Privacy Policy

At Simplr, we take protecting your privacy seriously.

 

 

We value privacy, especially yours

Last Updated: December 23, 2019

At Simplr, we take protecting your privacy seriously. In order for you to participate in the job application and recruitment process or to inquire about our services, we need to collect and use some of your personal information. We want you to understand what personal information we collect and how it is used.

What’s covered by this policy

This policy explains:

  • What personal information we collect and why we collect it;
  • How we use that information;
  • How we share that information; and
  • How to access and update that information.

Personal information we collect from you

Applicants - If you are interested in employment with Simplr and choose to participate in the application or recruitment process, we will need to collect your personal information which may include:

  • Your name, address, email address, telephone number and other contact information;
  • Your resume or CV, cover letter, previous work experience or other experience, education, transcripts, or other information you provide to us during the application and recruitment process;
  • Governmental identification information, if applicable;
  • Social Security Number;
  • Date of birth;
  • Information from communications, interviews, and phone-screenings you may have;
  • Details of the type of employment you are looking for, current or desired salary and other terms relating to compensation and benefits packages, or other job preferences;
  • Any demographic information obtained during the application or recruitment process;
  • Information about your eligibility to work in the United States; and
  • Reference information and information received from background checks (where applicable), drug-tests (where applicable), and including personal information provided by third parties.

If you work for us, we will retain this personal information in your personnel records. If you do not work for us, this Information will be retained and disposed of according to our data retention practices.

Simplr may leverage external data sources in order to provide context and background on applicants in order to improve the application/recruiting experience, mitigate fraud or malicious activity, or comply with internal company and external regulatory requirements.

Where permitted by applicable law, you may be given the opportunity to provide information on your gender, race, or ethnicity. We may gather this information from you for reporting and record-keeping requirements but we will only use this information in accordance with applicable law and will not use it in making any employment decisions. Providing this information is strictly voluntary, and you will not be subject to any adverse action or treatment if you choose not to provide it.

Customers – If you contact Simplr in order to inquire about or otherwise make use of our services, we may collect personal information such as:

  • Your name, address, email address, telephone number and other contact information;
  • Payment information if you purchase our products or services; and
  • Any additional information about you or your company that you provide when you communicate with us.

Personal information we collect when you visit our websites

Simplr and its partners use cookies or similar technologies on our websites to analyze trends, administer the site, track users’ movements around the site, and to gather demographic information about our user base as a whole.

Simplr also gathers certain information about the use of Simplr’s services, including the number of unique visitors, the frequency of visits, how users interact with the sites, user experience preferences, IP address, and other information that may help Simplr improve the user experience, mitigate fraudulent activity, and comply with legal requirements. Such information may include, but is not limited to the following:

Log Information

Simplr also automatically gathers and stores certain information in our server logs about the use of Simplr’s services, including the number of unique visitors, the frequency of visits, how users interact with our services, user experience preferences, and other information that may help Simplr improve the user experience, mitigate fraudulent activity, and comply with legal requirements. Such information may include personal information such as: IP address, Unique Device Identifier, CallerID / ANI (Automatic Number Identification) information, content of web pages, transaction with APIs (Application Program Interface), transactions with IVR (Interactive Voice Response) systems, activity and content of visitor interaction with call center representatives; hardware information, hardware and system settings, browser type, browser language, the date and time of your request, or referral URL.

Cookies, Pixel Tags, and Third-Party Data Sources

Simplr and its partners use cookies or similar technologies on our websites to analyze trends, administer the site, track users’ movements around the site, and to gather demographic information about our user base as a whole.

Cookies

A cookie is a small data file that is managed by your web browser or other application and stored on your local system. Simplr uses session and persistent cookies to, among other things, identify your device during a particular interaction and analyze your behavior during a particular visit. Most web browsers provide you with the ability to accept or decline cookies, as well as to be warned each time a cookie is being sent. If you choose to decline cookies, you may not be able to fully use Simplr’s services.

Pixel tags

Pixel tags, also known as web beacons, help Simplr better manage user experience and content tracking. Pixel tags are tiny graphics with a unique identifier, which provide a similar function to cookies and are used to track user interaction with content provided by Simplr or an affiliate organization. In contrast to cookies, which are stored on a user’s device hard drive, pixel tags are embedded within content. The small size and transparency of pixel tags are not intended to deceive content recipients, but rather minimize distraction.

Do Not Track and Third-Party Advertising Cookies

Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify sites that they do not wish to be “tracked” by third parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most sites, including Simplr sites, do not alter their behavior or change their services when they receive a “do-not-track” flag or signal. You can, however, make decisions about your privacy and the advertisements you receive.

Some of the ads you receive on sites are customized based on predictions about your interests generated from your visits to different sites. This type of ad customization is sometimes called “online behavioral” or “interest-based” advertising. We partner with third-parties to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here or if you are located in the European Union click here. Please note you will continue to receive generic ads. As an alternative to the opt-out, you can also elect to block all cookies from first parties (such as Simplr) and from third parties (such as entities involved in advertising) by using the cookie blocking options built into your browser software. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via these links:

Please note, however, that if you do decide to block cookies or similar technologies, some parts of Simplr’s sites may not function correctly.

Third-party data sources

Simplr may leverage external data sources in order to provide context and background on the users of its services in order to improve customer experience, mitigate fraud or malicious activity, or comply with internal company and external regulatory requirements.

How we use your personal information

Applicants - Simplr will use your personal information for the purposes of carrying out the application and recruitment process which includes:

  • Assessing your skills, qualifications and interests;
  • Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;
  • Communications with you about the recruitment process and your application(s), including, in appropriate cases, informing you of other potential career opportunities at Simplr;
  • Creating and submitting reports as required under any local laws or regulations, where applicable;
  • Making improvements to Simplr’s application and recruitment process;
  • Complying with applicable laws, regulations, legal processes or enforceable governmental requests.

If you are offered and accept a position with us, some of the personal information you provide during the application and recruitment process will be transferred into our internal human resources and related systems for use during your employment. By participating in the applicant process, you agree to such a transfer and use of your personal information.

Customers - For individuals sharing personal information with Simplr in order to inquire about or otherwise make use of our services, we will use your personal information in order to provide the requested information, products, and/or services. Such uses may include:

  • Provide our services, including processing requested transactions;
  • Improving the quality of our services;
  • Sending communications about our products and services;
  • Enabling our business partners and service providers to perform certain Activities on our behalf; and
    • Establish and verify your identity;
    • Process payments;
    • Provide technical support;
    • Protect and improve our services;
    • Offer updates, notices and other information about applications and services available from Simplr or its affiliates as permitted by law. (Note: at any time you may choose to withdraw your consent to Simplr’s use or disclosure of your personal information for marketing and promotional purposes by contacting Simplr as outlined in Where to turn with questions section of this Policy);
    • Respond to your questions, inquiries, comments and instructions;
    • To enforce the applicable Terms of Service;
    • Comply with the law and defend our rights;
    • Track and analyze de-identified data and provide such data to third parties that Provide services to Simplr;
    • Protect against fraud and potential fraud;
    • Notify you of any known breach of your personal information; and
    • Maintain the security and integrity of Simplr’s systems and services.

How we share your personal information

We will not use or disclose your personal information to non-affiliated third parties except as disclosed in this policy.

Simplr may transfer your personal information to:

  • Non-affiliated companies to assist us in providing, maintaining and operating our application or recruiting services. These companies are required to comply with the principles set out in this policy and only use such personal information for the purposes for which it was provided to them;
  • A third-party, in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of its business or of any assets or shares of our business or a division thereof. In such an event, we will provide notice of any material change to this policy, in the manner described in this policy. In these circumstances, personal information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business.

Simplr may also disclose your personal information to:

  • Comply with the law and/or legal process in which a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding);
  • Defend our rights and/or property or the rights and property of others;
  • Enforce our Terms of Use and/or this policy;
  • Respond to claims that the content(s) of a communication violates the rights of another;
  • Detect, prevent or otherwise address fraud, security, or technical issues.

Applicants - Our recruiters (including both our employees and contracted recruiters for us) may contact you about other jobs for which you have not applied but that may be of interest to you based on information you provide about yourself during the application and recruitment process.

How we protect your personal information

We use commercially reasonable technical, administrative, and physical controls best practices to protect your personal information including data encryption where appropriate; however, since the internet is not a 100% secure environment, we cannot ensure the security of personal information during its transmission between you and us. Accordingly, you acknowledge that when you transmit such personal information, you do so at your own risk. We will notify you of any confirmed security breach of your personal information to the extent required by and in accordance with applicable law.

How long we keep your personal information

Simplr will retain your personal information as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or not prohibited by applicable law.

Your rights related to your personal information

While we take various steps to ensure the accuracy and completeness of your personal information, we rely upon you to provide accurate and complete personal information when interacting with us.

Upon your request and as allowed or required by law and consistent with our policies, you may request Simplr to take the following actions with your personal information: (i) provide you with a copy, (ii) correct, (iii) update, or (iv) delete. To make such a request, or if you have a privacy-related complaint, please contact Simplr via postal mail or email as provided in the Where to turn with questions section of this policy.

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 at https://feedback-form.truste.com/watchdog/request.

For non-U.S. residents

We may transfer personal information that we collect about you outside of the country in which it was collected. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring personal information about yourself to a country and jurisdiction that does not have the same data protection laws as the European Union or other region. By doing so, you are consenting to the transfer, use, and disclosure of personal information about yourself to the U.S. as described in this policy.

A few notes about social media

Please be aware that any information that you submit to a social media site such as Facebook, Instagram or Twitter is done at your own risk and without any expectation of privacy. Simplr cannot control the actions of social media site users and is not responsible for any content or submissions contained on such sites. You should always review the privacy policy of any third-party website, product, service, or application.

By using any functionality that permits submissions to social media sites, you are indicating that you have reviewed the applicable privacy policy and terms of use of that site. Additionally, in the event that we offer functionality through our services that permits the posting of content on social media, please be aware that these sites may allow you to publicly post and share this content. Simplr cannot guarantee the privacy and safety of these sites and is therefore not responsible for any content you post. Use these features at your own risk.

Children under 13

Our services are not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that your child is accessing the services and providing personal information without your consent, please contact us by using the information provided below. We will take steps to remove personal information from our storage systems and terminate the account if we determine that a child under 13 has accessed the services.

How you are notified if the policy changes

We may change this policy from time to time. If we do, we will post the updated policy with the last revised date. Your continued participation in the application or recruitment process means that you consent to the updates. You should periodically read the policy to understand our privacy practices.

If we make material changes to this Policy, we will notify you in the site, product, service, or application or by email and seek your affirmative consent where required.

Communicating with you electronically

By participating in the application or recruitment process or using our services, you agree that we can communicate with you electronically. This includes any required notifications (i.e. legal, technical, regulatory, security, privacy).

Commercial messages

Where required, Simplr will seek your express consent to send you such messages. This consent is sought by Simplr Solutions, Inc., 450 Townsend Street, Suite 204, San Francisco, CA 94107. You may withdraw your consent by using the "unsubscribe" link located in the Where to turn with questions section of this Policy.

Your California privacy rights

California Shine the Light Law

California residents may opt-out of Simplr disclosing their personal information to third parties for their marketing purposes. If you are a California resident and do not want Simplr to disclose your information to third parties for their marketing purposes, please contact Simplr by any of the ways described in the Where to turn with questions section below and Simplr will respond within 30 days.

California Consumer Privacy Act (CCPA)

The CCPA provides privacy protections for California consumers through the provision of certain disclosures and granting of specific rights. If you are a California consumer, the following sections provide you with these disclosures and information about your rights and how to exercise them, should you choose to do so.

Categories of Personal Information we collect

We may collect the categories of Personal Information described in the Personal Information we collect section of this Policy. These categories are classified under the CCPA as follows:

Personal Information under CCPA

Categories of Personal Information

Identifiers

Name, mailing address, email address, cell phone number, CallerID / ANI (Automatic Number Identification) information

California Customer Records personal information categories

Name, mailing address, email address, cell phone number, CallerID / ANI (Automatic Number Identification) information, and financial information such as credit card number and debit card number

Protected classification characteristics under California or federal law

Demographic information including age, marital status, and sex (including gender)

Commercial information

Records of products or services you have purchased from us

Internet or other similar network activity

Information we collect when you visit our websites: IP address, unique device identifier, the content of web pages, transactions with APIs (Application Program Interface), hardware information, hardware and system settings, browser type, browser language, the date and time of your request, referral URL, cookies, and pixel tags

 

Sensory information

Audio information from customer interactions with call center representatives

Inferences from Personal Information

Inferences we draw from the Personal Information we collect from you to potentially offer products or services that we believe would be a good fit for you

Categories of sources of Personal Information

We collect Personal Information from the following categories of sources:

  • Directly from you;
  • Partners and affiliates that assist us in providing products and services to you;
  • Non-affiliated companies to assist us in providing, maintaining and operating our services or marketing; and
  • Non-affiliated companies that provide us with demographic information.

Business purposes for collecting Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

  • Provide our services, including processing requested transactions;
  • Improving the quality of our services;
  • Sending communications about our products and services;
  • Enabling our business partners and service providers to perform certain activities on our behalf; and
    • Establish and verify your identity;
    • Process payments;
    • Provide technical support;
    • Protect and improve our services;
    • Offer updates, notices and other information about applications and services available from Simplr or its affiliates as permitted by law. (Note: at any time you may choose to withdraw your consent to Simplr’s use or disclosure of your Personal Information for marketing and promotional purposes by contacting Simplr as outlined in Where to turn with questions section of this Policy);
    • Respond to your questions, inquiries, comments and instructions;
    • To enforce the applicable Terms of Service;
    • Comply with the law and defend our rights;
    • Track and analyze de-identified data and provide such data to third parties that provide services to Simplr;
    • Protect against fraud and potential fraud;
    • Notify you of any known breach of your Personal Information; and
    • Maintain the security and integrity of Simplr’s systems and services.

Disclosure of Personal Information for a business purpose

We may disclose your Personal Information to the following categories of third parties:

  • Non-affiliated companies to assist us in providing, maintaining and operating our services or marketing. These companies are required to comply with the principles set out in this Policy and only use such information for the purposes for which it was provided to them; and
  • A third-party, in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of its business or of any assets or shares of our business or a division thereof in order for you to continue to receive the same or similar products and services from the third-party. In such an event, we will provide notice of any material change to this Policy, or our Services, in the manner described in this Policy. In these circumstances, Personal Information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business.

We may disclose the following categories of Personal Information to third parties for a business purpose:

  • Identifiers;
  • California Customer Records personal information categories;
  • Protected classification characteristics under California or federal law;
  • Commercial information;
  • Internet or other similar network activity;
  • Sensory information (i.e., audio information); and
  • Inferences drawn (e.g., preferences) from Personal Information.

We do not sell any Personal Information.

Access to and deletion of your Personal Information

  • Information Request: By submitting an information request, you may ask that Simplr provide you with a copy of your Personal Information.
  • Deletion Request: By submitting a deletion request, you may ask that Simplr delete any of your Personal Information that we have collected about you and retained, subject to certain exceptions. These exceptions include but are not limited to the following:
  • Providing a good or service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performing our contract with you;
  • Detecting security incidents and protecting against fraud or illegal activity;
  • Debugging products and services;
  • Enabling solely internal uses that are reasonably aligned with consumer expectations;
  • Complying with a legal obligation; and
  • Making other internal and lawful uses of your Personal Information that are compatible with the context for which you provided it.

To make such an access or deletion request, please contact Simplr as provided in the Where to turn with questions section below. We will not discriminate against you for exercising any of your rights related to your Personal Information.

Accountability and Governance

Simplr has implemented various measures to monitor compliance with and enforce this Policy.

Where to turn with questions

If you have any questions about this policy, about our site, or want to request access to, correction, or deletion of your personal information, or have a privacy-related complaint, you can contact Simplr here, or by telephone at 1-844-4SIMPLR or by mail:

Simplr Solutions, Inc.

Attn: Privacy Office

c/o Office of the General Counsel

648 Grassmere Park

Nashville, TN 37211

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