Privacy Policy

Last Updated: October 22, 2021 1983283 Ontario Inc., doing business as “Secure Digital Markets”, a corporation existing under the laws of Ontario, and Secure Digital Markets Canada Inc., a corporation existing under the laws of Ontario (individually or collectively referred to as “SDM”, “we”, “us” or the “Company”, as applicable) have developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your Personal Data when you visit us at https://sdm.co/ (“Website”). If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us here. This privacy policy applies only to our collection, retention, processing, sharing and transferring of your Personal Data (as defined below) on or through our Website. This policy is not applicable to any information collected offline or via channels other than our Website. By using our Website, you hereby consent to our Privacy Policy and agree to its terms.

1. Information We Collect

The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Data. If you contact us directly, we may receive additional information about you such as your name, email address, telephone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. When you register for an account, we may ask for your contact information, including items such as your name, company name, address, email address, and telephone number. We may require you to provide us with additional Personal Data as you use our Website. When you access our Website, we may automatically collect information from the device used to access the Website. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Website; geolocation information; and information that tells us how you use the Website, such as what you have searched for and viewed on the Website and the way you use the Website, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Website and other usage and browsing information collected through Cookies.

2. How We Use or Process Information

We use the information we collect in various ways, including to:
  • Provide, operate, and maintain our Website
  • Improve, personalize, and expand our Website
  • Understand and analyze how you use our Website
  • Develop new products, services, features, and functionality
  • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Website, and for marketing and promotional purposes
  • Send you emails
  • Manage risk, and protect the Website and you from fraud
  • Comply with our legal and regulatory obligations and to enforce the terms of use of our Website

3. Cookies

When you visit our Website, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a user and to customize your online experiences, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Website. Certain aspects and features of our Website may only be available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Website may be limited or not possible. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals. Please review our Cookie Policy to learn more about how we use Cookies.

4. Why We May Retain Personal Data

We may retain personal information which may be associated with an identified or identifiable person (“Personal Data”) to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

5. Ways We May Share Information

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy. We may share your Personal Data or other information for the following reasons: With other members of the SDM corporate family: We may share your Personal Data with members of the SDM family of entities to, among other things, provide services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of SDM products, services, and communications. With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support. With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for SDM’s business purposes or as permitted or required by law, including:
  • if we need to do so to comply with a law, legal process or regulation;
  • to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to SDM or SDM’s corporate family;
  • if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial or other loss or in connection with an investigation of suspected or actual illegal activity;
  • to protect the vital interests of a person;
  • to investigate violations of our Website terms and conditions or enforce a user or other agreement or other legal terms applicable to any service available on our Website;
  • to protect our property, services and legal rights;
  • to help assess and manage risk and prevent fraud against us, our users and fraud involving our Website, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals;
  • to facilitate a purchase or sale of all or part of SDM’s business;
  • to companies that we plan to merge with or be acquired by; and
  • to support our audit, compliance, and corporate governance functions.
With your consent: We also will share your Personal Data and other information with your consent or direction. In addition, SDM may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users visit our Website. This data will not personally identify you or provide information about your use of the Website. We do not share your Personal Data with third parties for their marketing purposes without your consent.

6. What Privacy Choices Are Available to You?

You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you register for an account on the Website or in the context of your use of the Website. You may be provided with instructions and prompts within the experiences as you navigate the Website.
  • Choices Relating to the Personal Data We Collect
    • Personal Data. You may decline to provide Personal Data when it is requested by SDM, but access to certain services and portions of the Website may be unavailable to you.
    • Location and other device-level information. The device you use to access the Website may collect information about you, including geolocation information and user usage data that SDM may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
  • Choices Relating to Our Use of Your Personal Data
    • Online Tracking and Interest-Based Advertising. We may work with partners and third-party service providers to serve you advertising using ad-related cookies and web beacons. You can opt-out of third-party advertising-related cookies and web beacons, in which case our advertising should not be targeted to you. You will continue to see our advertising on third party websites.
      • For more information on third-party advertising-related cookies and interest-based advertising, and to learn how to opt-out of these practices with companies participating in industry self-regulation, please visit AdChoices.
  • Mobile Device Tracking. You may opt out of the processing and use of certain Personal Data on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at https://youradchoices.ca/appchoices/.
  • Choices Relating to Cookies
  • You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you to delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options but doing so may prevent you from using many of the core features and functions available on our Website.
  • You may have an option regarding the use of cookies and other tracking technologies when you use the Website. For example, you may be asked if you want the Website to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.
  • You can learn more about our cookies and tracking technologies by visiting here.
  • Choices Relating to Your Registration and Account Information
    • If you have an account on the Website, you generally may review and edit Personal Data by contacting us. Contact us if you do not have an account or if you have questions about your account information or other Personal Data.
  • Choices Relating to Communication
    • Notices, Alerts and Updates from Us:  
      • Marketing:We may send you marketing content about our Website or services and products, as well as the products and services of unaffiliated third parties and members of the SDM corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications by following the instructions in the communications you receive. If you have an account with us, you may also adjust your communication preferences in your account settings. For messages sent via push notifications, you may manage your preferences in your device.
      • Informational and Other:We will send communications to you that are required or necessary to send to users of our Website, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications.

7. What Are Your Rights?

You may have certain rights in respect of your Personal Data. In particular, you may have a right of access and correction. If you wish to exercise these rights, please contact us. Depending on applicable law where you reside, you may be able to assert certain rights related to your Personal Data identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, we have absolute discretion in providing you with those rights. Your rights to your Personal Data are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons. Access and Portability. You may request that we provide you a copy of your Personal Data held by us. If required by applicable law, this information will be provided subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your Personal Data in a structured, commonly used and machine-readable format, and to have us transfer your Personal Data directly to another data controller. Rectification of Incomplete or Inaccurate Personal Data. You may update or correct Personal Data at any time by contacting us here for help. Erasure. You may request to erase your Personal Data, subject to applicable law. If you wish to deactivate your account, please contact us here but note that we may retain certain information as required by law or for legitimate business purposes. If you close your account, we will mark your account in our database as “Closed,” but may keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with our legal obligations. However, if you close your account, your Personal Data will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required or permitted by law, or in accordance with this Privacy Policy. Withdraw Consent. To the extent that the processing of your Personal Data is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of any processing we did prior to your withdrawal that was done on the basis of your consent. Restriction of Processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your Personal Data under certain circumstances. We may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law. Automated Individual Decision-Making, Including Profiling. We may rely on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your Personal Data, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws. Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies, but please note, that if you choose to remove or reject cookies, this could affect the availability and functionality of the Website. Promotional Communications. You may opt out of receiving promotional emails or text messages by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations, in accordance with applicable laws. If you believe that we have infringed your rights, we encourage you to contact us first so that we can try to resolve the issue or dispute informally. You can also complain about our processing of your Personal Data to the relevant data protection authority.

8. How Do We Protect Your Personal Data?

We may maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Website, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

9. Can Minors Use Our Services?

The Website is not directed to children under the age of majority. We do not knowingly collect information, including Personal Data, from minors or other individuals who are not legally able to use our Website or services. If we obtain actual knowledge that we have collected Personal Data from a minor, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a minor.

10. What Else Should You Know?

Changes to This Privacy Policy. We may revise this Privacy Policy from time to time to reflect changes to our business, the Website or services available on our Website, or applicable laws. The revised Privacy Policy will be effective as of the published effective date. If the revised version includes a substantial change, we will provide you with at least 15 days’ prior notice by posting notice of the change on the “Policy Update” page of our Website or requiring your acceptance of the amended Privacy Policy – if required by applicable law. We also may notify users of the change using email or other means. Transfers of Your Personal Data to Other Countries Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers may store and process your Personal Data outside of Canada, in the United States of America and elsewhere in the world. We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other countries. By using our Website and services available on our Website, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Website and services available on our Website are appropriate or available in any particular jurisdiction.

11. Contact Us

You may contact us if you have general questions about our Privacy Policy and practices or questions about your account information or Personal Data. We want to make sure your questions go to the right place:
  • Click here to contact us about your SDM account or transaction or in relation to any privacy related matter you have questions or concerns about.