To Our Clients:
Our clients’ privacy is important to us and maintaining our clients’ trust and confidence is one of our highest priorities. We respect our clients’ right to keep their data and personal information confidential and understand their desire to avoid unwanted solicitations.
All data privacy is addressed though customer contractual agreements. We only collect information about our clients when that information is provided by our clients or is obtained by us with their authorisation.
In accordance with the contractual agreements with our clients, we do not disclose business or personal information about our clients or former clients to anyone.
Confidentiality and Security of Non-public Personal Information
We restrict access to non-public business and personal information about our clients to employees of our firm. Our employees’ right to further disclose and use the information is limited by the policies of our firm, our Confidentiality and Non-Disclosure Agreements and applicable law. We also maintain physical, electronic, and procedural safeguards in compliance with applicable client contracts, laws and regulations to guard our clients’ business and personal information from unauthorised access, alteration, or premature destruction.
What personal information do we collect from the people that visit our website?
When visiting or registering on our site, as appropriate, you may be asked to enter your name, email address, phone number or other details to help you with your experience.
When do we collect information?
We collect information from you when you register on our site, subscribe to a newsletter, fill out a form or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, sign up for our newsletter, respond to a survey or marketing communication, visit the website, or use certain other site features in the following ways:
• To personalise user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To send periodic emails regarding our products and services.
How do we protect visitor information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Do we use ‘cookies’?
• Place and keep track of advertisements. Refer to the below mentioned Google Adwords and Remarketing section.
• Compile aggregate data about site traffic and site interactions to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you turn cookies off, some features will be disabled and some of our services may not function properly.
Third party disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information.
Third party links
We do not include or offer third party products or services on our website.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions.
To be in accordance with CANSPAM we agree to the following:
• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third party email marketing services for compliance, if one is used.
• Honour opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email.
Smartlock may use all of the features of Google Analytics for Display Advertisers. That includes obtaining specific visitor cookie data, such as the source, medium and keyword used to visit our website. Google Analytics does not store any visitor specific data and we will not use visitor specific data in any way related to Google Analytics, Google Adwords, and Remarketing.
Smartlock may use remarketing with Google Adwords and analytics to display content specific advertisements to visitors that have previously visited our site when those visitors go to other websites that have the Google Display Network implemented.
Smartlock and other third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitor’s past visits to our website.
We take our users’ privacy very seriously. We feel that certain personal information should always be kept private, so we’ve developed restrictions around the types of ads where we don’t allow remarketing. When creating remarketing lists, we can’t use any sensitive information about users. This includes information such as their financial status, sexual orientation, and other sensitive categories.
As adwords advertisers, we are restricted from and will not perform the following actions:
(a) Running ads that collect Personally Identifiable Information (PII) including, but not limited to, email addresses, telephone numbers, and credit card numbers
(b) Creating a remarketing list or creating ad text that specifically targets users in ways that are outlined as “prohibited” in the categories below
Visitors can opt out of Google Analytics for Display Advertisers and opt out of customized Google Display Network ads by visiting the Ads Preferences Manager.
User – a unique instance of a browser, application or similar technology.
User Cookie – the User identifier (of which a cookie is one example) associated with a User for remarketing or similar audiences.
Remarketing Lists – a list of User Cookies created or otherwise obtained by you and used in connection with remarketing or similar audiences.
Similar Audiences Lists – means a list of Users created by Google based on a Remarketing List for use in connection with similar audiences.
Properties – properties or content on which advertisements are shown.
Creation, Migration and Use of Remarketing Lists – You must have all rights necessary to create or otherwise obtain Remarketing Lists, migrate Remarketing Lists to, and use Remarketing Lists or Similar Audience Lists on the Properties. Google will not allow another advertiser to use your Remarketing Lists or Similar Audiences Lists without your consent.
Data, Selection and Targeting Restrictions – You may not (a) send to Google information or (b) use Remarketing Lists or Similar Audience Lists to select or target advertisements (i) based on past or current activity by Users on adult or gambling sites, government agency sites, or sites directed at children under the age of 13 years or (ii) based on other inferred or actual sensitive information (including without limitation, health or medical history or information, financial status or other detailed information pertaining to a person’s finances, racial or ethnic origins, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of any crime, political opinions or beliefs, trade union membership, or sexual behaviour or orientation).
PII Restrictions – You may not, for the purpose of serving Ads, transmit personally identifiable information including, but not limited to, email addresses, telephone numbers, and credit card numbers (“PII”) with the User Cookie without robust notice of, and the User’s prior affirmative (i.e., “opt-in”) consent.
Advertising Cookies Policy & Third Party Ad Serving – This conflicts your use of the User Cookie via Remarketing Lists and is subject to this Interest Based Advertising Policy and the Google Advertising Cookies Policy. Google’s use of Remarketing Lists is also subject to this Interest Based Advertising Policy and the Google Advertising Cookies Policy. If you’re using third-party ad serving in order to serve Interest-Based Advertisements, then you need to comply with both the Third-Party Ad Serving Policy and this Interest Based Advertising Policy. To the extent there is any conflict between this Interest Based Advertising Policy and either the Google Advertising Cookies Policy or the Third-Party Ad Serving Policy then you need to comply with the version of the conflicting provision in this Interest Based Advertising Policy.
DoubleClick Remarketing (formerly known as Doubleclick Boomerang) and other Remarketing List Services – You may not use a Remarketing List created via DoubleClick’s Remarketing or other Remarketing List services on the Properties unless the properties from which those User Cookies were compiled (i) properly disclose the data collection and usage contemplated by this Interest Based Advertising Policy and (ii) comply with the privacy and notice requirements of this Interest Based Advertising Policy.
Remarketing List Transparency – You grant to Google the right, should Google elect to do so, to display to any end user that is part of your Remarketing Lists that the User is on at least one of your Remarketing Lists, along with displaying your domain or display name.
In Ads Notice Labeling – Google may also, should Google elect to do so or should Customer request Google to do so, label advertisements served based on Remarketing Lists or Similar Audience Lists with notices or overlays intended to advise Users that the advertisements are based on Remarketing Lists or Similar Audience Lists, and you may not modify or obscure these labels.
Policies applicable to Advertisements based on Google-defined interest categories – In Ads Notice Labeling. Google may also, should Google elect to do so or should Customer request Google to do so, label advertisements served based on Google defined interest-categories with notices or overlays intended to advise Users that the advertisements are based on Google defined interest-categories, and you may not modify or obscure these labels.
We value the business and trust relationship with our clients and are committed to protecting their data privacy.