Privacy Policy

At 16877214 Canada Inc., operating as The Smart Lines ("we"), we are committed to maintaining the accuracy, confidentiality and security of your personal information. We have developed this Privacy Policy to describe our privacy policies and practices and how we collect, use and disclose the personal information of those individuals who visit our website.

Privacy Policy Effective for Canada

It is our policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.

What is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person's business title or business contact information when used or disclosed for the purpose of business communications.

What Personal Information Do We Collect?

You can visit our website without telling us who you are or revealing any information about yourself, including your e-mail address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes contact and identification information, such as your name and e-mail address, and any payment information provided in connection with a user's subscription.

Where you request information from us, we may use the contact information that you provide to send you information relating to your request.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities.

As a general rule, 16877214 Canada Inc. collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may use the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why Do We Collect Personal Information?

We collect personal information to enable us to manage, maintain, and develop our business and operations, including:

• to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
• to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
• to protect us against error, fraud, theft and damage to our goods and property;
• to enable us to comply with applicable law or regulatory requirements; and
• any other purpose to which you consent.

How Do We Use Cookies?

When you visit the website, we place a "cookie" on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs.

Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you will not be able to access a number of web pages found on the website.

First-Party Analytics

Alongside Google Analytics, we keep our own usage statistics so we can see which features are used and how visitors become subscribers. Your browser stores a random visitor identifier (in local storage, not a cookie) and records the pages you view and a few actions, such as opening a sportsbook link, logging a bet, creating an alert or starting checkout. With each visit we also record the referring site, campaign tags in the link you arrived from, a coarse device type, browser and operating system, and the odds format and location setting you chose on the site. When you are signed in, these records and account events (sign-up, with any promo code you used, logins, password resets and subscription changes) are linked to your account. Your account stays private until you post a pick: the public handle you choose then is what other members see on the leaderboard, on your profile and in search, with the picks you post. We never store your IP address: it is replaced by a keyed one-way hash that changes every day and is used only to limit abuse and to count visits. This data is used only by our staff to improve the service; it is not sold, and the only sharing with an advertising platform is the ad measurement described below. Detailed event records are deleted after 13 months; daily activity totals are kept with your account. We honour the Global Privacy Control signal: if your browser sends it, we do not record these statistics at all. You can also opt out in this browser at any time with the "Don't track my visits" setting at the bottom of every page or here:

Opting out stops the page and feature statistics from this browser. Records we need to run your account and billing (such as sign-ins, daily signed-in activity and subscription payments) are still kept as account records.

Advertising Measurement

When we advertise on Reddit, our website uses the Reddit Pixel (Reddit, Inc., USA) to measure those ads. It tells Reddit when a visitor views a page, creates an account or starts a free trial, so we can see which ads bring people to the service. Reddit receives the address of the page, your browser and device details, your IP address and its own cookies or identifiers, and may connect this to your Reddit account under Reddit's privacy policy. We do not send Reddit your email address, your bets, your picks or your settings. The pixel follows the same choices as our own statistics: it is not loaded when your browser sends the Global Privacy Control signal or when you turn on "Don't track my visits".

Error Reports

When something fails on the website, on our servers or in our data pipeline, an error report is sent to Sentry (Functional Software, Inc., USA), which we use only to find and fix bugs. A report describes the error: the page or web address involved (with any passwords, keys and the codes in password-reset and verification links removed), your browser and operating system, and the last few things the site did before the error. Reports do not include your IP address, cookies, passwords or what you typed into forms, and we do not record your screen. Sentry deletes reports automatically after at most 90 days.

What about Links to Other Websites?

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. 16877214 Canada Inc. is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

How Do We Use and Disclose Your Personal Information?

We may use and disclose your personal information:

• for the purposes described in this Privacy Policy; or
• for any additional purposes for which we have obtained your consent to use or disclose your personal information.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law to do so.

When Do We Disclose Your Personal Information?

The personal information we collect is used and disclosed for our business purposes, including for those purposes explained in this Privacy Policy.

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you.

We may disclose your information to third parties, including: third parties that provide services to us or on our behalf; third parties that assist 16877214 Canada Inc. in the provision of services to you; and third parties whose services we use to conduct our business.

For example, servers used with Render (Ohio, USA), Amazon Web Services (Ohio, USA), Vercel (California, USA), Sentry (USA) may provide certain information technology and data processing services to us from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in Canada, and the United States of America. In these circumstances, the governments, courts, law enforcement, national security, or regulatory agencies of such other jurisdictions may be able to obtain access to your personal information through the laws of the foreign country.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of 16877214 Canada Inc through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• to protect the rights and property of 16877214 Canada Inc.
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• where the personal information is publicly available; or
• with your consent.

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Choice/Opt-Out

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to, or acquire products or services from, you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

How is Your Personal Information Protected?

16877214 Canada Inc. endeavors to maintain technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while this website strives to protect your personal information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk. Once this website receives your transmission, we make commercially reasonable efforts to ensure its security on our systems.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law allows or requires us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to applicable law.

Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Privacy Officer
Attn: Michael Arena
E-mail: smartlinesinbox@gmail.com

Revisions to this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website www.thesmartlines.com/privacy and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on the date provided above.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word "including" is used, it shall mean "including without limitation."

This Privacy Policy does not impose upon 16877214 Canada Inc. any obligations, or create or confer upon any individual any rights, outside of, or in addition to, those imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.