manufacturing.

Unless expressly stated otherwise, these consultations are offered free of charge and no payment is required to complete the booking.

The website platform may nevertheless record, display or manage a free booking as an “order”, “purchase” or “transaction” with a zero monetary value. This is a technical function of the booking and website management system. It does not mean that the visitor has purchased a product or incurred a payment obligation.

Information submitted during the booking process may include your name, email address, telephone number, selected service, preferred date and time, time zone and any notes you provide.

We use this information to:

• arrange and confirm the consultation;
• send booking confirmations or reminders;
• manage changes or cancellations;
• prepare for the meeting;
• communicate with you about your enquiry; and
• maintain appropriate administrative records.

Where the platform generates an order or transaction reference for a free consultation, that reference may be retained as part of the booking record.

Creating a customer account may allow you to view, manage, reschedule or cancel your bookings. Where account creation is optional, you may choose whether to create one.

5. How We Use Personal Information

We may use personal information to:

• respond to enquiries and requests;
• evaluate potential projects;
• arrange consultations and meetings;
• provide design, development, manufacturing or technical support;
• communicate about projects and services;
• prepare proposals, quotations or project documentation;
• administer website accounts and bookings;
• provide customer or technical support;
• maintain records of enquiries and business communications;
• operate, secure and improve the website;
• measure website performance and understand general usage;
• prevent fraud, abuse or unauthorised access;
• comply with legal, regulatory, accounting or contractual obligations;
• establish, exercise or defend legal rights; and
• send relevant business communications where permitted by law.

We will not use personal information for purposes that are incompatible with the purpose for which it was collected unless permitted or required by law.

6. Basis for Processing

Depending on the circumstances, we process personal information because:

• you have provided your consent;
• processing is necessary to respond to your request;
• processing is necessary before entering into, or for performing, an agreement with you;
• processing protects our legitimate business interests or those of a third party;
• processing is necessary to comply with a legal obligation; or
• processing is otherwise permitted under applicable law.

You may withdraw consent where processing is based on consent. Withdrawal will not affect processing that took place lawfully before consent was withdrawn.

7. Cookies and Similar Technologies

Our website uses cookies and similar technologies.

Essential cookies may be required to:

• keep the website secure;
• enable navigation;
• remember privacy preferences;
• operate forms;
• support account login; and
• process and manage consultation bookings.

With your permission, we may also use analytics or performance cookies to understand how visitors use the website and to improve its functionality.

Advertising or marketing cookies will only be used where they are enabled and where the required permission has been obtained.

You can accept or refuse optional cookies through the cookie banner or your browser settings. Refusing or deleting certain cookies may affect website functions, including account access or booking management.

8. Analytics and Marketing

Where enabled, we may use analytics services to understand aggregated website traffic, page performance and visitor interactions.

Analytics information is used to improve the website and our services. We do not use analytics information to make automated decisions that produce legal or similarly significant effects concerning visitors.

We may send information about Smerilli Design Manufacturing services, projects or developments where:

• you have requested such communication;
• you have provided consent;
• an existing business relationship permits the communication; or
• the communication is otherwise permitted by applicable law.

You may opt out of marketing communications at any time by using the unsubscribe option provided or by contacting us.

Operational messages concerning an enquiry, consultation, booking, project or account are not considered marketing messages and may still be sent where necessary.

9. Sharing Personal Information

We may share personal information only where reasonably necessary with:

• our website hosting and booking platform provider, including GoDaddy;
• email, communication and calendar service providers;
• analytics providers, where enabled;
• IT, website maintenance and security providers;
• professional advisers, including legal, accounting and compliance advisers;
• employees, contractors or service providers involved in responding to your enquiry or supporting your project;
• public authorities, regulators or law enforcement bodies where required by law; and
• another organisation in connection with a merger, restructuring, sale or transfer of all or part of our business, subject to appropriate safeguards.

Service providers may process personal information only to perform the relevant service or as otherwise permitted by law.

We do not sell personal information.

10. International Processing and Transfers

Some of our website, hosting, email, booking, analytics or technology service providers may process or store information outside South Africa.

Where personal information is transferred outside South Africa, we will take reasonable steps to ensure that the recipient is subject to appropriate data protection requirements, contractual safeguards or another lawful basis for the transfer.

11. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to:

• respond to an enquiry;
• manage a booking or consultation;
• evaluate or complete a project;
• maintain business and contractual records;
• meet legal, regulatory, accounting or reporting requirements;
• resolve disputes; or
• establish, exercise or defend legal claims.

The appropriate retention period depends on the nature of the information, the purpose for which it was collected and any applicable legal obligations.

When information is no longer required, we will delete, destroy, anonymise or restrict it where reasonably practicable and legally appropriate.

12. Security

We take reasonable technical and organisational measures to protect personal information against:

• loss;
• damage;
• unauthorised destruction;
• unlawful access;
• unauthorised disclosure; and
• unlawful processing.

These measures may include access controls, password protection, secure website connections, platform security measures, restricted access to business records and appropriate service-provider arrangements.

No internet transmission or storage system can be guaranteed to be completely secure. Visitors should therefore take appropriate care when sending information online.

13. Your Rights

Subject to POPIA and other applicable laws, you may have the right to:

• ask whether we hold personal information about you;
• request access to your personal information;
• request correction of inaccurate or incomplete information;
• request deletion or destruction of information where legally permitted;
• object to certain processing;
• withdraw consent where processing is based on consent;
• object to direct marketing;
• request information about how your data has been used or shared; and
• lodge a complaint with the Information Regulator of South Africa.

We may need to verify your identity before responding to a request. Some rights may be limited where we are legally required or permitted to retain or continue processing the information.

Requests may be sent to:

info@smerillidm.co.za

14. Children

This website and SDM’s professional services are not intended for children under the age of 18.

We do not knowingly collect personal information directly from children without the authorisation of a parent, guardian or other competent person where required by law.

If you believe that a child has provided personal information through the website, please contact us so that we can investigate and take appropriate action.

15. Third-Party Websites and Services

Our website may contain links to third-party websites, platforms or services.

We are not responsible for the privacy practices, content or security of third-party websites. Visitors should review the privacy information provided by those third parties before submitting personal information.

16. Changes to This Privacy Notice

We may update this Privacy Notice when our services, website functions, service providers or legal obligations change.

The revised version will be published on this page with an updated revision date. Material changes may also be communicated through the website or by another appropriate method.

17. Contact Us

For questions about this Privacy Notice, the processing of your personal information or the exercise of your privacy rights, please contact:

Smerilli Design Manufacturing Pty Ltd
Shop 1, 10 Industrial Street
George Industria
George, South Africa

Telephone: +27 72 132 3048
Email: admin@smerillidm.co.za
Email: info@smerillidm.co.za

You may also lodge a complaint with the Information Regulator of South Africa if you believe that your personal information has been processed in breach of POPIA.