Welcome to Smartbilder Online Shopping Store !
PRIVACY POLICY
LAST UPDATED: May 29th, 2020
Individuals in the European Union (“EU”) should be
sure to read the important information provided below, in addition to the other
provisions in this Privacy Policy.
II. THE INFORMATION WE COLLECT ABOUT YOU
III. HOW IS YOUR PERSONAL INFORMATION COLLECTED
IV. THIRD-PARTY INTERACTIONS
V. THIRD-PARTY ANALYTICS PROVIDERS & AD
SERVERS; ONLINE TRACKING
VI. HOW WE USE YOUR PERSONAL INFORMATION
VII. DISCLOSURES OF YOUR PERSONAL INFORMATION
VIII. YOUR CHOICES
IX. DATA SECURITY
X. USERS OUTSIDE OF THE CANADA AND INTERNATIONAL
TRANSFERS
XI. QUESTIONS
XII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE
EUROPEAN UNION
I. IMPORTANT INFORMATION AND WHO WE ARE
A. APPLICATION OF THIS PRIVACY POLICY
This Privacy Policy applies to www.smartbilder.shop
and all other websites, features, or online services that are owned or
controlled by V-Plan Inc. and that post a link to this Privacy Policy
(collectively, the “Websites”), whether accessed via computer, mobile device,
or otherwise. Note, however, this Privacy Policy does not apply to the use of
unaffiliated websites that link to our Websites. Once you enter another website
(whether through an advertisement, service, or content link), be aware that we
are not responsible for the privacy practices of such other websites.
B. PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on
how V-Plan Inc. collects and uses your Personal Information through your use of
the Websites, including any information you may provide through the Websites
when you sign up for an account, sign up to receive information or
communications from us, purchase a product or service or request further
services or information from us.
It is important that you read this Privacy Policy
together with any other privacy notice or fair processing notice, we may provide
on specific occasions when we are collecting or using Personal Information
about you so that you are fully aware of how and why we are using your
information. This Privacy Policy supplements the other notices and is not
intended to override them.
C. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO
INFORM US OF CHANGES
This version was last updated on May 29th, 2020 and
historic versions can be obtained by contacting us. We reserve the right, at
any time and without notice, to add to, change, update or modify this Privacy
Policy, simply by posting such change, update or modification on the Websites.
Any such change, update or modification will be effective immediately upon posting
on the Websites. However, unless you consent, V-Plan Inc. will not use your
Personal Information in a manner materially different than what was stated in
our posted Privacy Policy at the time your Personal Information was collected.
Please check this Privacy Policy regularly to ensure you are aware of any
changes in our practices.
It is important that the Personal Information we
hold about you is accurate and current. Please keep us informed if your
Personal Information changes during your relationship with us. You are
responsible for maintaining the accuracy of the information you submit to us,
such as your contact information. If you contact us with changes, we will make
good faith efforts to make requested changes in our then-active databases as soon
as reasonably practicable. Note, however, that information may persist
internally for our administrative purposes and that residual data may remain on
backup media or for other reasons.
D. THIRD PARTY CONTENT, LINKS TO OTHER WEBSITES,
AND V-PLAN INC. CONTENT FOUND OUTSIDE THE WEBSITES
The Websites may include links to third-party
websites, plug-ins and applications and certain content on the Websites may be
hosted and served by third parties that V-Plan Inc. does not control. When you
click on a link to any other website or location, you will leave our Websites
and go to another site and another entity may collect Personal Information from
you. We have no control over, do not review, and cannot be responsible for,
these outside websites or their content. Please be aware that the terms of this
Privacy Policy does not apply to these outside websites, their privacy statements
or content, or to any collection of your Personal Information after you click
on links to such outside websites. We encourage you to read the privacy
policies of every website you visit. The links to third-party websites or
locations are for your convenience and do not signify our endorsement of such
third parties or their products, content or websites. In addition, V-Plan Inc.
content may be included on web pages and websites that are not associated with
V-Plan Inc. and over which we have no control. These third parties may collect
data through the use of their own cookies, pixel tags or other technology,
independently collect information or solicit Personal Information, and may have
the ability to track your use of their websites and services. V-Plan Inc. is
not responsible for the privacy practices or the content of any third party.
II. THE INFORMATION WE COLLECT ABOUT YOU
Personal Information or personal data means any
information about an individual from which that person can be identified. It
does not include information where the identity has been removed (anonymous
data). We and our third-party service providers may collect, use, store, and
transfer different kinds of Personal Information about you that we have grouped
together as follows:
●
IDENTITY INFORMATION includes name, username or similar identifier, title, date
of birth, and gender.
●
DEMOGRAPHIC INFORMATION includes zip code, age, and/or income.
●
CONTACT INFORMATION includes billing address, delivery address, email address
and telephone numbers.
●
FINANCIAL INFORMATION includes bank account and payment card details
(applicable if any payments were made).
●
TRANSACTION INFORMATION includes details about payments to and from you and
other details of services you have purchased from us (applicable if any
payments has been made).
●
TECHNICAL INFORMATION includes internet protocol (IP) address, your login data,
browser type and version, time zone setting and geographical location, browser
plug-in types and versions, operating system and platform and other technology
or other unique identifiers (a set of numbers or characters that is assigned to
your computer, mobile phone, or other devices when you are on the Internet)
(“Device Identifier”) for any computer, mobile phone, tablet or other device
(any of which are referred to herein as a “Device”) used to access the
Websites.
●
PROFILE INFORMATION includes your username and password, purchases or orders
made by you (applicable if any orders were made), your interests, preferences,
product feedback, and survey responses.
●
USAGE DATA includes information about how you use our Websites, products and
services, including all of the areas within our Websites that you visit or use
and the time of day you visited the Websites, among other information.
●
MARKETING AND COMMUNICATIONS INFORMATION includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
●
LOCATION INFORMATION includes information about your location using a variety
of technologies, such as GPS, IP address, and connected or nearby Wi-Fi
networks.
●
USER CONTENT INFORMATION includes text (including questions, comments, and
suggestions), pictures, audio, videos, or other content (collectively,
"User Content") you share by participating and posting content
publicly in reviews, interactive features, or other communication functionality
(“Community Features”).
We also collect, use and share AGGREGATED
INFORMATION such as statistical or demographic information for any purpose.
Aggregated Information may be derived from your Personal Information but is not
considered Personal Information in law as this information does not directly or
indirectly reveal your identity. For example, we may aggregate your Usage Data
to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Information with your Personal
Information so that it can directly or indirectly identify you, we treat the
combined information as Personal Information that will be used in accordance
with this Privacy Policy. We do not collect any SPECIAL CATEGORIES of Personal
Information about you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and genetic and
biometric data). Nor do we collect any information about criminal convictions and
offences.
III. HOW WE COLLECT YOUR PERSONAL INFORMATION
We use different methods to collect information
from and about you including through:
●
DIRECT INTERACTIONS. You may give us your Identity, Demographic, Contact,
Financial, Profile, or Marketing and Communications Information by filling in
forms or by corresponding with us by mail, phone, email, or otherwise. This
includes Personal Information you provide when you:
●
purchase our products or services;
●
create an account on our Websites;
●
subscribe to emails or newsletters;
●
request services or other information;
●
enter a competition, promotion or survey; or
●
give us feedback about products, services, or Websites.
●
AUTOMATED TECHNOLOGIES OR INTERACTIONS.
As you navigate through the Websites, we may
automatically collect Technical, Usage, and Location Information about your
equipment, browsing actions, and patterns. We collect this Personal Information
by using cookies, pixel tags, embedded scripts, and other similar technologies.
[We may also receive Technical Information about you if you visit other
websites employing our cookies.]
●
COOKIES - Cookies are small data files that a website sends to your Device
while you are viewing the website that is stored on the Device. Cookies can be
used for many purposes, including to monitor use of websites, to customize
content specific to your interests, to ensure that you do not see the same
advertisement repeatedly, to speed up your searches and purchases and to
recognize you when you return to our Websites and/or store your user name and
password so you do not have to re-enter it each time you visit the Websites.
You may refuse to accept cookies by activating the appropriate setting on your
browser. However, if you choose to disable cookies on your Device, some
features of the Websites or our content may not function properly.
●
PIXEL TAG – Pixel Tags (also referred to as clear GIFs, 1x1
GIFs Web beacons, or Web bugs) are small graphic images or other web
programming code that may be included on the Websites and in our e-mail
messages. In contrast to Cookies, which are stored on a user’s Device, Pixel
Tags are embedded invisibly in web pages. Pixel Tags may be invisible to you,
but any electronic image or other web programming code inserted into a web page
or e-mail can act as a pixel tag. Pixel Tags or similar technologies may be
used for a number of purposes, including, without limitation, to count visitors
to the Websites, to monitor how users navigate the Websites, to count how many
e-mails that were sent were actually opened or to count how many particular
articles or links were actually viewed.
●
EMBEDDED SCRIPTS - Embedded scripts are programming code designed to collect
information about your interactions with the Websites, such as the links you
click. The code is temporarily downloaded onto your Device from our web server
or a third-party service provider, and is active only while you are connected
to the Websites.
●
FLASH LSOS – When we post videos, third parties may use local
shared objects, known as “flash cookies,” to store your preferences for volume
control or to personalize certain video features. Flash Cookies are different
from browser Cookies because of the amount and type of data and how the data is
stored. Cookie management tools provided by your browser will not remove Flash
Cookies. To learn how to manage privacy and storage settings for Flash cookies,
please visit:
HTTP://WWW.MACROMEDIA.COM/SUPPORT/DOCUMENTATION/EN/FLASHPLAYER/HE
LP/SETTINGS_MANAGER07.HTML.
●
COMMUNITY FEATURES. The Websites may provide you the opportunity to participate
and post User Content publicly through reviews, surveys, interactive features,
or other communication functionality (“Community Features”). We may provide
functionality for you to submit or post User Content through Community
Features, by linking the Websites to a third-party service, or otherwise.
Please note that certain information, such as your name, may be publicly
displayed on the Websites along with your User Content. User Content consisting
of uploaded files may contain metadata, which may contain Personal Information
or other information about or relating to you. You may wish to remove metadata
from your files before transmitting such files to V-Plan Inc. . NOTE THAT
ANYTHING YOU POST THROUGH COMMUNITY FEATURES IS PUBLIC – OTHERS WILL HAVE
ACCESS TO YOUR USER CONTENT AND MAY USE IT OR SHARE IT WITH THIRD PARTIES. IF
YOU CHOOSE TO VOLUNTARILY DISCLOSE PERSONAL INFORMATION, THAT INFORMATION WILL
BE CONSIDERED PUBLIC INFORMATION AND THE PROTECTIONS OF THIS PRIVACY POLICY
WILL NOT APPLY. IF YOU SUBMIT USER CONTENT, IT MAY BE PUBLISHED ONLINE OR
OFFLINE AT ANY TIME. IN ADDITION, WE MAY USE YOUR USER CONTENT AND ANY EXCERPT
FROM YOUR USER CONTENT IN CONNECTION WITH OUR ADVERTISING, MARKETING, PUBLICITY
AND PROMOTIONAL ACTIVITIES.
●
THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES. We may receive Personal
Information about you from various third parties. For example, if you are on
another website and you opt-in to receive information from us, the other
website will forward your Contact Information and other information to us so
that we may contact you as requested. We also may supplement the information we
collect with outside records from third parties in order to provide you with
information, services or goods you have requested, to enhance our ability to
serve you and to tailor our content to you. We may combine the information we
receive from those other sources with information we collect through the
Websites. In those cases, we will apply this Privacy Policy to the combined
information. Examples of third-party sources include:
●
Technical Information from the following parties: ○ analytics providers; ○ advertising networks; and ○ search for information.
●
Contact, Financial and Transaction Information from providers of technical,
payment and delivery services.
●
Identity and Contact Information from publicly available sources.
●
INFORMATION PROVIDED FROM OTHER USERS. If you decide to invite a third party to
create an account and/or purchase our merchandise, we will collect the Identity
and Contact Information you provide (e.g., name and e-mail address) for you and
the third party in order to send a message to the third party and follow up
with the third party. We rely upon you to obtain whatever consents from the
third party that may be required by law to allow us to collect such information
and contact the third party as described in the foregoing sentence. You or the
third party may contact us at support@smartbilder.shop to request the removal
of this information from our database.
IV. THIRD PARTY INTERACTIONS
Certain functionality on the Websites may permit
interactions that you initiate between the Websites and a third party website
or service (“THIRD PARTY INTERACTIONS”). Examples of Third Party Interactions
may include technology that enables you to “like” or “share” content from the
Websites on or to other websites or services; to transmit content to the
Websites from your account on a third-party website or service; to otherwise
connect the Websites to a third-party website or service, such as through an
application programming interface (API) made available by V-Plan Inc. or a
third party; or for users to register for an account and login through social
networking sites such as Facebook and Google (each an “SNS”). By registering or
logging in through an SNS, you are allowing the Websites to access your
information and you are agreeing to the SNS’s Terms of Use and Privacy Policy
in your use of such services. We may receive information from the SNS to make
it easier for you to create an account with us. Any information that we collect
from your SNS account may depend on the privacy settings you have with that
SNS, so please consult the SNS’s privacy and data practices.
If you choose to use Third Party Interactions,
information you post or provide access to may be publicly displayed on the
Websites or by the provider of the Social Feature that you use. Similarly, if
you post information on a third-party platform that references the Websites
(e.g., by mentioning one of the Websites or using a hashtag associated with one
of the Websites in a tweet or status update), your post may be published on our
Websites in accordance with the terms of the third-party website or service.
Also, both V-Plan Inc. and the third party may have access to certain
information about you and your use of the Websites and the third-party website
or service. In addition, we may receive information about you in connection
with other users’ use of Third Party Interactions (e.g., we may learn that you
are a “friend” or “connection” of the third party or receive other information
about you that the other user enables us to receive). The information we
collect in connection with Third-Party Interactions is subject to this Privacy
Policy.
The information collected and stored by the third the party remains subject to the third party’s privacy practices, including whether
the third party continues to share information with us, the types of
information shared, and your choices with regard to what is visible to others
on that third-party website or service.
V. THIRD-PARTY ANALYTICS PROVIDERS & AD
SERVERS; ONLINE TRACKING
V-Plan Inc.
works with certain third parties (including network advertisers, ad agencies,
and analytics companies) to provide us with information regarding traffic on
the Websites, to serve advertisements, including our advertisements elsewhere
online, and to provide us with information regarding the use of the Websites
and the effectiveness of our advertisements.
These third parties may use Device Identifier and
Usage Data to compile reports on user activity. For example, if you clicked on
one of our advertisements that led you to one of the Websites, our service
provider(s) may be able to tell us which advertisement you clicked on and where
you were viewing the advertisement. These third parties may set and access
their own tracking technologies (including cookies, embedded scripts, and pixel
tags) and may otherwise collect or have access to your Device Identifier, Usage
Data and related information about you. Cookies and pixel tags, including those
set by third-party network advertisers, may be used to, among other things,
target advertisements, prevent you from seeing the same advertisements too many
times, conduct research regarding the usefulness of certain advertisements to
you, and assist in providing analytics. These third parties may also transfer
Device Identifier and Usage Data to other third parties where required to do so
by law, or where such third parties process analytics information on their
behalf. Each of these third party’s ability to use and share Device Identifier
and Usage Data is restricted by their respective Terms of Use and Privacy
Policy. By using our Websites, you consent to the processing of data about you
by these third parties in the manner and for the purposes set out above. For a
full list of third party analytics services, please contact us at
support@smartbilder.shop.
We may share Device Identifier and Usage Data about
visitors with third-party advertising companies, analytics providers and other
vendors for similar purposes. While we may use a variety of service providers
to perform advertising and analytics services, some of these companies maybe
members of the Network Advertising Initiative ("NAI”) or the Digital
Advertising Alliance ("DAA") Self-Regulatory Program for Online
Behavioral Advertising.
For additional information regarding targeted
advertising and the “opt-out” procedures of NAI members and DAA Self-Regulatory
Program participating companies, you may visit:
●
NAI Opt-Out Tool (for website users):
http://www.networkadvertising.org/managing/opt_out.asp
●
DAA Consumer Choice (for website users): http://www.aboutads.info/choices/
●
DAA AppChoices (for mobile app users): http://youradchoices.com/appchoices
Please note that opting out through these
mechanisms does not opt you out of being served advertising. You will continue
to receive generic ads while visiting the Websites and elsewhere online. Some
third parties may collect Personal Information about your online activities
over time and across different websites.
Your browser settings may allow you to
automatically transmit a “Do Not Track” signal to websites and online services
you visit. However, there is no consensus among industry participants as to
what “Do Not Track” means in this context. Like many websites and online
services, the Websites currently do not respond to or alter their practices
when they receive a “Do Not Track” signal from a visitor’s browser. To find out
more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
VI. HOW WE USE YOUR PERSONAL INFORMATION
We may use the information we collect about you,
including Personal Information and Usage Data:
● to
provide you with our products and services and related customer service;
● to
process your registration and account creation with the Websites, including
verifying your contact information is active and valid;
● to
identify you as a user in our system;
● to
provide you with information, products or services that you have requested or
agreed to receive;
● to
provide improved administration of our Websites and services;
●
(if applicable) to process transactions you initiate, process payments and
provide accurate billing and shipping;
●
(if applicable) to send you administrative e-mail notifications, such as order
confirmations, order status updates, security, or support and maintenance
advisories;
●
(if applicable) to bill you for V-Plan Inc. products or services;
●
respond to your inquiries related to employment opportunities or other
requests;
●
send newsletters, surveys, offers, and other promotional materials related to
our services and for other marketing purposes of V-Plan Inc.;
● to
market our products/ services, including recommending products / services that
might be of interest to you;
● to
improve our Websites, product and service offerings;
● to
present our Websites and its contents in a suitable and effective manner for
you and for your computer;
● to
customize and tailor your experience on the Websites, for example, by
displaying content that we think you might be interested in;
● to
improve the quality of experience when you interact with our Site and Services
for internal business purposes.
●
for compliance fraud prevention and safety, including enforcing our terms of
service and this Privacy Policy, protecting our rights privacy, safety, or
property and/or that of you or others, and protecting against, investigating or
deterring fraudulent, harmful, unauthorized, unethical or illegal activity;
● to
carry out our obligations and enforce our rights arising from any contracts
entered into between you and us.
● to
notify you about changes to our service.
● to
comply with applicable laws, lawful requests, and legal process, such as to
respond to subpoenas or requests from government authorities.
● to
contact you with regard to your use of the Websites and, in our discretion,
changes to the Websites policies or functionality; and
● to
perform other functions as described at the time of collection, with your
consent, or as further described in this Privacy Policy. In addition to the
above, we may use anonymous data to analyze request and usage patterns so that
we may enhance the content of our services and improve navigation on the Websites.
We reserve the right to use anonymous data for any purpose and disclose
anonymous data to third parties in our sole discretion.
A.EMAIL COMMUNICATIONS
We may use your Identity, Contact, Technical, Usage
and Profile Information to form a view on what we think you may want or need,
or what may be of interest to you. This is how we decide which products,
services and offers may be relevant for you.You will receive newsletters or
marketing communications from us if you have requested information from, purchased
goods or services from us, or if you provided us with your details when you
entered a competition or registered for a promotion and, in each case, you have
consented receiving marketing communications at that time.
B.COOKIES
A cookie is a data file containing an identifier (a
string of letters and numbers) that is sent by a web server to a web browser
and is stored by the browser. The identifier is then sent back to the server
each time the browser requests a page from the server. Cookies may be either “persistent”
cookies or “session” cookies: a persistent cookie will be stored by a web
browser and will remain valid until its set expiry date, unless deleted by the
user before the expiry date; a session cookie, on the other hand, will expire
at the end of the user session, when the web browser is closed. Cookies do not
typically contain any information that personally identifies a user, but
Personal Information that we store about you may be linked to the information
stored in and obtained from cookies.
We may use both session cookies and persistent
cookies to provide you with a more personal and interactive experience on our
Site. This type of information is collected to make the Websites more useful to
you and to tailor the experience with us to meet your special interests and
needs.
Most browsers allow you to refuse to accept cookies
and to delete cookies. The methods for doing so vary from browser to browser,
and from version to version. You can however obtain information about blocking
and deleting cookies for some commonly used browsers via the links below:
●
CHROME: https://support.google.com/chrome/answer/95647?hl=en;
●
EDGE:
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;
●
FIREFOX: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
●
INTERNET EXPLORER:
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
●
OPERA: http://www.opera.com/help/tutorials/security/cookies/; and
●
SAFARI: https://support.apple.com/kb/PH21411.
Please note that blocking all cookies will have a
negative impact upon the usability of many websites and if you choose to block
cookies, you may not be able to use all the features on our Websites.
VII. DISCLOSURES OF YOUR PERSONAL INFORMATION
We may share non-personally identifiable
information, such as aggregated user statistics, in our discretion and without
restriction. We may disclose the information we have collected about you,
including Personal Information, as disclosed at the time you provide your
information, with your consent, as described in this Privacy Policy, or in the
following circumstances:
A. INTERNAL THIRD PARTIES
V-Plan Inc.
may, and reserves the right to, share your information with any other company
that is not presently, but becomes, a V-Plan Inc. parent, subsidiary, or
affiliate. You may be presented with an opportunity to receive information
and/or marketing offers from V-Plan Inc. and our affiliated businesses,
partners and agents. If you agree at that time to receive such communications,
your Personal Information will be disclosed to that third party (or parties).
For more information, please refer to the Marketing Communications section.
B. EXTERNAL THIRD PARTIES
Third Party Service Providers
We may share personal information with third party
service providers in connection with the performance of services to, or on
behalf of, V-Plan Inc. and the Websites, including to conduct quality assurance
testing; to facilitate creation of accounts; to provide technical support;
and/or to provide other services to V-Plan Inc.. You acknowledge and agree that
your use of the Websites may include having your Personal Information
transferred to and stored by our web hosting company pursuant to their privacy
policy.
We may also share Information when we work with
businesses, partners or agents to develop a direct relationship with you or in
connection with the Referral Program.
These service providers may store or use your
information outside of the EU or United States.
Administrative & Legal Reasons
We may transfer and disclose information, including
Personal Information, to third parties:
● to
comply with a valid legal inquiry, investigation, or process such as a search
warrant, subpoena, statute or court order, or if in our opinion such disclosure
is required by law;
● to
obtain or maintain insurance coverage, manage risks, obtain professional
advice, or establish, exercise or defend legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
● to
protect the safety, interests, rights, property or security of V-Plan Inc.,
you, or any third party; this may include exchanging information with other
companies and organizations for the purposes of fraud protection and credit
risk reduction;
● to
respond to a breach or attempted breach of the security of our Websites;
● to
defend or assert our legal rights pursuant to any of the Websites’
Terms of Use, any policies applicable to the Websites, or any other agreement
you may have with V-Plan Inc.;
or
● at
the request of governmental authorities conducting an investigation.
We may also use Technical Information to identify
users, and may do so in cooperation with copyright owners, Internet service
providers, wireless service providers, or law enforcement agencies in our
discretion.
Social Networking Sites
As set forth in Section IV, our Websites and
services enable you to post content to SNSs. If you choose to do this, we will
provide information to such SNSs in accordance with your elections. You
acknowledge and agree that you are solely responsible for your use of those
websites and that it is your responsibility to review the terms of use and
privacy policy of the applicable SNS. We will not be responsible or liable for:
(i) the availability or accuracy of such SNSs; (ii) the content, products or
services on or availability of such SNSs; or (iii) your use of any such SNSs.
Community Features
As set forth in Section III, our Websites and
services enable you to post User Content through Community Features. If you
choose to use these features, you will be identified by your first name and
last initial. Please note that any Personal Information you include on a public
area of the Site will be publicly viewable. Once displayed publicly, that information
can be collected and used by others. We cannot control who reads your postings
or what other users may do with the information that you voluntarily post, so
it is very important that you do not put data such as private contact
information that you do not want to make available to the public in your posts.
Once you have posted information publicly, while you will still be able to edit
and delete it on the Site, you will not be able to edit or delete such
information cached, collected, and stored elsewhere by others (e.g., search
engines).
We require all third parties to respect the
security of your Personal Information and to provide the same level of privacy
protection as required by this Privacy Policy.
C. SHARING BETWEEN V-PLAN INC. COMPANIES; BUSINESS
TRANSFERS
V-Plan Inc. may also disclose and transfer your
Personal Information: (i) to a subsequent owner, co-owner or operator of the
Websites or applicable database, or of our products or services; (ii) if V-Plan
Inc. (or any of its affiliated, parent, or subsidiary companies) assigns its
rights regarding any of your information to a third party; or (iii) in
connection with or during negotiation of a corporate merger, financing
consolidation, restructuring, the acquisition or dissolution transaction or proceeding
involving sale, transfer, divestiture, or disclosure of all or a portion of our
business or assets including, without limitation, during the course of any due
diligence process. In the event of an insolvency, bankruptcy, or receivership,
Personal Information may also be transferred as a business asset. If another
company acquires our company, business, or assets, that company will possess
the Personal information collected by us and will assume the rights and
obligations regarding your Personal information as described in this Privacy
Policy. These transfers and disclosures may be carried out without notice to
you.
VIII. YOUR CHOICES
You have several choices regarding the use of
information on our Websites and services:
A. ACCESSING, UPDATING, CORRECTING OR DELETING
INFORMATION
You can review, request access to, update, correct
or delete your Personal Information by contacting us at
support@smartbilder.shop.
You may request deletion of your Personal
information by contacting us and we will use commercially reasonable efforts to
honor your request, but please note that we may be required to keep such
information and not delete it (or to keep this information for a certain time,
in which case we will comply with your deletion request only after we have
fulfilled such requirements). When we delete any information, it will be
deleted from the active database, but may remain in our archives. We may also
retain information for fraud prevention or similar purposes. Also, note that we
may need to delete your user account in order to delete your Personal
Information.
You are responsible for maintaining the accuracy of
the information you submit to us, such as your contact information. If you
contact us with changes, we will make good faith efforts to make requested
changes in our then-active databases as soon as reasonably practicable. Note,
however, that information may persist internally for our administrative
purposes and that residual data may remain on backup media or for other
reasons.
B. OPTING OUT
We will only send you direct marketing emails or
other similar communications if you opt-in to receive such emails. In the
future, if you do not wish to have your e-mail address or other contact
information used for promotional purposes, you may indicate a preference to
stop receiving further communications from us and can “opt-out” by following
the unsubscribe instructions provided in the e-mail you receive or by
contacting us directly (please see contact information in Section A above).
Where you opt out of receiving these marketing messages, this will not apply to
Personal Information provided to us as a result of the purchase of any service
or other transaction and we may send you service related communications,
including notices of any updates to our Terms of Use or Privacy Policy.
C. CHOOSING NOT TO SHARE PERSONAL INFORMATION
You may choose not to provide us with any Personal
Information. In such an event, you may still be able to access and use some of
the Websites; however, you may not be able to access and use those portions of
the Websites that require your Personal Information. You may opt out of
receiving marketing e-mails by following the opt-out instructions above or
provided to you in those e-mails. Please note that we reserve the right to send
you certain communications relating to your account or use of any of the
Websites (for example, administrative and service announcements, shipping
notices, and order confirmations) and these transactional account messages may
be unaffected if you opt-out from marketing communications.
Where we need to collect Personal Information by
law, or under the terms of a contract we have with you and you fail to provide
that information when requested, we may not be able to perform the contract we
have or are trying to enter into with you (for example, to provide you with
goods or services). In this case, we may have to cancel a product or service
you have with us but we will notify you if this is the case at the time.
D. MARKETING COMMUNICATIONS
We strive to provide you with choices regarding
certain Personal Information uses, particularly around marketing and
advertising. You can opt-out of such communications as outlined in Section B,
above Please note that you may continue to receive service-related and other
non-marketing communications.
E. DE-LINKING THIRD PARTY INTERACTIONS AND SNS
As set forth in Section IV, our Websites and
services enable you to interact with or post content to certain third parties
and SNSs. If you would like to discontinue these interactions and connections,
please refer to the privacy settings of the third party or SNS to determine how
you may adjust our permissions and manage the interactivity between the
Services and your social media account.
IX. DATA SECURITY
V-Plan Inc. uses commercially reasonable security
measures to safeguard the Personal Information we collect from loss, misuse and
unauthorized access, disclosure, alteration and destruction. However, please
note that no system can be completely secure and V-Plan Inc. does not ensure or
warrant the security of any information we collect. You use our Websites and
provide us with your information at your own risk.
We have put in place procedures to deal with any
suspected Personal Information breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
X. USERS OUTSIDE OF THE CANADA AND INTERNATIONAL
TRANSFERS
The Websites are hosted and operated in the Canada
and third party service providers and partners operate in the Canada and other
jurisdictions. If you are located outside of the Canada, please be aware that
any information you provide to us may be transferred to and processed in the
Canada and other countries. By using the Websites, or providing us with any
information, you acknowledge and consent to this transfer, processing and
storage of your information in countries where the privacy laws may be less
stringent than those in the country where you reside or are a citizen.
XI. QUESTIONS
If you have any questions or concerns regarding our
privacy policy or practices, please feel free to contact us via email at
support@smartbilder.shop.
XII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE
EUROPEAN UNION
A. PERSONAL INFORMATION
References to “Personal Information” in this
Privacy Policy are equivalent to “Personal Data” governed by European data
protection legislation.
B. LEGAL BASES FOR PROCESSING PERSONAL DATA
We will only use your personal data when the law
allows us to do so. Most commonly, we will use your Personal Information in the
following circumstances:
●
Where we need to perform obligations relating to a contract to which you are a
party or to take steps at your request before entering into such a contract.
●
Where it is necessary for our legitimate interests (or those of a third party)
and your interests and fundamental rights do not override those interests. Our
legitimate interests include those related to conducting and managing our
business to enable us to give you the best service/product and the best and
most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process
your Personal Information for our legitimate interests. We do not use your
Personal Information for activities where our interests are overridden by the
impact on you (unless we have your consent or are otherwise required or
permitted to by law). You can obtain further information about how we assess
our legitimate interests against any potential impact on you in respect of specific
activities by contacting us.
●
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal
basis for processing your Personal Information other than in relation to
sending marketing communications to you via email. You have the right to
withdraw consent to marketing at any time by contacting us using the contact
information provided above.
We have set out below, in a table format, a
description of the ways we plan to use your personal data, and which of the
legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate. Note that we may process your personal data
for more than one lawful ground depending on the specific purpose for which we
are using your data. Please contact us if you need details about the specific
legal ground we are relying on to process your personal data.
C. CONTROLLER
This Privacy Policy is issued on behalf of
support@smartbilder.shop.
If you have any questions about this Privacy
Policy, including any requests to exercise your legal rights, please contact us
using the details set out below.
D. DATA RETENTION
We will only retain your personal data for as long
as necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for
personal data, we consider the amount, nature, and sensitivity of the personal
data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether
we can achieve those purposes through other means, and the applicable legal
requirements.
In some circumstances, you can ask us to delete
your data: see the Request Erasure subsection below for further information.
In some circumstances we may anonymise your
personal data (so that it can no longer be associated with you) for research or
statistical purposes in which case we may use this information indefinitely
without further notice to you.
E. CHANGE OF PURPOSE
We will only use your personal data for the
purposes for which we collected it, unless we reasonably consider that we need
to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us. If we need
to use your personal data for an unrelated purpose, we will notify you and we
will explain the legal basis that allows us to do so.
Please note that we may process your personal data
without your knowledge or consent, in compliance with the above rules, where
this is required or permitted by law.
F. EU RESIDENT PERSONAL DATA RIGHTS
Under certain circumstances, EU Residents may have
rights under data protection laws in relation to your personal data as outlined
below:
●
REQUEST ACCESS to your personal data (commonly known as a “data
subject access request”). This enables you to receive a copy of the
personal data we hold about you and to check that we are lawfully processing
it.
●
REQUEST CORRECTION of the personal data that we hold about you. This enables
you to have any incomplete or inaccurate data we hold about you corrected,
though we may need to verify the accuracy of the new data you provide to us.
●
REQUEST ERASURE of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for
specific legal reasons that will be notified to you, if applicable, at the time
of your request.
●
OBJECT TO PROCESSING of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation that makes you want to object to processing on this ground
as you feel it affects your fundamental rights and freedoms. You also have the
right to object where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling legitimate
grounds to process your information that override your rights and freedoms.
●
REQUEST RESTRICTION OF PROCESSING of your personal data. This enables you to
ask us to suspend the processing of your personal data in the following
scenarios: (a) if you want us to establish the data’s accuracy; (b) where our
use of the data is unlawful but you do not want us to erase it; (c) where you
need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to our use
of your data but we need to verify whether we have overriding legitimate grounds
to use it.
●
REQUEST THE TRANSFER of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.
●
WITHDRAW CONSENT at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing
carried out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out
above, please contact support@smartbilder.shop
No Fee Usually Required
You will not have to pay a fee to access your
personal data (or to exercise any of the other rights). However, we may charge
a reasonable fee if your request is clearly unfounded, repetitive, or
excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
What We May Need from You
We may need to request specific information from
you to help us confirm your identity and ensure your right to access your
personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further information
in relation to your request to speed up our response.
Time Limit To Respond
We try to respond to all legitimate requests within
one month. Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.
Complaints to Supervisory Authority
EU Residents may have the right to make a complaint
at any time to the supervisory authority for data protection issues. However,
we would appreciate the chance to deal with your concerns before you approach
the supervisory authority so please first contact us directly to allow us to do
so.
