Privacy Policy

SMART-TRANSFER (the "Company") knows how important your privacy is to you and we are committed to collecting, using, safeguarding and disclosing personal information responsibly and only to the extent necessary for the services we provide. We comply with the Personal Information Protection and Electronic Documents Act ("PIPEDA") which requires us to provide this policy to you on request.

Personal information means any information that may be used to identify an individual, including, but not limited to, name, address, phone number, financial information, opinion and evaluations. As defined by PIPEDA, "personal information" means information about an identifiable individual.

Please note this Privacy Policy only relates to www.smart-transfer.com. The Privacy Policy is deemed to be part of the Terms and Conditions and they must be read together. Please read this Privacy Policy carefully before using the Company's website www.smart-transfer.com. By using the Company's website, you confirm your acceptance of the terms of this Privacy Policy. If you do not agree with the Company's Privacy Policy, please do not use www.smart-transfer.com.

1. WHAT THIS POLICY COVERS
This policy explains how we collect, use, safeguard and disclose the personal information you provide to us to assist you in making informed decisions when using our services.

2. INFORMATION COLLECTION, USE AND DISCLOSURE
When we collect personal information from you, we wish you to be aware of:

A) Our identity and how to contact us;
1278 St. Clair Ave. W. Suite 14
Toronto, ON
M6E 1B9
Canada
Please call us at 416.840.1466
Toll Free: 1.800.724.5685 | Fax: 647-722-2963
Tele-Support: 416.295.5350

Website: www.smart-transfer.com.

B) That the administrative contact can gain access to the information you provide to us.

C) Without limiting the generality of the foregoing, the Company collects personal information for the following purposes:
(i) to facilitate the sale of the Company's products and its related internet services;
(ii) to satisfy the Company's Know Your Customer policies;
(iii) to ensure the Company complies with applicable laws governing the Company and the provision of its products and services;
(iv) to accurately complete transactions requested by a customer or enquiries made by governmental authorities with respect to same, as the context requires;
(v) to provide customer service; and
(vi) generally, to fulfill any applicable legal and/or regulatory requirements.

D) The Company will not sell or distribute your personal information to third parties, unless specifically authorized by you or as required by law.

E) Company websites www.transcardinter.com and www.smart-transfer.com collect non-personal information such as your network location (IP address), the pages you visit, time of visit, your operating system and browser, in order to generate website traffic reports. Non-personal information submitted to the Company's websites www.transcardinter.com and www.smart-transfer.com is treated as non-confidential and non-proprietary by the Company.

F) Company websites include forms where you can voluntarily provide us with personal contact information so that we may follow-up with you.

G) Certain information may be shared by the Company which is necessary to complete card based transactions, including, without limitation, clearing houses, payment network/system owners, administrators, processors and financial institutions. These third party entities are responsible for their own privacy policies which they shall at all times offer at the same level of protection offered herein.

3. OUR COMPANY'S OBLIGATIONS
Pursuant to PIPEDA, our Company meets its obligations with respect to the collection, use, safeguard and disclosure of personal information by taking the following steps:

A) Accountability:
(i) Information is restricted to the listed administrative contact and protected via appropriate hardware and software.
(ii) Information Officer can be contacted at 416-840-1466 regarding compliance with PIPEDA.
(iii) Staff are aware of our policies and practices regarding personal information.

B) Identifying Purposes:
We have identified the purposes for which we collect personal information in section 2 above. We require the consent of our clients/customers prior to using their personal information for any purpose other than that for which it was originally collected.

C) Consent:
The Company is committed to ensuring that you are aware of how your personal information is used and that you have consented to provide this information. By your use of our products and services or requests for transfer services, you are deemed to have read, understood and consented to the provisions of this Privacy Policy. Where required by law, we may disclose personal information without your knowledge and consent.

D) Limiting Collection:
The Company collects personal information to fulfill the purposes stated in section 2 above. We collect personal information only by lawful and fair means.

E) Limiting Use, Disclosure and Retention:
The Company does not use and/or disclose your personal information for purposes other than those for which it was collected, unless it has first obtained your consent. We retain your personal information for some period in order to answer any questions you may have about the services we provided to you.

F) Accuracy:
The Company is committed to maintaining accurate, complete, and up-to-date personal information. If during the course of the business relationship, any of your information changes, please inform us so that we can make any necessary changes or use our website forms to update the information.

G) Safeguards:
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, the Company has put in place appropriate physical, technological and organizational measures to safeguard and secure the information collected by the Company. All customer account numbers are stored on a computer server that is not connected to the Internet. After you enter your card number or personal information on-line, the information is automatically transferred to a secure server using a one-way interface.

H) Openness:
Through this Privacy Policy we provide information about the Company's policies and practices regarding the collection, use, safeguard and disclosure of personal information held by us.

I) Individual Access:
You may request access to your personal information held by us. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access.

J) Challenging Compliance:
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. We are committed to resolving disputes in a timely manner. We will investigate your complaint and respond via email, facsimile or telephone.

4. CONTACT INFORMATION
Our Information Officer can be reached at:
416.840.1466
Toll Free: 1.800.724.5685 | Fax: 647-722-2963
Tele-Support: 416.295.5350
1278 St. Clair Ave. W. Suite 14
Toronto, ON
M6E 1B9
Canada

5. GENERAL INQUIRIES
For general inquiries about privacy legislation and policies in the private sector, you may contact:
The Office of the Privacy Commissioner of Canada
112 Kent Street , Ottawa, Ontario, Canada K1A 1H3
Telephone: 1 (613) 995-8210
Toll-free: 1 800 282-1376
Facsimile: 1 (613) 947-6850
Web site: www.privcom.gc.ca

6. CHANGES TO PRIVACY POLICY
The Company reserves the right, at its sole discretion, to modify this Privacy Policy at any time, and such modifications shall be effective immediately upon the posting of same.

7. UNAUTHORIZED ACTIONS
The Company takes commercially reasonable precautions to ensure your privacy on the terms contained within this Privacy Policy, however, it cannot totally prevent unintended disclosures by such means as hackers and other unauthorized individuals, and inadvertent or illicit employee actions.