Version 1.0, last updated 29 August 2026.
Draft for review. Confirm your legal entity name, KvK number, retention periods, processors and any DPO or representative details before publication.
NoSmoky, established at Demmersweg 86, 7556 BN Hengelo, the Netherlands, is the controller for the personal data described here.
Questions and requests: info@nosmoky.com
We sell to businesses. In practice we process data about the people who represent those businesses: buyers, store managers, finance contacts. Company data such as a registration or VAT number is not personal data, but it is often linked to a named contact, so we treat the record as a whole with care.
Quote requests and account applications. Company name, country, registration number, VAT identification number, website, contact name, business email, telephone, requested products and quantities, preferred delivery date and any message. We use this to verify that you buy as a business, to prepare a quotation and to open a trade account. Legal basis: performance of a contract or steps taken at your request, and our legitimate interest in preventing consumer purchases on trade terms.
VAT verification. We submit the VAT identification number you enter to the European Commission’s VIES service to confirm validity, and we record the result and its date. Legal basis: compliance with our legal obligation to substantiate a zero-rated intra-community supply.
Orders, invoicing and delivery. Order history, delivery addresses, payment status and correspondence. Legal basis: performance of the contract and our legal obligation to keep accounting records.
Support and warranty claims. Descriptions, photographs and correspondence relating to a claim. Legal basis: performance of the contract and our legitimate interest in handling claims and improving the product.
Website use. Functional data needed to serve the site securely. Analytics or marketing cookies are only set with your consent, which you may withdraw at any time.
If you are a dealer or have asked us for a quotation, we may send you range, stock and season information relevant to your business, on the basis of our legitimate interest. Every message contains an unsubscribe link, and opting out never affects the service you receive.
Only where necessary: our hosting and email providers, our CRM, our accountant and auditor, carriers who need a delivery address and contact, payment providers, the VIES service for VAT validation, and credit insurers or collection agents where payment terms are granted. Processors act on our instructions under a data processing agreement. We do not sell personal data. Where a provider processes data outside the EEA, we rely on an adequacy decision or the European Commission’s standard contractual clauses.
Quote requests that do not lead to an account: 12 months. Trade account and correspondence records: for the duration of the relationship and 24 months afterwards. Invoices, VAT verification records and accounting data: seven years, as required by Dutch tax law. Warranty files: for the warranty period plus two years. Consent records: for as long as we rely on the consent, plus proof of withdrawal.
You may request access, rectification, erasure or restriction, object to processing based on legitimate interest, receive your data in a portable format, and withdraw consent. If you are not satisfied you may complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or to the supervisory authority in your own country.
Write to info@nosmoky.com and we respond within one month.
Access to trade records is limited to staff who need it, transport is encrypted, and accounts use multi-factor authentication. We log and assess incidents and report qualifying breaches to the supervisory authority and to you where required.
VAT validation is automated, but no trade account is approved or refused by a machine alone. A person always reviews an application before a decision is taken.
We update this policy when our processing changes. Material changes are communicated to active trade accounts by email. The version and date at the top always show what is in force.