Effective Date: July 1st, 2018
Website Privacy Notice
Simply Digital Technologies Inc. (“Simply Digital”) takes privacy and data security seriously. We are committed to transparency in the collection and use of your personal information. The Privacy Notice below describes how we use personal information, and the circumstances under which we may share this information. This Privacy Notice applies to the privacy practices of Simply Digital on its trademarked CoinSmart website located at http://www.coinsmart.com/ (the “CoinSmart Website”).
Collection and Use of Personal Information
- Account Creation:
We collect your name, date of birth, email address, mailing address, geographic location, phone number, and a username and password that you select to create an account with us. We use this information to administer your account.
You may also have the option to sign in from your Facebook or Google account. If you chose to sign in from your Facebook or Google account, you may authorize us to collect certain information from that social media account (e.g., name, username, email address, profile picture, gender, friend or contact list, or other information you make public on your social media profile). You may be able to control what information you provide us with in the preferences or settings of your social media account. We may use this information to personalize your experience on the websites.
- Account Verification
To verify your account, we collect a photograph of you along with your passport or driver’s license, as well as a recent bill or piece of mail that confirms your current address. We collect this information to verify your identity and to satisfy know-your-client and other industry compliance obligations,
- Social Media:
We may offer you the opportunity to engage with Simply Digital or its content on or through third-party social networking websites, plug-ins and applications. When you engage with us on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture) to deliver content or as part of the operation of the CoinSmart Website, plug-in or application.
- Payment Information:
If you make a purchase on the CoinSmart Website, we collect your payment-card details (including payment card number, security code, expiration date, cardholder name and billing address) for the purposes of processing your payment.
- Cryptocurrency Transactions:
When you engage in cryptocurrency transactions through the CoinSmart Website, we collect transaction information on the purchase or sale of digital currencies, or other transaction-based information that you generate or that is connected to your account.
- Marketing Communications:
You may select if you wish to receive email marketing communications with updates and other information regarding Simply Digital by providing us with your name and email.
You can opt out of receiving marketing emails from us using the opt-out or “unsubscribe” instructions provided in the communication. Alternatively, you may contact our Privacy Officer at email@example.com
In connection with a job application or related inquiry, you may provide us with personal information including a resume, cover letter, or similar employment-related materials. This information will be used for the purpose of processing and responding to your application for current and future career opportunities.
- Contact Us:
When you contact us with a comment or question, we collect the information you provide such as your name, phone number and email address, along with additional information that we may need to help us promptly respond to your inquiry. We retain this information to assist you in the future and to improve our customer service and service offerings. We also use personal information to establish and manage our relationship with you and provide quality service.
Information We Collect Automatically
We and our third party service providers, including Google Analytics and FullStory, collect, process, store and analyze information obtained from your browser when you visit our CoinSmart Website, including IP address, device identifiers, browser characteristics, operating system details, language preferences, referring URLs, length of visits, and pages viewed geographic location, time spent on pages, scrolling, mouse movements, and links clicked. We use “cookies” or other tools that track, measure and analyze the behaviors and usage patterns of visitors to the CoinSmart Website. We use this information to help us understand how visitors engage with the CoinSmart Website and to improve our visitors’ experience.
You can obtain additional information on Google Analytics’ collection and processing of data and data privacy and security , including how to learn more about opting out of Google Analytics’ data collection.
FullStory stores some of this information to create user session replays. You can obtain additional information on FullStory’s collection and processing of data , including how to learn more about opting out of FullStory’s data collection.
Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, the CoinSmart website is not designed to respond to “Do Not Track” signals received from browsers. You can learn more about “Do Not Track” signals here .
Sharing of Personal Information
Except as set forth in this Privacy Notice and as required or permitted by law, we do not sell or share your personal information with third parties without your consent.
Your personal information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. We use third parties to host and manage the CoinSmart Website, to verify your identity and your identification documents, to create user session replays, and to handle payment processing. Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes.
Your personal information may be maintained and processed by us, our affiliates and other third party service providers in the US or other jurisdictions. In the event that personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.
Legal and Compliance
We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.
Sale of Business
Personal information may be provided to third parties in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Simply Digital or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Safeguarding and Retention of Personal Information
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.
Access to Personal Information
You have the right to access, update and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in other personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
Third Party Websites
The CoinSmart Website may contain links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our service and go to another site. During this process, another entity may collect personal information from you.
Updates to the Privacy Notice
We may update this Privacy Notice to reflect changes to our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices.
Simply Digital welcomes your comments and questions regarding this Privacy Notice and the use of your personal information. If you have questions or concerns please contact our Privacy Officer: firstname.lastname@example.org