1 Collecting information on the Website
1.1 Master data
When you create a profile on the Website, we collect the following master data: Your username, your password and your email address. The purpose of the collection of this information is to identify you as user when you log on to the Website.
When you make a review of a company, we collect the information you state in the review, including which company you review, which purchase(s) the review concerns, and how you evaluate the company.
1.4 IP adresses and browser settings.
When visiting the Website, the IP address and the browser settings of your computer are registered. The IP address is the numerical address of the computer used when visiting the Website. Browser settings are e.g. the type of browser you use, browser language, timezone etc. The IP address and browser settings are registered to enable Smarter.loans to trace the used computer in case of misuse or unlawful actions in connection with the visit on or use of the Website. Further, the IP address is used to derive your approximate location (city level).
If you sign up for Smarter.loans’s newsletters, Smarter.loans register the information supplied by you (e.g. your name, email address etc.). If you no longer wish to receive newsletters from Smarter.loans, you can unsubscribe by clicking the “unsubscribe” button inside the email.
1.6 Information from other services, including Social Network(s)
As part of our services, we provide you with the possibility of connecting your profile on the Website with your profile on social networks such as Facebook, Google+, LinkedIn and Twitter (“Social Network(s)”). Some information about you will automatically be collected from Social Networks when connecting your Smarter.loans profile with your profile on Social Networks.
The information collected from Social Networks depends on what information you have made available on the network and your privacy settings for sharing such information on the network. Depending on the settings, we may e.g. collect the following information about you:
- Name and/or username
- E-mail address
- Date of birth
- Profile photo
When you request to have your Smarter.loans profile connected to a profile on a Social Network, you will be informed on which information we will collect from the network in question before your request is executed.
The purpose of collecting information from Social Networks is to connect members of your network, which are both users of Smarter.loans and of one or more of the Social Networks, and thereby both increase the confidence in the reviews made by the members of the network as well as create a better user experience on the Website.
Smarter.loans does not collect other personal identifiable information from visitors of the Website, unless the visitor provides the information to us.
2 Disclosure of personal data
2.1 Sharing of Personal Data
Smarter Loans provides a service of connecting people looking for financing with reputable lending companies in Canada. We collect, use and disclose personal information to enable us to manage and develop our service and operations, for example, we may collect, use or disclose your personal information as we:
- establish and maintain our relationship with you (for example, we may send you updates, newsletters, special offers or account statements);
- comply with applicable law or regulatory requirements (for example, we may collect personal information to satisfy the obligations imposed on us by various regulatory agencies);
- comply with your requests (for example, if you advise us of a preferred telephone number at which to be contacted, we will use this information to contact you at that number); and
- protect ourselves against error, fraud and theft (for example, by using your information to verify your identity)
When you provide your personal information through the Smarter Loans website, you are consenting, acknowledging and agreeing to the disclosure of your personal information with potential providers of loans (or different services, dependent on your request)
By entering your e-mail address and other contact details in your online application and by clicking the privacy checkbox in the application form, you consent to Smarter Loans or any of our 3rd– party partners, contacting you by phone, mail, text message or e-mail to:
- send you promotional offers, including third party offers;
- assist you in completing your online application;
- confirm and verify your personal information and identity.
2.2 Disclosure of data on the Website
Please note that your consent to these guidelines implies that your profile on the Website may not be anonymous.
When you create a profile on the Website, your username will be available for other users of the Website.
Other information provided by you on the Website, including photos and reviews, are automatically made available for other users of the Website. In some instances, the companies you review will also receive information about your review.
If you connect to a Social Network, information such as your profile photo, your name, year of birth and approximate location will be collected from your profile on the Social Network and used to identify you on the Website. Consequently, all users of the Website will, subject to information available from the Social Network, be able to identify the reviews created by you.
If your contacts or your contact’s contacts (jointly referred to as “Connections”) on the Social Network also have connected with Smarter.loans, we may display on the Website how you are connected to these Connections through the Social Network.
2.3 Disclosure on services to which you connect your profile
If you choose to connect your Smarter.loans profile with profiles on a Social Network information and reviews provided by you on the Website or data compiled by us about your use of the services on the Website (e.g. number of reviews) will be shared with and displayed in connection with your profile on the Social Network.
2.4 Disclosure to other services
A main purpose of Smarter.loans is to increase the exposure and the availability of the reviews made on the Website. Hence, we permit other services to show the reviews created on the Website thus increasing other consumers’ knowledge of your reviews.
The categories of third parties to which the information is disclosed are:
- Search engines, including e.g. Google and Bing,
- Operators of consumer portals and business portals, including price comparison websites, shopping guides etc.
- Companies or services that have been reviewed on the Website or which have a relationship with Smarter.loans
- Operators of other similar websites or services where, in Smarter.loans’s assessment, it will be relevant for the consumer to search for reviews.
Your review is disclosed as you make it available on the Website, which entails a disclosure of the following information:
- Your reviews
- Your username and demographics such as age and gender.
- Your approximate city location
2.5 Other disclosure
Smarter.loans may be required to disclose information by a court order from a competent court of law or public authority in accordance with the existing legislation.
3 Data controller
3.1 The information for which Smarter.loans is the data controller
Smarter.loans shall be data controller of the master data you enter in connection with your creation of a profile or registration for newsletters, i.e. your name, your password and your email address, as well as registration of your IP address..
3.2 The information for which you are the data controller
You shall be data controller of the content you choose to disclose on the Website and for the data disclosed on your profile on Social Networks, which is the consequence of the connection of your profile on the Website with your profile on the Social Network.
3.3 Links to websites
The Website contains links to other websites. Note that by clicking such links you will be transferred to other websites for which Smarter.loans is not the data controller. We thus recommend that you always read the personal data policy of these websites, as their procedure for collecting and processing personal data may be different from ours.
4 Data processor
Smarter.loans uses an external company for maintaining the technical operation of the Website. This company is the data processor with regards to the personal data for which Smarter.loans is the data controller.
By accepting this personal data policy, you accept that Smarter.loans also allows the data for which you are the data controller be processed by the same data processor.
The data processor shall solely act according to instructions from Smarter.loans. By accepting these terms and conditions, you authorize Smarter.loans to give such instructions to the data processor which are necessary for the processing of data in accordance with this personal data policy and for the purpose of use of the Website.
The data processor has made necessary technical and organizational safety measures against the information being accidentally or illegally destroyed, lost or deteriorated, and against the information coming to the knowledge of unauthorized persons, is misused or in other ways is processed in violation with the act on processing of personal data. On your request – and against remuneration of the data processor’s current hourly rates at any time for such work – the data processor shall supply you with sufficient information to demonstrate that the above-mentioned technical and organizational safety measures have been made.
5 Security measures
Smarter.loans will use commercially reasonable efforts to see that the recorded data, including the personal information, under its control is handled using appropriate security measures. Smarter.loans regularly audits its system for possible vulnerabilities and attacks. However, since the internet is not a 100% secure environment, Smarter.loans cannot ensure or warrant the security of information you transmit to Smarter.loans. Emails sent via the Website are not encrypted, and Smarter.loans therefore advises you not to communicate any confidential information through these means.
6.1 What is a cookie are similar technologies?
Cookies are small information units which the Website places on your computer’s hard disk, on your tablet or on your smartphone. Cookies contain information that the Website uses to make the communication between you and your web browser more efficient. The cookie does not identify you as an individual user but identifies your computer. There are two types of cookies – session cookies and persistent cookies. Session cookies are temporary bits of information which are deleted when you exit your web browser. Persistent cookies are more permanent bits of information that are stored and remain on your computer until they are deleted. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website.
The Website uses session cookies and persistent cookies.
We use similar technologies for storing and accessing information in the browser or device which utilizes local units and local storage, such as HTML 5 cookies, Flash and other methods. These technologies can operate across all your browsers. In some cases, the use of these technologies cannot be controlled by the browser, but requires special tools. We use these technologies to store information to ensure the quality of reviews and to spot irregularities in the use of the Website.
6.2 What type of cookies do we use and for what purposes?
Measuring Website traffic i.e. number of visits on the Website, which domains the visitors come from, which pages the visitors visit on the Website and in which overall geographical area the visitors are located.
- Improvement of the functionalities of the Website:
Optimizing your experience with the Website, which includes remembering your user ID and password when you return to the Website so you do not have to log in again.
- Connect with Social Media:
We give you the possibility of connecting with Social Media, such as Facebook.
- Quality assurance
Ensuring the quality of reviews and to prevent misuse or irregularities in connection with writing reviews and using the Website.
- Targeted advertisement:
Displaying specific advertisements on the Website which we believe you will find interesting.
6.3 Third party cookies
Google Analytics: for statistical purposes. You can decline cookies from Google Analytics by clicking on this link: http://tools.google.com/dlpage/gaoptout
Facebook: Set by Facebook only if you interacts with the Facebook plugin or is already logged into Facebook from other source for the purpose of connecting and integrating with them.
Twitter: Set by Twitter only if you interacts with the Twitter plugin or is already logged into Twitter from other source for the purpose of connecting and integrating with them.
Google+: Set by Google only if you interacts with the Google+ plugin or is already logged into Google from other source for the purpose of connecting with them.
Google ads: for the purpose of displaying relevant advertisements.
6.4 Deletion of cookies
If you want to delete the cookies already on your equipment, you can, if you use a PC or a more recent browser, press CTRL + SHIFT + DELETE simultaneously. If the shortcuts do not work on your browser, please visit the support page for the browser in question. Please note that our Website will not work to its full extent if you delete the cookies.
7 Access, correction and deletion
Upon written request to Smarter.loans via the contact information stated in section 9, Smarter.loans shall inform you of the purpose of the processing; who receives the information and from where the information originates.
Requests regarding the above shall only be processed if more than 6 months have lapsed since your previous request, unless you can substantiate a special interest in obtaining the information earlier.
7.2 Correction and deletion
If you discover that the information which Smarter.loans as the data controller process on you is incorrect or misleading, please contact firstname.lastname@example.org to have it corrected.
Smarter.loans reserves the right to block the access to your profile and/or delete your profile, if the profile or the content of your profile on the Website in our assessment is discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or in other ways violates the legislation, third party rights or the purpose of the Website. If we block the use of your profile, you shall be informed hereon, as well as on the reason for blocking the access, by email to the address you have stated in your profile.
1501-30 North Park Rd.