Politique de vie privée

Part A: Introduction

1. About Smartbills

1.1 At Smartbills, we are dedicated to providing innovative and practical solutions that address real-world challenges.

1.2 The Smartbills App offers access to these solutions, streamlining your receipt management experience.

1.3 The Smartbills Loyalty Program aggregates merchant-specific loyalty programs, allowing you to collect loyalty points at a variety of merchants, retailers, and service providers using the App.

1.4 As part of the Smartbills App, we provide a digital transaction record functionality. Our solution replaces paper receipts with feature-rich, digital transaction records that may be delivered through a bank partner’s mobile application, a merchant partner’s mobile application, the Smartbills mobile application, or via SMS or email ("Digital Receipts").

2. Introduction

2.1 Smartbills Technologies Inc. (referred to as "we", "us", or "our") recognizes the importance of protecting your privacy and safeguarding personal information.

2.2 At Smartbills, protecting your data is of utmost importance. We respect your privacy rights in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws, such as Quebec’s Act Respecting the Protection of Personal Information in the Private Sector. We comply with all requirements of Canadian privacy laws regarding the collection, management, and disclosure of your personal information.

2.3 The term "personal information" is defined under Canadian privacy laws. In general, personal information refers to any information about an identifiable individual, which could include your name, address, telephone number, email address, or any other data that can identify you.

2.4 By using and accessing the Smartbills website at https://Smartbills.io (and any sites related to that domain) (the "Site"), the Smartbills App, and/or our services, you consent to the terms and conditions of this privacy policy.

Part B: Smartbills Loyalty Program

3. What personal information do we collect, hold, use, and disclose?

3.1 We may collect the following types of personal information:

Your name;
Your contact information, such as your email address, telephone number, or postal address;
Your age or date of birth;
The merchant loyalty programs you have signed up for or enquired about, along with any additional information necessary to enroll in specific merchant loyalty programs;
Information collected through the use of cookies and other tracking technologies, including button clicks, screens viewed, and app state changes;
Any additional information relating to you that you provide directly through the Smartbills App or indirectly through the use of our Smartbills App, the Site, social media, or online presence, through our representatives, or otherwise.

4. For what purposes do we collect, hold, use, and disclose your personal information?

4.1 We collect personal information about you to perform our business activities and provide you with the highest quality of customer service. In particular, we collect, hold, use, and disclose your personal information for the following purposes:

To provide services to you;
To send communications to you;
To respond to inquiries and provide information or advice about our services;
To assess the performance of our Site and the Smartbills App and to improve their operation;
To conduct business administration and processing functions, including sharing personal information with contractors, service providers, or other third parties;
For marketing, planning, product or service development, quality control, and research purposes;
To update our records and keep your contact details current;
To process and respond to any complaints made by you;
To enforce our legal rights and protect the rights of third parties;
To comply with any law, regulation, lawful order, decision, or direction of a regulatory authority, or in cooperation with any governmental authority.

5. Who will we disclose your personal information to?

5.1 We may disclose your personal information to:

Merchant partners, where you have signed up for the merchant’s loyalty program;
Our employees, contractors, or service providers for the purposes of operating the Smartbills App and our business activities;
Suppliers and other third parties with whom we have commercial relationships for business, marketing, and related purposes;
Government agencies, regulatory bodies, law enforcement agencies, or similar entities, as required or authorized by law;
Accountants, auditors, lawyers, and other professional advisors who require access to information;
Third-party acquirers in the event that we sell or transfer all or part of our business or assets; and
Any organization for an authorized purpose with your express consent.

Part C: Smartbills Digital Receipts

Smartbills Digital Receipts delivered in Bank partners’ mobile application‍

We provide Digital Receipts to customers of partnering Banks directly to their mobile banking application (subject to this feature being activated). We do not collect personal information to deliver Digital Receipts in Bank partners’ mobile applications, in other words, the data we collect is not identifiable to you. The feature works by linking your anonymised Bank transaction details with your anonymised Merchant transaction details to render your Receipts inside your mobile banking application. Bank partners and Smartbills exchange information using a randomly generated customer identifier meaning that Bank partners do not share your identity with Smartbills.

Partnering Banks are financial institutions that issue credit cards or debit cards, or an entity providing other payment method, to customers and has entered into, and remains a party to, a services agreement with Smartbills to provide Digital Receipts to its customers (Bank).

6. What personal information and/or data do we collect, hold, use and disclose?

6.1 As part of this service, we may collect the data outlined below:

Type of data	Data Description	How data is collected
Anonymised information about transactions you made with your registered Bank cards enabling us to match those with your corresponding Merchant receipts, including:
Bank transaction details (anonymised)	anonymised account details payment authentication details transaction time, amount and currency other transaction metadata	Supplied by Bank partners
Anonymised information typically available on your tax receipts enabling us to surface such information inside your Receipts and to match your corresponding Bank transactions, including:
Merchant receipt details (anonymised)	your matching transaction details: details of Merchant you purchased from details of items you purchased your loyalty and membership number where relevant* your business number (BN) where relevant* * To protect your privacy, your loyalty or membership number and BN are stored in encrypted form.	Supplied by Merchant partners
Your anonymised demographic details:
Customer demographics (anonymised)	age range; gender; and approximate area of residence	Supplied by Bank partners
Information about how you access and use our services, including:
Usage data (anonymised)	the time when you access Digital Receipts your device type and operation system (iOS, Android) your feature use (including receipt exports, receipt searches and interactive links)	Supplied by Bank partners

6.2 At each stage, data is collected (either from Bank partners or Merchant partners) electronically using RESTful Application Programming Interface (API) technology.

7. How do we use the information collected to provide Digital Receipts in Bank partners’ mobile application?

7.1 We will only use the information collected where we have a legitimate business purpose to do so and in accordance with the contractual terms agreed with our relevant Bank and Merchant partners. Below is an outline of the purposes for which we may use the information we collect:

to generate Digital Receipts and display those in Bank partners mobile application;
to perform internal analysis, helping us improve and develop our services;
to provide Merchant and Bank partners with analytics products and insights using anonymised data;
to conduct general administration of the business (including preparing partners’ invoices, accounting, finance, answering enquiries from partners and their customers);
to monitor and conduct activities related to the security of our informatic systems and services;
to comply with our legal and regulatory obligations and exercise our legal rights; and
to provide any additional services you have consented to (including additional Digital Receipt integrations with third-party services such as expense and financial management tools).

8. Who will we disclose your personal information to?

8.1 We may disclose the information we collect to the following:

bank partners for the purpose of surfacing the Digital Receipts inside their mobile application;
third-parties you have consented to share information with (including third-parties who provide services integrated with Digital Receipts such as expense and finance management tools);
Merchants that you shop with to access Digital Receipts issued on their behalf and de-identified demographic information about customers who transacted with them;
accountants, auditors, lawyers and other professional advisors we engage who require access to information;
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law;
third-party service providers to whom we may outsource certain organisational functions; and
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

Smartbills Digital Receipt - Digital Receipts delivered via SMS, email or Merchant mobile applications

We provide Merchants with the ability to deliver Digital Receipts to their customers via email, SMS or mobile applications owned, operated, or controlled by a Merchant.

9. What personal information and/or data do we collect?

9.1 When providing this service, Smartbills may collect the information outlined below:

Type of data	Data description	How data is collected
Contact details	Mobile number, email enabling us to send Digital Receipts via SMS, Email	Supplied by Merchant partners
Anonymised information typically available on a tax receipt enabling us to surface such information inside the Digital Receipts, including:
Merchant receipt details (anonymised)	Your anonymised transaction details details of Merchant you purchased from details of items you purchased your loyalty and membership number where relevant* your business number (BN) where relevant* * To protect your privacy, your loyalty or membership number and BN are stored in encrypted form.	Supplied by Merchant partners
Anonymised information about how you access and use our services, including:
Usage data and cookies (Anonymised)	the time when you access Digital Receipts the IP address used to access our web hosted receipt any cookies	Collected via Sites

10. How do we use the information collected to provide Digital Receipts in Merchant partners’ mobile applications, email or via SMS?

10.1 We will only use the information collected where we have a legitimate business purpose to do so and in accordance with our Merchants’ services agreements. Below outlines the purposes we may use the information we collect:

to generate Digital Receipts and deliver those via email, SMS or to Merchant to make available via their mobile application (Digital Receipts are hosted on our Site and Smartbills provides a unique link to access them);
to perform internal analysis helping us improve and develop our services;
to provide Merchants with analytics products and insights using anonymised data;
to conduct general administration of the business (including partners’ invoice, accounting, finance, answering partners and their customers’ enquiries);
to monitor and conduct activities related to the security of our systems and services; and
to comply with our legal and regulatory obligations and exercise our legal rights.

11. Who will we disclose your information to?

11.1 We may disclose the information we collect to the following:

Merchants that you shop with to access Digital Receipts issued on their behalf;
accountants, auditors, lawyers and other professional advisors we engage who require access to information;
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law;
third-party service providers to whom we may outsource certain organisational functions; and
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

Smartbills Digital Receipt - Digital Receipts delivered via Smartbills App

We provide Merchants with the ability to deliver Digital Receipts to their customers via the Smartbills App.

12. What personal information and/or data do we collect?

12.1 When providing this service, Smartbills may collect the information outlined below:

Type of data collected	Data description	How data is collected
Contact details	Name Email Phone number	Supplied by you upon signing up to the Smartbills App
Information typically available on a receipt enabling us to surface such information inside the Receipts, including:
Merchant receipt details	Your transaction details details of Merchant you purchased from details of items you purchased your loyalty and/or membership number where relevant	Supplied by Merchant partners
Information about how you access and use our services, including:
Usage data and cookies (Anonymised)	information you provide in free text fields, such as surveys, search terms or chat functions the time when you access Digital Receipts the IP address used to access our web hosted receipt and general location information information from any enabled cookies information from third parties you enable or connect to Smartbills other information stored on your phone that you grant us access to, such as scanned or online receipts	Collected via Sites and/or Smartbills partners you interact with

12.2 Where information is collected from Merchant partners, this information is collected electronically through APIs.

13. How do we use the information collected to provide Digital Receipts in the Smartbills App, Merchant partners’ application, email or via SMS?

13.1 We will only use the information collected where we have a legitimate business purpose to do so. Below outlines the purposes we may use the information we collect:

to generate Digital Receipts and deliver those via SMS, email, or via any Merchants' application;
to perform internal analysis helping us improve and develop our services;
to provide Merchants with analytics products and insights using anonymised data;
to conduct general administration of the business (including accounting, finance, answering enquiries);
to monitor and conduct activities related to the security of our systems and services; and
to comply with our legal and regulatory obligations and exercise our legal rights.

14. Who will we disclose your information to?

14.1 We may disclose the information we collect to the following:

Merchants that you shop with to access Receipts issued on their behalf;
accountants, auditors, lawyers and other professional advisors we engage who require access to information;
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law;
third-party service providers to whom we may outsource certain services or functions;
third-party service providers who you connect or enable with Smartbills; and
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

Smartbills Digital Receipt – Users interacting with our Site or merchant portal (“Smartbills ”)

We provide a range of services on our Site and our merchant portal which are accessible by a range of different users. For example, Merchants can create an account with Smartbills, manage their account details and access their Digital Receipts. Users (whether they are retailers, Digital Receipt recipients or any other individual visiting our Site) can provide feedback or seek to get in touch with us. We also conduct business activities such as marketing, recruitment and corporate communications operations via our Site.

15. What personal information and/or data do we collect?

15.1 As part of these services, Smartbills may collect the information outlined below:

Type of data	Data Description	How data is collected
Contact details you provide when contacting us via our Sites, including your:
Contact details	name email address relationship with Smartbills (i.e. customer, retailer, Bank or other).	Supplied by you when contacting us
Views, opinions, requests, etc.	Any information you share with us when contacting us	Supplied by you when contacting us
Information to set up a Merchant account with Smartbills, to enable Digital Receipts to be offered to your customers including:
Merchant account details	your business details (including BN, phone number and trading name) your store details (including name, address, phone number, BN, opening hours) your branding details (including logo, brand colour palette, social links, website)	Supplied by Merchants when using our Sites and managing their accounts
Usage data and Cookies	Information about how you access and use our services	Collected via your interactions with our Sites

16. How do we use the information collected when you use our Sites?

16.1 We will only use the information collected where we have a legitimate business purpose to do so. Below outlines the purposes we may use the information we collect:

to answer enquiries and feedback submitted via our Sites;
to perform internal analysis, helping us improve and develop our Sites and services;
to monitor and conduct activities related to the security of our systems and services;
to conduct general administration of the business (including management of Merchants’ accounts, partners’ invoice, accounting and finance);
to comply with our legal and regulatory obligations and exercise our legal rights;
to communicate with you about maintaining and updating your contact information where appropriate; and
to communicate with you on subject which may be of interest including:
1. service updates and news about our services;
2. news items and other information in which you may be interested;
3. maintaining and updating your contact information where appropriate; and
4. conducting surveys.

17. Who will we disclose your information to?

17.1 We may disclose the information we collect to the following:

accountants, auditors, lawyers and other professional advisors we engage who require access to information;
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law;
third-party service providers to whom we may outsource certain organisational functions (including direct marketing); and
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

Smartbills Digital Receipt - General Business Operations

Smartbills may collect information from any person who interacts with us in the course of conducting business, including employees, job applicants, clients (current and prospective) and other third-parties.

18. What personal information and/or data do we collect?

18.1 Smartbills may collect the information outlined below:

Type of data	Data description	How data is collected
We may collect information from employees and job applicants to carry out relevant operations:
Employee and job application details	your contact details (name, email, mobile number and address) your payment details (bank details, superannuation details and tax file number) your health information where relevant (including allergies and disability affecting your work) your resume, background checks and performance and disciplinary records records of your access to our systems and devices.	Information is normally supplied by you, referees or third-parties (such as University or professional bodies) Some information may also be directly collected by our systems
We may collect the below information from clients, prospective clients and third parties we conduct business to carry out relevant operations:
Clients, prospective clients and third-parties we conduct business with details	your contact details (name, email, mobile number and work address) the company your represent and your role records of your previous interactions with Smartbills for customer relationship management purposes	Information may be supplied by you directly, a colleague of yours or one of our partners.

19. How do we use the information collected from employees, job applicants, clients and third-parties we engage with?

19.1 We will only use the information collected where we have a legitimate business purpose to do so. Below outlines the purposes we may use the information we collect:

to consider the suitability of employment for prospective job applicants;
to conduct general administration of the business (employee payroll, organising networking events and managing employee performance);
to perform internal analysis helping us improve and develop our services;
to monitor and conduct activities related to the security of our systems and services;
to comply with our legal and regulatory obligations and exercise our legal rights; and
to communicate with you on subject which may be of interest including:
1. Service updates and news about our services.
2. News items and other information in which you may be interested.
3. Open roles.
4. Maintaining and updating your contact information where appropriate.
5. Conducting surveys.

20. Who will we disclose your information to?

20.1 We may disclose the information we collect to the following:

accountants, auditors, lawyers and other professional advisors we engage who require access to information;
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law;
third-party service providers to whom we may outsource certain organisational functions (including direct marketing); and
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

Part D: General Terms

21. Do we disclose your personal information to anyone outside Canada

21.1 Currently, we do not disclose your personal information to third-party suppliers, service providers, or data hosting and IT service providers located outside of Canada. Should this change in the future, we will update our privacy policy to ensure compliance with Canadian privacy laws, including PIPEDA.

22. Direct marketing materials

22.1 We may send you direct marketing communications and information about our products or services that we believe may be of interest to you. These communications may be sent in various forms, including mail, SMS, email, or push notifications within our Smartbills App. All such communications will be sent in accordance with applicable marketing laws, such as Canada’s Anti-Spam Legislation (CASL).

22.2 By using our services, you consent to us sending you direct marketing communications by any of the methods identified above.

22.3 You may opt out of receiving direct marketing communications from us at any time by unsubscribing from our mailing list via the link in the marketing communication or by contacting us using the details set out below.

22.4 We may share your personal information with Smartbills loyalty program and Digital Receipt merchant partners for the purpose of direct marketing. As part of the sign-up process for the Smartbills App, you consent to us providing your personal information to merchant partners for marketing purposes. You can withdraw this consent at any time.

23. Security

23.1 We take reasonable steps to protect your personal information from misuse, loss, and unauthorized access, modification, or disclosure, including:

Staff Education: We train and remind our staff about their obligations regarding your personal information.

System Security: We encrypt data sent to our systems when you transact with us on the internet via our Sites or via our partners’ APIs.

Building Security: Our facilities have physical protections such as cameras and access controls to prevent unauthorized access.

Data Disposal: We have policies to ensure that personal information is kept only as long as necessary to meet user needs, legal obligations, or internal purposes. When no longer needed, we take steps to de-identify or destroy it, depending on how it was collected and stored.

23.2. As our Site and Smartbills App are connected to the internet, and given the inherent security risks of the internet, we cannot guarantee the security of any personal information you transmit to us online. The transmission of any personal information is at your own risk.

24. Links

24.1 Our Site and Smartbills App may contain links to third-party websites, including those operated by our merchant partners. We are not responsible for the privacy practices of these third-party websites and make no representations or warranties regarding their content or privacy policies.

24.2 It is the responsibility of third-party websites to inform you about their own privacy practices.

25. Maintaining Data Accuracy

25.1 On an ongoing basis, we take reasonable steps to ensure that:

your personal information is accurate and has been kept up to date (where necessary); and
any of your personal information that we process that is inaccurate (having regard to the purposes for which it is processed) is erased or rectified if we become aware of the inaccuracy.

25.2 From time to time we may ask you to confirm the accuracy of your personal information.

26. Cookies

26.1 We may use cookies or similar tracking technologies to provide services to you.

26.2 When you visit our Sites, we may use cookies or similar technologies to track your usage and remember your preferences. Cookies are small files stored on your device that help us recognize you across websites and services. While we do not use browsing information to identify you personally, we may record information such as pages visited, the time and date of visits, referral sources, and your device’s IP address.

26.3 You can change your cookie settings in your browser at any time. Blocking cookies may limit the functionality we can provide. By continuing to use our Sites without changing your settings, you consent to our use of cookies.

27. Web Beacons

27.1 Our direct marketing communications may contain electronic images known as web beacons, which allow us to track whether you have opened our communications or clicked on certain links. Web beacons help us analyze engagement and improve your experience.

28. Anonymity

28.1 Where lawful and feasible, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general inquiry, you do not need to provide your name unless necessary to address your query.

28.2 We generally do not collect the names of customers from our merchant partners who receive Digital Receipts. However, we may need your name, contact details, and other information to provide certain services.

29. Accessing, updating, and correcting your personal information

29.1 We strive to ensure that the personal information we collect from you is accurate, complete, and up to date.

29.2 You may request access to, or correction of, the personal information we hold about you at any time by contacting us using the details below. We will need to verify your identity before processing your request. Subject to legal exceptions, we will provide access to your personal information within a reasonable time (usually within 30 days).

29.3 There may be circumstances where we cannot grant access to your personal information, such as when doing so would violate the privacy of others or breach confidentiality. If access is refused, we will provide written reasons for the refusal.

30. Contacting Us

30.1 If you have any questions about this Privacy Policy, our treatment of your personal information, or wish to request access to or correction of your information, please contact us at [email protected].

31. Complaints

31.1 If you wish to make a complaint about our handling of your personal information, we will promptly consider and respond to your complaint. If we cannot resolve the issue within 30 days, we will contact you to explain why and provide a timeline for resolution.

31.2 If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC). You can contact the OPC via their website at www.priv.gc.ca or at:

Office of the Privacy Commissioner of Canada

30 Victoria Street, Gatineau, QC K1A 1H3

1-800-282-1376

32. Changes to our Privacy Policy

32.1 We may update this Privacy Policy from time to time. Any updated versions will be posted on our Site. Please review it regularly for changes.

32.2 This privacy policy was last updated on October 14^th, 2024.