SHOELACE TECHNOLOGIES INC.
PRIVACY POLICY

Shoelace Technologies Inc. (“Shoelace”/ “we”/”us”) is committed to protecting privacy and personal information. We make the website, www.shoelace.com (the “Website”) and our online shopping behavior tracking and targeted advertising services available to online vendors (“Vendors”/“Clients”), as further described in our Terms of (the “Services”). In order to provide the Services we must collect certain personal information from our Client’s customers (“Customers”). This Privacy Policy describes how we collect, store, use and distribute personal information about our Client’s Customers collected through our Clients’ use of our Services.

Consent: By using the Website or our Services you consent to the use of Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, Personal Information will not be used for any other purpose without a Customer’s consent. Subject to the terms of the Services we provide and the disclosures we make to Vendors in connections with such Services, we do not actively collect Personal Information for the purpose of sale or marketing in a way that specifically identifies the individual. Customers may withdraw their consent to our processing of their Personal Information at any time. However, withdrawing consent may result in the inability to continue using our Client’s websites or online sales venues. Vendors may also withdraw their consent to our collection of their Customer’s personal information at any time, however, this may affection a Vendor’s ability to continue using the Services. It is a condition of receiving our Services that Vendors disclose to Customers in their own privacy policies their use of cookies and tracking pixels, and Vendors are responsible for obtaining consent from Customers so that we may collect any such Personal Information.

Collection of Information: We aim to collect, use and disclose only such information as is required to enable us to provide the Services to our Clients (including providing information to our Clients about online shopping behaviors) to respond to Customer inquiries about our Services or provide feedback, and for service improvement. We will maintain the confidentiality of any personal information we collect in connection with the Services, and only use and disclose Customer personal information for the purposes for which we have collected it, and to the particular Vendor who has purchased our Services (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.

Two types of information may be collected through our Services: Personal Information and Non-Personal Information. This Privacy Policy does not extend to the collection, use or disclosure of the following information which is currently not limited by applicable privacy laws: (a) information that is publicly available, such as names, addresses, telephone numbers and electronic address when listed in a directory or made available through directory assistance (such as a telephone book); or (b) Non-Personal Information (as defined further below).

"Personal Information" is personally identifiable information, such as your name, address, e-mail address, credit card information, birth date and gender. At the time of collection, we will clearly identify the information being collected and the purposes for which it will be used. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Website or be able to access and use the Website at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Website. We collect Personal Information about our Client’s Customers when they use our Client’s websites, as well as information we collect from our partner Shopify.

"Non-Personal Information" is information of an anonymous nature, such as an Internet Protocol Address (IP Address) if it has been stripped of personal information, the domain used to access the Website, and the type and version of browser or operating system being used by visitors to the website. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, and average time spent on the Website is not considered Personal Information. Similarly, business contact information such as the name, title, business address, or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.

Although the use of certain Non-Personal Information collected, used or disclosed through the Internet as described herein is not restricted (and to the extent that such is the case, the obligations under this Privacy Policy do not apply to such information), we provide information in this Privacy Policy about the collection of such information for the sake of transparency with respect to the operation of the Website. Such Non-Personal Information is collected or derived by us in the course of operating this Website. For example, our web servers may automatically collect Non-Personal Information that is provided through your browser or stored in a cookie when you choose to visit the Website.

Use of Information: We collect, use and disclose information for the following purposes:

  • Services: In order to provide the Services to our Clients, we track our Client’s Customer’s online behavior. For example, we collect information about the products Customers or potential customers view, the time of day a purchase is made, the value of the purchase, the products that are purchased, you IP address, and location information associated with that IP address. We also track any purchases that are made as a result of a Customer clicking on a targeted advertisement that We serve to that Customer via their Facebook account. We track which Customers come to a Vendor’s website from a targeted ad on Facebook by tracking the URL. We will provide this information to the Vendors subscribing to our Services, as well as to create targeted advertising campaigns on behalf of Vendors, which we serve to Customers via their Facebook accounts. For greater certainty, We do not collect any other information from Facebook
  • Statistics: We also collect statistics on behalf of our Clients about the use of their website. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to third parties.
  • System Logs & Cookies: We provide the Services to our Clients through the use of cookies and tracking pixels. Our Clients place the tracking pixels and/or cookies on their website, to track Customer actions on their website. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server and a tracking pixel is a piece of code that tracks user behavior on a website. We use cookies and tracking pixels to help compile aggregate statistics about usage of our Client’s websites, such as how many users visit our Client’s website, what products are viewed, what products are purchased, whether the Customer came to the website as a result of clicking on one of our targeted Facebook advertisements, how long users spend viewing a Client’s website, time and value of purchases, product purchases and what pages are viewed most often. We provide this information to our Clients. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of our Client’s websites.
  • Advertisements: In addition to providing tracking services, we use the information we collect to serve targeted advertising to Customers on behalf of our Clients. We serve such advertisements via a Customer’s Facebook account using the Facebook Marketing API. These third party web advertisers may set cookies. These cookies allow the advertisement server operated by that third party to recognize your computer each time they send you an online advertisement. Accordingly, advertisement servers may compile information about where or whether you viewed their advertisements and which advertisements you clicked on. This information allows web advertisers to deliver targeted advertisements that they believe will be of most interest to you. The Privacy Policy applies to cookies placed on your computer by us, but does not cover the use of cookies by any third-party web advertisers. For the privacy practices of such third-party web advertisers, you should consult the applicable privacy policy for the relevant third-party web advertiser(s).

If we plan to use your Personal Information in future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled ‘Amendment of this Policy’.

Disclosures & Transfers: We have put in place contractual and other organizational safeguards with our agents (see further below) to ensure a proper level of protection of Personal Information (see further Security below). In addition to those measures, we will not disclose or transfer Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further Important Exceptions below).

Our servers are also located in the United States, and accordingly Customer Personal Information may be available to Canadian and United States governments or their agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

From time to time we may employ third parties to help us improve the Services. These third parties may have limited access to databases of Customer information solely for the purpose of helping us to improve the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.

Important Exceptions: We may disclose Personal Information to third parties without consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Customers, our Clients, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Security: The security of our Clients’ Customers’ Personal Information is important to us. We use commercially reasonable efforts to store and maintain Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us, including the use of firewalls and data encryption. We have implemented procedures designed to limit the dissemination of Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

Retention: We will keep Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained personal information will remain subject to the terms of this Privacy Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints.

Amendment of this Policy: We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post an appropriate notice on the home page at www.shoelace.com. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Website. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about any individual. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes.

Access and Accuracy: You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another individual. In such circumstances we will provide reasons for the denial upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Contact Us: You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at: [email protected].

Last Updated: April 4, 2016

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