Smarty Co. Privacy Policy

Last Updated: February 29, 2016

This Privacy Policy describes how we collect, store, use and distribute information through our software, website, documentation, and related services (together, the “Services”).

1. Consent

By using the Services, you consent to the use of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We do not actively collect Personal Information for the purpose of sale of such information in a way that specifically identifies the individual (i.e. we don’t sell customer lists). You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using some or all of the Services.

2. Collection of Information

Personal Information

When registering to use the Services, we may require you to provide some personal contact information, such as your name and email address (these are referred to below as your “Personal Contact Information”). When purchasing any paid Services, we will require you to provide financial and billing information, such as billing name and address, and credit card number (“Billing Information”). Your Personal Contact Information and your Billing Information are collectively referred to as your “Personal Information.

User Content, Diagnostic   Login Information

You may be able to create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages or other materials using the Services (this is collectively referred to below as “User Content”). Some of this User Content may be stored and maintained on our servers. If you run into technical errors in the course of using the Services, we may request to obtain a crash report along with certain logging information from your system documenting the error (“Diagnostic Information”). Such information may contain information regarding your Operating System version, hardware, browser version (and .NET version information in case of Windows systems), and your email address, if provided. Additionally, certain login information may be maintained in a cookie stored locally on your personal computing device (i.e. not on a server) in order to streamline the login process (“Login Information”).

Analytics Information

The Services track and gather information regarding your driving performance during your use of certain racing simulation computer programs. This is referred to as “Racing Data.” As you use our Services, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our web site (such as the web pages viewed and the links clicked). Collectively, this information is referred to as “Analytics Information.”

Geo-Location Information

We do not collect any information regarding your real-time geo-location while using the Services. However, we may do so at some point in the future. We will request your permission before collecting such information.

3. Use of Information

We use the information we collect in the following ways:

Information Collected Use
Personal Contact Information We use this information to manage your account, to provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes, for service improvement, and to address issues like malicious use of the Services. We may also use Personal Information for limited marketing purposes, namely, to contact you to further discuss your interest in the Services, and to send you information regarding information about us or our partners.
Billing Information We use credit card information to manage your account, to provide the Services, and to check the financial qualifications of prospective customers and to collect payment for the Services. We may use a third-party service provider to manage credit card processing. If we do so, such a service provider will not be permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on our behalf.
User Content, Diagnostic Information and Login Information We use this information solely for the purpose of administering and improving our Services to you.
Analytics Information We use Analytics Information to provide and improve our Services to you. We may also use Analytics Information in a de-identified, anonymized way, such as, in conjunction with an analytics service such as Google Analytics, to monitor and analyze use of the Services, for the Services’ technical administration, to modify the Services, to increase the Services’ functionality and user-friendliness for all users, and to verify users have the authorization needed for the Services to process their requests.

If we plan to use your Personal Information in the 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 Privacy Policy”.

4. 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 your Personal Information (see further “Security” below). In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further “Important Exceptions” below).

As of the date of this Privacy Policy, we share Personal Information about you in respect of the Services with our business partners. Our servers are also located in third party datacenters in the United States and accordingly your Personal Information may be available to the United States government or its agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

Our business partners may include:

  • Software developers
  • Hardware vendors
  • Advertising networks
  • Analytics services

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 user information or registered member 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. Such agents or third parties do not have any rights to use Personal Information beyond what is necessary to assist us.

5. Important Exceptions

We may disclose your Personal Information to third parties without your 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 users of the Services, 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 your 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.

These Services are hosted in the United States and are intended primarily for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your Personally Identifiable Information outside of those regions to the United States for storage and processing. By providing your Personally Identifiable Information through the Services, you consent to such transfer, storage, and processing.

6. Security

The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your 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. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.

7. Sharing Information with Third Parties

You may be able to share information with third parties through use of the Services. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

8. Retention

We will keep your 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. Please note that if you request that your name be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.

Amendment of this Privacy 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 or provide appropriate notice. 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 http://www.virtualracingschool.com/privacy-policy.html or via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account. 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. Your continued use of the Services signifies your acceptance 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 user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavour to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your 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 email 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:

Smarty Co.
2885 Sanford Ave SW #12670
Grandville, MI 49418

info@virtualracingschool.com