Privacy Policy

Last Modified: May 6, 2020

Effective Date: May 6, 2020

TERMS

This privacy policy as well as our Terms of Service found here: https://snappysplit.com/termsOfService.php ("Terms of Service") govern your access of https://snappysplit.com (and subsites) as well as the Snappy Split application for iOS and Android (collectively known as "Products") , whether: (a) accessed on a computer connected to the internet at https://snappysplit.com (and subsites) ("Sites") (b) on the Stockley Consulting Inc. owned social media properties (including those carrying the Snappy Split name); or (c) by mobile device, either through an app download or by accessing the Sites (individually and collectively, (a), (b) and (c) are the Products), as owned and operated by Stockley Consulting Inc., a Canadian corporation having its location at 4871 Yorkshire Avenue, Mississauga, Ontario, L4Z4G8 (referred to in these Terms as "we", "us", "Stockley Consulting" or the "Company").

INTRODUCTION

We are committed to maintaining the confidentiality, integrity and security of any personal information (as defined below) about users of our Products. We aim to deliver to our users compelling Products, while respecting your privacy expectations and protecting your personal information. To demonstrate our commitment to protecting your privacy, we have developed this privacy policy ("Privacy Policy"), which describes how we will collect, use, disclose and protect your personal information through our Products. By accessing and/or using our Products, you agree to all the terms and conditions of this Privacy Policy and the Terms of Service and which are incorporated here by reference. If you do not agree to all the terms and conditions of this Privacy Policy and the Terms of Service, do not use our Products.

AMENDMENTS

We may amend or change this Privacy Policy at our sole discretion at any time, and in accordance with the amendment provisions set out in the Terms of Service. The use of the information we collect at any given point is subject to the Privacy Policy in effect at the time of collection. Your continued use of this Website and the Products after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your Personal Information.

WHAT INFORMATION DO WE COLLECT FROM YOU?

Information You Give to Us

We receive, store and process information, including personal information, that you make available to us when accessing our Products. Examples include but are not limited to:

  • When you fill in a form on our Products, providing personal details, uploading images, expenses or other similar actions;
  • When you access and view information on Snappy Split
  • Your responses to surveys that we may ask you to complete for research purposes
  • Records and copies of your correspondence (including email address), if you contact us

By collecting, storing and processing this information, we are able to provide you with the best possible content and experience when accessing our Products.

Information We Collect Automatically

When you use our Products, we automatically collect, store and process certain data. This data is usually about your device (or browser, or other technology), as well as usage of our Products. The information we collect automatically is statistical information and may include Personal Information and we may maintain it or associate it with Personal Information we collect in other ways that you provide to us, or receive from third parties. It helps us to improve our Website and our Products to deliver a better and more personalized service, including by enabling use to: estimate our audience size and usage patterns, store information about your preferences allowing us to customize our Website and our Products according to your individual interests, speed up searches, and recognize you when you return to our Website and our Products. Furthermore, we may collect or track the following:

  • We collect usage stats from you, telling us how you use our Product and other behavioural data within our Products;
  • We may collect your IP address and some device or browser data;
  • We may collect location data if permitted by you, while using our Products;
  • We use cookies and other similar technologies, such as mobile application and other device identifiers in our Products. We may also allow our business partners, including Google, to use their cookies and other tracking technologies in our Products (refer to "3rd Party Data Collection" for details). As a result, when you use our Products, you will provide or make available certain information to us and our business partners.
  • While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a "Do Not Track" signal in the HTTP headers from your browser or mobile device.
3rd Party Data Collection

We use certain 3rd party services for our Products to enhance the experience and quality of what we offer to users.

  • We currently use Google Analytics in our Products to provide additional usage statistics for outlining how our Products are used. Google Analytics may place a cookie or other tracking device on your device or browser to facilitate collection of these usage statistics of our Products. We may in the future use a different 3rd party product to collect usage statistics for our Products. It is very likely that any such tool may place a cookie or other tracking device onto your device or browser to measure usage of our Products.
  • We currently use SendGrid to manage our opt-in mailing list. When you provide an email address or other information that confirms your desire to be placed on our mailing list, the information you provide to sign up to the mailing list will be stored and managed by SendGrid. We may in the future use a different 3rdparty product to manage our mailing list. In that case, the information you provide to sign up to the mailing list will be stored and managed by the 3rd party.
  • We currently make use of GMail from Google to manage communication with our users. When you contact us through our Products, a record of the communication(s) will be stored and managed by GMail. We may in the future use a different 3rd party product to manage communication(s) with our users. In that case, a record of the communication(s) will be stored and managed by the 3rd party.
  • We offer the ability for you to share information through various communications channels including SMS messaging, email and social media services. Any data you share through these channels is between you and the person or persons in question (for example, usernames, passwords, your contacts, and so on) – we do not see or record any of that information.
  • When you choose to upload an image of a receipt to our Products, that image is stored on our servers until such time as you request that we delete it or we elect to remove it from our servers. You may contact us for assistance to remove the images that you have uploaded if you are having difficulty doing so yourself.
  • If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our own Products or Services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request.
  • Google's use of advertising cookies enables it and its partners to serve ads to you based on your visits to our Sites and/or other sites on the Internet as well as based on your usage of our Products. You may opt out of personalized advertising by visiting Google's Ad Settings website or by visiting www.aboutads.info

HOW DO WE USE AND DISCLOSE YOUR PERSONAL INFORMATION?

We use your information to improve our services and provide better content to users of our Products.

We may share your personal information with affiliates, third-party vendors, consultants or other service providers (collectively "Service Providers") who help us to run our operations or to otherwise fulfill your request or as required by law. Our Service Providers are restricted from using your personal information in any way other than for the service they are providing. We ensure that such third parties maintain reasonable and appropriate safeguards.

In general, we may use your personal information to:

  • enforce our Terms of Service;
  • provide customer service and support, administrative messages, resolve disputes between You and Us, and troubleshoot problems including helping third-party service providers fulfil their functions;
  • fulfill your requests for certain features of our Products;
  • customize, measure, and improve our Products;
  • offer or provide you with products and services including providing you information relating to technical notices, updates, and security alerts;
  • provide personalized advertising that will hopefully be of greater interest to you;
  • inform you of targeted marketing, service updates, and promotional offers if you have opted into such communications;
  • assist us to measure our performance and to share performance information with others;
  • carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection;
  • comply with legal or regulatory requirements (as described below); and
  • fulfill other purposes, subject to your explicit consent.

From time to time, we may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy, except as specifically set forth in the rules for those contests, giveaways or promotions. From time to time, we may also ask you to participate in surveys designed to help us improve our Products. Any personal information provided to us in connection with any survey will be used only in relation to that survey and as elsewhere set forth in this Policy.

In the event that the Company, or all or a portion of our business, or one or more of its divisions, is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, liquidation or another similar transaction, your personal information shall be one of the transferred assets.

We may retain your personal information while you have an account with us and thereafter for as long as we need it for purposes not prohibited by applicable laws and subject to the provisions in our Terms of Service. This data may be retained for approximately 12 months after your relationship with us has been terminated.

Notwithstanding the foregoing, we reserve the right (and you authorize the Company) to share or disclose your personal information when we determine, at our sole discretion, that the disclosure of such information is necessary or appropriate:

  • to enforce our rights against you or in connection with a breach by you of this Privacy Policy or the Terms of Service;
  • to investigate or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others;
  • to prevent prohibited or illegal activities; or
  • when required by any applicable law, rule, regulation, subpoena, or other legal process.

TRANSFERRING YOUR PERSONAL INFORMATION

As stated, we may transfer Personal Information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website and Product improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy.

We process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada.

LINKS TO OTHER WEBSITES

Links to sites controlled or operated outside of our domain (each individually a "Third-party Site" and collectively the "Third Party Sites") are provided as a convenience to you only and do not imply an endorsement by us of a Third Party Site or the company it purports to represent. We do not assume any responsibility for information and materials found on, or the privacy practices of, a Third Party Site. This Privacy Policy does not apply to a Third Party Site.

SECURITY MEASURES

We take your privacy very seriously. To keep your personal information secure, you are required to safeguard your access information in accordance with the Terms of Service.

In addition, we restrict unauthorized access through protective policies, procedures, and technical measures, including:

  • providing reasonable physical and electronic safeguards with regard to the storage of personal information;
  • limiting access to your personal information to those employees or contractors who we reasonably believe need to come into contact with that information to provide products or services to you or in order to do their jobs; and
  • governing employees and other contractors by strict standards and policies to ensure that personal information is secure and treated with the utmost care and respect.

Please note that no data transmission over the internet or otherwise can be guaranteed to be completely secure. As a result, while we strive to protect your personal information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.

If you have a security related concern, please contact us at the contact details provided below. We will work closely with you to ensure a quick and personal response to your concerns.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information to fulfill the purposes we collected it for, which is approximately 12 months after your relationship with us has been terminated, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.

You can review and change your Personal Information by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us a message using the contact information below to request access to, correct, or delete any Personal Information that you have provided to us. [We cannot delete your personal information except by also deleting your user account.] We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your Personal Information, subject to exceptions set out in applicable privacy legislation. Examples include:

  • Information protected by solicitor-client privilege.
  • Information that is part of a formal dispute resolution process.
  • Information that is about another individual that would reveal their Personal Information or confidential commercial information.
  • Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact us through the contact information provided below.

DISCLAIMER

IF YOU CHOOSE TO ACCESS OUR PRODUCTS, YOU DO SO AT YOUR OWN RISK, AND ARE RESPONSIBLE FOR COMPLYING WITH ALL LOCAL LAWS, RULES AND REGULATIONS. WE MAY LIMIT THE AVAILABILITY OF OUR PRODUCTS IN WHOLE OR IN PART, TO ANY PERSON, GEOGRAPHIC AREA AND/OR JURISDICTION WE CHOOSE, AT ANY TIME AND IN OUR SOLE DISCRETION. OUR PRIVACY POLICY DOES NOT COVER THE INFORMATION PRACTICES OF OTHER COMPANIES AND ORGANIZATIONS WHO ADVERTISE OUR SERVICES, AND WHO MAY USE COOKIES, PIXEL TAGS, AND OTHER TECHNOLOGIES TO SERVE AND OFFER RELEVANT ADVERTISEMENTS.

INDIVIDUALS YOUNGER THAN 13 YEARS OF AGE ARE PROHIBITED FROM ACCESSING OR USING OUR PRODUCTS.

NOTIFICATIONS

In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we may notify you by the primary notification method we have on file.

We will never send messages to customers requesting confidential information such as passwords, credit card numbers, or social security or social insurance numbers. Please do not act on any such emails as you may compromise your personal information by replying or by following links to a fraudulent website.

MISCELLANEOUS

If any portion of this Privacy Policy is deemed unlawful, void or unenforceable by any arbitrator or court of competent jurisdiction, this Privacy Policy as a whole shall not be deemed unlawful, void or unenforceable, but only that portion of this Privacy Policy that is unlawful, void or unenforceable shall be stricken from this Privacy Policy. The insertions of headings are for convenient reference only and are not to affect the interpretation of this Privacy Policy.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

If you have questions or concerns regarding our policy or practices, please contact our privacy officer by filling out the contact form here or at the following address:

Stockley Consulting Inc.
4871 Yorkshire Avenue
Mississauga, Ontario
L4Z 4G8

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this Privacy Policy please contact us using the contact information listed above.

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