Legal
Privacy Policy
Effective May 20, 2026
This Privacy Policy explains how Cache Distribution, LLC (d/b/a SmartPicks) (“SmartPicks,” “we,” “us,” or “our”) collects, uses, and shares information when you visit smartpicks.vip (the “Site”).
We have written this policy to comply with the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (CCPA/CPRA), and similar laws in other U.S. states (Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana). If you live somewhere with stronger local rules, those rules also apply to you.
1. Who we are (Data Controller)
The data controller responsible for your information is Cache Distribution, LLC (d/b/a SmartPicks), 1401 21st Street, Sacramento, CA 95811, United States. You can reach our privacy team at [email protected]. We do not currently maintain an EU establishment; if EU data-protection law applies to a specific processing activity we will identify a representative in line with Article 27 GDPR.
2. What we collect, why, and on what legal basis
We try to collect as little information as possible. The categories below are exhaustive — we do not sell personal information, and we do not maintain any “hidden” tracking that is not described here.
| Data | Purpose | Legal basis (GDPR Art. 6) | Retention |
|---|---|---|---|
| Email address (newsletter) | Send weekly product picks; remember whether you double-opted-in | Consent (Art. 6(1)(a)) | Until you unsubscribe; up to 30 days afterward in our suppression list to honor the unsubscribe. |
| IP address & timestamp at signup | Demonstrable consent log; abuse prevention | Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) | 24 months |
| Aggregate page-view counts (Umami, cookieless) | Understand which content readers find useful | Legitimate interest (Art. 6(1)(f)); does not require consent under ePrivacy because no terminal-equipment storage is used | Aggregated indefinitely; raw events 12 months |
| Outbound affiliate-link clicks (anonymous count) | Understand which products readers find useful and track affiliate revenue | Legitimate interest (Art. 6(1)(f)) | 24 months |
| Account info (admins only — name, email, OAuth subject id) | Authenticate site editors | Contract (Art. 6(1)(b)) | Until the editor requests deletion |
| Server & security logs (IP, user-agent, request URL) | Detect abuse, prevent attacks, debug errors | Legitimate interest (Art. 6(1)(f)) | 90 days |
We do not place advertising cookies, use cross-site trackers, or build advertising profiles. We do not use Facebook Pixel, Google Ads, or similar retargeting technology.
5. International transfers
SmartPicks is operated from California, United States. If you access the Site from the European Economic Area, the United Kingdom, or Switzerland, your information will be transferred to and processed in the U.S. We rely on the European Commission’s Standard Contractual Clauses (2021/914) for any transfer that requires them, and we apply supplementary measures (TLS 1.2+ in transit, encryption at rest, and access controls) consistent with the EDPB Recommendations 01/2020.
6. Your rights
Depending on where you live, you may have some or all of the following rights regarding your personal information:
- Right to know / access what we hold about you
- Right to correct or update inaccurate information
- Right to delete (right to be forgotten)
- Right to a portable copy of your data
- Right to restrict or object to processing
- Right to withdraw consent (does not affect prior processing)
- Right to opt out of “sale” or “sharing” for cross-context behavioral advertising — we already do not engage in this
- Right to non-discrimination for exercising these rights
- Right to lodge a complaint with your local data protection authority (e.g. your EU DPA, the UK ICO, or the California Privacy Protection Agency)
To exercise any right, email [email protected] with the subject line “Privacy request.” We will respond within 30 days (45 days under CCPA/CPRA, extendable once if necessary). We may need to verify your identity before fulfilling requests; if we cannot verify you we will say so and explain why.
Authorized agents (California): you may designate an authorized agent to make a request on your behalf by providing them with written, signed permission and verifying your own identity directly with us.
7. Children's privacy
SmartPicks is not directed to children under 13. We do not knowingly collect personal information from children under 13 in the United States, or from anyone under 16 in the EEA/UK without parental consent. Our “Baby” product category is written for parents and caregivers, not for children. If you believe a child has provided us with personal information, please email [email protected] and we will delete it.
8. Security
We use TLS 1.2+ for all data in transit, encryption at rest for our database, the principle of least privilege for staff access, and periodic review of dependencies. No system is perfectly secure. If we experience a breach that affects your data we will notify you and the relevant supervisory authorities consistent with applicable law (within 72 hours under GDPR Art. 33).
9. Changes to this policy
We may update this policy as our practices evolve or as the law changes. The “Effective” date at the top of this page reflects the most recent revision. Material changes will be announced on the Site at least 30 days before they take effect, and emailed to active newsletter subscribers when the changes affect newsletter processing.
10. Contact
Cache Distribution, LLC (d/b/a SmartPicks)
1401 21st Street
Sacramento, CA 95811
United States
[email protected]