SNAILE INC. PRIVACY POLICY

 
This Privacy Policy applies to all of our operations in Canada or operations in connection with Canada, unless we have provided you with a separate privacy statement for a particular product, service or activity.

This Privacy Policy does not apply to third-party applications, websites, products, services or platforms that may be accessed through third-party (i.e., non-Snaile) links that we may provide to you. These third-party sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any Personal Information that you provide to these websites will be governed by the third party’s own privacy policy. We cannot accept liability for the actions or policies of these third-party sites, and we are not responsible for the content or privacy practices of such sites.

 
This Privacy Policy applies when you interact with us by doing any of the following:

• Access or otherwise make use of our services;
• Visit our website (as defined herein); or
• Contact us or receive any communication from us, including newsletters, emails, calls, or texts.

 
Meaning of Personal Information
Personal Information may include your name, mailing address, e-mail address, telephone number, and other contact information you provide to us.

Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work e-mail address.

Personal Information also does not include information that has been de-identified, anonymized, or aggregated in such a way that there is no serious possibility it can be used, or where it could not be used in reasonably foreseeable circumstances, to identify an individual whether on its own or in combination with other information.
 
Personal Information We Collect

For individuals who are located in Canada who use our products or services, we may collect certain Personal Information about you, including (without limitation) the following:

• Registration information such as your name, building address, unit number, email address, and phone number.

For property managers and locker owners located in Canada, we may collect certain additional Personal Information from you including (without limitation) the following:

• Payment information such as your billing address, phone number, credit card, debit card or other payment method.

For individuals located in Canada who visit our website and located at https://www.snaile.com/, https://www.snailelockers.com or any of our related websites, including to access the Snaile services (collectively, “our website”), we may collect information from you or from your activities on our website as further described in the “Device and Usage Data” section below.

For individuals located in Canada who otherwise interact with us, whether in person, by phone or email, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, who respond to surveys and questionnaires, or who submit testimonials or other feedback, we may collect information that you provide to us during these interactions.

• This information may include your name, e-mail address and other contact information.

Device and Usage Data
When you visit our website, we automatically collect and store information about your visit using “cookies” (i.e., files which are sent by us to your computer) or similar technology, or enlist third party services which use cookies to track your preferences and activities on our website. 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 use “web beacons” to better understand how our website is being used and to enhance your online experience. Web beacons are Internet tools that help us determine, for example, whether a page of our website has been viewed.

We also process information when you use our services and products. This information may include (without limitation):

• Login information
• IP address
• Time stamps
• Authentication records
• Location information
• Web terms or searches that led you to our website

 
Information We Collect From Third Parties
We may receive your Personal Information from third parties such as companies subscribing to Snaile services, partners and other sources. This information is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your Personal Information is handled by third parties. As always, you have the right to review and rectify this information. If you have any questions you should first contact the relevant third party for further information about your Personal Information. Where that third party is unresponsive to your rights, you may contact the Data Protection Officer at Snaile using the contact information in the “Contact Us” section below and we can assist you.

We collect, use and disclose your Personal Information with your consent to provide, maintain, and develop our products and services and understand how to improve them.

These purposes include:

• To deliver your product or service
  • To fulfill orders including electronic and non-electronic shipment; and
  • generating de-identified data to conduct research and analysis related to our business, products and services
• Building a Safe and Secure Environment
  • To improve the effectiveness and safety of the Snaile services;
  • To verify or authenticate your identity;
  • Investigate and prevent security incidents such as breaches, attacks and hacks;
  • To respond to inquiries and other requests; and
  • Investigating legal claims.
• Providing, Developing, and Improving our Products and Services
  • Deliver, maintain, debug and improve our products and services.
  • Enable you to access Snaile services and set up accounts.
• Provide you with technical and customer support.
  • providing you with information that we think may interest you, including information about our products and services

We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable Canadian privacy laws.

We may use the information that we collect to advertise third party products and services, or targeted advertising of Snaile products and services, across third party websites or service offerings. You may opt-out by contacting us directly using the contact information in the “Contact Us” section below.

 
We collect, use and disclose your Personal Information with your consent or as permitted or required by Canadian privacy laws. How we obtain your consent (i.e., the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the Personal Information in question. 

If you provide Personal Information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.

 
We rely on third-party service providers to deliver, perform a variety of services on our behalf and help us improve our products and services. We may share your Personal Information 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 Information, please contact us by using the information in the “Contact Us” section below.

If we provide your information to service providers, then we require that the service providers keep your Personal Information secure, and only handle it for limited purposes for which it is provided. We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their own purposes. If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your Personal Information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets, or other business transaction.
If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

 
We are constantly deploying and updating our technical and organizational security measures to protect against loss, misuse or alteration of Personal Information that we have collected or received from a third-party. To the extent permitted by law, Snaile may 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 Information, and network access control technology to limit access to the systems on which Personal Information is stored, and we monitor for possible vulnerabilities and attacks. Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you become aware that there has been a breach in security of any of the Personal Information 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.
 
Opting Out of Communications
If you no longer want to receive marketing-related communications from us, you may opt-out of receiving marketing-related communications by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us via the instructions provided in the “Contact Us” section below, or by contacting the organization that provided you with access to the Snaile services (e.g., your property manager).

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

You may opt-out of receiving text messages by replying with the keyword STOP. For more information on text messaging you may also reply with the keyword HELP for details to contact our support team.

 
We will only retain your Personal Information 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 Information, we will remove it from our systems and / or take steps to anonymize it.

 
Our products and services are not intended for children under the age of 16. We do not knowingly collect Personal Information from children under the age of 16. Children under the age of 16 should not use our products and services and should not provide us with their Personal Information.

 
Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations. These rights may include:
 
Access

You have the right to request a copy of the Personal Information that we have collected, used or disclosed, and we will provide you with any such Personal Information to the extent required by applicable laws.
 
Accuracy

You have the right to have incomplete or inaccurate Personal Information that we have in our records about you rectified. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your Personal Information. Any such identifying information will be used only for this purpose.

If you wish to withdraw your consent to our collection, use or disclosure of your Personal Information, please contact us using the contact information in the “Contact Us” section below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide you with certain products or services.

 
You can make a request to exercise any of these rights in relation to your Personal Information by sending the request to our Data Protection Officer via the instructions provided in the “Contact Us” section below.

For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.
 
International Transfer and Storage of Information

Your Personal Information may be stored and processed at our offices in Canada or at the offices of our third party service providers, or at data centers managed by us or third party service providers, in Canada and the United States. Other jurisdictions may have different data protection rules than Canada. While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located. Those laws may require disclosure of your Personal Information to authorities in that country. For written information about our policies and practices regarding service providers outside of Canada, contact our Data Protection Officer using at the contact information in the “Contact Us” section below.

 
This Privacy Policy is current as of the “last updated” date, which appears at the bottom of this page. We may modify this Privacy Policy at any time and we will provide you of notice of changes to this Privacy Policy. If we make changes to this Privacy Policy then we will post an updated version of this Privacy Policy on our website. When changes are made to this Privacy Statement they will become effective on the date set out in any notice or on the “updated” date as published in a revised Privacy Policy posted on our website.

 
You may direct any questions or enquiries with respect to our Privacy Policy or our practices by contacting our Data Protection Officer:
Snaile Inc.,
Attention: Data Protection Officer
14-1 Crescent Road, Huntsville, ON P1H 1Z6
Telephone: 1-833-200-5169
Email: privacy@snailelockers.com
 
Date of last update: Sept. 10, 2021