Privacy Policy

Effective: October 20, 2024

1. This privacy policy governs the manner in which Smart Starter Inc. its subsidiaries and affiliate companies (“Smart Starter”), collect, use, disclose and protect information collected from users of the www.smartstarter.ca website (“Site”). This Privacy Policy applies to the Site, and all products and services offered by Smart Starter (collectively, the “Services”). By using the Services, you accept the terms of this Privacy Policy, and hereby grant your consent for Smart Starter to collect, use, disclose and protect your information.

2. How we Collect Information

Smart Starter collects two types of information from users: information provided by users, and information collected automatically.

Information Provided by Users

Smart Starter collects information provided by users via the use of its Services. Examples of the data we collect include, but are not limited to:

Contact information: name, address, phone number, email address and other similar information.
: usernames, passwords and similar security information used to authenticate and provide access to user accounts.
Demographic information: age, birth date, gender, country of residence and other similar information.
User Communications: the contents of any user communication received by Smart Starter, including feedback, reviews, customer support inquiries and other similar information.
Payment Information: credit card information and other similar data necessary to process a payment made to purchase Services provided by Smart Starter.

Information Collected Automatically

Smart Starter collects some information automatically when users engage with its Services. Examples of the data automatically collected include, but are not limited to:

Device and Network information: the type of user device or browser used to engage with the Services, the device’s operating system, IP/MAC address, location, language, service provider and other similar information and device identifiers.
Service Use Information: the features used, the Services purchased, the time of browsing, web pages visited, and other similar information.
Location Information: data on a user’s location may be collected using the users IP address, GPS location, cell tower data and other similar information.
: Cookies are used to enhance user experience when using the Site and to track how users interact with the Site. Users may opt out of the use of cookies via their web browser settings; however, this may cause the Site to not function correctly. Smart Starter reserves the right to work with third parties to track, collect and analyze information collected via the use of cookies, and to combine this information with other information collected from users.

3. How We Use Information

The information collected by Smart Starter through the use of its Services will be retained only as long as necessary to fulfill the purpose for which it was collected. The information collected, including personal data, may be used for a legitimate purpose, including but not limited to:

To provide, update and maintain Services.
To personalize and enhance user experience.
To provide and improve customer service.
To communicate with users, including but not limited to communications regarding their transactions, promotion of Services and to request feedback.
To monitor and analyze trends, usage, and activities.
To prevent and address fraud, security issues, breach of policies or terms, and threats or harm.

4. How We Share and Disclose Information

Smart Starter may share user information in various circumstances, including but not limited to:

Service Providers: user information may be shared with third-party service providers who perform functions on our behalf and assist in delivering our Services.
Legal Compliance: user information may be shared to comply with applicable law or a legal obligation arising from a lawful request from a regulator, government, law enforcement or public authority.
Business Transfers: in the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction.

Smart Starter does not sell, trade, or rent a user’s personal identification information to third parties. Smart Starter reserves the right to share aggregated information that does not identify a user, or de-identified information about a user with third parties for any lawful purpose.

5. How We Protect Your Information

Smart Starter implements the appropriate security measures to protect your information from unauthorized access, alteration, disclosure, or destruction.

6. How To Consent

You hereby consent to the collection, use, disclosure, and protection of your information by Smart Starter, as set out in this Privacy Policy. You may withdraw or limit your consent at any time by contacting us at info@smartstarter.ca.

7. Third Party Websites

We may include content on our Site that links to third-party websites, or our Site may be linked by third-party websites. We do not control these third-party websites, have no responsibility for their contents or practices, and are not liable for their use. The collection of information by these third-party websites will be governed by their own privacy policies.

8. European Union Privacy Rights

If you are located in the European Union or if you access our Services from the European Union, the processing of your personal data is subject to the General Data Protection Regulation (“GDPR”). We are committed to complying with the GDPR's principles and requirements for the protection of personal data.

Legal Basis for Processing

Smart Starter may process your personal data based on one or more legal grounds, including:

You have provided explicit consent for the processing of your personal data for specific purposes.
Contractual Necessity: The processing is necessary for the performance of a contract between you and us, or for the implementation of pre-contractual measures.
Legal Obligations: The processing is necessary for compliance with a legal obligation to which we are subject.
Legitimate Interests: The processing is necessary for our legitimate interests or those of a third party, provided that your interests and fundamental rights do not override those interests.

Your Rights

Under the GDPR, you have certain rights regarding the processing of your personal data, including:

The right to access your personal data and receive a copy of the information we hold about you.
The right to rectify inaccurate or incomplete personal data.
The right to erasure of your personal data under certain circumstances.
The right to restrict processing when specific conditions are met.
The right to data portability, allowing you to receive your personal data in a structured, commonly used, and machine-readable format.
The right to object to the processing of your personal data for certain purposes, including direct marketing.

Data Transfers

If we transfer your personal data to countries outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place to protect your data, as required by the GDPR.

9. Contact Us

If you have any questions or wish to exercise your rights under the GDPR, please contact us at info@smartstarter.ca. We will respond to your request within one calendar month of the date of the request, if that is not possible, we will notify you of the delay within one calendar month and will respond within three calendar months of the date of request.

10. Age Limitation

Smart Starter does not allow use of our Services by individuals under the age of 18 years old. Smart Starter does not knowingly collect personal information from individuals under the age of 18 years old.

11. Changes To This Privacy Policy

Smart Starter may change this Privacy Policy at any time. Any changes will be posted on this page and will be effective immediately upon posting. We encourage users to review our Privacy Policy frequently to remain informed of any changes. Your continued use of our Services indicates consent to the Privacy Policy as posted on this page.

12. Contacting Smart Starter Inc.

If you have any questions about this Privacy Policy, Smart Starter’s practices, or if you are seeking to exercise any of your legal rights, you may contact us at info@smartstarter.ca.