SmartONE

Privacy Policy

PRIVACY POLICY

SmartOne Solutions Inc. (“SmartONE”, “SmartOne”, “we”, “our”, “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (the “Privacy Policy”).

This Privacy Policy is effective May 1, 2022 and governs our practices to the collection, use and disclosure of Personal Information (as defined below) that we collect from Users of our SmartOne Solution (as defined below). Please see https://smart-one.ca/privacy-policy/ to review the privacy policy that applies with respect to collection, use and disclosure of Personal Information (as defined below) that applies with respect to visitors to our website and individuals who otherwise provide us with Personal Information. 

By using the SmartOne Solution and supplying your Personal Information, you acknowledge that you have read and understood this Privacy Policy, and you agree and consent to the collection, use, disclosure and other processing of your Personal Information as outlined in this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please do not the SmartOne Solution or supply your Personal Information to us.  

Please note, that in some cases, SmartONE provides the SmartOne Solution on behalf of business clients, such as property managers and landlords (“Clients”).  In these cases, SmartOne processes Personal Information on behalf of the Client as the Client’s service provider. When we act as a service provider to a Client, the Client – and not SmartONE – is accountable for and in control of your Personal Information collected through the SmartOne Solution.  In such cases, we process your Personal Information in accordance with our Client’s instructions.  You will know when this is the case because you will be asked to accept the Client’s privacy policy before you start using the services associated with the SmartOne Solution.  

Definitions 

  • Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of SmartOne. Implied consent is consent that can reasonably be inferred from the circumstances or from an individual’s action or inaction. 
  • Disclosure: making Personal Information available to a third party for that party’s own use. 
  • Personal Information means information, recorded in any form, that identifies an individual or that could be used to identify an individual, but does not include aggregated, anonymized, or depersonalized information that cannot be associated with an individual. 
  • SmartOne Solution means the SmartOne proprietary solution that provides smart home and connected community capabilities, and includes the customized smartphone application that users download from the Apple iTunes Store or Google Play Store (the “SmartOne Application”). 
  • Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of SmartOne. 
  • Use: the treatment, handling, and management of Personal Information by and within SmartOne. 
  • Users: mean end-users of the SmartOne Solution. 

 

Accountability 

SmartOne is responsible for Personal Information under our possession and control. We have a designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and applicable privacy legislation.  SmartOne will make known, upon request, the title of the person or persons designated to oversee SmartOne’s compliance with this Privacy Policy. 

SmartOne is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. SmartOne shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party. 

SmartOne shall implement policies and practices to give effect to these principles, including: 

a. implementing procedures to protect Personal Information; 

b. implementing an internal process to receive and respond to complaints and inquiries relating to this Privacy Policy; and 

c. training staff and communicating to staff information about the organization’s policies and practices. 

As described above, in some cases, SmartOne processes Personal Information on behalf of our Client as the Client’s service provider. In these circumstances, the Client is accountable for the Personal Information that we process on their behalf in accordance with their instructions. 

a. Personal Information

Personal information that SmartOne collects includes, but is not limited to: 

  • Contact and Registration Information: you need to create an account before you can use the services through the SmartOne Solution.  When you register for an account, we will collect your first and last name, email address, password, location of where service is being used, and your mobile phone number. 
  • Location Information: we collect information that describes the geographic location of the SmartOne Solution, including user and device information when using the SmartOne Application. 
  • User Content: data and content generated through the use of the SmartOne Application, such as thermostat settings, home alarm use, etc.  
  • Identifiers: user identifiers (e.g. SmartOne assigned account number) and device identifiers. 
  • Usage Data and Diagnostics: user activity (e.g. app launches, taps, clicks and scrolling information) and diagnostics (e.g crash logs, launch time and energy use). 
  • Account Settings: you can set various preferences and provide person details on the account tab on the SmartOne Application. 
  • Other Information: we also collect Personal Information from service requests and inquiries.  

When we act as a service provider to a Client, we collect Personal Information on the Client’s behalf. 

 b. Non-Personal Information

Non-Personal Information (“NPI”) means information that is aggregated, depersonalized, anonymized or otherwise cannot be linked with any individual.  Subject to the terms of our contracts with Clients, we may generate NPI from Personal Information collected through the SmartOne Solution by removing information that makes the data personally identifiable to an individual.  We may use this NPI for any reasonable purpose, including improving our products and services, and disclose such data to third parties in our sole discretion.

We collect, use, and disclose your personal information in order to provide you with our Products, including to provide the SmartOne Solution on behalf of our Clients.  We also collect, use and disclose your Personal Information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable laws.  We will only use the Personal Information that we collect for the purposes for which it was collected.   

Except when we act as a service provider to our Clients, SmartOne uses Personal Information for the following purposes: 

  • to provide you with the services provided through the SmartOne Solution; 
  • to establish and maintain commercial relations with you; 
  • to respond to your questions that you send by email or through the SmartOne Solution;   
  • subject to applicable law, to provide you with newsletters and articles; to improve the functionality and customize the software solution displayed to you, including the SmartOne Application; 
  • to improve the SmartOne Solution, and help us develop new services, apps, tools and product features;  
  • to support our business functions such as internal business processes, marketing and advertising; and 
  • to meet any legal or regulatory requirements.  

When we act as a service provider to our Clients, we collect and use Personal Information on behalf of our Client in order to provide the SmartOne Solution.  This may include responding to your questions on behalf of our Client.  Where permitted by our Client, we may also use NPI that is generated through Users use of the SmartOne Solution to improve our products and services. 

We limit the collection of Personal Information to that which is necessary to fulfill the purposes identified in this Privacy Policy and we collect, use and disclose your personal information in accordance with this Privacy Policy.  

SmartOne will retain your Personal Information for as long as necessary to fulfill the purposes for which we collected the information, to ensure your compliance with our terms of service, and to comply with our legal or contractual obligations.  When we act as a service provider to our Clients, we will retain such Personal Information in accordance with our Client’s instructions. 

SmartOne will maintain the strict confidentiality of all Personal Information collected and will not sell, transfer, or otherwise disclose any of your Personal Information to any third party without your knowledge and consent except for the purposes outlined in this Privacy Policy.  

When we act as a service provider to our Clients, we will only collect, use and disclose your Personal Information in order to provide the SmartOne Solution on the Client’s behalf in accordance with the Client’s instructions.  

We may share your Personal Information with third party service providers that help us with our business operations or to support the SmartOne Solution.  For example, we may share your Personal Information to service providers that help with our operations or our products, including, without limitation, for customer service, monitoring, billing, analyzing activity, and operating and maintaining the products.  Such service providers may only use your Personal Information as provided herein. 

We may also disclose your information, including Personal Information, in the event we sell or transfer all or a portion of our business or assets (including corporate reorganization, merger or amalgamation with another entity, dissolution or liquidation). 

From time to time we may disclose your Personal Information to third parties under the following limited circumstances: 

  • when necessary to protect our safety, property or other rights, our representatives, customers and users of the SmartOne Solution, including to detect and prevent fraud;  
  • with your consent; or 
  • when otherwise required or permitted by law. 

Any Personal Information that we process as a service provider to our Client will remain under our Client’s control and will not be disclosed to a third party except on our Client’s instructions or when required by law. 

We respect your privacy and, unless otherwise required by law, we will not collect, use, transfer or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means.  In certain circumstances, your consent may be implied by your actions.  For example, downloading and accessing the Application and registering for an account is implied consent for SmartOne to provide you with the SmartOne Solution services. 

In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when SmartOne wants to use information for a purpose other than those identified above).  The form of consent sought by SmartOne may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, SmartOne shall consider the sensitivity of the Personal Information and the reasonable expectations of our Users.  SmartOne will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.  

Subject to legal or contractual restrictions, your consent can be withdrawn at anytime; however, withdrawing your consent may impact our ability to continue to provide you with the services you requested.  If we process your Personal Information as a service provider to our Client, our client is responsible for obtaining your consent and you will need to make any consent withdrawal request to the Client directly. 

As discussed above, we may engage third party service providers to perform certain services on our behalf.  These providers may store, process and transfer Personal Information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada.  As a result, Personal Information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions.  For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our service providers to maintain protections on personal information that are equivalent to those that apply in Canada.

Our Site may contain links to other sites that are independently owned and operated by unrelated third parties.  These other sites may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any sites owned and operated by any unrelated third parties.  Other sites may collect and treat information collected differently, so we encourage you to carefully review the privacy policy of each site you visit.

As you interact with this Site, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of the SmartOne Solution and collects certain other information about you and your surfing habits.  This data collection technology may include cookies, web beacons and other similar devices on this Site to enhance functionality and navigation for our visitors.  

We may use web beacons on this Site to count users and to recognize users by accessing our cookies.  We may also employ cookies and action tags to collect information about your use of, and activities on, our Site for our use.  If you do not allow cookies, you may be restricted in how you are able to use the SmartOne Solution. 

We maintain technical, physical, and administrative security safeguards to protect your Personal Information against loss, theft, and unauthorized access including during the storage and transmission of such personal information.  Any Personal Information that you provide to us is exchanged on a secure server. We recognize that no data transmission over the Internet can be guaranteed to be completely secure, and as a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.  

We take reasonable steps to verify your identity before granting you access to your account, however you are solely responsible for maintaining the secrecy of your username, password and any other account information.  We also take reasonable steps to ensure that our employees, contractors and vendors are aware of the importance of maintaining the confidentiality of personal information and have signed confidentiality/non-disclosure agreements with them as applicable.  We endeavour to limit access to Personal Information to those personnel that require access to such personal information on a ‘need to know’ basis in order to perform their obligations. 

If you have questions or concerns about Personal Information collected by us and would like assistance accessing that information and/or would like to confirm its accuracy, please contact our Privacy Officer at (i) at legal@smart-one.ca; or (ii) by mail at SmartOne Solutions Inc. at 100 Allstate Parkway, Suite 601, Markham, ON  L3R 6H3.  In limited circumstances, we may not be able to provide you with access to your Personal Information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege.  If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so. 

Please note that where we process your Personal Information as a service provider to our Client, you will need to make your request to the Client directly.  

You may request to update and change your Personal Information in our control at the contact information set forth below.  We shall endeavor to correct or complete any Personal Information which you advise us is inaccurate or incomplete.  Where appropriate, the amended information shall be transmitted to third parties having access to such information. Where we process your Personal Information as a service provider to our Client, you will need to make your request to the Client directly. 

We are committed to protecting the privacy of children and we do not knowingly solicit Personal Information from children under the age of 13.  If a child has already provided us with Personal Information, his or her parent or guardian may contact us for the purpose of deleting this information. This request may need to be made to a Client when SmartOne is acting as a service provider.  

We comply with Canada’s anti-spam legislation (CASL) and we will not send you electronic communications in contravention of this law.  You may have also opted in to receive email communications from us.  If you opted-in to receive such communications, we may use the information to: communicate with you regarding our products, and promotions; provide you with other information that you request; and/or improve our product and service offerings.  

You will always have the opportunity to “unsubscribe” from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us.  At any time, may opt-out of contact from us by sending us an e-mail to legal@smartone.solutions.ca.  If you decide to unsubscribe, we will only contact you for the purposes allowed under applicable law. 

We reserve the right to change or replace this Privacy Policy at our sole discretion at any time.  Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy Policy.  We will post the most current version on our website and within the Application and we will indicate at the top of this page the date this Privacy Policy was last revised.  Your continued access or use of the SmartOne Solution after any such changes constitutes your acceptance of the Privacy Policy as revised. 

We welcome your feedback.  If you have questions, comments or concerns about this Privacy Policy, or would like to do any of the following:  

  • see your Personal Information that you have already sent us so that you can correct, update or delete it from our files; 
  • if your child under 13 has used the SmartOne Solution and sent us Personal Information, delete that Personal Information from our files; 
  • ask that we not send you electronic communications or otherwise contact you; or  
  • report any violation of this Privacy Policy, 

please contact us our Privacy Officer (i) at legal@smart-one.ca; or (ii) by mail at SmartOne Solutions Inc. at 100 Allstate Parkway, Suite 601, Markham, ON  L3R 6H3, and we will endeavour to get back to you promptly. 

Please note that if we process your Personal Information as a service provider to our Client, you will need to submit all requests and inquiries to the Client directly. Please see the Client’s privacy policy for more information. 

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