SmartersWeb Privacy Policy

1 Privacy Accountability

SmartersWeb designates a privacy contact responsible for privacy compliance and inquiries.

SmartersWeb maintains privacy practices and a process for addressing privacy questions and complaints.

2 Information We May Collect

Depending on the relationship, information may include name, email, phone, business/organization, job title, website/domain, inquiry details, project communications, approvals, invoices, transaction references, support tickets, meeting notes, technical requirements, IP address, server/security logs, browser/device information, DNS/hosting records, analytics configuration and account-access information.

Where payment is processed through an external processor, SmartersWeb may receive transaction status and references without receiving the complete payment-card number.

3 Why We Use Information

SmartersWeb may use information to answer inquiries, prepare proposals, deliver services, authenticate access, provide support, investigate incidents, operate hosting/domains, administer accounts, process transactions, prevent fraud, maintain security, measure website/service performance, manage advertising, keep business records, comply with law and establish/exercise/defend legal rights.

4 Consent & Appropriate Use

Where consent is required, SmartersWeb seeks consent appropriate to the purpose, context and sensitivity of the information. Some processing is reasonably necessary to answer a request or perform a contracted service.

Optional marketing, analytics and advertising activity may involve additional choices. Consent may be withdrawn where legally permitted, subject to contractual, operational or legal consequences.

5 Service Providers & International Processing

SmartersWeb may use hosting, domain, analytics, advertising, email, security, backup, payment, scheduling, communications and professional-service providers. Some providers operate systems outside Canada. Information processed outside Canada may be subject to the laws of the jurisdiction where it is processed.

6 Google Services & Advertising Technology

SmartersWeb may use or configure Google Analytics, Google Tag Manager, Google Ads, Search Console, reCAPTCHA and related Google services. Depending on configuration and consent, these services may process website interaction, campaign, device/browser, approximate-location, conversion and attribution information.

Where enhanced conversions or other customer-data features are enabled for a Client, those features require Client authorization and appropriate rights/consent where required.

7 Cookies, Tags & Consent

Cookies and similar technologies are described in the Cookie Policy. Google Tag Manager may be used to deploy tags but does not itself replace consent. Where required, non-essential tags are configured to respond to an applicable consent mechanism.

8 Data Retention

SmartersWeb retains information only as long as reasonably needed for operational, contractual, accounting/tax, security, dispute or legal purposes. Retention varies by record type and system.

• Client/project records may be retained while needed to administer the relationship and document work.
• Financial records may be retained for applicable accounting/tax periods.
• Security and server logs are retained for an operationally appropriate period based on system needs.
• Credentials should be retained only while reasonably necessary.
• Analytics data follows the applicable property/product configuration rather than a universal fixed period.

Information may be held longer where reasonably required for litigation, a security investigation, legal hold or statutory obligation.

9 Security

SmartersWeb uses reasonable safeguards appropriate to the information and service, which may include HTTPS/TLS, access restrictions, strong authentication, multifactor authentication where available, firewalls, logging, backups, malware controls, security updates, rate limits and restricted administrative access.

No Internet-connected system can be guaranteed completely secure.

10 Privacy & Security Incidents

If SmartersWeb becomes aware of an incident affecting personal information, it will assess what happened, the information involved, affected individuals where identifiable, risks created, containment/remediation and any notification/reporting duties required by applicable law.

11 Access, Correction & Deletion Requests

Subject to applicable law, an individual may request access to personal information held by SmartersWeb and correction of inaccurate information. Identity verification may be required.

Deletion may be requested, but some information may need to be retained for accounting, contractual, security, fraud-prevention, dispute or other lawful purposes.

12 Marketing Communications

SmartersWeb may send service communications needed for an inquiry or client relationship. Promotional electronic messages are sent only where permitted by applicable law and should include required sender identification/contact information and an unsubscribe mechanism.

Unsubscribing from marketing does not prevent necessary transactional, security or service messages.

13 Children

SmartersWeb's commercial services are not directed to children. SmartersWeb does not knowingly create ordinary commercial service accounts for minors without appropriate authorization where required.

14 Changes & Complaints

This Policy may be updated as services, technology or legal obligations change. Material changes are reflected by the updated date and communicated where required.

Privacy concerns should be directed to the privacy contact above. SmartersWeb will review the concern and respond in accordance with applicable requirements.