February 1, 2020
Changes to This Policy
Information We Collect
Users can browse the Site without logging in or providing any Personal Information. Providing Personal Information is necessary to become an Advertising Customer and to access certain features and services available on the Site. For example, we will request your name, contact information, company information, and payment information. When users register and log in as Advertising Customers, we collect an email address and password. When users request a demo or otherwise contact us with inquiries, we collect the Personal Information needed to respond like a name, email address, and phone number. When users connect to the Site from a social media platform, we collect the Personal Information you have provided to that particular social media platform in accordance with the social media platform’s privacy practices and your settings on that platform.
Users can also register as an Advertising Customer and pay for our services by phone. When users call to register, we collect your name, contact information, company information, and payment information to enable us to process the transaction and set up and manage the user’s account.
When users apply for a job with Simplifi, we collect Personal Information such as contact information and other Personal Information provided by the user on his or her resume or C.V.
It is always your choice whether or not to provide us with the Personal Information described above. If you do not provide the necessary Personal Information you will not be able to become an Advertising Customer and you will not be able to access our advertising services or other services available on the Site. We also will have no way to respond to your questions or inquiries or to provide a demo or other requested services.
When users access our Site, we collect certain information automatically including IP addresses and cookie identifiers. We collect information about your device and your visit(s), such as browser type and version, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
How We Use Your Information
We use your information to operate and improve our business and provide the services you have requested, such as to receive information about our products and services, to become and to interact with us as an Advertising Customer, to process your billings, for our legal compliance, to be contacted in regard to an employment opportunity or to provide you with customer service. We also send you marketing materials, including by using your email address to send you email updates and promotional materials from or about Simplifi if you are a U.S. resident or if you are an E.U. resident and have opted in to receive promotional emails. You may unsubscribe from promotional emails at any time by clicking “unsubscribe” on the emails you receive from us.
Information Sharing and Disclosure
We will not sell, trade or share your Personal Information with other companies for their direct marketing purposes, unless we have your consent.
We may share the information we collect with other parties for other reasons, including the following:
- With our affiliates and third party vendors who provide services on our behalf, such as an email marketing company who distributes our newsletters to our users, and our third party payment processors who process your transactions. These companies are authorized to use your Personal Information only as necessary to provide these services to us.
- 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 the law or 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 Site and other services, or the public; (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.
- 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.
You may unsubscribe from Simplifi’s promotional emails at any time by clicking “unsubscribe” on the emails you receive from us.
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.
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.
Third-Party Targeted Advertising
We partner with one or more third parties to display advertising on our Site and/or to manage our advertising on other sites. Such third parties may use technologies such as cookies to gather information about your activities on this Site and other unrelated sites over time in order to provide you with more relevant advertising based upon your browsing activities and interests. This is called interest-based advertising. Simpli.fi complies with the Digital Advertising Alliance Self-Regulatory Principles and the NAI Code of Conduct in connection with this activity on our Site. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out with respect to companies participating in industry self-regulation by clicking http://optout.networkadvertising.org/?c=1 or http://preferences-mgr.truste.com/, or if located in the European Union click http://www.youronlinechoices.eu/. Please note this does not opt you out of being served ads. You will continue to receive ads, but they will not be targeted based on your browsing activity.
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. 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. By accessing the Site, using Advertising Services, providing Personal Information or sending us email, you expressly and unambiguously agree to such transfer, processing, storage and disclosure in countries outside your own.
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 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
RIGHTS FOR CALIFORNIA RESIDENTS
Our clients who are California residents have certain rights under the California Consumer Privacy Act (“CCPA”) with respect to the personal information that we collect about you:
- With respect to the right to opt out of sales of personal information, we do not and will not sell your personal information in any manner that requires an opt-out opportunity under the CCPA.
- If we engaged in sales, you would have the right not to receive discriminatory treatment for the exercise of your opt-out right conferred by the CCPA.
THIRD-PARTY LINKS AND TOOLS
Social Media Features
Our Site includes social media plug-ins which are interactive mini-programs that run on our Site. These features may allow the third parties that offer the features to collect information such as your IP address, which page you are visiting on our Site, and other data. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it. Our Site is not sponsored or endorsed by LinkedIn, Facebook, Twitter, Google+ or YouTube or other third party websites, which are trademarked and owned by third parties and not by us.
Links to Other Sites; Transactions with Third Parties
We will retain the information you provide to the Site for as long as your account is active, as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
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 Site is 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 the Site, please contact us at email@example.com.
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 Site is:
Simpli.fi Holdings, Inc.
1407 Texas St # 202
Fort Worth, TX 76102 USA