LAST MODIFIED JULY 2022
The following Privacy Statement (“Statement”) outlines the manner in which Smooth Commerce collects, uses, discloses and otherwise manages personal information, including in connection with our website www.smooth.tech (the “Site”), Smooth Commerce Mobile Applications and White Label Applications (“Mobile Application[s]”), related Services, and any other websites owned and operated by Smooth Commerce that direct the viewer or user to this Statement. This Statement does not apply to websites and services that are owned and operated by third parties.
In this Policy, “we” and “our” mean SmoothPay, Inc. and its related subsidiaries and affiliated companies, and “you” means any person who visits our website or registers for and/or uses one of our Mobile Application(s) including our White Label Applications.
HOW WE COLLECT INFORMATION
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site or Mobile Applications, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. We collect Device Information on our website, through our Mobile Applications, from you and from “Third Parties”. For example, we collect and obtain information using the following technologies:
- Using cookies and automatic collection methods. For example, we and the Third Parties we work with may collect information from the computer, tablet, phone, or other device: that you install our Mobile Application on; that you use to access our website; or that you use to open an email or click on an advertisement from us. This collection includes automatically collected information, and generally does not include personal information unless you provide it through our Mobile Application or website or you choose to share it with us. Methods we may use include:
- “Cookies” – data files that are placed on your device or computer and often include an anonymous unique identifier. These may be session-based or persistent, and are typically small data files that are stored on your hard drive or in connection with your Internet browser. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org;
- “Web beacons,” “tags,” and “pixels” – electronic files embedded into websites or emails used to record information, that send information about your computer, tablet, phone, or other device when you visit our website, use or mobile application, or open an email we send to you;
- “Log files” – track actions occurring on the Site and Mobile Applications, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps;
- Flash cookies or Local Stored Objects – these may be placed using Adobe Flash software;
- And other technologies which may be similar to or different than the methods noted above.
- You provide, when you register for a Mobile Application, make a purchase(s), contact us, participate in a contest or sweepstakes, sign up for emails or other forms of electronic or traditional marketing, sales and business activities;
- From Wi-Fi and mobile devices, such as information about your device and location if you have installed a Mobile Application on your device and your device is near a Merchant location, even if you are not currently using the mobile application. You can disable location sharing using your device or application settings;
- From other sources, such as publicly available information you submit to a blog, a chat room, or a social network like Facebook, LinkedIn, Instagram, Twitter, Google or others. We may also collect information about you from other companies, organizations and offline sources. By gathering additional information about you, we can correct inaccurate information and give you product recommendations and special offers that are more likely to interest you.
WHAT INFORMATION WE COLLECT
By “Personal information”, we mean information that directly identifies you or by which we can identify you, such as your name, address, or email address. We collect a variety of types of information. Examples include:
- Contact information, such as your name, address, phone number, or email address;
- Purchase information, we may collect information about the products you buy, including where you buy products, and the rewards earned due to a purchase.
- Preference information, such as your contact and marketing preferences, and brand and merchandise interests;
- Profile and account information, including your first and last name, username, password, email address, postal address, phone number, payment information, birthday, city of birth, demographics information, and any other information you choose to give us when using our Services.
- Location information of your device that you use with our Mobile Applications or the computer or mobile device you use to access our website provided your device settings allow us to collect this information.
HOW WE USE INFORMATION
We use information that we collect generally to fulfill any tasks associated with our Site or Mobile Applications. Examples of how we use information include:
- To process your purchases of products and services;
- To communicate with you about orders, purchases, services, accounts, programs, contests, promotions and sweepstakes;
- To respond to your customer service inquiries and requests for information;
- To post your comments or statements on our websites;
- To send you personalized promotions and special offers;
- To inform you about brands, products, events, or other promotional purposes;
- To maintain and improve our sites and the products and services we offer;
- To detect, prevent, or investigate security breaches or fraud; and
- To maintain appropriate records for internal administrative purposes.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site and Mobile Applications (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above, however we do not share personal information about you with third parties for third party marketing or advertising purposes. For example, we share personal information with:
- Service providers that provide products or services to us, that help us market or advertise to you (including co-branded marketing and advertising), or that provide products or services to you. We may use third parties or service providers to perform any of the actions or activities allowed under this Policy;
- Parties to business transactions such as those we deal with in mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third party; and
- Additional third parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law, such as for the legal and safety purposes described under the “How We Use Information” Section above, or otherwise to help prevent harm or fraud to us, you, our customers, or other third parties. We also may share personal information with third parties upon your request or with your approval, though we may not be able to accommodate all requests.
- We also use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
PROMOTIONAL COMMUNICATIONS CHOICES
You can opt out of receiving promotional emails, text messages, telephone calls, and mailings by informing us of your preference at the time you sign up for an account, modifying your promotional preferences in your account’s profile management section, or adjusting your text and notification preferences in your mobile device’s settings or by following the opt-out instructions in the promotional emails we send you.
Alternatively, you may let us know that you do not wish to receive some or all of these promotional communications by emailing us at email@example.com.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by visiting the following:
- FACEBOOK – https://www.facebook.com/settings/?tab=ads
- GOOGLE – https://www.google.com/settings/ads/anonymous
- BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make a submission through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
HOW WE PROTECT YOUR INFORMATION
We protect your information by using technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. Some of our safeguards include firewalls, data encryption, physical access controls, and administrative informational controls. When you transmit highly sensitive information (such as a credit card number) through our Site or in one of our Mobile Applications, we encrypt the transmission of that information using the Secure Sockets Layer (SSL) protocol. While we have employed security technologies and procedures to assist safeguarding your personal information, no system or network can be guaranteed to be 100% secure.
We welcome your questions, comments and concerns about privacy. You may use this form to ask us a privacy question or correct personal information found in your profile, Mobile Application, or digital property. You can also contact us by email at firstname.lastname@example.org or write to us at Smooth Commerce, 100 University Ave, 5th Floor, Toronto, ON M5J 1V6.