Services Privacy Policy

This Privacy Policy describes how Simplifi Holdings, LLC (“Simplifi,” “we” or “us”) collects, receives, uses, retains, processes, discloses, transfers, and secures Personal Information through our suite of advertising services (“Advertising Services”). It also describes your choices regarding use, access, deletion, and correction of your Personal Information. Our clients, including advertisers or publishers, are referred to in this Policy as “Advertising Customers.” All references to “you,” “your” or “user” apply to consumers whose Personal Information we collect for our Advertising Services. For information about our data practices on our website located at https://simpli.fi, or our online client portal located at https://app.simpli.fi/login, please review our Website Privacy Policy.

“Personal Information” in this Privacy Policy is information about you that is personally identifying or could reasonably be used to identify you, such as your name, email address, or telephone number. The definition of Personal Information depends on the laws that apply in your location and may include other types of information as well, such as location data (including precise geo- location data), your Internet Protocol (IP) address, your mobile advertising identifier, or another unique identifier. This Privacy Policy covers information we collect online only, unless local law requires otherwise.

1. CHANGES TO THIS POLICY

This Privacy Policy may change from time to time, so please check back periodically for any changes. If we make any material changes, we will notify you by means of a notice on our website prior to the change becoming effective.

2. 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 geolocation of Internet users (“GeoFencing”). 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 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. Simplifi also engages in cross-device linking.

We may combine all of the information that we collect to provide our Advertising Services.

3. HOW WE COLLECT AND USE INFORMATION

We use cookies, JavaScript, and similar technologies to provide our Advertising Services. Among these technologies, we employ a software technology called clear gifs (or web beacons), that help us better manage the advertising content on our network of third-party sites. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online activities of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. In compliance with the Network Advertising Initiative (NAI) and its Accountability and Self-Regulatory Framework, we do not tie the device identifying information gathered by clear gifs to personally identifiable information except as put forth by the NAI Accountability and Self-Regulatory Framework.

In performing our Advertising Services, we collect information in multiple ways, including:

• on our own websites
• on the websites of publishers or Advertising Customers,
• 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.

4. INFORMATION SHARING AND DISCLOSURE

We may share the information we collect with other parties for our business 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 Advertising Services, 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, where permitted by law.

5. SALE OF ASSETS

In the event that Simplifi is involved in a potential or actual 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.

6. YOUR CHOICES

Opting Out of Simplifi Targeted Advertising on Your Browser
Simpli.fi engages in interest-based advertising activities, including cross-device linking, as described above. To learn more information on interest-based advertising, please visit the NAI’s FAQ on digital advertising here. If you would like to stop receiving interest-based advertising from Simplifi on your browser, click here. By doing so, Simplifi will replace your unique cookie with an “opt-out” flag that will prevent us from serving you interest-based advertising. An opt-out choice means that we no longer use or transfer data from the opted-out device for targeted advertisements, and we no longer use data collected on other devices to inform advertisements on that device. We will still collect and store information through such cookies for other purposes such as metrics and analytics and we may still serve you advertising, but it will not be tailored for you. Because cookies are browser specific, if you use more than one browser or device, you will need to make your opt-out choice on each browser or device that you use. To do so, point each browser that you use to this page, and click on the opt-out link above. Please note that you will need to set the Simplifi opt-out cookie again in some cases, for example, under the following circumstances: you buy a new computer or device, delete cookies from your browser, or upgrade or change the browser of your existing computer or device.

Simplifi is a member of the Network Advertising Initiative (NAI) and are members in good standing with the NAI. Additional information on the NAI and its Accountability and Self-Regulatory Framework can be viewed at https://thenai.org/self-regulatory-framework/.

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)

Simplifi participates in the IAB Europe Transparency & Consent Framework and maintains compliance with the Policies and Specifications with the Transparency & Consent Framework.

The IAB Europe assigned ID’s include:
Vendor IDs: Simplifi – 73 Bidtellect – 185

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 is inaccurate, or has been processed in violation of the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) or when otherwise required by law. To make such requests, please contact us at privacy@simpli.fi or please fill out this WEBFORM to exercise your rights. We may take reasonable steps to confirm your identity. 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.

7. INTERNATIONAL OR CROSS-BORDER TRANSFER OF YOUR PERSONAL INFORMATION

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 to the U.S., where our servers are located and where it will be processed and stored on servers in the U.S. Individuals from the European Union, United Kingdom, and Switzerland, please see the section below on “Cross-Border Transfers from Europe” for more information.

8. EU, UK, and SWISS 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, UK, and Swiss 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 privacy@simpli.fi or fill out this WEBFORM to exercise your rights. 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.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Simplifi commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Simplifi commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to:

1.  EU Data Protection Authorities (DPAs), an alternative dispute resolution provider based in the European Union;
2.  Swiss Federal Data Protection and Information Commissioner (FDPIC), an alternative dispute resolution provider based in Switzerland; or
3.  The UK Information Commissioner’s Office (ICO), an alternative dispute resolution provider based in the United Kingdom

If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit the appropriate DPF-relevant web page above for more information or to file a complaint. The services of above are provided at no cost to you.

Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.

Simplifi does not transfer personal information to third-party countries or organizations. In the future, should any transfers of personal information to third parties be required, Simplifi shall remain liable under the DPF Principles if its agent processes such personal information in a manner inconsistent with the DPF Principles, unless the organization proves that it is not responsible for the event giving rise to the damage. Simplifi will be subject to appropriate safeguards, such as standard contractual clauses or certification schemes, to ensure that the information remains protected in accordance with applicable data protection laws.

Additionally, Simplifi is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to personal data transferred under the Data Privacy Framework.

9. CROSS-BORDER TRANSFERS FROM EUROPE

Simplifi relies on safeguards such as the SCCs to receive Personal Information from the European Union, United Kingdom and Switzerland. Simplifi complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Simplifi has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Simplifi has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

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 Data Privacy Framework website here: https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf

10. US Privacy Rights

Simplifi is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to personal data transferred under the Data Privacy Framework. This section contains disclosures required by those laws and explains the rights that may be available to you.

Personal Information We Collect and Disclose for a Business Purpose
In the past 12 months, we have collected, and disclosed to third parties, the following categories of Personal Information about users, for our business or commercial purposes:

• Personal and online identifiers (such as email address, postal address, or unique online identifiers)
• Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
• Geolocation information (including precise location derived from your device)
• Inferences reflecting potential interests or characteristics, including race/ethnicity, health and wellness interests, and political interests.

Categories of Sources
We collect this Personal Information from the following categories of sources:

• Our Advertising Customers;
• Our service providers;
• Affiliates not under the Simplifi brand; and
• Third party data providers.

Categories of Recipients
We may disclose all of the categories of Personal Information listed above to our service providers, to affiliates not under the Simplifi brand, and to other entities for purposes like legal compliance, as described in the “Information Sharing and Disclosure” section of this Privacy Policy above.

We share all of the categories of Personal Information listed above to our business customers for interest-based advertising (also called targeted or cross-context behavioral advertising). This may be considered a sale in some states. We do not otherwise sell Personal Information about users for our Advertising Services.

Why We Collect, Use, and Share Personal Information
We use and disclose the personal information we collect for our commercial and business purposes, as further described above in the “How We Collect and Use Information” and “Information Sharing and Disclosure” sections of this Privacy Policy.

Your Rights Regarding Personal Information
Some U.S. residents have certain rights under various state laws with respect to the Personal Information collected by businesses. If you are a resident of one of these states, you may exercise the following rights regarding Personal Information, subject to certain exceptions and limitations:

• The right to confirm whether Simplifi is processing Personal Information about you.
• The right to correct inaccuracies in the Personal Information we have collected about you.
• The right to know the categories of Personal Information we collect, use, disclose, and sell about you, the categories of sources from which we collected Personal Information , our purposes for collecting or selling Personal Information , the categories of 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 access the specific pieces of Personal Information we have collected about you.
• The right to request that we delete the Personal Information we have collected about you.
• The right to opt out of the processing (including sharing) of Personal Information for interest-based (also called targeted or cross-context behavioral) advertising. Please note that if you opt out of certain practices, we may be unable to provide you with some services.
• Depending on your state, the right to limit Simplifi’s processing of certain “sensitive” Personal Information about you (or to withdraw consent for such processing if you previously gave it).
• The right not to receive discriminatory treatment for the exercise of the above privacy rights.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

• If you reside in a state, country or region that provides individuals with the rights to access, correct, or delete your personal data, please fill out this WEBFORM to exercise your rights. We may take reasonable steps to confirm your identity.
• By email at privacy@simpli.fi
• By phone at 800.840.0768

For residents of certain states, if you have submitted a request that you believe we have not fulfilled, you may contact us to appeal our decision by sending an email with the subject line “Appeal” to privacy@simpli.fi.

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.

Authorized Agent
For residents of certain states, you may designate an authorized agent to make a request on your behalf by verifying your identity and providing the agent with written permission to make a request on your behalf. An authorized agent may submit a request through the methods provided above.

Minors’ Right to Opt In
We do not knowingly sell, or share for interest-based advertising, Personal Information about minors under 16 years of age.

11. DATA RETENTION

We retain the information we collect through our Advertising Services for a minimum of 30 days, or longer if needed for auditing purposes. We do not retain any data collected for interest-based advertising longer than 24 months in an identifiable form, except as required by law.

We retain other Personal Information in compliance with applicable laws and as reasonably necessary for our processing purposes set out in this Privacy Policy. When it is no longer necessary for us to process Personal Information for these purposes, we will deidentify, aggregate, or delete this data.

12. SECURITY

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.

13. CONTACT US

If you have inquiries or complaints regarding this Privacy Policy please contact Simplifi at:
privacy@simpli.fi

or:

Where Simplifi acts as a controller with respect to Personal Information processed through the Advertising Services, the controller of Personal Information is:

Simplifi Holdings, LLC
128 East Exchange Avenue, Suite 700
Fort Worth, TX 76164 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
Denmark

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 Advertising Services.