The following document outlines the Privacy Policy of the Setter website. Before using any of the Setter services, you are required to read, understand, and agree to these terms.

This Privacy Policy covers Setter'streatment of personal information that Setter gathers when you are on the Setter website and when you use Setter services. This policy does not apply to the practices of third parties that Setter does not own or control, or to individuals that Setter does not employ or manage.

  1. OUR PRIVACY POLICY At Setter Inc. (“Setter” and also “our”, “us”, “we”), we are committed to protecting your privacy, and maintain a general policy of openness about how we collect, use and disclose your personal information. Setter is an Ontario corporation. This Privacy Policy (the “Policy”) constitutes a legal, binding agreement between you (“you”, “your” or “user(s)”), a user of our websites, and Setter.

The purpose of this Privacy Policy is to inform you about Setter's practices relating to the collection, treatment, disclosure and safeguard of any personally identifiable information that may be provided through access to or use of our website, services and publications, or that may otherwise be collected by us by using our website or mobile app or submitting information to our website at www.setter.com or mobile app (the “Site”).

This Policy applies only to people who wish to enter our Site. If you do not need or do not want to use our Services, please close this web tab or this mobile app and exit the Site. You hereby consent that Setter may collect, use and disclose such personal information (as defined below) in accordance with the following terms and conditions, and as permitted or required by law.

This Privacy Policy also explains how you can contact us if you have a question about, want to make a change to or want to delete any personal information that Setter may be maintaining about you. We strongly recommend that you take the time to read this Privacy Policy and retain it for future reference. For purposes of this Policy, the Site shall be the initial point of contact between you and Setter, and will serve as initial point of collection of any personal data you may provide us. Please read carefully this Policy and our applicable Terms & Conditions, incorporated by reference.

As used herein, the terms “use”, “collect”, “treat”, “process” and “disclose”, when related to personal information and other data, include, among other items, use of cookies inside a computer, and statistical and analytical complication thereof for the creation of aggregate databases and marketing strategies; also including but not limiting, the storage, use, combination, integration, disclose, process and transfer of such personal information within our affiliates or other third parties.

  1. COLLECTION OF PERSONAL INFORMATION For the purpose of this Privacy Policy, and in accordance with applicable privacy laws, "personally identifiable information" is generally defined as personal information about an identifiable individual or person, not a legal entity, or information that allows an individual to be personally identified.

Public Content: In general we collect, use and disclose personal information for use on the Site. From time to time, we may ask you to provide us with more detailed information and we will inform you as to why we are collecting it. Location & Activity: The personal information Setter may collect about you may include, but is not limited to: your contact information, including an online name & neighbourhood of residence, zip or postal code, the date and time of your visit, your IP address, content viewed, the name of companies recorded in your account, e-mail address and demographic information. Contractors: If you sell your services through us, your billing information may be stored. This sensitive information is encrypted according to industry standards and is only shared with third parties who will assist Setter in completing the transaction. Messaging: We may also retain any communications you send us and other users, including e-mail messages, forum posts, reviews and responses we send you.

  1. CHILDREN AND MINORS Children and minors, that is, persons under the age of 18, are not eligible to use the Site unsupervised, and therefore we ask that children do not submit any personal information to us. If you are under the age of 18, you may only use this Site in conjunction with and under the supervision of your parents or legal guardians.

  2. TREATMENT AND PURPOSE OF PERSONAL INFORMATION We use your personal information for the purposes of operating and providing the products and services of Setter on or in connection with the Site. More specifically, we generally collect, use and disclose your personal information, but communications on consent for the following purposes:

To verify the validity of your e-mail address and identity; To communicate with you regarding information you submit to the Site; To research, develop, manage, protect and improve those communications; To respond to questions, suggestions, and job requests you submit to the Site; To verify any reviews submitted to the Site; To advise you about new products and services that may be of interest to you; To allow other Users to communicate with you regarding quotes;

In addition, from time to time, we may use your personal information for the following purposes:

To detect and protect Setter and third parties against error, fraud, theft and other illegal activity, and to audit compliance with Setter's policies and contractual obligations; To understand your needs and preferences, including to contact and communicate with you and to conduct surveys, research and evaluations; and For any other purpose we may indicate to you from time to time.

  1. DISCLOSURE OF PERSONAL INFORMATION Except with your consent and as set out below, we will not sell, license, trade or rent your personal information to or with others.

Third Parties: we may disclose personal information to our authorized third party providers, including those engaged to assist us in providing our services via the Site (including but not limited to, software development, website development and hosting, data processing, document management and office administration) to you or to carry out one or more of the uses described above. These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by Setter and to comply with the general privacy principles describes in this Privacy Policy. Investigations: Setter reserves the right to disclose personal information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so. Business Transfers: Setter also reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase of all or any portion of Setter or of any of the business or assets or shares of Setter or a division thereof in order for you to continue to receive the same products and services from the third party. Aggregate: Aggregate information is collected by Setter. This information may be shared with third parties, such as advertisers. Often this information is collected and used for statistical purposes to determine the current areas of interests of users. Defense: We will also release any and all collected information and/or personal data under the following circumstances: if required by applicable law, to defend ourselves and our affiliates from legal claims by third parties and to respond to such claims and legal processes (including takedown notices and subpoenas), to protect the property, rights and integrity of Setter or any third party, and to prevent or terminate any activity we may consider to be -- or which me may consider posing a risk -- of any illegal, unethical or objectionable activity.

  1. KNOWLEDGE AND CONSENT Use of the Setter website is voluntary. We will seek express consent for the use or disclosure of your personal information at the time of collection or to communicate with you. In certain rare circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified).

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information that may be of value to you.

We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.

  1. USE OR DISCLOSURE FOR MARKETING, ADVERTISING AND SPONSORSHIP PURPOSES We may also use your personal information to promote and market additional goods, services and special offers from us, our affiliates and sponsors, including by means of direct marketing. We may only disclose aggregated statistics with anonymized data, based upon use of the Site by our users.

From time to time, we will ask you for express permission and consent to receive Commercial Electronic Messages (‘CEM’), which we will sometimes send from or to Canadian computers to our users. A CEM is a message in an electronic format (e.g. emails, SMS, social media messages, push notifications and other form of communications) which is then sent to an electronic address (e.g. email, instant message accounts, smartphone, social media profile) that contains a message asking recipients to participate in commercial activities (e.g. purchase of products and services). For purposes of this Policy, and in compliance with the Canada Anti-Spam Law (‘CASL’), express consent shall require our clear and concise description of the purpose of such consent, along with a description of the CEMs you may receive from us.

Express consent for CEMs does not apply for those CEMs that we may send and that are: (i) opened or accessed outside of Canada; (ii) for security, refunds or guarantees of products and services on our Site; (iii) for providing information about purchases and transactions about your account; (iv) account related notifications.

Setter may use proprietary software tools and other third party tools such as Google Analytics, Branch, Amplitude, Google Ads, Segment, Zendesk, Front, and Facebook Advertising (which include remarketing code functionalities) to gather information about websites you browse view or when you undertake specific actions in a website.

Finally, if you use the Site through a mobile device, you may also use your device’s settings for control items such as your location sharing, tailored advertising and other privacy settings.

  1. COOKIES When you visit our Site, we may place a "cookie" in the browser directory of your computer's hard drive. A cookie is a small text file of information that a website can store on your web browser and later retrieve. Some cookies are temporary and others can be valid for several weeks or months, stored on your computers or mobile devices even beyond when you exit your browser. We also use web beacons, tags and other means on our Site. Such beacons are an electronic file, sometimes only a pixel or small image, embedded on websites. We use such kind of cookies for various legitimate business purposes. In addition to the identified uses described in this Policy, we may use information provided by cookies and disclose it to third parties to measure the use of our Site, to improve the functionality and content of the Site and to facilitate usage of the Site. You can reset your browser to notify you when you have received a cookie or refuse to accept a cookie. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent, usually through the settings tab.

  2. WE PROTECT YOUR PERSONAL INFORMATION Setter makes all commercially reasonable efforts to ensure that personal information collected from you is protected against loss and unauthorized access. Your Setter account information is protected by sending you a unique verification code to your provided mobile phone number for your privacy and security. Protect against unauthorized access to your password and to your computer by logging out of the application.

This protection applies in relation to information stored in both electronic and hard-copy form. Access to your personal information is restricted to select employees or representatives. In addition, Setter employs appropriate information security techniques to protect personal information against loss and unauthorized access. Setter educates its employees on the importance of privacy. It is Setter’s policy to give access to personal information to persons who require it to carry out the responsibilities of their jobs.

Setter educates all its employees on the importance of privacy. It is Setter’s policy to give access to personal information only to those employees who require it to carry out the responsibilities of their jobs or to other such third parties with similar designated responsibilities and who are subject to contractual confidentiality restrictions with Setter.

  1. LINKS TO THIRD-PARTY SITES This website may offer links to unaffiliated third-party websites for your convenience. You should be aware that operators of linked websites may also collect your personal information (including information generated through the use of cookies) when you link to their websites. Setter is not responsible for how such third parties collect, use or disclose your personal information, so it is important to familiarize yourself with their privacy policies, which may differ from ours, before providing them with your personal information. Setter cannot be held liable for your use of such third-party websites.

  2. CONTROL OF YOUR PERSONAL INFORMATION At Setter, we want you to be able to maintain control over how we use your personal information. We continuously try to improve our user experience, and to give you the best choices for providing, editing, removing or instructing us not to use certain personally identifiable information collected by us from you.

  3. CHANGES TO OUR PRIVACY POLICY Setter reserves the right to modify this Privacy Policy at any time without notice, and at our sole and final discretion. The Policy posted at any time or from time to time via this Site shall be deemed to be the Policy then in effect, and therefore we strongly suggest that you review frequently for any updates. Your simple access or use of our Services after such amendments or changes become effective is your acknowledging and acceptance of the new Policy.

  4. REMOVAL OF YOUR INFORMATION Upon your request to us, and after proper review, we may edit, deactivate and/or delete your personal data and other information from our active databases. Please be advised that we may not be able to delete all of your personal data from some of our secure databases and, in such case, we will make the data permanently inaccessible to any third parties. You may also be able to edit the personal information we store about you, by going to your account settings in the Site.

  5. HOW TO CONTACT US If you have any questions regarding this Privacy Policy, you can reach us at the following address: Setter Inc. 204-360 Dufferin Street, Toronto, Ontario, M6K 1Z8 Tel: 1-647-5035390

Date of last update to this policy: 1 October 2018