At Snaile (“us”, “we”, “our” or the “Company”) we value your privacy and the importance of safeguarding your data. This Privacy Statement describes our privacy practices for the activities set out below. As per your rights, we inform you how we collect, store, access, and otherwise process information relating to individuals. In this Privacy Statement, “Personal Data” refers to any information that on its own, or in combination with other available information, can distinguish an individual.
We are committed to protecting your privacy in accordance with the highest level of privacy regulation. As such, we follow the obligations under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and the applicable provincial legislation.
This Privacy Statement applies to the Snaile websites, domains, applications, services, and products.
We may process your Personal Data on behalf of our customers, such as property managers and owners of the building in which you live or work, and in which a locker is installed. When we process Personal Data on behalf of such property managers or locker owners, that Personal Data is subject to that third party’s own separate privacy policies. We do not have any control over how your Personal Data is handled by third parties. If you have any questions about how the building in which you live, work or shop uses Snaile services and products, you should contact the property manager of that building. If that third party is unresponsive, you may contact the Data Protection Officer at Snaile (contact details below) and we can assist you in contacting the relevant third party.
This Privacy Statement applies when you interact with us by doing any of the following:
Data You Provide
When you are signed up to use our services, we collect the following data:
For property managers and locker owners, we additionally collect the following personal data:
If you provide us, or our service providers, with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contacting us” section below.
Device and Usage Data
When you visit a Snaile website, we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer), or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help Feature on most browsers will provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.
We also process information when you use our services and products. This information may include:
Data We Collect from Third Parties
We may receive your Personal Data from third parties, such as property managers and owners of the building in which you live or work, and in which a locker is installed. However, as noted above, where we are processing your Personal Data on behalf of such property managers or locker owners, your Personal Data is subject to that third party’s own separate privacy and data collection policies. We do not have any control or input on how your Personal Data is handled by third parties.
Our websites and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which you should review to better understand those third parties’ privacy practices.
We collect and use Personal Data about you with your consent.
We may also receive your Personal Data from third parties, such as property managers and locker owners of the building in which you live or work, and in which a locker is installed. In that case, we collect and use your Personal Data on behalf of such property managers or locker owners, and they are responsible for obtaining your consent. The purposes for collecting, using and disclosing your Personal Data include:
We do not use the personal data we collect to engage in interest-based or behavioral advertising of Snaile products and services across third-party websites or service offerings. We may engage in interest-based or behavioral advertising in connection with your use of our website, newsletters, and other services, and across third-party websites or service offerings when you leave our website or other services.
Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business for example against fraud. Consent will be required to initiate services with you. New consent will be required If any changes are made to the type of data collected. Within our contract, if you fail to provide consent, some services may not be available to you.
We may use or disclose your Personal Data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, to protect our rights or property, or to allow us to pursue available remedies or limit the damages that we may sustain. Where possible and practical to do so, we will tell you in advance of such disclosure.
We may use a third-party service provider, independent contractors, agencies, or consultants to deliver and help us improve our products and services. We may share your Personal Data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services. For further information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section below.
We have deployed technical, organizational and physical security measures to protect your Personal Data against loss, theft, unauthorized access, use, alteration, or disclosure. To the extent permitted by law, Snailemay review, scan or analyze communications for fraud prevention, investigation, regulatory compliance, risk assessment, research, product development, and customer support purposes. We use industry-standard encryption technologies when transferring and receiving Personal Data, and network access control technology to limit access to the systems on which Personal Data is stored, and we monitor for possible vulnerabilities and attacks. If you become aware that there has been a breach in security of any of the Personal Data that we store or that is stored by our third-party service providers, please contact us via the instructions provided in the Contact Us section below.
We retain your Personal Data for as long as necessary for the purpose for which that data was collected and to the extent required by applicable law. When we no longer need Personal Data, we will remove it from our systems and / or take steps to anonymize it.
We will not knowingly collect Personal Data from children under the age of 16.
Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations. These rights may include:
You have the right to request a copy of the personal data we hold about you.
You have the right to request that incomplete or inaccurate Personal Data that we process about you be rectified.
However, when we are processing Personal Data on behalf of one of our customers, we conduct our activities in accordance with their instructions and pursuant to our contractual arrangements with them. In such circumstances, that customer is usually in control of your Personal Data, and you should please contact that customer (i.e. the Subscribing Property) who is responsible for your locker.
If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge, such as where you wish to opt out from marketing messages that you receive from us. If you wish to withdraw your consent, please contact the property or location manager who is responsible for your locker.
You can make a request to exercise any of these rights in relation to your Personal Data by sending the request to our privacy team by using the form below.
For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.
We may modify this Privacy Statement at any time. If we make changes to this Privacy Statement then we will post an updated version of this Privacy Statement on our website at www.snailelockers.com. When using our services, you will be asked to review and accept our Privacy Statement. In this manner, we may record your acceptance and notify you of any future changes to this Privacy Statement.
You may direct any questions, enquiries, or complaints with respect to our Privacy Statement or our practices, or make an access or correction request by contacting:
Snaile Inc. Privacy Officer
Address: 14-1 Crescent Road, Huntsville, ON P1H 1Z6
As noted above, Snaile is a service provider to other organizations. If your building or an organization that you work for or do business with uses Snaile’s services and products, and you have questions about your Personal Data, you should first contact the property manager of the building in which you live or work, and in which a locker is installed, or the relevant organization you work for or do business with. If that third party is unresponsive, you may contact the Data Protection Officer at Snaile and we can assist you in contacting the relevant third party.
If you have any questions about how the building in which you live, work or shop uses Snaile services and products, you should contact the property manager of that building. If that third party is unresponsive, you may contact the Data Protection Officer at Snaile (contact details above) and we can assist you in contacting the relevant third party.
Date of last update: January 19, 2022