Supplemental Privacy Notice for California Residents

This supplemental privacy notice for California residents (the “Notice”) is effective as of August 1, 2020.

The California Consumer Privacy Act of 2018, as amended (“CCPA”), establishes specific rights for you to control your personal information and requires businesses to provide specific information on how personal information is collected, used and shared.

This Notice applies solely to individual residents of the state of California who use our Services (“consumers”, or “you”) and provides you information required by the CCPA and your rights under CCPA. This Notice supplements the information contained in our Privacy Policy which provides more comprehensive information on how and why Simply (“we”) collect and process your data.

Unless otherwise expressly stated, capitalized terms in this Notice shall have the same meaning as in our Privacy Policy or as otherwise defined in the CCPA.

How We Collect And Use Personal Information

When we use the term “personal information” in this Notice we mean information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. For additional information on our data collection, please refer to our Privacy Policy.

Depending on the Services you have used, in the last 12 months, we have collected the following categories of personal information about you:

Categories of personal information


Identifiers, such as your alias, IP address, email address, device ID or other identifiers we may assign to your account

Sources:

  • Directly from you (including automatically when you interact with our Services);
  • Our advertising partners, if you interact with our ads we have outside our Services;
  • Third party account providers, if you link a third-party account to our Services;
  • Third party payment service providers, if you make purchases in our Services, and other service providers

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your name

Sources:

  • Directly from you, or
  • Third party account providers, if you link a third-party account to our Services and allow your name to shared

Commercial information, such as information regarding purchases you have made

Sources:

  • Directly from you (including automatically when you interact with our Services or
  • Third-party payment service providers, if you make purchases in our Services.

Internet or other electronic network activity information, such as information regarding your interaction with our Services, including your progress in the app, and your interactions with our ads we have outside our Services

Sources:

  • Directly from you (including automatically when you interact with our Services);
  • Our advertising partners, if you interact with our ads, we have outside our Services
  • service providers

Geolocation data, such as your general location determined based on your IP Address

Sources:

  • Directly from you (including automatically when you interact with our Services);
  • service providers

Financial Information

We use payment processors that are our service providers to process your payment transactions on our behalf. They have access to your credit card data, while we may only obtain access from our payment processors to limited card data to allow us to solve issues related to purchases from time to time

Sources:

  • Directly from you
  • service providers

 

We may use or disclose the personal information we collect for one or more of the reasons set forth in Section 3 of our Privacy Policy, and for the business purposes as further detailed in the CCPA as follows:

  • To fulfill or meet the reason for which the information is provided;
  • To provide you with information, products or services that you request from us;
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • Auditing related to an interaction with you and concurrent transactions;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and potentially prosecuting those responsible for such activities;
  • Debugging to identify and repair errors in our Services;
  • Short-term, transient uses;
  • Performing our Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, advertising and marketing;
  • For testing, research, analysis and product development;
  • Activities to verify or maintain the quality of safety of our Services, improving, upgrading, enhancing our services as well as activities to verify and maintain the quality of our services;
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

To Whom We Share Personal Information

As described in Section 5 and 6 of our Privacy Policy, we share information with a variety of recipients, such as our service providers, to achieve these business purposes. The categories of personal information we share for a business purposes are listed above table in Section 1.

We share personal information to, or allow access to personal information by, the following categories of recipients:

  • Simply affiliates;
  • Customer support platforms;
  • Hosting service providers;
  • Payment processors;
  • Analytics partners;
  • Third party account providers;
  • Social media services;
  • Advertising partners;
  • Online advertising;
  • Service providers.

We let certain third-party advertising partners collect the categories of personal information identified above in Section 1 for online advertising purposes. These third party businesses collect personal information directly from a device or browser through cookies or similar tracking technologies when a consumer visits or interacts with our websites, uses our apps or otherwise engages with us online. These third parties use your personal information to serve relevant ads outside our Services on other websites or mobile apps, to serve you personalized advertising based on your interests and behavior, and to carry out other services relating to online advertising, such as analytics, reporting and attribution meaning tracking the source of installs related to ads seen outside the Services. These parties may use collected personal information for their own purposes in accordance with their own privacy policies. Because this disclosure of information can be interpreted as “sale” as defined in the CCPA, we provide you the possibility to opt-out from us disclosing your personal information to our advertising partners for this purpose. Please learn more of your opt-out right below in Section 3.

Your Rights And Choices

CCPA grants California residents various rights to their personal information. When you submit a request to exercise your rights, we are required to verify that you are the consumer to whose personal information the request relates or that you are the person authorized to act on behalf of such consumer. If you use the automated tools provided in our applications, we will typically not need any additional information to verify your request. If you submit your request by other means (email), we may need to ask you for additional information to validate that you are the account holder or have the right to act on behalf of the account holder. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.

  • Right to know:

You have the right to request that we disclose to you, upon verification of your identify, what categories of personal information we have over the past 12 months collected from you, from which categories of sources, for which purposes we have collected that information and also to which categories of third parties we have shared the information with. You also have the right to request a copy of the specific pieces of personal information we have collected about you. To learn what categories of personal information, from what sources, for which business purposes we disclose the personal information, please refer to Section 1 and 2 of this Notice. To learn how we “sell” your data within the meaning of CCPA, please refer to “Online Advertising” in Section 2. To request a copy of your data, you can contact us by email at the following address: info@hellosimply.com. For more information, please refer to Section 5 in this Notice.

  • Right to delete

You have the right to request that we delete personal information we have about you. For deleting your data, you can contact us by email at the following address: info@hellosimply.com. For more information, please refer to Section 5 in this Notice. Following receiving your verifiable request, we will delete or anonymize your personal information and direct our service providers to do so, unless we have a lawful right to retain your information under the CCPA. For example, we may deny your request if retaining your personal information is necessary to detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activities or to comply with a legal obligation.

  • Right to opt-out

You have the right to direct us to not sell your personal information which in our case means that we do no longer share your identifiers and other information with our ads partners to make the ads you see outside our Services more relevant to you. To exercise your right to opt-out, please contact us at the following email address: info@hellosimply.com.

  • Right to non-discrimination

You have the right not to receive discriminatory treatment for exercising any of the rights described above.

Changes To This Notice Your Rights And Choices

We reserve the right to amend this Notice at our discretion and at any time and may update it due to changes in our operations or in the processing of personal information. The date this Notice was last updated is identified at the top of this page. You are responsible for periodically visiting the Simply website and this Notice to check for any changes.

Contact Us

If you have any questions about this Notice, the ways we collect or use your personal information, your rights and choices regarding such use or if you wish to exercise your rights under the CCPA, you may contact us via email at info@hellosimply.com.