February 1, 2020
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 may receive this Precise Location Data from third-party partners including Cuebiq. 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.
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.
- We may disclose Personal Information with your consent.
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.
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.
We partner with third parties to provide customers with political targeting options. If you would like to view the current list of third-party political interest segments available through Simplifi, please click here.
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:
— Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page ( https://youradchoices.com/appchoices)
— 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’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.
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, or where the rights of persons other than the individual would be violated.
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.
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 firstname.lastname@example.org. 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.
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,the United Kingdom 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.
CALIFORNIA PRIVACY RIGHTS
This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice by using a screen reader.
Personal Information We Collect and Disclose for a Business Purpose
We collect the categories of personal information about California consumers identified in the chart below. As further set forth in the chart below, in the past 12 months, we have disclosed California consumers’ personal information to third parties for business or commercial purposes.
|Categories of Personal Information||Collected in the last 12 months:||Categories of sources from which information is collected:||Business or commercial purposes for collection, use, and sharing:||Disclosed for business purposes to the following categories of third parties:|
|Personal and online identifiers (such as first and last name, email address, postal address, or unique online identifiers)||Yes||All categories listed below.||All purposes listed below.||All categories listed below.|
|Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)||Yes||All categories listed below.||All purposes listed below.||All categories listed below.|
|Geolocation information||Yes||All categories listed below.||All purposes listed below.||All categories listed below.|
Categories of Sources
We collect this personal information from the following categories of sources:
- Our Advertising Customers;
- Service providers;
- Affiliates not under the Simplifi brand; and
- Third party data providers.
Why We Collect, Use, and Share California Information
- Our commercial purposes, including selling and otherwise disclosing the personal information to our Advertising Customers.
- Our business purposes as identified in the CCPA, which include:
— Auditing related to our interactions with you;
— Legal compliance;
— Detecting and protecting against security incidents, fraud, and illegal activity;
— Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
— Internal research for technological improvement;
— Internal operations;
— Activities to maintain and improve our services; and
— Other one-time uses.
Your Rights Regarding Personal Information
California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
- The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
- The right to request that we delete the personal information we have collected from you or maintain about you.
- The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:
- By email at email@example.com
- By phone at 800.840.0768
Verification Process and Required Information
Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.
You may designate an authorized agent to make a CCPA request on your behalf by verifying your identity and providing the agent with written permission to make a request on your behalf.
Minors’ Right to Opt In
We do not knowingly sell the personal information of minors under 16 years of age.
We retain the information we collect through our Advertising Services for a minimum of 30 days, or longer if needed for auditing purposes.
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.
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.
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)
c/o Amalie 6 ApS
Amaliegade 6. 2. tv.
DK – 1256 Copenhagen K
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.