Website Privacy Policy
smwco.ai
Effective date: August 30, 2026
Last updated: August 30, 2026
Legal organization name: SMWCO
Privacy Officer: Sarah Wickham, CPO
Privacy email: PRIVACY@SMWCO.AI
Privacy Policy
This Privacy Policy explains how SMWCO.ai ("smwco.ai," "we," "us," or "our") collects, uses, discloses, and protects personal information when you visit smwco.ai, submit a form, subscribe to our newsletter, communicate with us, or otherwise interact with our website and services.
We are based in Canada and may serve individuals and business contacts in Canada and the United States. This Policy is intended to provide transparent notice under applicable Canadian privacy laws and, where applicable, U.S. state privacy laws. It does not create rights that do not otherwise apply under law.
1. Scope
This Policy applies to personal information handled through the smwco.ai website, newsletter, contact forms, and related business communications. It does not apply to information processed solely on behalf of a client under a separate contract, where that client determines the purposes and means of processing. In that situation, the client's privacy notice may apply.
Our website may link to third-party websites or services. Their privacy practices are governed by their own notices, and we encourage you to review them.
2. Personal information we collect
Information you provide
Contact and inquiry information may include your name, email address, telephone number, company, job title, the subject and content of your message, and any other information you choose to provide. Please do not submit sensitive personal information through a general contact form unless we specifically request it through an appropriate secure process.
Newsletter information may include your name, email address, subscription preferences, and records of your consent, such as the date, time, source form, and technical information reasonably needed to demonstrate consent.
Business relationship information may include correspondence, meeting details, proposal or engagement information, client contact details, and records needed to manage a prospective or existing relationship.
Information collected automatically
When you visit the website, our systems and providers may automatically collect technical and usage information such as your IP address, browser type and version, device type, operating system, language, approximate location derived from IP address, referring page, pages viewed, interactions, dates and times, session information, and cookie or similar identifiers.
Some of this information is necessary for security, network operation, and basic website functionality. Analytics information is collected only after you provide the consent required by our settings and applicable law.
3. How we use personal information
We may use personal information to:
operate, secure, maintain, and troubleshoot the website;
respond to inquiries, schedule conversations, and provide requested information;
evaluate and manage prospective and existing client relationships;
send the newsletter and related updates when you have consented, and maintain consent and suppression records;
measure website performance and understand how visitors use the website, where you have enabled analytics;
prevent fraud, abuse, security incidents, and other harmful activity;
comply with legal, tax, accounting, regulatory, and contractual obligations; and
establish, exercise, or defend legal claims and enforce our terms.
We will not use personal information for a materially different purpose without giving you appropriate notice and obtaining consent where required.
4. Cookies and Google Analytics 4
The website uses essential technologies needed to provide requested functionality, remember privacy choices, maintain security, and operate the site. These technologies cannot always be disabled through our preference tool, although you may be able to control them through your browser.
With your permission, we use Google Analytics 4 (GA4), a web analytics service provided by Google, to understand website traffic and usage. GA4 may collect or receive information such as pages viewed, events and interactions, device and browser information, approximate location, referral information, and online identifiers. Google processes this information on our behalf and may process it in the United States and other countries where it or its service providers operate.
Non-essential analytics storage and tags are configured not to activate until you select "Accept analytics" or otherwise enable analytics in the preference centre. You can reject analytics without losing access to the website, and you can change or withdraw your choice at any time through the "Cookie Settings" link in the website footer. Withdrawal does not affect processing that occurred before your preference changed.
We configure GA4 to reduce data collection and do not intentionally send Google information that directly identifies you, such as your name, email address, or contact-form contents. We recommend disabling Google Signals and advertising personalization unless a separate, clearly disclosed advertising use is added later.
For more information, review Google's Privacy Policy and Google Analytics privacy controls. You may also use Google's browser add-on to opt out of Google Analytics, but our own preference centre remains the primary website control.
5. Newsletter and electronic communications
We send newsletters or other promotional emails only when we have a lawful basis to do so, including valid consent where required by Canada's Anti-Spam Legislation (CASL) or other applicable law. Newsletter consent is separate from submitting a contact form or receiving a requested service, and promotional consent is not a condition of making an inquiry.
Each marketing email will identify the sender, include required contact information, and provide a working unsubscribe mechanism. You may unsubscribe at any time by using that link or contacting us. We may retain limited suppression information, such as your email address and opt-out date, to honour your request and demonstrate compliance.
We may still send non-promotional messages that are necessary to respond to your inquiry, administer a client relationship, deliver a requested service, address security, or satisfy legal obligations.
6. Contact forms and consent
When you submit a "Contact Me" or similar form, we use the information you provide to respond, route the inquiry, prevent spam, keep appropriate business records, and take steps you request before entering into a contract. The form should present a short collection notice and a link to this Policy at the point of collection.
If a contact form offers newsletter enrollment, that option will use a separate, optional, unchecked box. We will not treat a general inquiry, downloaded resource, or service request as consent to receive promotional emails unless applicable law clearly permits it.
7. How we disclose personal information
We may disclose personal information to:
website hosting, security, content-delivery, anti-spam, and technical support providers;
Google for analytics, only where analytics is enabled;
our newsletter and email delivery provider;
form, customer relationship management, scheduling, cloud storage, and collaboration providers used to manage inquiries and client relationships;
professional advisers such as lawyers, accountants, auditors, and insurers;
a buyer, investor, lender, or successor in connection with a proposed or completed business transaction, subject to appropriate protections; and
government bodies, regulators, courts, law enforcement, or other parties where required or permitted by law or reasonably necessary to protect rights, safety, and security.
We require service providers to handle personal information only for permitted purposes and with safeguards appropriate to the information and services involved.
8. Sale, sharing, and targeted advertising
We do not sell personal information for money. We also do not use or disclose personal information for cross-context behavioural advertising or targeted advertising as those terms are defined under applicable U.S. state privacy laws. If our practices change, we will update this Policy and provide any required opt-out mechanism before the change takes effect.
Where applicable law requires recognition of an opt-out preference signal, such as Global Privacy Control, we will process the signal as required. Because our analytics are consent-based and advertising features are intended to remain disabled, rejecting analytics through our preference centre is the most direct way to prevent non-essential website measurement.
9. International and cross-border processing
We are based in Canada, but our service providers may store or process personal information in Canada, the United States, and other countries. Information processed outside your province, state, or country may be subject to the laws of that jurisdiction and may be accessible to courts, law enforcement, or national security authorities in accordance with applicable law.
We use contractual, organizational, and technical measures designed to protect personal information during cross-border processing. Contact our Privacy Officer if you would like more information about our service providers or processing locations.
10. Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, to meet legal and business requirements, and to resolve disputes. Our intended retention schedule is:
Information
Typical retention
Contact inquiries
24 MONTHS AFTER THE LAST INTERACTION, unless needed for a client relationship or legal purpose.
Newsletter records
Until you unsubscribe or the newsletter ends; limited consent and suppression records may be kept longer for compliance.
GA4 event data
4 MONTHS, subject to provider operational data.
Client/business records
For the relationship and then 24 months], or longer where tax, accounting, limitation, or other laws require.
Security logs
365 days, unless needed to investigate an incident or comply with law.
11. Security
We use administrative, technical, and physical safeguards designed to protect personal information against loss, theft, and unauthorized access, use, alteration, or disclosure. These measures may include access controls, encryption in transit, provider due diligence, backups, logging, and staff confidentiality obligations, as appropriate.
No internet transmission or storage system is completely secure. You should avoid sending highly sensitive information through general website forms. If we become aware of a breach, we will investigate and provide notices or reports where required by applicable law.
12. Your privacy choices and rights
Canada
Subject to applicable law, you may request access to personal information we hold about you, ask us to correct inaccurate or incomplete information, challenge our compliance, or withdraw consent to future collection, use, or disclosure. Withdrawal may affect our ability to provide a requested service where the information is necessary for that service.
You may also change cookie choices through the website preference centre and unsubscribe from promotional emails using the link in any such email.
United States
Depending on your state of residence and whether the relevant law applies to us, you may have rights to confirm whether we process your personal information; access, correct, delete, or obtain a portable copy of it; opt out of sale, targeted advertising, or certain profiling; limit certain uses of sensitive personal information; and appeal a refusal to act on a request. We will not discriminate against you for exercising applicable privacy rights.
You may authorize an agent to submit a request where permitted. We may need to verify your identity or the agent's authority before completing a request. We will use verification information only for that purpose.
How to exercise a right
Email privacy@smwco.ai with the subject line "Privacy Request" and describe the right you wish to exercise. You may also write to the address in Section 16. We will respond within the period required by applicable law. We may deny or limit a request where an exception applies and will explain the basis where required.
13. Children
The website is intended for business audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information, contact us so we can investigate and delete it where appropriate. We do not knowingly sell or share the personal information of individuals under 16.
14. Quebec residents
Where Quebec privacy law applies, our Privacy Officer is the person responsible for the protection of personal information. You may contact that person using the details below to exercise applicable rights or ask about our privacy governance, automated processing (if any), or cross-border disclosures. We will make a French version of this Policy and related consent notices available where required.
15. Changes to this Policy
We may update this Policy to reflect changes in our services, providers, practices, or legal obligations. We will post the updated version on this page and revise the "Last updated" date. If a change is material, we will provide additional notice and obtain new consent where required.
16. Contact us
Questions, complaints, and privacy requests may be directed to:
Privacy Officer: Sarah Wickham
Organization: CPO
Email: privacy@smwco.ai
Mail:
Sarah Wickham, 44 Davis Crescent, Stoney Creek, Ontario, L8J 3X5
If we do not resolve a Canadian privacy concern to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada or the relevant provincial privacy regulator. U.S. residents may also contact the regulator or attorney general in their state, where applicable.