SmartWay LLC believes it is important to be transparent about the privacy of your personal information. The SmartWay LLC website and associated applications (the "Website") is comprised of various web pages, applications, and features operated by SmartWay LLC. The terms "we" "our" and "us" refer to SmartWay LLC, its subsidiaries, and affiliates, and the terms "you" or "your" refer to any individuals who access this Website. This privacy policy is intended to inform you about what kind of information we gather through our Website and what we do with that information. By using this Website, or continuing to use this Website, you consent to this privacy policy in full and also to our Terms and Conditions of Use.
When you visit our Website we issue a "cookie" file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information. Cookies enable us to: improve the use of our Website; to recognise your computer; to store settings to help facilitate your use of our Website; and to deliver a better and more personalised service. Some of the cookies we use are essential for the Website to operate and have already been set. You may delete and block all or some cookies from this Website. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website. If your computer is configured to accept cookies we will be able to provide time saving functionality such as the ability to pre-fill the enquiry forms with your details, thus preventing the need to re-input them each time you need to contact us.
We automatically log generic information about your computer and your computer's connection to the Internet which we call "session data". Session data consists of things such as device information, IP address, operating system and browser software information, and the activities conducted by you while on our Website. An IP address is a number that lets computers attached to the Internet, such as our web servers, know where to send data back to the user, such as the pages of the Website the user wishes to view. We collect session data because it helps us to analyse such things as what vehicles visitors are likely to click on most, the way visitors are clicking through the Website, how many visitors are surfing to various pages on the Website, how long visitors to the Website are staying and how often they are visiting. It also helps us diagnose problems with our servers and lets us better administer our systems. It is possible to determine from an IP address a visitor's Internet Service provider (ISP) and the approximate geographical location of his or her point of connectivity. We also use session data to help prevent fraud and unauthorised use of our Website.
Your payment provider may transmit information about the payment that we may collect or process.
Our partners may create transactions on your behalf, in these situations the information that can be provided is the same as the information we may request, collect and process from individual users. Whilst our partners platforms will be governed by their own privacy policy, any personal information that is transferred to our platform will be treated and protected as though it was submitted by a user.
We use information technology security measures to protect your personally identifiable information that is transmitted through our Website. We also use information technology security features to protect the personally identifiable information stored by us. However, in spite of our security efforts and protocols, we cannot guarantee that information sent to us through our Website will be secure. Therefore, we make no warranties or representations regarding the security of your information.
When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used.
Our Website may provide links to other websites for the convenience of our Website users. Our Website may also make use of widgets, embeds, social media, or other third party features that are hosted by a third party or hosted directly on our Website. Your interactions with any link or third party widget, embed, social media, or other feature are governed by the privacy policy of the third party providing the widget, embed, social media, or other third party feature, or the privacy policy of the linked website. The privacy policies of third parties may be substantially different than this privacy policy, and any personally identifiable information collected by or provided to third parties will be guided by the privacy policies of such third parties. We neither own nor control third party websites, widgets, embeds, social media, or other features that are accessible through this Website. Therefore, before visiting the website of a third party, or making use of a third party feature on our Website, whether by means of widget, embed, social media feature, or otherwise, you should first consult that third party's privacy policy (if any) and inform yourself of the privacy practices (if any) used by that third party.
The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:
The 'lawful processing' grounds on which we will use personal information about our users are (but are not limited to):
We may disclose your personal information to third parties that participate in a transaction with you, including but not limited to:
The personal information of users may be held or processed on our behalf outside Australia, including 'in the cloud', by our third party service providers. Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions.
Our third party service providers include:
We may also disclose your personal information to third parties for the following purposes:
As we are a global company, with offices around the world, your personal information may be processed by staff in any of our offices. Escrow currently has offices in The United States of America, Australia, The Philippines, Canada, and Argentina.
You have the right to request access to the personal information Escrow holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer.
You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance please contact our customer support.
You have a number of other rights in relation to the personal data Escrow holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, provide protection for the legitimate users, and meet our legal obligations - these data uses are protected against the below rights.
You have the right to:
Direct marketing and profiling - users can unsubscribe by following the link included at the bottom of each email.
Erasure - Most personal information cannot be deleted as they are used to support contracts between users, document financial transactions, and are used in providing protection for users on the platform. In the case of non-personal data that can be linked with personal data, it will either be erased or otherwise anonymised from the personal data.
Temporary restriction to processing - under certain circumstances you may exercise this right, in particular if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting our privacy officer.
Unless stated above, users may exercise any of the above rights by contacting our Privacy Officer.
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