Your Privacy Is Important to Us.
Who is Smartway?
What is personal information?
Personal information is information about an identifiable individual. Personal information includes your name, address, age, income, date of birth, gender, financial information and credit records, as well as your opinions, preferences and purchase patterns. We collect different categories of personal information depending on how you interact with us.
Types of personal information we collect:
• Information You Give Us: You may provide us with information through your request for services and the use of our products or services. This includes, but is not limited to information you provide through our mobile applications or the purchase and use of any products or services we offer. We may receive and store any information you provide. Certain products, such as smart devices, may also collect personal information. You can choose not to provide certain information to us, but then you might not be able to take advantage of all of our products or services.
• Information Collected Automatically By Our Websites or Apps: We automatically collect and store certain types of information about your use of our websites and apps, including information about your interaction with content and services. We may use "cookies" or other unique identifiers to collect this information.
• Information from Other Sources: We may receive information from third parties who provide us with services, such as security or fraud prevention services and identity verification service providers.
1. We are accountable to you
2. Why we collect your personal information
Smartway identifies the purpose for which your personal information is collected. We do this before or at the time the information is being collected. We may collect, use and disclose your personal information in order to:
• process and administer your payment for the purchase of products or services,
• process your application for a product, provide a service,
• better understand your product and services needs and to offer relevant information, products, services, and programs to meet those needs, including sending you (and others on your behalf) communications by way of postal mail, e-mail, facsimile, telephone, text message, or other type of electronic message;
• support business purposes and programs for you and other customers;
• solicit feedback to provide product insights including to other customers, product reviews, improve our products and services, and generate content for our website;
• determine your interest and eligibility for, and where appropriate provide you with, products, services, and programs;
• administer the delivery, return or exchange of products, services, and programs to you;
• track and analyze your purchases, other transactions, shopping patterns, account activity, and payment history for marketing analysis purposes or tailoring promotional offers to you;
• track and analyze website use to provide a better customer experience such as customized offers and advertisements;
• conduct surveys and analysis for research, statistical purposes (information will be de-identified to the extent possible);
• verify your identity and protect against error and fraud;
• manage and assess our risk;
• assess and update your credit-worthiness on an ongoing basis;
• process, service, analyze and audit your relationship with us, including collecting any money you owe us;
• support promotions and contest administration;
• perform tests to implement or modify systems;
• comply with applicable legal, regulatory and self-regulatory requirements;
• process and respond to your application for employment;
• respond to your questions, comments or requests to customer service; and
• achieve other purposes as may, from time to time, be permitted or required by law.
We may also collect contact information about your friends and family members when you participate in one of our refer-a-friend programs. In these instances, we may send a message to your friend or family member on your behalf. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the
message from you.By providing your information to Smartway, you consent to Smartway using your personal information for the purposes outlined above.
Withdrawal of consent to collect, use and disclose your personal information may restrict our ability to provide you with some products and services, such as the privileges and opportunities of being a member of a Loyalty Program.
3. We obtain your consent to collect, use or disclose your personal information
Smartway obtains your consent to collect, use or disclose your personal information, except as otherwise permitted by law. The method of obtaining consent may depend on the circumstances and the sensitivity of the information. Consent may be oral or written, express or implied. Your express consent (verbal, written or electronic agreement) is generally obtained to collect, use or disclose sensitive personal information.
Benefits you receive through consent
Smartway is a growing network of interrelated businesses offering a unique mix of products and services. We want to give you exceptional customer service and additional value which is facilitated by sharing your information within Smartway and across our various businesses. This sharing enables us to better understand our customers, notify current and new customers of products, services, rewards and special offers they might enjoy. We may also provide your personal information to Smartway affiliates or other third-party marketing partners (“Marketing Partners”), including under a Loyalty Program, so that they can notify you directly of products, services, rewards and special offers that may be of interest to you. These notices may be given to you by postal mail, e-mail, facsimile, telephone, text message or other form of electronic message using the contact information that you provide to us.
“Opting-out” or withdrawing your consent
If you decide that you do not want to receive marketing offers for products and services, you may always withdraw or refuse your consent by clicking on the unsubscribe link in our email communications or by contacting us as set out in Section 10 below. Your request will be promptly processed but may not be in time to remove you from promotions already in progress. Please note that even if you have opted out of receiving marketing communications, we may still contact you for purposes of administering your account and sending you transactional or operational messages.
The consequences of withdrawing or refusing consent
If you decide to withdraw or refuse your consent, our ability to communicate with you may be diminished. For example, we will generally not be able to tell you about price discounts, rewards, customized balance transfer offers, contests, or other products and services that may be of value to you.
5. We limit use, disclosure and retention of your personal information
Smartway uses and discloses your personal information for the purposes for which it was collected, except with your consent or as otherwise required or permitted by applicable law. We do not sell or rent personal information. We may transfer your personal information to entities outside Smartway, such as our vendors, suppliers and agents (“Service Provider”) who require the information in order to perform a service for us. When your personal information is transferred to a Service Provider, we require them to
In the event that Smartway, any of its affiliated companies, brands or substantially all of their assets are acquired by an unrelated third party, your personal information may be one of the transferred assets. By providing your personal information to us, you agree that we may disclose your personal information, on a confidential basis, to any prospective transferee and its professional advisors for the purposes of their due diligence investigations, the completion of any such transaction and the continued operation of the acquired business.
Smartway, and our Service Providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian or other law. We may also disclose personal information where necessary for the establishment,
exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
6. We keep your personal information accurate
We want to keep your personal information up-to-date, accurate and relevant for its intended use. We rely on you to let us know if your address, telephone number or other information you provide us changes, so that we may provide you with the best possible service.
7. How we protect your personal information
The security of your personal information is important to us. We have implemented appropriate technical, physical and administrative safeguards and security measures designed to protect your personal information. All of our Service Providers are required under their contracts with us to maintain your confidentiality and may not use your information for any unauthorized purpose. When we are required by law to provide information, we take reasonable steps to verify the lawful authority for the collection and we disclose only the information that is legally required. We review our procedures and security measures regularly to ensure that they are properly administered and remain effective and appropriate for the sensitivity of the information.
8. We are open about our privacy practices
We are committed to providing you with understandable and easily available information about our policies and practices related to management of your personal information.
9. You can access your personal information stored by us
You have the right to access, update and correct inaccuracies in your personal information in our custody or control. To access your personal information, a request must be submitted in writing to us (see Contact Information below). We will respond to your request for access or information in a reasonable time. There may be times when we are unable to fulfill your request - for example, if
providing access to your personal information would reveal confidential commercial or proprietary information or personal information about someone else (and we are unable to separate your data), or if we are prohibited by law from disclosing the information. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their
personal information records.
10. We respond to your questions, concerns and complaints about privacy
Smartway responds in a reasonable time to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures. We will investigate and respond to any concern you have regarding the handling of your personal information. In most cases, an issue can be resolved simply by telling us about it and discussing any issues.
You may contact us:
• by e-mail at firstname.lastname@example.org
• by mail at 2891 Sideroad 10, Bradford ON L3Z 2K8 - Re: Privacy Inquiries