Effective date: 1st August 2021
DTSW Services Inc. (“DTSW”, “we”, “us”, “ The Smart Divorce” and “our”) respects your privacy and recognizes the importance of your personal information. We are committed to protecting your information through our compliance with The Personal Information Protection and Electronic Documents Act of Canada (PIPEDA) and any other privacy law/regulation applicable to our jurisdiction.
- What is Personal Information?
Personal information is defined in PIPEDA as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card.
- Collection of Personal Information
Any interaction may result in our collection of your Personal Information. We collect Personal Information directly from you, or indirectly from third party sources as otherwise permitted by applicable law. We may collect the following information to provide you our products and services:
- Personal Information: This includes your name, home address, home phone number, gender, date of birth, language preference, email address, credit card information, PayPal information or account information with us. If we use a third party payment processor, your payment information will be with that third party.
- Log Data: Our servers automatically record information (“Log Data”) related to your actions on the Website. Log Data may include information such as your IP address, browser type, internet service provider, date/time stamps, the referring domain, pages visited, products viewed and search terms. Other actions, such as interactions with the Website may be also included in Log Data. Log Data may also be recorded by third party websites.
- Links: The Website may keep track of how you interact with links by redirecting clicks or through other means. We do this to help improve our Services, and to be able to share aggregate click statistics such as how many times a particular link was clicked on. We also use web beacons, tags and pixels to record information about how you browse the Website.
- Device Identifiers: When you use a mobile device like a tablet or cell phone to access our Website, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to your device.
- E-Mail and Chat: You may decide to send us Personal Information in an e-mail message or via the Chats. Before you can interact with our representatives via the Chats, you will be asked to provide your e-mail address.
- Third Party Services: We use a variety of services hosted by third parties to help provide our Services, and to help us understand the use of our Website, such as Google Analytics. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request.
- How We Use Your Information
- establish, maintain and manage client relations with you so that we may provide you with the mediation services that have been requested;
- provide personalized content and information to you and others, which could include promotional emails, online ads, opportunities presented by other organizations and additional products or services that we determine may be of interest to you or other forms of marketing (you can choose not to receive any electronic marketing communication communications from us by clicking the Unsubscribe” function contained in all of our electronic communications or by emailing [email protected]
- conduct client satisfaction surveys and provide client service to you;
- develop and test new services and features and improve our level of service;
- provide service notifications;
- monitor metrics such as total number of visitors, traffic, and demographic patterns;
- process payments for our Payable Services upon your authorization;
- diagnose or fix technology problems; and
- such other purposes consistent with these objectives and as may be permitted or required by applicable law.
Information about you and your use of the Services may be aggregated with other information in ways that do not personally identify you or constitute personally identifiable information. This type of aggregated or statistical information may be used by us to improve the quality of the Services or for other purposes that we may deem appropriate.
- Sharing of Information
We may share your Personal Information:
- with unaffiliated service providers with whom we may subcontract with, including warehouses, website hosting companies, fulfillment companies, payment processing companies, and other third-party service providers; and
- with government agencies and law enforcement officials, when required to do so to respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims.
- Information Sharing and Disclosure
- Your Consent: We may share or disclose your information with your consent. Consent can be either express (verbally, in writing or electronically) or implied, where permitted under applicable law. In determining the appropriate form of consent, we will consider the sensitivity of the information. When you provide your Personal Information voluntarily on the Website or to us, you imply that you have consented to the collection, use and disclosure of such information. You or as parent or guardian on behalf of someone who is under the age of 18 years old, may change or withdraw your/their consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us at —[email protected]. Please note that in some circumstances, a change in or withdrawal of consent may severely limit our ability to provide the services you have purchased to you.
- Without Consent: Please note that there are circumstances where the use and/or disclosure of your Personal Information may be justified or permitted or where we are obliged to disclose information WITHOUT consent. Such circumstances are consistent with PIPEDA and the DPA and may include, but are not limited to the following: if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property.
- Non-Private or Non-Personal Information: We may share or disclose your non-private, aggregated or otherwise non-Personal Information.
- Third Parties
You agree that we are not responsible and do not have control over any third parties that you authorize to access your content through our site. If you are using a third-party website or service and you allow them to access your Personal Information you do so at your own risk.
- Accessing and Modifying Personal Information
We endeavor to ensure that your Personal Information is accurate, current and complete as possible to fulfill the purposes for which the information has been collected, used, retained and disclosed. You may email us at [email protected] to request access to review, challenge the accuracy of or request deletion of your Personal Information held by us and to request corrections and we will respond within a reasonable time. To guard against fraudulent requests, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or modifying any Personal Information. We may also deny your request if permitted or required by law and if so, provide you with the reasons for the denial.
If you successfully demonstrate the inaccuracy or incompleteness of any of your Personal Information, we will amend or delete the Personal Information as required. If we do not agree on the resolution to your satisfaction, we will document the substance of the unresolved challenge.
Where appropriate, we will transmit the amended information or the existence of the unresolved challenge, as the case may be, to third parties having access to the information in question so that they may modify their records accordingly. We are however, not responsible nor liable for the failure of such third parties to update their records.
If you are a parent or guardian, you can email us to request access to review, modify, replace or request deletion of the Personal Information provided by your minor. We may require evidence of your parent or guardian rights prior to responding to your request. Please note that in some circumstances, a removal of a minor’s Personal Information without replacement with your own Personal Information may severely limit our ability to provide the Payable Services to you.
- Protection of Personal Information and Disclaimer
We endeavor to maintain appropriate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to the disposal or destruction of Personal Information. We further protect your Personal Information and any financial or payment information by restricting its access to those employees and contractors who need to have knowledge of that information in order for us to provide our Services, as determined by our management. While we continue to work hard to protect your Personal Information, no data transmission over the internet can be guaranteed to be absolutely secure, and we cannot ensure or warrant the security of any information you transmit to us via the Website or otherwise. Transmitting Personal Information is done at your own risk.
We will retain your Personal Information for as long as necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed, or as permitted or required by law.
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