Effective Feb 2, 2015
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States.
Information Collection and Use
Our primary goals in collecting information are to provide and improve our Site, services, features and content, to administer your membership (together, the “Service”) and to enable users to enjoy and easily navigate the Site.
Personal Information We Collect. In accordance with applicable law, we collect the following categories of personal information:
- Blog Content. Simplee offers a publicly accessible blog, accessible at simplee.com/resources/ (the “Blog”). You should be aware that any information you provide on the Blog, including, but not limited to, comments, may be read, collected and used by others who access the Blog. To request removal of your personal information from the Blog, contact us at firstname.lastname@example.org. 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 and why.
- Surveys, Contests or Sweepstakes. From time to time we may provide you the opportunity to participate in surveys, contests or sweepstakes (collectively, “Promotions”) on our Site. If you decide to participate, we will request certain personal information from you. Participation in these Promotions is completely voluntary and you have a choice whether or not to disclose this information. We use this information to administer your participation in each Promotion.
- Log Data. When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. We also use this information to verify that visitors to the Site meet the criteria required to process their requests.
- Information from Other Sources. As a Simplee Member who has registered for the Service, you have the option of providing your personal information in order to grant Simplee access to your personal accounts with certain third-party insurance company, financial and healthcare-related websites (collectively, “Third Party Websites”), so that Simplee can retrieve information that you have stored in your accounts with such Third Party Websites. You may also access the Service via certain Third Party Websites. Depending on the Third Party Website to which you provide Simplee your personal information, Healthcare and Financial Information that is posted to your account with the Third Party Website (including personal information) will be viewable by you and Simplee via the Service. Other online services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other online services you use. Please note that if the Third Party Website becomes unavailable or terminates Simplee’s access to your Third Party Website account, any Healthcare and Financial Information from that Third Party Website will no longer be available or viewable via the Service. You have the ability to disable the connection between the Service and any Third Party Website that you have chosen to access via the Service at any time via the “Settings” section of the Site.
Uses of Personal Information. We use your information for a variety of business purposes, including to:
Fulfill our contract with you and provide you with our Service, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Service;
- Communicating with you about your account, activities on our Service and policy changes;
- Undertaking activities to verify or maintain the quality or safety of the Service;
- Processing your financial information and other payment methods for products or Service purchased;
- Providing advertising, analytics and marketing services;
- Providing our Service on behalf of our customers, such as maintaining or servicing accounts, providing customer service, and verifying customer information;
- Processing transactions; and
- Allowing you to register for events.
Analyze and improve our Service pursuant to our legitimate interest, such as:
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Service and short-term, transient use, such as contextual customization of ads;
- Undertaking research for technological development and demonstration;
- Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
- Improving, upgrading or enhancing our Service or those of one of our partners or providers;
- Developing new products and Service;
- Ensuring internal quality control;
- Verifying your identity and preventing fraud;
- Enforcing our terms and policies; and
- Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
Provide you with additional content and Service, such as:
- Furnishing you with customized materials about offers, products, and Service that may be of interest, including new content or Service;
- Auditing relating to interactions, transactions and other compliance activities; and
- Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
De-Identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Service, or other analyses we create.
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Service;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Service. This may include identifying you when you sign into our Service or keeping track of your specified preferences, interests, or past items viewed;
- Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Service or on third-party sites.
Disclosing Personal Information to Third Parties. Except as provided below, Simplee does not sell, rent or trade personal information with third parties. We have not sold consumers’ personal information in the preceding 12 months.
- Service Providers. We may employ third-party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and Service are used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
- Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
Affiliates. We may share personal information with our affiliated companies.
- Compliance with Laws and Law Enforcement. Simplee cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Simplee or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
- Healthcare and Financial Information. We may publicly display certain Healthcare and Financial Information on the Site, including, but not limited to, the names and contact information of doctors and names and prices for medical procedures.
- Testimonials or Feedback. We may post customer testimonials and feedback on the Site which may contain personal information. We will obtain a Member’s consent via email prior to posting the testimonial or feedback in conjunction with such Member’s personal information.
- Business Transfers. Simplee may sell, transfer or otherwise share some or all of its assets, including your personal information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
- International Transfers. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
Your Choices. You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use de-identified or aggregated information regarding your activities on our Service and for other legal purposes as described above.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. To the extent applicable, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
- Access to/portability of personal information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information transferred to another party.
- Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.
- Request deletion of your personal information, subject to certain exceptions prescribed by law.
- Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, if applicable, where such requests are permitted by law.
If you would like to exercise any of these rights, please log into your account or contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
All Members may review, update, correct or delete the personal information in their Account by contacting us or by making edits via the “profile” section of the Site. If you completely delete all such information, then your Account may become deactivated.
Phishing. Identity theft and the practice currently known as “phishing” are of great concern to Simplee. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Data Retention. We will retain your information, including personal information, for as long as your Account is active or as needed to provide you the Service. If you would like us to delete your record in our system, please contact us at email@example.com with a request that we delete your personal information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Security of Your Information. Simplee is very concerned with safeguarding your information. The security of your personal information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you enter sensitive information or otherwise provide Simplee with access to sensitive information (such as login information and personal information), we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information where it is stored on our systems. Simplee has been verified by Verisign for its use of SSL encryption technologies.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal information (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Notice Concerning Third Party Websites. Our Site contains links to other websites and offers for third party products or services that may be complementary to your use of the Site. If you click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
Information of Minors. This Site is not directed to individuals under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at firstname.lastname@example.org. If we become aware that a child under 13 has provided us with personal information, we will delete such information from our files.