Privacy Policy

Last modified on May 24, 2018.

SEMPAD (“SEMPAD”, “we”, “us”, “our” and terms of similar meaning) take your privacy rights very seriously. We are committed to transparently describing our privacy practices, including how we collect, use and disclose your information and data as part of the normal operation of our Services, as defined in our Terms of Use (“Terms”).

We encourage you to read and understand our Terms and this Privacy Policy before using the Application. By accepting the Terms and/or Privacy Policy in registration or by accessing or using the Services (including by visiting the Site), you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms.

All capitalized terms that are not otherwise defined herein obtain their meaning from the Terms.

What Information Do We Collect?

Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose.

Personal and Identifying Information

Users of the Application must provide the requested contact and identity information and other personal information as indicated where appropriate on the Application. Where possible, on these forms we indicate which fields are required and which fields are optional.  In addition, as you use the Application, you can from time to time enter or send to us personal information.

The Application allows Users to connect their Campaigns. By connecting Campaigns, additional information may be shared with SEMPAD.

You always have the option to not provide certain personally identifying information by choosing not to become a User or by not using the particular feature of the Application for which the information is being collected.

Credit Card Information

If you have selected to pay by credit card, we may collect credit card information for payment and billing purposes.

Information Collected Automatically

When you use the Services, SEMPAD automatically receives and records information from your browser, including your location, IP address, browser type, operating information, device and application IDs, cookie information, and the page you requested. Unless otherwise stated in this Privacy Policy, SEMPAD only uses this data in aggregate form.

“Cookies” are small files placed on your hard drive that assist us in providing our Services. We use cookies to allow you to enter your password less frequently during a session, and we use data collection devices, including cookies, on certain pages of the Application to help analyze our web page flow and to offer certain features that are only available through the use of a cookie and to allow us to provide information that is targeted to your interest.

Information Collected from Third Parties

We may receive and store information that is received from third parties that interact in some way with the Services or that provide services to us. For example, as described above, you may choose to connect your Campaigns to the Application in order to view your ad data. The third party applications that operate the Campaigns may, if you permit, share your personal information and data with SEMPAD. For example, if you connect a Campaign to the Application, SEMPAD may automatically receive information and data related to your Campaigns, including but not limited to the location, registered name, ad budget, target audience, telephone number, etc. of that connected 3rd party account.

Please read the privacy policy of any such application or Campaign provider so that you understand its privacy practices.

How We Use Your Information

  • We may use personal information in the file we maintain about you, and other information we obtain from your current and past activities on the Application, to provide to you the Services; resolve service disputes; troubleshoot problems; deliver information to you that, in some cases, is relevant to your interests; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Terms; provide you with system or administrative messages, and as otherwise described to you at the time of collection.
  • We may also use personal information about you to improve our marketing and promotional efforts, to analyze Application usage, to improve our content and product offerings, and to customize the Application’s content, layout, and services. These uses improve the Application and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Application.

Please see our Terms for information on what we do to account information when you terminate your account with us.

For European Territory Visitors

Legal Basis for Requiring & Processing Personal Data

We provide the representations and information in compliance with the European General Data Protection Regulation (GDPR). They are specific to persons located in EEA countries and Switzerland. This information not applicable if you do not reside in one of those countries.

For European Territory visitors, our basis for collecting and using personal data will depend on the context in which it is collected. "European Territories" means the European Economic Area & Switzerland. For the purpose of this Privacy Notice, the term "European Territories" will include the United Kingdom, even after it leaves the European Economic Area.

In order to administer the platform and fulfill our obligations as a service provider, we will collect personal data when required for these purposes.

We may collect personal data based on consent. To the extent our Advertising Partners need to collect and share, or facilitate the collection of personal data to enable our services, it is the responsibility of these 3rd parties to provide adequate privacy notices & obtain consent(s).

If you have questions or require further information concerning the legal basis to collect and use your personal information, please contact us at

Retrieving, Deleting or Pausing Use of Your Personal Data

In compliance with the European General Data Protection Regulation (GDPR), if you are located in EEA countries or Switzerland and require stored personal data pertaining to yourself or your clients to be:

  • deleted
  • provided in a downloadable data file
  • paused from further use
  • handled in any way as specified in the GDRP

or you have any other questions or requirements, please contact us with your request at

Our Disclosure of Your Information

We will share your personal information with third parties only in the ways that are described in this Privacy Policy and in accordance with your permissions. We will not sell or rent your personally identifiable information to third parties without your explicit consent.

The following describes some of the ways that your information may be disclosed in the normal scope of business to provide our services:

Anonymized Aggregated Data. We aggregate and anonymize data and use and disclose such information for a variety of purposes, including analytics. However, in these situations, we do not disclose any information that could be used to identify you personally.

Subsidiaries and Affiliates; Service Providers.  We may from time to time use the services of affiliates, subsidiaries and unrelated service providers in the operation of the Application and the provision of our Services, and may disclose personal information to them in the course of our use of their services.  For example, we may use the services of third-party hosting companies to host the operation of the Application and the Services.  This may involve the hosting of data, including personal information, on servers operated by those hosting companies.  We may also use service providers to process payments of Users who wish to pay by credit card. We take care to use only service providers that we believe are reputable and able to live up to our and your expectations, including about the handling of confidential information.

Law and Harm; Jurisdictions. Notwithstanding anything to the contrary in this policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or any other person’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information. 

Sale of Business

We may also disclose personal information to the acquirer or its agents in the course of the sale of our business.  If we do this, the disclosure will be subject to confidentiality arrangements customary in such transactions.

Storing or Processing Your Data Outside of Canada

Finally, please note that in some cases, personal information that we collect may be stored or processed outside of Canada.  In such cases, we continue to protect the information with appropriate safeguards, but it may be subject to the legal jurisdiction of those countries and governmental authorities in those countries.

Correcting and Updating Your Personal Information

Users may review, delete and update your personal information to ensure it is accurate through the Application. Users may also disconnect any connected Campaigns through the Application. Alternatively, Users may contact us at to update or delete their personal information.

Children’s Privacy

The Services are not intended for children under the age of eighteen (18). SEMPAD does not target its Services or the Application to children under eighteen (18). SEMPAD does not knowingly collect personal information from children under the age of eighteen (18).


If applicable, your SEMPAD User Account is protected by a password for your privacy and security. You must prevent unauthorized access to your account by selecting and protecting your password appropriately, and limit access to your device.

While we strive to protect your information and data we cannot guarantee the security of your User Account information. Unauthorized entry or use, hardware or software failure and other factors, may compromise the security of User information at any time.

Other Information Collectors

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties through the Application, including Campaign providers, different rules may apply to their use, collection and disclosure of the personal information you disclose to them. Since we do not control the information use, collection or disclosure policies of third parties, you are subject to their privacy policies. We encourage you to ask questions before you disclose your personal information to others.

Managing Communications with SEMPAD

All communications made by SEMPAD to Users shall be in compliance with all anti-spam legislation and regulation. Users may manage their communication preferences and will be able to unsubscribe from all communications with SEMPAD by clicking the appropriate links contained in the footer of all marketing communications made by SEMPAD.

You may also manage your communication preferences by e-mailing SEMPAD at

Changes to This Privacy Policy

SEMPAD may amend this Privacy Policy from time to time. The use of information we collect is subject to the Privacy Policy in effect at the time the information is used. If we make any material changes in the way we use your personal information or data, we may notify you by e-mailing you at your e-mail address used to register for the Services (if any) and/or by posting an announcement in a visible location on the Site or Application. Users are bound by any changes to the Privacy Policy when they use the Services after such changes have been first posted.


It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please email our privacy officer at