Last modified September 2017
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 “Website”), Smooth Commerce Apps and White Label Apps, 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.
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. 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 Apps or White Label Apps.
What Information We Collect
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
- 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 App or White Label App or the computer or
mobile device you use to access our website provided your device settings allow us to collect this information.
- Device and browsing information, including information about your phone, tablet, computer, or device,
and online browsing activity (collectively, “automatically collected information”). Automatically collected
information may include IP addresses, unique device identifiers, cookie identifiers, device and browser settings
and information, and Internet service provider information, the date and time that you accessed our service, the
website that referred you to our website or Apps, the web pages you requested, the date and time of those
web beacons and similar technologies.
How we collect information
We collect information on our website, through our mobile application, from you and from third parties. For
example, we collect and obtain information:
You provide, when you register for an App, make a purchase, contact us, participate in a contest or
sweepstakes, or sign up for emails or marketing;
From Wi-Fi and mobile devices, such as information about your device and location if you have installed
an App on your device and your device is near a Merchant location, even if you are not currently using the
mobile application, though 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, Twitter or Google+. We may also collect information about you from other companies and
organizations. 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.
Using cookies and automatic collection methods. For example, we and 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 use include:
—cookies (which 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);
—web beacons or tags (small images embedded into websites or emails 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);
—website and mobile application log files (which we tend to create automatically in connection with access
to and use of our website and mobile application);
—Flash cookies or Local Stored Objects (which may be placed using Adobe Flash software — learn more about
privacy and storage settings for Flash cookies here); and
—other technologies (which may be similar to or different than the methods noted above).
How We Use Information
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, 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.
How We Share Information
In general, we do not share personal information about you with third parties for third party marketing or
advertising purposes. We do share personal information with third parties for other 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;
- Social media platforms and networks such as Facebook, Twitter, Pinterest, and Instagram that offer
functionalities, plugins, widgets, or tools in connection with our website or mobile Apps. If you choose to use
these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those
social media companies—for more information about what information is shared or collected, and how it is used,
- 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.
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 firstname.lastname@example.org
How we protect your information
Smooth Commerce protects your information 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 website 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.
Updates to This Policy
We may make changes to this Policy, and may apply any changes to information previously collected, as
permitted by law. When we make material changes to this Policy, we will notify you by posting the updated Policy
on our website, and we will update the effective date at the end of this Policy.
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 email@example.com or write to us at Smooth Commerce, #600-36 King Street East, Toronto ON M5C1E5.