Confidentiality Policy for Smilifly (A Tier Brand of Connexy)

Excluding Quebec, Canada

At Smilifly, we prioritize the privacy and confidentiality of our clients' personal information. This Confidentiality Policy outlines our commitment to adhering to Canadian privacy laws, excluding Quebec, particularly in regard to Facebook ads and the transfer of personal information to a dental clinic in Turkey for individuals interested in dental services.

1. Purpose

The purpose of this policy is to establish clear guidelines for the collection, use, and transfer of personal information obtained through Facebook ads for individuals interested in dental services in Turkey.

2. Scope

This policy applies to all employees, contractors, and third-party service providers of Smilifly involved in handling personal information collected from Facebook ads and transferring such information to the dental clinic in Turkey.

3. Collection of Personal Information

a. Personal information collected through Facebook ads will be limited to what is necessary for facilitating contact between interested individuals and the dental clinic in Turkey.

b. Explicit and informed consent will be obtained from individuals before collecting their personal information, outlining the purpose of collection and any potential transfers.

4. Use of Personal Information

a. Personal information collected will only be used for the specified purpose of facilitating contact with the dental clinic in Turkey regarding dental services.

b. Personal information will not be used for any other purposes without explicit consent from the individual, except as required by law.

5. Transfer of Personal Information

a. Personal information collected may be transferred to the dental clinic in Turkey to facilitate contact with interested individuals regarding dental services.

b. Secure measures, such as encryption and secure communication channels, will be implemented to ensure the safe transfer of personal information to the dental clinic in Turkey.

6. Security Measures

a. Appropriate technical and organizational measures will be implemented to protect personal information against unauthorized access, disclosure, alteration, or destruction.

b. Access to personal information will be restricted to authorized personnel who require access for legitimate business purposes.

7. Compliance

a. Smilifly will comply with all relevant Canadian federal and provincial privacy laws and regulations, excluding Quebec, pertaining to the collection, use, and transfer of personal information.

b. Any breaches of this policy will be promptly investigated, and appropriate actions will be taken to address the breach and mitigate potential harm.

8. Training and Awareness

a. All employees and contractors handling personal information collected through Facebook ads will receive training on this policy's requirements and their responsibilities for ensuring compliance.

b. Regular awareness campaigns will be conducted to keep all personnel informed about their obligations regarding personal information confidentiality.

9. Review and Revision

a. This policy will be reviewed regularly and updated as necessary to align with changes in laws, regulations, or business practices.

b. Employees and contractors will be informed of any policy changes and provided with necessary training to ensure compliance.

10. Contact Information

For inquiries or concerns about this Confidentiality Policy or the handling of personal information, individuals may contact: Communication@connexy.ca

Conclusion

Smilifly is committed to upholding the confidentiality and privacy of personal information collected through Facebook ads and transferred to the dental clinic in Turkey. This policy underscores our commitment to compliance with Canadian privacy laws, excluding Quebec, and outlines our efforts to implement appropriate measures to safeguard personal information against unauthorized access or disclosure. Smilifly is a distinct entity from Facebook and does not claim any affiliation or representation of Facebook's brand or services. The name "Facebook" is the property of Facebook Inc. and is used herein for descriptive purposes only.

Date of last update: March 2025