November 10, 2019
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Simplifi participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Simplifi is committed to subjecting all Personal Information received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List, here: https://www.privacyshield.gov.
To learn more about the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity & Purpose Limitation, Access & Recourse, Enforcement & Liability, please visit https://www.privacyshield.gov/welcome.
Simplifi is responsible for the processing of Personal Information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Simplifi complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, Simplifi is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Simplifi may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted, as described more fully on the Privacy Shield website here: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
Changes to This Policy
Information We Collect
Simplifi provides its online Advertising Services to Advertising Customers through site retargeting, search retargeting, contextual retargeting, Facebook API, and location-based services including (“GeoFencing”) of Internet users. These services are generally provided through third-party websites owned and/or operated by our Advertising Customers who publish their own content on the Internet.
We may receive Personal Information such as physical addresses from our Advertising Customers, which we de-identify and use for GeoFencing and to provide analytical reports to our Advertising Customers. We may also obtain information from third-party data providers, such as physical addresses (including precise geo-location data), information about physical locations of a device over time, and information about consumer characteristics such as demographics and predicted interests.
Through our Advertising Services, we collect information about users’ online activities over time and across non-affiliated web sites, mobile applications, or online services, as applicable, and across multiple devices including connected TVs. We collect information about your device and your visit(s) to websites, apps, and online services, such as browser type and version, Internet service provider (ISP), mobile operating system, referring/exit pages, operating system, date/time stamp, responses by a web visitor to an advertisement delivered by us or a third party, and/or clickstream data.
We also collect information that identifies your devices, which may be considered Personal Information. This information can include, for example, IP addresses, mobile advertising identifiers, and cookie identifiers.
Simplifi collects Precise Location Data (as defined by the NAI) for your device when, for example, a user makes such information available through a third-party mobile application or webpage on a particular device. Simplifi also engages in cross-device linking.
We may combine all of the information that we collect to provide our Advertising Services.
How We Collect and Use Information
In performing our Advertising Services, we collect information in multiple ways, including:
- on our own websites
- on the websites of publishers or Advertising Customers that call our pixels (or “beacons”)
- when we serve online advertisements, and
- from third party providers
The collection of this data about your online activities across non-affiliated properties and linked devices allows us and our Advertising Customers to better target advertising to user interests. This process is called interest-based advertising. The Advertising Services include various analytics and measurement services as well. The data also allows us to improve our services, for example, improving the effectiveness of the advertisements delivered to users and limiting the number of times a person sees a given advertisement.
EU Data Subjects: Processing of Personal Information
We process Personal Information with your consent. On other occasions, we may process Personal Information when we need to do so to fulfill a contract (for example, for billing purposes) or where required to do this by law. If necessary, we may also process Personal Information when it is in our legitimate interests to do this (e.g., for auditing purposes or for fraud detection) and when these interests are not overridden by your data protection rights.
EU data subjects may have rights to access, portability, to revoke consent, to correct, delete, and/or object to or restrict processing of the Personal Information you provide to us. You can email a request to us at email@example.com. We will respond to your request in a reasonable timeframe and in accordance with the law that applies to you. Sometimes a request in relation to your Personal Information may not apply to certain information, such as information we may keep to comply with legal requirements.
Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.
Opting Out of Simplifi Targeted Advertising on Your Browser
Simplifi is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Code of Conduct. Additional information on the NAI and its code can be viewed at http://www.networkadvertising.org/code-enforcement/code.
Simplifi also licenses the AdChoices icon from the Digital Advertising Alliance (“DAA”) at http://digitaladvertisingalliance.org/ and the DAAC at http://youradchoices.ca for the purpose of providing enhanced notice and to inform users when they are being behaviorally targeted and to provide an opportunity to opt out. Simplifi makes every effort to ensure adherence to the self-regulatory principles of the DAA and the DAAC.
To opt-out of interest-based advertising by other companies participating in the following consumer choice mechanisms, please visit:
-European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu)
-Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).
Do Not Track
We currently honor Do Not Track signals transmitted by browsers by treating this signal as an opt out of interest-based advertising.
Opting Out from Simplifi Targeted Advertising on Your Mobile Device
Most devices come with an identifier for advertising purposes that allows advertisers to track and identify users’ consumer interests, and which also provide an opt out. You can follow the instructions below to opt out of Simpli.fi’s interest-based advertising in mobile apps.
For iOS: Every iOS device comes with an identifier for advertising (IDFA), which has two key features:
- It can be reset by the user at any time.
- Users can opt out of all remarketing by enabling a device setting called “Limit Ad Tracking” (LAT), which restricts advertisers from using the IDFA for behavioral advertising. Learn how here: https://support.apple.com/en-us/HT202074
For Android: Every Android device comes with an Android Advertising ID. To opt out or change your Advertising ID settings, follow these instructions.
- If you run Android 2.3 or above, go to your Apps drawer and find ‘Google Settings’.
- Select Ads.
- Tap ‘Reset advertising ID’ to get a new ID number, which will also delete any previous information stored.
- Then check the ‘Opt out of interest-based ads’ checkbox.
If you prefer, you can instead view and modify your current ad settings through web interface by clicking on ‘Ads Settings’.
NAI Mobile Opt-Out Page and Limit Ad Tracking: You can find opt-out settings for various mobile devices at http://www.networkadvertising.org/mobile-choices.
Opting Out from Simplifi’s Location-Based Advertising
You may opt out of our collection, use, and transfer of precise location data for location-based advertising purposes, by using the location services controls in your mobile device’s settings.
We retain the information we collect through our Advertising Services for 30 days.
Simplifi uses commercially reasonable physical, managerial, and technical safeguards designed to preserve the integrity and security of your personal information and to protect it against loss or unauthorized use or disclosure.
Information Sharing and Disclosure
We may share the information we collect with other parties for other reasons, including the following:
- We share your Personal Information with our affiliates and third-party vendors who provide services on our behalf.
- We can disclose Personal Information to provide our Advertising Services, including disclosures to our Advertising Customers to enable them to serve interest-based advertisements to user devices based on the user’s browsing history and online activities.
- Simplifi may also disclose any information if required to do so by law or in the good faith belief that such action is necessary to: (1) comply with legal process served on Simplifi, (2) protect and defend the rights or property of Simplifi; (3) protect the personal safety of users of Simplifi, its Platform or other services; (4)provide updates and services that may be of interest to the user; or (5) prevent online fraud or other cyber threats, for example through an online threat exchange, or to report, detect and/or prevent security events.
- Simplifi is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Simplifi may disclose Personal Information with notice or with your consent, as permitted by law.
In the events above, you will be notified via email of such disclosure, as well as any choices you may have regarding your personal information, in accordance with applicable law.
Sale of Assets
In the event that Simplifi is involved in a merger, acquisition, or sale of all or a portion of its assets, including in bankruptcy, we reserve the right to include, disclose and transfer any or all stored Personal Information and other data among the assets transferred to the acquiring company. If this occurs, you will be notified via email and/or a prominent notice on our Site of any change in ownership or material changes in uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
International or Cross-Border Transfer of Your Personal Information and Your Express Agreement
By providing Personal Information and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information outside your country. The Personal Information of users who are located outside the U.S. may be transferred outside of each eligible country to the U.S., where our servers are located and where it will be processed and stored on servers in the U.S. As explained above, Simpli.fi has self-certified its compliance under the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework for transfers of Personal Information from the European Economic Area to the U.S.
Our Advertising Services are not directed to children and we do not knowingly collect Personal Information from users who are under age 16. If you believe that a child under 16 has provided Personal Information to us, please contact us at firstname.lastname@example.org.
We partner with third parties to provide customers with health targeting options. If you would like to view the current list of third-party health and wellness interest segments available through Simplifi, please click here.
Accessing Your Information
You may request to access your Personal Information that we hold, as well as to correct, amend or delete information when it has been processed in violation of the Privacy Shield Principles or when otherwise required by law. To make such requests, please contact us at email@example.com. We will respond to these requests in accordance with the laws that apply to you and within a reasonable timeframe. You can help us maintain the accuracy of your information by notifying us of any changes to your information. We may deny a request in some cases when permitted by law, such as when the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question (e.g. for legal requirements or auditing purposes), or where the rights of persons other than the individual would be violated.
Chief Privacy Officer
c/o Frost Prioleau, CEO
Simplifi Holdings Inc.
1407 Texas Street
Fort Worth, TX 76102
The controller of Personal Information collected through the Advertising Services is:
Simpli.fi Holdings, Inc.
1407 Texas St # 202
Fort Worth, TX 76102 USA
For EU Inquiries:
Data Protection Officer
c/o Henrik Duedahl Høyer, DPO
Simplifi Europe IVS (designated EU representative)
Terms and Conditions
Please read our Terms and Conditions at www.simpli.fi/terms/ as they also govern your use of the Site and our services.