Privacy Policy

LAST UPDATE OF THIS PRIVACY POLICY - as of 09 October 2018

This privacy notice aims to give you information on how Smartrade Exchange Services Inc collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase a product or service.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This Privacy Policy is applicable to Smartrade Exchange Services Inc (“Website”) and sets out our policy on the gathering and use of information on this site and our other sites (collectively “Sites”). The Website is committed to providing safe web sites for visitors of all ages and has implemented this Privacy Policy to demonstrate our firm commitment to your privacy. The Website complies with Canadian Federal and Provincial privacy laws and regulations including the Personal Information and Electronic Documents Act. The Website also follows the requirements of the EU GDPR Act and relevant data protection regulations.

There may be links from our Sites to other web sites; note that this Privacy Policy applies only to our Sites and not to web sites of other companies or organizations to which our Sites may be linked. You must check on any linked sites for the privacy policy that applies to that site and/or make any necessary inquiries in respect of that privacy policy with the operator of the linked site. These links to third party websites are provided as a convenience and are for informational purposes only. The Website does not endorse, and is not responsible for, these linked websites.

Although you are not required to register to access our Sites, you may be asked to provide us with personal information when you visit certain sections of our Sites. Your use of our Sites signifies your acknowledgement and consent to our Privacy Policy. If you do not agree to this Privacy Policy, please do not continue to use our Sites. Your continued use of the Sites signifies your acceptance of these terms and any changes in effect at the time of use.

COLLECTION OF PERSONAL INFORMATION:

Personal Information is information about you that identifies you as an individual, for example, your name, address, e-mail address, or telephone number.

We collect information that you voluntarily provide to us through responses to surveys, search functions, questionnaires, feedback, registration forms and the like. We may also ask you to provide additional information such as your permanent address, national id, passport number etc if you want to obtain additional services and features, information or to resolve complaints or concerns.

HOW DOES SMARTRADE EXCHANGE SERVICES INC AND THE WEBSITE USE INFORMATION GATHERED ABOUT ONLINE VISITORS AND CUSTOMERS IN GENERAL:

Before forwarding us any personal information, please be advised that any information gathered on our Sites may be used in the aggregate for research and development relating to our Sites and/or for future site development and, if you ask us to, to send you promotional materials.

In particular, we may use information gathered about you for the following purposes:

According to the FATF AML/CFT guidelines and the local regulations regarding money-laundering, Smartrade Exchange Services Inc collects data about users of its exchange platform including but not limited to personal information, source of funds information, photos/scans of IDs, passport numbers, permanent addresses and others. We are required to store such information for five years after the user’s account and/or business with Smartrade Exchange Services Inc terminates. In certain cases, the relevant authorities may require us to provide them with all data and information we have about a particular user. By using our Site and services you acknowledge and accept this fact.

PROMOTIONAL AND INFORMATIONAL OFFERS:

With the permission of an online visitor/ customer, information submitted at the time of registration or submission may be used for marketing and promotional purposes by the Website provided notice of this fact is made available online. If a visitor objects to such use for any reason, he/she may prevent that use, either by e-mail request or by modifying the registration information provided. The Website uses reasonable efforts to maintain visitors’ information in a secure environment. If you have submitted personal information and want to change it or opt-out, please contact us as described below.

DISCLOSURE OF INFORMATION:

The Website will not disclose personal information that you provide on its Sites to any third parties other than to a Website agent except: i) in accordance with the terms of this Privacy Policy, or ii) to comply with legal requirements such as a law, regulation, warrant, subpoena or court order, and/or iii) if you are reporting an adverse event/side effect, in which case the Website may be required to disclose such information to bodies such as, but not limited to, Canadian and/or international regulatory authorities. In cases where a bank partner requires KYC information in order to approve a transaction, we may give them that information about a customer. By using our Website you acknowledge and agree to this. Please note that any of these disclosures may involve the storage or processing of personal information outside of Canada and may therefore be subject to different privacy laws than those applicable in Canada, including laws that require the disclosure of personal information to governmental authorities under circumstances that are different than those that apply in Canada.

COOKIES:

The Website, in common with many web site operators, may use standard technology called “cookies” on its Sites. Cookies are small data files that are downloaded onto your computer when you visit a particular web site. You can disable cookies by turning them off in your browser; however, some areas of the Sites may not function properly if you do so. We use analytical tools like Google Analytics to improve the experience of users of our website.

PROTECTION OF CHILDREN ONLINE:

The Website considers the protection of children’s privacy, especially online, to be of the utmost importance. We do not knowingly collect or solicit personal information from children nor do we allow them to become registered users of, or to request information through, our Sites or help-seeking information lines.

SUBJECT ACCESS REQUEST (SAR):

According to the EU GDPR regulations, every data subject has the right to request access to the data held by Smartrade Exchange Services Inc and the Website about them. If you would like to make a subject access request, please send an email to kostadin@smartrade.com with your full name, current address, phone number email address, details of what identification you provide us with to confirm your name and finally the details of the data you request. You can also file a SAR on your personal account page on www.smartrade.com

THE RIGHT TO BE FORGOTTEN:

According to the EU GDPR regulations, every data subject has the right to request full erasure of personal data concerning him or her without undue delay and the Website has the obligation to do so if the following requirements are met:

Smartrade Exchange Services Inc has the right to reject your request for erasure of your data if the data processing is necessary:

If you want to exercise your right to be forgotten and request erasure of all your personal data held and processed by the Website, you can contact kostadin@smartrade.com for additional details and instructions on how to do that.

THE RIGHT OF CORRECTION

As a data subject, you have right to obtain from us without undue delay the correction of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If you would like to change any of your personal data you can do that on your account page on www.smartrade.com or contact kostadin@smartrade.com for further instructions.

REQUEST A TRANSFER OF YOUR DATA

You have the right to request a transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. You request will be fulfilled within 30 days.

WITHDRAWING YOUR CONSENT

You have the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

NO FEE USUALLY REQUIRED

Usually you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, excessive or requires unusual amount of effort to be done. Alternatively, we may refuse to comply with your request in these circumstances.

PROTECTION OF INFORMATION:

We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. The Website applies security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making personal information accessible only to authorized employees on a need-to-know basis.

STORAGE OF INFORMATION:

Personal information you share with us is stored on our database servers at Website data centers (in whatever country they may be located), or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Policy.

POLICY CHANGE:

If we alter our Privacy Policy, any changes will be posted on this page of our Site so that you are always informed of the information we collect about you, how we use it and the circumstances under which we may disclose it.

ACCEPTANCE OF OUR PRIVACY POLICY:

By using www.smartrade.com , you signify your acceptance of our Privacy Policy, and you adhere to the terms and conditions posted on the Website. By submitting your information, you agree that it will be governed by our Privacy Policy.

If you have any questions, requests or concerns regarding our privacy policy and data handling, please contact kostadin@smartrade.com