Site Privacy Policy

TRUSTe Privacy Certification

Effective Date
This Privacy Policy was last modified on August 1, 2016.

This website is operated by Simplifi Holdings, Inc. (“Simplifi,” “we” or ”us”).
This Privacy Policy covers how we collect, receive, use, retain, process, disclose and transfer Personal Information on http://www.simpli.fi (the “Website” or “Site”) and through our online advertising services (“Adverting Services”), which we provide to our partners. It also describes your choices regarding use, access and correction of your personal information. Our partners, including clients such as advertisers or publishers, are referred to in this Policy as “Advertising Customers.” All references to “you,” “your” or “user” apply to any person viewing, using or accessing the Site and its features and services, whether or not they are Advertising Customers.

“Personal Information,” or “PII” is information about you that is personally identifying, such as your name, email address, or telephone number, and that is not otherwise publicly available. The definition of Personal Information depends on your physical location and may include other types of information as well, such as location data, your Internet Protocol (IP) address or other unique identifier. Only the definition of Personal Information that applies to your physical location will apply to you under this Privacy Policy. This Privacy Policy covers information we collect online and off line.

EU-U.S. Privacy Shield
Simplifi participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Simplifi is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.

To learn more about the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity & Purpose Limitation, Access and Recourse, Enforcement & Liability, please visit https://www.privacyshield.gov/welcome.

Simpli.fi uses a self-assessment approach to assure compliance with this the Privacy Shield principles and this Privacy Policy. This includes periodically verifying that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed and accessible, and in compliance with the Privacy Shield Principles.

Simplifi is responsible for the processing of personal data it receives, under the 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 data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, 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 data 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, more fully described on the Privacy Shield Website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Simplifi is a Participating Member of the Network Advertising Initiative

We are a registered member of the NAI and adhere to their code of conduct. Additional information on the NAI and the code can be viewed at http://www.networkadvertising.org/code-enforcement/code.

Agreement
By accessing this Site, by becoming an Advertising Customer, and/or by providing Personal Information, you accept and hereby expressly and unambiguously consent to our collection, use, retention, processing, disclosure and transfer, including cross-border disclosure and transfer, of your Personal Information in accordance with the terms of this Privacy Policy.


This Privacy Policy may change from time to time, so please check back periodically to check the most recent modification date to ensure that you are aware of any changes in our processing of your Personal Information. If we make any material changes we will notify you by means of a notice on this Site prior to the change becoming effective. Your continued use of the Site or Advertising Services after any changes signifies your express and unambiguous consent to any such changes. If you do not agree to such changes, you must immediately stop using the Site and Advertising Services.

Information Collection and Use; Choice and Consent
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 our advertising platform and certain features and services available on the Site. It is always your choice whether or not to provide us with such information. If you do not provide the necessary information you will not be able to become an Advertising Customer and you will not be able to access our ad serving platform or certain 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. By using or providing Personal Information to the Site or becoming an Advertising Customer, you are providing your express consent to the collection, use, retention, processing, transfer, and disclosure, including international transfer and disclosure, of your Personal Information as described in this Privacy Policy.

Users can register and pay for our services or sign up for our advertising platform by phone. When users call to register, we collect their first and last name, email address, phone number, company name, billing address and payment information to enable us to process the transaction and set up and manage the user’s account.

When users log in, we collect an email address and password. When users request a demo, we collect first and last name, email address, and phone number. When users connect to the Site from a social media website, we collect the Personal Information the user has provided to that particular social media website in accordance with the social media website’s privacy practices, and we add the information to our user’s profile and to manage their account. When users contact us by phone or email to apply for a job with Simplifi, we collect Personal Information such as email address, phone number, and other Personal Information provided by the user on his or her resume or C.V. We also collect IP addresses when users access our site.

We use your information to provide the services you have requested, such as to receive information about our products and services, to become an Advertising Customer, to process your billings, to be contacted in regards to an employment opportunity or to provide you with customer service. We also use 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.

We do not collect Personal Information through the Advertising Services, as all information collected is de-identified, Non-Personal Information. While we do collect non-PII from third party sources, it is our policy not to supplement any data we have with any data from third party sources. In addition, it is our policy not to share any data we collect with any third party companies, including service providers and advertising networks, other than our partners and clients.

Please note that at some of Simplifi’s partner or advertiser properties, users may be asked to register and provide personally identifiable data. Although Simplifi is committed to making sure that our partners provide notice and choice to all consumers, the collection and use of such PII is controlled by the policies found on those sites. Since Simplifi cannot control those third party sites, we recommend that you take appropriate steps to control the use of PII on third party sites.

You may revoke your consent, and/or object to or block processing of the Personal Information you provide to us by emailing a request to us at privacy@simpli.fi. We will respond to your request in a reasonable timeframe and in accordance with the law that applies to you. Your Personal Information which we processed prior to your request may not be deleted from our Site system records but will be blocked from further processing without your permission. A request to revoke consent or block processing of your Personal Information may not apply to information collected by cookies or used internally to recognize you and/or facilitate your visits to the Site, or information we may keep to comply with legal requirements.

Public Forums
Our Website offers a publicly accessible blog. You should be aware that any information you provide in this area may be read, collected, and used by others who access it. To request removal of your Personal Information from our blog or community forum, contact us at privacy@simpli.fi. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so.

Non-Personal Information

Passive Collection As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

Tracking Technologies Our third party vendors and we use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. In addition, we use persistent cookies to assist us with the collection and use of de-identified browsing data, including IP address and Cookie ID for online behavioral advertising (“OBA”) activities. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. We do not link the information we store in cookies to any personally identifiable information you submit while on a site. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still navigate Websites, but your ability to use some areas of the site may be limited. To learn more about our cookies, please see our Cookie Policy.

Local Storage Our third party vendors may also use Local Storage/HTML5 to collect and store information in order to provide certain features on our website or to display advertising based upon your web browsing activity. Various browsers may offer their own management tools for removing HTML5.

Opting Out of Simplifi Cookies To Stop Receiving Online Behavioral Advertising From Us
If you would like to disable your unique Simplifi cookie, simply click here. By doing so, Simplifi will replace your unique cookie with an “opt-out” cookie that will prevent us from serving you online behavioral advertising. We will still collect and store information through such cookies for metrics and analytics purposes and we may still serve you advertising, but not based on such information. Because cookies are browser specific, if you use more than one browser on your computer, you will need to disable the Simplifi cookie while using the other browser(s) in order to opt-out completely. To do so, point each browser that you use to this page, and click on the disable link above. Please note that you will need to set the Simplifi opt-out cookie again under the following circumstances: You buy a new computer or upgrade the browser of your existing computer.

Clear Gifs (Web Beacons/Web Bugs)
We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), 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 movements 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. We do not tie the information gathered by clear gifs to personally identifiable information.

In performing our Advertising Services, we collect non-personally identifiable consumer information in multiple ways, including:
  • on our own web sites
  • on the web sites of publishers or Advertising Customers that call our pixels (or “beacons”)
  • when we serve online advertisements, and
  • from third party providers
This de-identified data includes, but is not limited to, information such as a web visitor’s web pages which have been viewed by a web visitor, date and time, domain type, and responses by a web visitor to an advertisement delivered by us or a third party advertising technology vendor. As the Internet evolves, we may use different types of technologies to collect these types of de-identified, non-personally identifiable information. The collection of this de-identified data allows us and our advertisers to better target advertising to user interests. The data also allows us provide improvements to 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.

Opting Out of Clear Gifs (Web Beacons/Web Bugs) To Stop Receiving Behavioral Advertising From Us
If you do not want us to use de-identified data that relates to your use of the Internet to serve you online behavioral advertising, please click here: Opt-Out. We will still collect and store information through such clear gifs for metrics and analytics purposes and we may still serve you advertising, but not based on such information.

JavaScript
We also use JavaScript to assist us with the collection and use of de-identified browsing data, including IP address and Cookie ID for OBA activities.

Data Retention
We will retain the information your 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. We retain the information we collect through our Advertising Services for 30 days.

Security
Simplifi uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information and to protect it against loss or unauthorized use or disclosure. As the Internet is not 100% secure, we cannot, however, ensure or warrant the security of any information you transmit to Simplifi and you do so at your own risk. Once we receive your transmission of information, Simplifi makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Information Sharing and Disclosure
We will not sell, trade or share your Personal Information with other companies for their promotional purposes.

We share your Personal Information with our 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.

Information that we collect through our Advertising Services is shared with and disclosed to our Advertising Customers to enable them to serve targeted advertisements to user devices based on the user’s browsing history and online activities. As stated above, only de-identified, Non-Personal Information is collected by the Advertising Services.

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) conform to the edicts of the law or comply with legal process served on Simplifi, (2) protect and defend the rights or property of Simplifi; (3) act in urgent circumstances to protect the personal safety of users of Simplifi, its websites or the public; (4) to provide updates and services that may be of interest to the customer; 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.

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 another company acquires all or substantially all of the assets related to the business, we reserve the right to include, disclose and transfer any or all stored Non-Personal and Personal Information among the assets transferred to the acquiring company. If Simplifi is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or 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

Given that the Internet operates in a global environment and that transfer of your data is necessary to provide you with requested services, to provide updates, to respond to your inquiries, and to provide Advertising Services, using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international, or cross-border, basis. 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 in this way. 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. The U.S. has not been recognized as providing an adequate level of protection according to EU data protection requirements, but we will take all steps reasonably necessary to ensure that users’ Personal Information is treated securely in respect of such transfer and as described in this Privacy Policy. 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 the EU.

Social Media Widgets
Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. 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
The Site may contain links to other sites that are not owned or controlled by Simplifi. Please be aware that we are not responsible for the privacy practices of these other sites. We encourage you to review the privacy policies and statements of other sites to understand their information practices. Our Privacy Policy applies only to information collected by our Site.

The Site uses Google Analytics. For more information about Google analytic cookies, please see Google’s help pages and privacy policy: Google Privacy Policy: http://www.google.com/intl/en/policies/privacy/
Google Analytics Help: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). If you want to opt out of Google Analytics, you can download and install the add-on for your web browser at https://tools.google.com/dlpage/gaoptout.

Third Party Advertising
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party advertising vendor may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here http://preferences-mgr.truste.com/. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Children’s Privacy
Our Site is not directed to children and we do not knowingly collect Personal Information from users who are under age 13. If you believe your child has provided Personal Information to the Site, please contact us at privacy@simpli.fi.

We currently do honor Do Not Track signals.

Accessing Your Information
You may access your Personal Information that we hold, as well as to correct, amend or delete information that is inaccurate by contacting us at privacy@simpli.fi. In addition, upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@simpli.fi. 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.

Advertising Services; Collecting Information on Users’ Online Activities Across Devices Over Time
Simplifi provides its online Advertising Services to Advertising Customers through site retargeting, search retargeting, contextual retargeting, Facebook API and the collection of location data (“GeoFencing”) of Internet users. These services are provided through third party websites owned and operated by our Advertising Customers who publish their own content on the Internet.

Through our Advertising Services, we collect Personal Information and Non-Personal Information regarding users’ online activities over time and across non-affiliated web sites, mobile applications, or online services, as applicable, and across multiple devices. We collect this information for the purposes of predicting user preferences or interests so our Ad Serving Customers can deliver advertising to a user’s computer or device based on the preferences or interests inferred from his/her online activities.

Advertising Opt-Out Rights To Stop Receiving Online Behavioral Advertising From Us.

Users may opt out of Simplifi’s Advertising Services at https://app.simpli.fi/opt-out. If you opt-out, we will still collect and store information for metrics and analytics purposes and we may still serve you advertising, but not based on such information. Opting-out for one of your devices will not serve as an opt-out for all of your devices. If you wish to opt-out for all of your devices, you must opt-out for each one.

You can learn more about, and opt out of, online advertising on the Network Advertising Initiative’s Consumer Opt-Out page at: http://www.networkadvertising.org/choices/#completed. In addition, you can opt out of online advertising at https://preferences-mgr.truste.com.

Mobile Advertising ID’s and Opting Out from Advertising 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.

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.

1. If you run Android 2.3 or above, go to your Apps drawer and find ‘Google Settings’.
2. Select Ads.
3. Tap ‘Reset advertising ID’ to get a new ID number, which will also delete any previous information stored.
4. 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.

Contact Us About Complaints, Questions, Comments, or Notices relating to this Privacy Policy
Simplifi commits to resolving complaints about your privacy and our collection, use or transfer of your Personal Information. Users with a need to provide a Notice to us under this Policy or our Terms of Use, or Users with inquiries or complaints regarding this Privacy Policy should first contact Simplifi at:

privacy@simpli.fi
or:
Chief Privacy Officer
c/o Frost Prioleau, CEO
Simplifi Holdings Inc.
1407 Texas Street, Suite 202
Fort Worth, TX 76102

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.