SMARTY CO. PRIVACY POLICY
Last Updated: September 29, 2018
This Privacy Policy describes how we (together with our affiliates, including Virtual Racing School Limited) collect, store, use and distribute information through our software, website, documentation, and related services (together, the “Services”).
If you are visiting us from the European Union or European Economic Area, please be sure to read the section entitled “Additional Information for Users in the European Economic Area” for information on how we comply with privacy laws applicable to you.
1. Consent
By using the Services, you consent to the use of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using some or all of the Services.
2. Collection of Information.
Personal Information
When registering to use the Services, we may require or ask you to provide certain personally identifiable information (these are referred to below as your “Personal Contact Information”). The Personal Contact Information that we require you to provide in order to access the Services may include, but is not limited to, the following:
- Full Name
- Email Address
We may also ask or require you to provide certain Personal Contact Information as you interact with our Services, including when you submit requests for support, when you request coaching, or when you make customer service requests.
When purchasing the Services, we will require you to provide financial and billing information, such as billing name and address, and credit card number (“Billing Information”).
Your Personal Contact Information and your Billing Information (together with Data, Diagnostic, Login, Usage and Analytics, and Generalized Geo-Location Information, as defined below) are collectively referred to as your “Personal Information.”
User Content, Diagnostic & Login Information
You may create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages or other materials using the Services (this is collectively referred to below as “User Content”). We may request to obtain a crash report along with certain logging information from your system documenting technical errors in the course of using the Services (“Diagnostic Information”). Such information may contain information regarding your Operating System version, hardware, browser version, and your email address.
Analytics Information
As you use our Services, we may also collect information through commonly-used information-gathering tools, such as cookies, log files, and Web beacons. Collectively, this information is referred to as “Usage and Analytics Information.”
Cookies
We use cookies to provide you with our Service, to personalize content and ads, and to provide you with the best experience possible on our website.
Log Files
We gather certain information automatically to analyze trends and administer the Services. This information may include your Internet Protocol (IP) address, device and application identification numbers, your location, and your browser type, among other details.
Web Beacons
We use web beacons alone or in conjunction with cookies to compile information about your usage of the Services and interaction with emails from us.
Geo-Location Information
We collect location information for billing and compliance purposes, as well as to detect and curb abuse of the Service.
Racing Data
The Services track and gather information regarding your driving performance during your use of certain racing simulation computer programs. This is referred to as “Racing Data.” Racing Data is not deemed to be Personal Information.
3. Use of Information
We use the information we collect in the following ways:
| Information Collected | Use |
|---|---|
| Personal Contact Information | Manage your account, provide Services, respond to inquiries, and for limited marketing purposes. |
| Billing Information | Manage your account, collect payment, and check financial qualifications. |
| User Content, Diagnostic Information and Login Information | Administer and improve our Services. |
| Analytics Information | Improve our Services and monitor usage. |
| Geo-Location Information | Administer and improve our Services. |
| Racing Data | Share with your coach as part of Coaching services. |
If we plan to use your Personal Information for any other purposes, we will inform you by updating this Privacy Policy.
4. Do Not Track
Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. However, we do not currently support Do Not Track signals.
5. Disclosures & Transfers
We will not disclose your Personal Information to third parties without your permission, except as specified in this Privacy Policy. Your information may be transferred to computers located outside of your jurisdiction, including the United States.
6. Important Exceptions
We may disclose your Personal Information without consent if we believe it is necessary to identify, contact or bring legal action against someone who may be causing injury or interference with our rights or property.
7. Security
We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. You are also responsible for helping to protect the security of your Personal Information.
8. Sharing Information with Third Parties
You may be able to share information with third parties through the Services. The privacy policies of these third parties may differ from ours, and you should review their policies directly.
9. Retention
We will keep your Personal Information for as long as necessary for the identified purpose or as required by law. We may retain certain data to prevent fraud or future abuse.
10. Amendment of this Privacy Policy
We reserve the right to change this Privacy Policy. Non-material changes will become effective on the date posted, and any material changes will become effective 30 days from posting.
11. Access and Accuracy
You have the right to access your Personal Information and request updates or deletions. We will endeavor to deal with all access requests in a timely manner.
12. Service Providers
We may employ third-party companies to facilitate our Services. These third parties have access to your Personal Information only to perform tasks on our behalf.
13. Cookie Policy
What are cookies?
Cookies are small text files containing characters that can be placed on your computer or mobile device that uniquely identify your browser or device.
What are cookies used for?
Cookies help us understand how the site or service is being used, help you navigate efficiently, and improve your browsing experience.
How to control and review cookies?
You can change your browser settings to manage cookies. If you do not accept cookies, you may not be able to use some portions of our Services.
14. Contact Us
You can help by keeping us informed of any changes such as a change of email address or telephone number. If you have any questions, please contact us at:
Smarty Co.
2885 Sanford Ave SW #12670
Grandville, MI 49418
ADDITIONAL INFORMATION FOR USERS IN THE EUROPEAN ECONOMIC AREA
Personal Information
References to “Personal Information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller and EU Representative
Smarty Co. is the controller of your personal information for purposes of European data protection legislation. We have appointed a local representative in the European Union for compliance with EU data protection legislation.