Privacy Policy


SMARTECH ("We") are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We take information security seriously and use reasonable physical, electronic and managerial procedures to help prevent unauthorized access, maintain data security and correctly use the information we collect online.

INFORMATION WE MAY COLLECT FROM YOU We may collect and process the following data about you: Information that you provide by filling in forms including online product registration on our site www.smartechproduct.com ("our site"). This includes information provided at the time of registering to use our site, registering to have your product warranty extended [subscribing to our service, or requesting further services.] We may also ask you for information when you enter competitions or promotion or if you report a problem with our site. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. Details of transactions you carry out through our site and of the fulfillment of your orders. Details of your visits to our site and the resources that you access.

IP ADDRESSES We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

COOKIES AND OTHER TECHNICAL INFORMATION We may send "cookies" to your computer primarily to enhance your online experience. "Cookies" are files that can identify you as a unique customer and store your personal preferences as well as technical information (including click through and click stream data). Cookies can either be permanent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). We may also use "Web beacons" that monitor your use of our websites. Web beacons are one-pixel transparent images (although they can be visible images as well) located on a Web page or in an e-mail or other type of message, and are hosted on a server enabling the verification of a user's viewing or receipt of a Web page or message. Web beacons can be used to track the IP (Internet Protocol) address of the computer or device that downloaded the page on which the Web beacon appears, the URL (Uniform Resource Locator) of the page on which the Web beacon appears, the time the page containing the Web beacon was viewed, the type of browser used to access the Web page containing the Web beacon and the identification number of any cookie on the computer or device previously placed by the server hosting the web beacon. When we correspond with you via HTML capable e-mail, Web beacons let us know whether you received and opened our e-mail. On their own, cookies or Web beacons do not contain or reveal any personally identifiable information. However, if you choose to furnish the website with personally identifiable information, this information can be linked to the data stored using cookies/Web beacons. Note that we do not use cookies, collect IP addresses (other than potentially in our server log files), use Internet tags, or tie user activity to personally identifiable information on the investor relations portion of our website.
WHERE WE STORE YOUR PERSONAL DATA The data that we collect from you may be transferred to, and stored at, a destination outside the United States or European Economic Area ("EEA"). It may also be processed by staff operating outside the United States or EEA, who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

By accepting this Privacy Notice, you specifically agree to our use of cookies and Web beacons as described herein. You may adjust your browser to reject cookies from us or from any other website. If you have a Flash player installed on your computer, your Flash player may be able to be set to reject or delete Flash cookies. Please consult the "Help" section of your browser or Flash player for more information. Additionally, by setting your Web browser to display HTML e-mails as text only, you may be able to prevent the use of some Web beacons. However, certain areas of our websites may only be accessed in conjunction with cookies or similar devices, and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content.


USES MADE OF THE INFORMATION We use information held about you in the following ways: To ensure that content from our site is presented in the most effective manner for you and for your computer. To provide you with information, products or services that you request from us, or which we feel may interest you, where you have consented to be contacted for such purposes. To carry out our obligations arising from any contracts entered into between you and us. To allow you to participate in interactive features of our service, when you choose to do so. To notify you about changes to our service. We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services, which may be of interest to you, and they or we may contact you about these by post or telephone. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services for other products we sell or are similar to those which were the subject of a previous sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.

DISCLOSURE OF YOUR INFORMATION How we use and disclose this information: We may use the information you provide us in order to respond to your inquiries about our services, and to send you periodic updates about RW Direct Inc. We sometimes use the non-personally identifiable information that we collect to improve the design and content of our publications and websites and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze website usage. We will disclose information we maintain when required to do so by law, for example, in response to a court order or subpoena. We may also disclose such information in response to a law enforcement agency's request. We may use third-party partners to help operate our website and deliver our products and services, and may share your information with our service providers and other third parties that provide products or services for or through this website or for our business. In the event that RW Direct Inc or all or substantially all of its assets relating to the website are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, your personal information may be one of the transferred assets. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Notice. Because we operate internationally, and many of our computer systems are currently based in the United States, your personal information will be processed by us in the U.S., where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union and Canada. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may disclose your personal information to third parties: In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. If RW Direct or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of RW Direct, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

CHANGES TO OUR PRIVACY POLICY This Privacy Notice may be changed by RW Direct Inc. The revised Privacy Notice will be posted to this page so that you are aware of the information we collect, how we use it, and under what circumstances we may disclose it. We encourage you to periodically check and review this page so that you know what information we collect, how we use it and to whom we disclose it. Under certain circumstances (for example, in connection with certain material changes), we may also elect to notify you of changes or updates to our Privacy Notice, or to request your consent for such changes, by additional means, such as posting a notice on the front page of our website or sending you an e-mail.

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Your choices and opting-out


We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:


• You can opt-out of receiving targeted ads served by us: You can opt out of receiving targeted ads served by us or on our behalf by clicking on the blue icon in the corner of the ads we serve or by clicking here. Please note that, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again. Further, if you use multiple browsers or devices you will need to execute this opt out on each browser or device. If you opt-out we may collect some data about your online activity for operational purposes (such as fraud prevention) but it won't be used by us for the purpose of targeting ads to you.
• You can opt-out of receiving targeted ads served by us or other advertising companies: AdRoll is also a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing targeted ads from us and from other NAI approved member companies.
• We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving targeted ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.
• We also comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt out of receiving targeted ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website here.
• We also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt out via their Your Online Choices website.
• Please note that when using the ad industry opt-out tools described above:
• If you opt-out your browser may still send us data, for example your IP address. However, we isolate this data and do not use it other than for accounting and, in some cases, for fraud prevention. If you have opted-out on that browser, we do not use this data to personalize ads or to track you.
• If you use multiple browsers or devices we will additionally opt out those we have linked to you. Since we may not have all your browsers or devices connected back to your user, you may need to execute this opt out on each browser or device.
• Other ad companies’ opt-outs may function differently than our opt-out.
• To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:
• iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
• For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”
Please note: Opting out will not prevent you from seeing ads, but those ads will likely be less relevant because they won’t be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.
You can request that we stop email marketing to you. You can use the unsubscribe link in our marketing emails or contact service@smartechproduct.com.
Some internet browsers allow users to send a "Do Not Track" signal to websites they visit. We do not respond to this signal.


YOUR RIGHTS You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at service@smartechproduct.com. Our site may, from time to time, contain links to and from Third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should consult the other websites' privacy notices, because we have no control over information that is submitted to, or collected by, these third parties. The inclusion of a link to a third-party website does not imply endorsement of the website by RW Direct Inc. or any association with the third-party website's operators.

CONTACT Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to service@smartechproduct.com.