Privacy Policy

Smartzey Inc., along with its affiliates and subsidiaries (collectively referred to as "Smartzey," "we," or "us" as detailed under "Who We Are"), is dedicated to safeguarding your privacy. This Privacy Policy ("Policy") outlines our practices for collecting, using, disclosing, retaining, and processing your personal information when you interact with our Smartzey websites, apps, forums, social media channels, blogs, and related features; participate in Smartzey contests or sweepstakes; purchase our products or services; visit our physical locations; or engage in other experiences we offer (collectively referred to as the "Services"). Please read this Policy carefully.

We may also implement different or additional privacy notices for specific activities, programs, and offerings. Our privacy practices adhere to the laws of the regions where we operate, ensuring compliance with local legal requirements.

This Policy is incorporated into Smartzey’s Terms of Service (North America) and Terms of Service (International) by reference, as though fully included therein.

For California residents, please refer to the “Additional Disclosures for California Residents” section.

Contents

  • Who We Are
  • Information We Collect
  • Use of Your Personal Information
  • Legal Bases for Processing
  • How We Disclose Your Personal Information
  • Targeted Advertising and Analytics Services
  • Your Privacy Rights and Choices
  • Children
  • Third Party Links and Social Media Platforms
  • Data Transfers
  • Sensitive Information
  • Security
  • Data Retention
  • Additional Disclosures for California Residents
  • Notice of Financial Incentives and Bona Fide Loyalty Programs [for California and Colorado Residents]
  • Nevada Privacy Rights
  • Updates to this Policy
  • Contacting Us

Who We Are

Depending on your preferences and shipping location, Smartzey entities responsible for managing your personal information include Smartzey Inc., Smartzey U.K. Limited, and/or Smartzey ANZ Pty. Contact information for these entities is available in the "Contacting Us" section below.

Information We Collect

Personal information refers to any data that can identify you directly or indirectly. The types of personal information we collect depend on your interactions with us or use of our Services.

Information You Provide to Us

We may collect the following categories of personal information:

  • Contact details such as your name, email address, mailing address, and phone number.
  • Account details including email address, reward information, and benefits.
  • Purchase details such as product types, order information, delivery details, payment information, and return or exchange data. Note that we do not store full credit/debit card numbers.
  • Optional information you provide, including birthdate, social media handles, gift card recipient information, and demographic details (e.g., ethnicity, treated as "sensitive information" if provided).
  • Communication data submitted through customer service interactions or other communications with Smartzey employees or third parties on our behalf, including recorded customer service calls for quality assurance.
  • Additional information you voluntarily provide, such as product reviews, survey responses, contest participation, marketing preferences, or customer support details.

Information We Collect From Other Sources

We may also gather information from other sources and combine it with information you provide, including:

  • Other users: If you refer a friend or purchase an e-gift card, we may collect information about your friend to facilitate their engagement with us.
  • Social media platforms: We may collect data about your interactions with our content on platforms like Instagram, Facebook, Google, TikTok, and Pinterest. Review the privacy policies of these platforms for more details.
  • Partners: We may collaborate with third parties for promotions or co-branded products and may receive information from them.
  • Data analytics providers and other sources: We may obtain information from analytics, advertising, and fraud prevention providers to enhance our understanding of your interests and preferences.

Information We Derive or Infer

We may infer or derive information about you based on our data collection, such as determining your location from your IP address or predicting your purchase interests from your browsing and purchase history.

Automated Data Collection

We automatically collect data through technologies like cookies, pixels, and web beacons. This data includes device and network details, usage patterns, and session-replay information. This helps us improve user experience, security, and functionality.

Use of Your Personal Information

Your personal information is used to:

  • Provide and improve our products and services.
  • Complete transactions and manage accounts.
  • Communicate service-related notifications and updates.
  • Market our Services and manage advertising.
  • Conduct research, manage promotions, and enhance user engagement.
  • Ensure safety and security, and address technical issues.
  • Process information during corporate transactions.
  • Obtain consent when necessary and comply with legal obligations.

Legal Bases for Processing

We process personal information based on:

  • Contractual obligations (e.g., processing payments).
  • Legitimate interests (e.g., marketing and analytics).
  • Legal requirements.
  • Protection of vital interests.
  • Consent (e.g., promotional communications).

How We Disclose Your Personal Information

We may disclose personal information in various contexts:

  1. Within Smartzey: To affiliates and employees who need it for operational purposes.
  2. Vendors and Service Providers: For tasks like order fulfillment and analytics.
  3. Business Partners: For co-branded services and joint promotions.
  4. Professional Advisors: For business management and transactions.
  5. Data Providers: For identifying potential customer interests.
  6. Advertising Partners: For targeted advertising and analytics.
  7. Social Media Platforms: Through features and tools that interact with these platforms.
  8. Other Third Parties: As required for legal obligations or in response to requests.
  9. Other Users: Content you post publicly may be visible to others.
  10. Business Transactions: Information may be transferred during corporate changes.
  11. Aggregated Data: Disclosed in aggregated or anonymized forms where permitted.

Targeted Advertising and Analytics Services

We may collaborate with external partners for advertising and analytics. They use tracking technologies to collect data and provide targeted advertising. For more details on these practices and opt-out options, refer to the "Your Privacy Rights and Choices" section.

Your Privacy Rights and Choices

You have rights regarding your personal information, including opting out of marketing communications and managing cookie preferences. Specific rights vary by location. For more information and to exercise your rights, follow the instructions in the "Your Privacy Rights and Choices" section.

Cookies and Tracking Technologies

At Smartzey, we use cookies and similar tracking technologies to analyze traffic to our site and emails, aiming to enhance our website, services, and marketing efforts. Most browsers are set to accept cookies by default, but you can adjust your browser settings to remove or reject cookies if preferred. Please note that disabling cookies may impact the functionality and accessibility of our site.

Even if you opt out of cookies used for targeted advertising, you may still see our ads, but they will no longer be tailored based on your browsing behavior. For more details on our cookie practices, please refer to our Cookie Policy.

Opting Out of Targeted Advertising and Data Sharing

As outlined in our "Targeted Advertising and Analytics Services" section, we occasionally share personal data to provide customized advertising related to our services. We also disclose information for advertising and marketing as detailed in the “How We Disclose Your Personal Information” section. These disclosures may qualify as a “sale” or “sharing” of your data or “targeted advertising” under certain laws. Please note that such requests will only apply moving forward. We do not knowingly sell or share data of individuals under 16 for online targeted advertising.

Depending on your location, you can opt out of data sharing and targeted advertising by clicking “Your Privacy Choices” in the site footer or filling out this form.

We also honor legally-required browser-based opt-out signals (like the global privacy control) in line with our legal obligations. To use the Global Privacy Control (GPC) signal, visit https://globalprivacycontrol.org/orgs and enable it on your supported browsers.

Your Rights Regarding Personal Data

Depending on your location, you may have rights including (i) accessing or obtaining a copy of your personal data; (ii) receiving details on how we process your data; (iii) correcting or updating your data; (iv) requesting deletion of your data; (v) objecting to or restricting certain data processing; (vi) receiving your data in a machine-readable format and transferring it to another entity; and (vii) withdrawing consent if consent was our basis for processing. Requests are subject to certain exceptions.

To exercise these rights, contact us via the “Contacting Us” section, fill out this form, or call 877-564-6404. We will need to verify your identity before processing requests, which may involve confirming your name and email, and possibly requesting additional information. We will respond within the time frame allowed by law. Note that some information may be retained for recordkeeping or transaction completion, and residual data may remain in our records. Deleting your data may affect access to certain products and services. You can appeal if your request is denied, and we will provide details on the appeals process.

You may designate an authorized agent to make requests on your behalf. If we receive a request from an authorized agent, we may require proof of authorization.

Non-Discrimination

We do not discriminate against individuals exercising their rights as described in our Privacy Policy.

Children's Privacy

Our services are intended for general audiences and are not targeted at children. If we learn we have collected data from children under the age requiring parental consent, we will delete it promptly.

Third-Party Links and Social Media

Our services may include links to third-party websites and applications or integrate third-party technologies. Third parties control their own data processing practices. We may also offer social features that allow sharing actions with other media. For privacy practices of these platforms, review their policies and settings.

Data Transfers

If accessing our services from outside the U.S., be aware that your data may be processed in the U.S. and transferred to other countries, such as Canada, Europe, the UK, and Australia. Some of these countries may have less stringent data protection laws. For data transfers from the EU, UK, or Switzerland to the U.S., we use approved mechanisms like Standard Contractual Clauses. In Australia, we ensure overseas recipients comply with Australian Privacy Principles. By using our services, you consent to this data transfer and processing.

Sensitive Information

Please avoid sending us sensitive information (e.g., Social Security numbers, racial or ethnic origin, political opinions, religion, health data, or criminal background) through our services.

Security

We take various measures to protect your personal data but cannot guarantee 100% security. You are responsible for keeping your account password confidential. By using our services, you agree to electronic communication regarding security and privacy issues. We may notify you of security breaches electronically if they impact you.

Payment transactions are processed by Shopify, PayPal, Venmo, Apple Pay, Google Pay, Klarna, or other providers, who adhere to PCI-DSS standards. For Shopify’s privacy practices, visit https://www.shopify.com/legal/privacy.

Data Retention

We retain personal data as long as necessary for processing purposes and related activities, such as audits, compliance with laws, and resolving disputes. Retention criteria include service provision, legal obligations, and our legal position.

When data is no longer needed, it is removed or anonymized in accordance with the law.

Additional Disclosures for California Residents

This section applies to personal information processing under the California Consumer Privacy Act (CCPA) and the Shine the Light law. The CCPA gives California residents rights to know the categories of personal information collected, its use, and sharing practices. For a summary of our practices over the past 12 months, see the following table.

"Sale" or "Share" of Personal Information

California law mandates transparency regarding the personal information we "sell" or "share" with third parties. According to the CCPA, a business is deemed to "sell" personal information if it transfers this data to another entity in exchange for something of value. At Smartzey, we do not sell your personal information for monetary gain. However, there may be instances where a third party is classified as a recipient of "sold" information if we disclose personal details to them beyond the specified business purposes under California law or if their agreement does not limit their use of the data to the service they provide to us.

In terms of "sharing," this refers to disclosing personal data to third parties for cross-context behavioral advertising. We engage in "sharing" to offer you more relevant and customized advertisements related to our services. The following table outlines the types of personal information we have collected and the categories of recipients with whom we have "sold" or "shared" this information over the past year.

Information on Data Use and Rights

For details about our data collection practices, usage purposes, and third-party disclosures, please refer to the “Data Collection,” “How We Use Your Data,” and “Disclosure of Your Data” sections above.

Limiting the Use of Sensitive Information

Residents of California can restrict the use of sensitive personal information if it's used to infer characteristics about them. At Smartzey, we do not utilize sensitive personal information for this purpose.

Data Retention

For information on how long we keep your data, please review the "Data Retention" section above.

Do Not Track Signals

Smartzey currently does not respond to Do Not Track (DNT) signals on our website. To manage targeted advertising, adjust your cookie settings as described above.

Shine the Light

California law allows residents to request information about how their personal data is shared with third parties for marketing purposes or to opt out of such sharing. If you are a California resident and wish to make such a request, please contact us at hello@smartzey.com. Smartzey may share personal information for marketing purposes as detailed above or as authorized by you.

Financial Incentives and Loyalty Programs [For California and Colorado Residents]

We may offer financial benefits such as discounts, special offers, credits, or gifts as incentives for providing personal information, joining loyalty programs, participating in surveys, or entering contests (collectively, the “Programs”). When you engage with a Program, we collect information such as your name, contact details, and any additional demographic data you choose to provide. To administer these Programs, we might share this data with service providers and third parties including advertising networks, marketing partners, and data analytics firms.

You can opt into a Program by following the provided instructions and opt out at any time by contacting us at hello@smartzey.com. Additional terms and conditions for specific Programs may be provided during sign-up. We assess the value of benefits offered relative to the personal information collected to ensure fairness. Please note that requesting deletion of your personal information may impact your eligibility for certain Programs.

Nevada Privacy Rights

Nevada residents have the right to opt out of the sale of their information. While we do not sell personal data as defined by Nevada law, if you are a Nevada resident and seek more information on our data practices, please contact us at hello@smartzey.com.

Policy Updates

We may update this Policy periodically. Any changes will be posted on our website with the date of the latest revision. Significant changes affecting you will be communicated through prominent notices on our site or direct notifications. Continued use of our Services after such updates signifies your acceptance of the new terms. Please review our Policy regularly to stay informed.

Contact Us

For inquiries, feedback, or concerns regarding this Privacy Policy, please reach out as follows:

For all other customers and users:

Smartzey
10 Daybar Avenue
Etobicoke, ON M9W 4M6, Canada
hello@smartzey.com

If we cannot resolve your concerns about our data processing practices, you have the right to file a complaint with your local data privacy authority:

  • Switzerland: See here.
  • Australia: Office of the Australian Information Commissioner (www.oaic.gov.au).
  • Canada: Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or the privacy authority in your province.
  • UK: Information Commissioner’s Office (https://ico.org.uk/).
  • EU: List of data protection authorities and their contact details can be found here.
  • Germany: Complaints are handled by the State Data Protection Authority of the federal state where you reside. Relevant authorities can be identified via the provided list.