PRIVACY POLICY

Last updated September 01, 2024

This Privacy Notice for Smart Family Choices (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

  • Visit our website at smartfamilychoices.com or smartfamilychoices.ca, or any website of ours that links to this Privacy Notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@smartfamilychoices.com.



SUMMARY OF KEY POINTS

  • What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact, your choices, and which products/features you use.
  • Do we process any sensitive personal information? We do not process sensitive personal information.
  • Do we collect any information from third parties? We do not collect information from third parties.
  • How do we process your information? We process it to provide, improve, and administer our Services, communicate, for security/fraud prevention, and to comply with law. With your consent, for additional purposes.
  • In what situations and with which parties do we share personal information? We may share in specific situations and with categories of third parties.
  • How do we keep your information safe? We have organizational and technical processes in place, but no system is 100% secure.
  • What are your rights? Depending on where you are located, you may have rights over your personal information (access, correction, deletion, etc.).
  • How do you exercise those rights? You can submit a data subject access request or contact us.



TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. DO WE COLLECT INFORMATION FROM MINORS?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO WE MAKE UPDATES TO THIS NOTICE?
  13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
  15. USE OF ARTIFICIAL INTELLIGENCE (AI) FOR COMMUNICATION AND APPOINTMENT BOOKING



1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us
In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • phone numbers
  • email addresses
  • mailing addresses

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected
In short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.



2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts.
  • To deliver and facilitate delivery of services to the user.
  • To respond to user inquiries/offer support to users.
  • To send administrative information to you.
  • To request feedback.
  • To deliver targeted advertising to you.
  • To evaluate and improve our Services, products, marketing, and your experience.
  • To identify usage trends.
  • To determine the effectiveness of our marketing and promotional campaigns.



3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services or to fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.



4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties we may share personal information with are as follows:

  • Order Fulfillment Service Providers

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition.
  • Affiliates. We may share your information with our affiliates.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.



5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.



6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: Yes, some features/tools may be powered by AI, machine learning, or similar technology.

These may include tools provided by third-party service providers. We ensure any personal information processed through AI systems is handled in compliance with this Privacy Notice.



7. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required by law.



8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures to protect your information. However, no system is entirely secure.



9. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect or market to children under 18 years of age.



10. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your location, you may have rights under applicable data protection laws to access, correct, or delete your personal information, and to withdraw consent at any time.



11. CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to browser Do-Not-Track signals.



12. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we may update this Privacy Notice from time to time.



13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Smartly Digital Solutions
Data Protection Officer
5343 Dundas St W Ste 601 #103
Etobicoke, Ontario M9B 6H8
Canada
📧 legal@smartfamilychoices.com



14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You may request access, correction, or deletion of your personal information by contacting us via email or through our data request form.



15. USE OF ARTIFICIAL INTELLIGENCE (AI) FOR COMMUNICATION AND APPOINTMENT BOOKING

In Short: We use AI-powered text and voice systems to help you connect with our licensed advisors efficiently and conveniently.

We may use artificial intelligence (AI)–driven communication tools to contact you by text message, chat, or voice call following your request for information or a quote through our website. These systems assist in following up, scheduling, confirming, or rescheduling appointments with our licensed advisors.

The AI systems are designed to enhance customer experience by providing timely, accurate, and convenient interactions. All AI communications are:

  • Supervised by human representatives who can review, intervene, or complete conversations as needed.
  • Limited in scope to communication and scheduling — AI does not make any financial, legal, or eligibility decisions.
  • Securely logged or recorded only for appointment management, quality assurance, and compliance purposes.

You may opt out of AI-based communications at any time and request to communicate solely with a human representative by contacting us at support@smartfamilychoices.com or legal@smartfamilychoices.com.

All AI-related data is handled in accordance with applicable privacy laws, including Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). We are committed to transparency, consent, and maintaining the security and confidentiality of your personal information.