Smorgads Market Tech Inc. - Personal Information Protection Policy

Updated April 2015

This is the Privacy Policy of the Smorgads website (the "Site"), operated by Smorgads Market tech Inc. and our related products and services. It describes the information that we collect from you as part of the normal operation of our Site, and how we use and disclose this information.

At Smorgads Market Tech Inc., we are committed to providing our customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers, protecting their personal information is one of our highest priorities.

While we have always respected our customers' privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Canada's Personal Information Protection And Electronic Documents Act (PIPEDA). PIPEDA, which came into effect on January 1, 2004, sets out the ground rules for how Canadian businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPEDA, outlines the principles and practices we will follow in protecting customers' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers' personal information and allowing our customers to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to Smorgads Market Tech Inc.. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Smorgads Market Tech Inc.

Definitions

Personal Information - means information about an identifiable individual (including real name and mailing address). Personal information does not include contact information (described below).

Contact information - means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPEDA.

Privacy Officer - means the individual designated responsibility for ensuring that Smorgads Market tech Inc. complies with this policy and PIPA.

By accepting the Privacy Policy in registration or by visiting and using the Site, you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms Of Use.

How We Use Your Information

We use personal information in the file we maintain about you, and other information we obtain from your current and past activities on the Site, to provide to you the services offered by the Site; resolve service and billing disputes; troubleshoot problems; bill any amounts due from you; measure consumer interest in our products and services, inform you about online and offline offers, products, services, events and updates; deliver information to you that, in some cases, is relevant to your interests, such as product news; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Terms Of Use; provide you with system or administrative messages, and as otherwise described to you at the time of collection. On occasion we use email address or other contact information to contact our customers to ask them for their input on our services and to forward to them media opportunities.

We may also use personal information about you to improve our marketing and promotional efforts, to analyze Site usage, to improve our content and product offerings, and to customize the Site's content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.

If you wish to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe in the email. If you wish to no longer receive our newsletters you may update the settings in your account, follow the instructions located in the email, or you may contact us at info@smorgads.com.

What Information Do We Collect

Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose.

In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. Once you become a User, we require you to provide various contact and identity information, billing information, and other personal information as indicated on the relevant forms on the Site (which vary, depending on what kind of User you are), and you are no longer anonymous to us. Where possible, on these forms we indicate which fields are required and which fields are optional.

You always have the option to not provide information by choosing not to become a User or by not using the particular feature of the Site for which the information is being collected.

We also automatically track certain information about you based upon your behaviour on our Site and store it through log files. We use this information to do internal research on our users' demographics, interests, and behaviour to better understand, protect and serve you and our community. This information may include the URL that you just came from, which URL you next go, your computer browser information, and your IP address. We may provide Customers' IP addresses to payment intermediaries in the course of the payment process.

Technologies such as: cookies, beacons, tags and scripts are used by Smorgads Market Tech Inc. and our partners (e.g., advertising, marketing and analytics), affiliates, or other service providers. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to remember users' settings, store login addresses, authenticate users, run website experiments, and store analytics data. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use Local Storage Objects (LSOs) such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Policy 1 - Collecting Personal Information

  • 1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
  • 1.2 We will only collect customer information that is necessary to fulfill the following purposes:
    • To verify identity;
    • To verify creditworthiness;
    • To identify customer preferences;
    • To understand the marketing needs of our customers;
    • To open and manage an account;
    • To deliver requested products and services;
    • To process a subscription;
    • To enrol the client in a program;
    • To ensure a high standard of service to our customers;
    • To meet regulatory requirements;

Policy 2 - Consent

  • 2.1 We will obtain customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
  • 2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
  • 2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the customer does not opt-out.
  • 2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers can withhold or withdraw their consent for Smorgads Market Tech Inc. to use their personal information in certain ways. A customer's decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer in making the decision.
  • 2.5 During the course if a transaction you will may well be given access to another customer's information. You may not release this information to a third party with the customer's written consents and rights and as laid out in our Terms of Use. You must also recognize that the indemnity you gave us in the Terms of Use applies to any non-compliance by you with the foregoing.
  • 2.6 We may collect, use or disclose personal information without the customer's knowledge or consent in the following limited circumstances:
    • When the collection, use or disclosure of personal information is permitted or required by law;
    • In an emergency that threatens an individual's life, health, or personal security;
    • When the personal information is available from a public source (e.g., a telephone directory);
    • When we require legal advice from a lawyer;
    • For the purposes of collecting a debt;
    • To protect ourselves from fraud;
    • To investigate an anticipated breach of an agreement or a contravention of law;

Policy 3 - Using and Disclosing Personal Information

  • 3.1 We will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
    • To conduct client, customer, member surveys in order to enhance the provision of our services;
    • To contact our customers directly about products and services that may be of interest;
  • 3.2 We will not use or disclose customer personal information for any additional purpose unless we obtain consent to do so.
  • 3.3 We will not sell customer lists or personal information to other parties.
  • 3.4 We do not collect or store credit card or other payment method information. In all cases our payment processors have the sole and complete responsibility for the storage of credit card and payment information.
  • 3.5 If you post on our forum or blog your username and other information you include is displayed in your postings or comments, and is therefore available to the public. If you disclose personal information in any posting in our forum or blog and wish to have it removed, you can submit a request to info@smorgads.com. Our blog commenting system is also managed by a third party application that may require you to register to post a comment. You will need to contact or login into the third party application if you want the personal information that was posted to the comments section removed. To learn how the third party application uses your information, please review their privacy policy.

Policy 4 - Retaining Personal Information

  • 4.1 If we use customer personal information to make a decision that directly affects the customer we will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it.
  • 4.2 Subject to policy 4.1, we will retain customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 - Ensuring Accuracy of Personal Information

  • 5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.
  • 5.2 Customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information should be forwarded to the Privacy Officer at info@smorgads.com.
  • 5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customer's correction request in the file.

Policy 6 - Securing Personal Information

  • 6.1 We are committed to ensuring the security of customers personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
  • 6.2 The following security measures will be followed to ensure that customer personal information is appropriately protected:
    • The use of user IDs
    • Passwords
    • Encryption
    • Firewalls
    • Restricting employee access to personal information as appropriate
    • Contractually requiring any service providers to provide comparable security measures
  • 6.3 We will use appropriate security measures when destroying customers' personal information such as shredding documents and deleting electronically stored information. However, the complexity and nature of this business means that we are obligated to keep a record of transactions and appropriate documentation that is consistent with accepted accounting principles.
  • 6.4. When a customer choses to close an account we will remove their information from our marketing and billing system.
  • 6.5 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 - Providing Customers Access to Personal Information

  • 7.1 Customers have a right to access their personal information, subject to limited exceptions such as solicitor-client privilege.
  • 7.2 If you are unable to change any personal information by logging in a request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to correct personal information should be forwarded to the Privacy Officer at info@smorgads.com.
  • 7.3 Upon request, we will also tell customers how we use their personal information and to whom it has been disclosed if applicable.
  • 7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
  • 7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer of the cost and request further direction from the customer on whether or not we should proceed with the request.
  • 7.6 If a request is refused in full or in part, we will notify the customer in writing, providing the reasons for refusal and the recourse available to the customer.

Policy 8 - Data Retention

  • 8.1 We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Policy 9 - Questions and Complaints: The Role of the Privacy Officer or designated individual

  • 9.1 The Privacy Officer or designated individual is responsible for ensuring Smorgads Market Tech Inc.'s compliance with this policy and PIPEDA.
  • 9.2 Customers should direct any complaints, concerns or questions regarding Smorgads Market tech Inc.'s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of Ontario.

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact information for Smorgads Market Tech Inc.'s Privacy Officer or designated individual is:
Smorgads Market Tech Inc.
100 Front St. East, Suite 400, Toronto, ON M5A 1E1
Email: info@smorgads.com