Purpose of the Policy

7098693 Canada Inc. o/a Smarter IT Services (“Smarter IT” or “we”) may collect personal information in the course of its activities. Smarter IT is committed to ensuring compliance with the Canada Personal Information Protection and Electronic Documents Act (“PIPEDA”) and all other applicable privacy legislation.

The purpose of this Privacy Policy is to establish rules that govern the collection, use, disclosure, and retention of personal information by Smarter IT in a manner that recognizes the need to balance an individual’s right of privacy with respect to personal information and Smarter IT’s need to collect, use, and/or disclose that information in order to fulfill its purposes.

This Policy is expected to change as the body of knowledge in this area grows and as the environment within which Smarter IT operates evolves. Smarter IT will post and explain any changes to this Privacy Policy as soon as they go into effect.

By providing us with your Personal Information, you are consenting to the collection, use, disclosure, and retention, by us, of your Personal Information, as set out in this Policy.

Scope

All employees, directors, officers, representatives, consultants, contractors, agents, and other persons who act or provide services on behalf of Smarter IT shall be subject to this Policy.

Definitions

Personal Information – Personal information is any factual or subjective information, recorded or not, about an identifiable person (e.g. age, name, address, income, phone number, etc.). Personal information does not include the name, title, or business address or telephone number of an employee of an organization.

Policy

While browsing our websites, you do not need to provide any information about yourself. However, if you choose to provide Personal Information to us, we will take the necessary steps to safeguard it to the furthest extent possible.

Smarter IT is committed to ensuring that all personal information gathered by Smarter IT is kept confidential and is treated in a manner that a reasonable person would consider appropriate in the circumstances.

All personal information under the control or custody of Smarter IT shall be regarded as confidential and available only to authorized users. Subject to specific limitations and exceptions, individuals (or their legal representatives) may access their own personal information contained in records under the custody or control of Smarter IT following the process outline in this Policy.

Smarter IT’s websites were not designed and are not directed to children eighteen (18) years of age or younger. Committed to protecting children’s privacy in an on-line environment, we do not intentionally collect or maintain Personal Information provided by children.

The following are Smarter IT’s key privacy principles, codified as Schedule 1 of PIPEDA:

  1. Accountability for Personal Information

Smarter IT shall be responsible for the personal information in its custody or control, including information that has been transferred to a third party for processing. Smarter IT shall use contractual or other means to ensure the protection of any information in the possession of a third party. Smarter IT’s employees and agents shall be responsible for any personal information that they have in their possession at all times.

Smarter IT has a Privacy Officer that is committed to ensuring Smarter IT’s compliance with PIPEDA.

  1. Identifying Purposes for Collecting Personal Information

Smarter IT shall collect your personal information for the purpose of providing our services or fulfilling any other legal obligations owing by us (such as the transfer of purchased goods) to you.

When personal information is required to be collected from an individual, Smarter IT will identify and document the purpose for which it is being collected, will explain how it will be used, and will obtain the individual’s consent to collect, use, and disclose it. Smarter IT will use reasonable efforts to ensure that the individual reasonably understands how the information will be used and disclosed.

If personal information that has been collected is required to be used for a different purpose than originally disclosed, the new purpose will be identified to the relevant individual prior to use. Unless the new purpose is required or permitted by law, such individual’s consent will be obtained before the information is used for that new purpose.

  1. Consent for Collection, Use, and Disclosure of Personal Information

Consent is required for the collection of personal information and the use and disclosure of such information. Smarter IT shall seek consent for the use and disclosure of personal information either prior to or at the time of collection.

In determining the form of consent to collect, use, or disclose personal information (implied/express, verbal/written), Smarter IT will take into account the sensitivity of the information and applicable legal requirements. Regardless of the form of consent given, Smarter IT will ensure that the consent is knowledgeable, voluntary, related to the information in question, and given by the relevant individual.

Consent may be withdrawn at any time, subject to legal restrictions and reasonable notice. If an individual would like to withdraw his/her consent to Smarter IT’s use of his/her personal information, such individual can do so by emailing support@smarterit.ca. A withdrawal of consent will not apply to a collection, use, or disclosure that had occurred prior to receiving the notice of withdrawal.

  1. Limiting Collection of Personal Information

The collection, use, and disclosure of personal information will be limited to that which is necessary to fulfill the purposes identified.

  1. Limiting Use, Disclosure, and Retention of Personal Information

Smarter IT will only use personal information for the purposes for which consent has been given.

Smarter IT may provide personal information to other parties:

  • when consent to do so has been provided; and/or
  • when Smarter IT is required or permitted to do so by law.

Personal information will be kept until the stated purpose is complete and the relevant individual has exhausted any legal recourse regarding an access request. At such time, or at the end of the legislatively required retention period, whichever is longer, the personal information will be disposed of by means of shredding or another secure disposal method, with care taken to prevent unauthorized parties from gaining access to the information.

  1. Ensuring Accuracy

While Smarter IT will use reasonable efforts to ensure that an individual’s personal information is as accurate, complete, and up-to-date as necessary for the purposes for which Smarter IT uses the information, ultimately, an individual will be responsible for ensuring that Smarter IT has his/her current and complete personal information in Smarter IT’s records. Smarter IT will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.

  1. Use of Safeguards to Protect Information

Smarter IT will use appropriate procedures and security measures to protect personal information in its custody or control against theft, loss, and unauthorized use, disclosure, modification, or disposal, regardless of the format in which the information is held.

The personal information collected by Smarter IT may be shared, stored, or accessed in Canada or in other countries where Smarter IT maintains an office, conducts business, and/or has internet facilities.

If personal information is stolen, lost, or accessed by an unauthorized person, Smarter IT will notify the relevant individual(s) and/or other third parties (such as the Privacy Commissioner) at the first reasonable opportunity, if required to do so by applicable law.

Smarter IT does not sell, rent, or lease personal information to third parties.

  1. Openness About Privacy Policy

This Privacy Policy will be available www.smarterit.ca/privacy

  1. Individual Access to Personal Information

Upon written request, and proof of identification, Smarter IT will inform an individual whether or not it holds personal information about the individual. Smarter IT will allow the individual to access this information in accordance with applicable legislation. Certain situations will prevent Smarter IT from providing access to personal information, including for legal, confidentiality, or security reasons; in such situations, Smarter IT will give a written notice to the individual that states that the request for access is being refused, provides reasons for the refusal, and informs the individual that he/she is entitled to make a complaint about the refusal to the Office of the Privacy Commissioner of Canada. Smarter IT will respond to a request for access within thirty (30) calendar days of receipt of the request, unless extensions are permitted under law and Smarter IT has informed the individual of the length and reason for the extension.

If an individual informs Smarter IT about the inaccuracy or incompleteness of his/her personal information, Smarter IT will respond to the correction request, with the amendments, within thirty (30) days of receiving the request, unless extensions are permitted under law and Smarter IT has informed the individual of the length and reason for the extension.

In certain circumstances, Smarter IT will not correct a record of personal information, if prohibited from doing so under law. If a correction is refused, Smarter IT will inform the individual of the refusal, the reasons for the refusal, the individual’s right to file a complaint regarding the refusal to the Office of the Privacy Commissioner of Canada, and the right of the individual to attach a statement of disagreement to Smarter IT’s records (so that any other organization that has access to the Information can view the statement).

  1. Challenging Compliance

Smarter IT’s Privacy Officer can be contacted at:

Burke Rutherford
282 Fralicks Beach Road
Port Perry, Ontario L9L1B6
289-222-8882

Smarter IT’s Privacy Officer is available to answer any questions an individual may have about Smarter IT’s collection, use, disclosure, and retention of personal information, or to register a complaint. An individual whose personal information is held by Smarter IT has several other avenues of recourse, including registering a complaint with the Office of the Privacy Commissioner of Canada. Smarter IT is committed to investigating all complaints and taking appropriate action.

  1. Websites

The following Smarter IT websites will be governed by this Privacy Policy:

Smarterit.ca, email.smarterit.ca, www.smarterit.ca

Smarter IT does not guarantee, and is not responsible for, the information collection and privacy practices of any third-party websites to which Smarter IT’s websites may link.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.