Privacy Policy

1. PREAMBLE

Simpliciter, Ltd. (“herein after referred to as “Simpliciter”, the “Company”, “We”, and through similar words such as “us”, “our”, etc.) provides an advanced sales enablement solution for organizations to enhance their professional business relationships, share their documents in an interactive platform, receive actionable data and oversee the interests of the prospects (the “Services”).
This Privacy Policy (“Policy”) defines Simpliciter’s practices and policies regarding the use and processing of personal information while providing the Services. This Policy describes the kinds of personal information we collect through simpliciter.io and/or app.simpliciter.io (both of “Website”), how we use that information, our legal basis for doing so, with whom we share it, your rights, and choices in this regard, and how You can contact us about our privacy practices. This Policy does not apply to third-party sites, products, or services, even if they link to our Services or Website, and You should consider the privacy practices of those third parties carefully.
Capitalized words not defined in this Privacy Policy are defined in our Terms and Conditions (the “Terms”).
By agreeing this Policy, You are accepting the practices outlined in this Privacy Policy (including any future revisions that may be made), and the Terms, which governs this Policy and contains all warranty disclaimers and liability limitations.

2. DEFINITIONS

Capitalized words not defined under this Policy shall be understood as described under our Terms. It is of utmost importance to read the Policy provided herein in tandem with the Terms to better grasp the key concepts provided and explained therein.
Within the scope of this Policy, the following terms shall have the meanings ascribed to them below. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

# Description
Business for the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California
CCPA means the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act (“CPRA”) (collectively, “California Privacy Laws”)
Company

means Simpliciter Ltd., a corporation incorporated and validly operating in the United Kingdom having its registered address at 3M Buckley Innovation Centre, Firth Street, Huddersfield, West Yorkshire, HD1 3BD, United Kingdom
For the purpose of the UK GDPR, the Company is the Data Controller
Consumer for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (i) every individual who is in the USA for other than a temporary or transitory purpose, and (ii) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose
Data Controller For the purposes of the UK GDPR, means the legal person which determines purposes and means of process of Personal Data alone or jointly with others
Data Subject means a natural person who can be identified or rendered identifiable through the personal data related to
Device means any device that is suitable to access the Service such as a computer, a cellphone or a digital tablet and with an internet connection
Do Not Track (DNT) is a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites
Space

A platform provided by the Company for Members to;
(i) upload and demonstrate their documents in supported file formats,
(ii) embed links,
(iii) schedule meetings and,
(iii) share videos, informative documents and other contents (via Third-Party Service Providers such as Loom, YouTube, Google etc.),
(iv) to benefit from other features may be added time to time
GDPR

means (i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (General Data Protection Regulation) (the "EU GDPR"); and (ii) the EU GDPR as saved into United Kingdom law by virtue of section 3 of the United Kingdom's European Union (Withdrawal) Act 2018 (the "UK GDPR"); in each case as may be amended or superseded from time to time
Personal Information/Personal Data

means any information that relates to an identified or identifiable individual


For the purposes of the UK & EU GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.


For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You
Personal Data Breach means a breach of security whether accidental or on purpose, resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data
Sale of Data

for the purposes of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration
Special Categories of Personal Data

means personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership and genetic and biometric information, information concerning data subject’s sex life or sexual orientation
Service Provider

Any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used


For the purpose of the UK GDPR, Service Providers are considered as Data Processors
Third Party means any other natural or legal person that is not part of Simpliciter
Third-Party Services means any product that Third-Party Service Providers submit to Users for the proper performance of the Website and Space
Third-Party Service Provider means any tool, website or application which a Member can benefit while generating a Space
UK GDPR

United Kingdom General Data Protection Regulation signed into law on 1 January 2021. The UK GDPR forms part of the data protection regime in the UK, together with the new Data Protection Act 2018 (“DPA”). The main provisions of this apply, like the GDPR, from 25 May 2018
Usage Data means data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit)
Website

The website and subdomains, and other media including all of their respective features and content belongs to Simpliciter, accessible from www.simpliciter.io
You

The individual accessing or using the Website or other legal entity on behalf of which such individual is accessing or using the Website, as applicable


For the purpose of the UK GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service

3. GENERAL

Simpliciter obtains personal information concerning You from certain sources to provide the Services and to manage the Website. “You” may be a Visitor, Viewer or Member (both are the “User”) regarding our Services.

You may visit our Website via different accounts depending on the process You will carry out. Here are the titles  are specified in our Website:

  1. Visitor: It shall mean the natural person who accesses and/or uses certain parts of our Website during their visit. To exemplify, a Visitor may request a demo and contact us by e-mail or Website.
  2. Member: It shall mean a natural or legal person who carries out membership transactions on the Space and uses Space to benefit its Services.
  3. Viewer: It shall mean the natural person who accesses, views, and uses the Space with a unique Magic link and whom the Member would like to build and maintain a professional business relationship via Simpliciter. Viewer refers especially to the customers, prospective customers of Member, and the other individuals that the Member reaches out to by using Simpliciter.

4. HOW WE COLLECT DATA

For the purposes of managing the Website and offering the Services, we gather personal information about You from a variety of sources. We also obtain information from You and from Third Parties as detailed below.
Please note that if You decline to provide any of the required information requested by the Company, You may not be able to take full advantage of the Services and their features.

a) Website Users and the Services
We collect information from and about You and your transactions and other interactions with us. This may include, but is not limited to, when You visit our Website and Spaces, when You ask for information about the Service (for example, when You request a demo or ask us to send You offers or price information), create an account, use and benefit from the Services, make a purchase of paid Services, book a demo, reach out to us through the support assistant, or otherwise contact us through the Website, e-mail or any other channels provided by the Company for this purpose.

If You are a Viewer, a Member may request You to provide them with the information including your Personal Data in order for You to view the Space of them. We are able to keep this data on behalf of the Member as a component of our Service. We may also receive your Personal Data (such as your email address) through other Users, for example, if they have tried to share something with You or tried to refer Space to You.

At the time You ask for information about the Service, we will use your contact information to respond to your request. Kindly note that for EU data subjects, use of your account information is necessary to respond to or implement your request.

While contacting us, we strongly ask You not to share the following data belonging to You or any third-party;

    • Special Categories of Personal Data (which means personal data consisting of genetic and biometric information, information concerning sex life or sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership etc.)
    • confidential information of any legal entity e.g., trade secrets, know-how, and other non-public business-related information
    • any data that is not necessary for the purposes of our communication
If You provide your or a third party’s the kinds of data above mentioned, Company cannot be held responsible for the process, transfer, and storage of them.
 
 c) Third-Party Integrations
We benefit from Third-Party Services, to assist us for the performance of the Services. Hence, we use Third Party Service Providers to enable Members to share their content in significant parts of Space, receive accurate analytics to track the engagement, monitor the interests of the Viewers, purchase the membership, manage your partnership requests, provide an interactive support assistant, and manage your FAQ requests. Third-party companies may request various information from Users (name-surname, region, etc.). These Service Providers are prohibited from using personal information for any other purpose and are contractually obligated to comply with all applicable laws and requirements.

Simpliciter is solely the processor of Personal Data collected through its Services and is not responsible for the collection and processing of Personal Data with regard to Third-Party Service Providers.
Third-Party Service Providers are bound by their own use and privacy policies, and Simpliciter cannot be held responsible for behaviors of the Third-Party Service Providers that violate any right arising from personal data protection legislation.
We strongly advise You to read the terms and conditions and privacy policies of any Third-Party Service Providers or web sites that You visit.

d) Third Party Analytics and Advertisements
We also may use third party advertisements, analytics, and tracking tools to better understand who is using the Website, how people are using the Website, who views the Space, how to improve the effectiveness of the Services, the Space and the associated content, and to help us or those third parties serve more targeted advertising to You across our media channels. These third parties may use technology such as cookies, web beacons, pixel tags, log files, flash cookies, or other technologies to collect and store information. They may also combine information they collect from your interaction with the Website with information they collect from other sources, which combination may be subject to the third party’s control and privacy practices thereupon.
 
f) Third Party Social Media Services
We obtain personal information from social media networks and platforms including Facebook, Twitter, LinkedIn, Pinterest, WhatsApp, and Instagram that You use in conjunction with our Website and Services or that allow You to share information with us. For example, if You use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our Website (e.g., to share a Space link with your followers on social media), we will obtain the information that You share with us, or that those social media platforms or networks share with us. Third Party Social Media Services are prohibited from using personal information for any other purpose and are contractually obligated to comply with all applicable laws and requirements.
For more information about social media platform and network privacy practices, please review the privacy policies and settings of such social media platforms and networks.
 
g) Cookies and Automatic Collection Methods
We may also collect information about your online activities on the Website and your Devices to use Website over time and across third-party websites, devices, apps, and other online features.
 
This collection includes automatically collected information, and generally does not include personal information unless You provide it through our Website or You choose to share it with us by other means. Methods we use are described below:
  • Cookies (which may be session-based or persistent, and are typically small data files that are stored on your hard drive or in connection with your internet browser as set forth thoroughly under our “Cookie Policy” section)
  • Web beacons or tags (small images embedded into websites or emails that send information about your Device when You visit our Website, or open an e-mail we send to You);
  • Website log files (which we tend to create automatically in connection with your access to and use of our Website).
To learn more about the cookies that may be served through our Website and how You can control our use of cookies and third-party analytics, please see our Cookie Policy section.
 
 

5. TYPES OF DATA COLLECTED

a. Personal Data that We Collect from Members 
While using our Service, we may ask Members to provide us with certain personally identifiable information in connection with the sign-up, purchase, use, or support of the Member account, to provide the Member with access to the Website and Service, contact You regarding use of the Service and/or the Website, or to notify You of important changes to the Service and/or the Website. Personally identifiable information may include, but is not limited to:
  • First name and last name
  •  Email address
  • Company name and logo
  • Occupational information (title etc.)
  • Internet activity
  • Billing information

b. Personal Data that We Collect from Viewers
While using our Website, we may request from Viewers to provide us with certain personally identifiable information as follows:

  • First name and last name
  • Email address
  • Company name
c. Personal Data that We May Collect from Visitors
When You share your e-mail through Website to join wishlist, we request the following information of You:
  • First name and last name
  • Occupational information (title, sector, number of employees in the organization, number of employees in the sales department)
  • Location (home country)
  • LinkedIn address
Information that We Collect Automatically on Our Website and Services
Our Website uses cookies and other technologies to function effectively. These technologies record information about your usage of our Website, including:
  • Browser and Device Data, such as IP address, device type, internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, brand, model, technical specification and operating system information of the device used, and the language version of the Website You are visiting;
  • Usage Data, such as time spent on the Website, pages visited, links clicked, bounce rate, roll percentage, language preferences, views, Website usage time, communication preferences, payment amount, payment channels, approaches to in-platform notifications/offers/campaigns, habits, favorites, likes, behaviors, preferences, search activities, segments, cookie records, cookie and ad identifier and Device ID, and the pages that led or referred You to our Website.
We also may collect information about your online activities on the Website and connected Devices over time and across third-party sites, devices, apps, and other online features and services. We use web log analysis software (Google Analytics etc.) on our Website to help us analyze your use of our Website and diagnose technical issues.
 
 

6. USE OF PERSONAL DATA

a. Our Services
We rely upon several legal grounds to ensure that our use of your Personal Data is compliant with the applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with legal obligations, and to pursue our legitimate business interests. 
 

Contractual and pre-contractual business relationships. We use Personal Data to enter business relationships with prospective Members and to perform the contractual obligations under the contacts that we have with Users. Activities that we conduct in this context include:

  • Creation and management of account and Space, including the evaluation of applications to commence or expand the use of our Services;
  • Accounting and billing activities; 
  • Responding to inquiries, sending service notices, and providing customer support; and
  • Processing of payments, communications regarding such payments, and related customer services.
Legal and regulatory compliance. We use Personal Data to verify the identity of our Users in order to comply with laws. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties and to submit to third-party verification audits.
Legitimate business interests. In order to process some Personal Data pertaining to You, we rely on our legitimate business interests. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose Personal Data we process. 
  • Mitigating financial loss, claims, liabilities, or other harm to Users and Simpliciter;
  • Promoting, analyzing, modifying, and improving the Space and related systems, and tools, and developing new Services, increasing our Services’ functionality and user-friendliness;
  • Personalizing and improving your access to and use of the Site and the Service;
  • Managing, operating, and improving the performance of our Website and Services by understanding their effectiveness and optimizing our digital assets;
  • Analyzing and advertising our Services;
  • Conducting aggregate analysis and developing business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business;
  • Sharing Personal Data with Third-Party Service Providers that provide services on our behalf and business partners who help us operate and improve our business;
  • Preventing, malicious, fraudulent, misuse, or other unauthorized or illegal activity of Services; 
  • Ensuring network and information security throughout the Website and our Services.
Payment transactions and related services. For payment transactions, we make use of third-party payment services. The third-party payment processing Service Providers receive and process the data that You submit to complete the payment process. We advise You to review the Privacy Policies and Terms of Use for these third-party payment systems to understand how they handle your Personal Data.
 
If we need to use your Personal Data in any other way, we will notify You specifically at the time of collection and, if required by the relevant legislation, we will obtain your consent.
 
b. Marketing and Events-related Communications
We may send You e-mail marketing communications about Simpliciter and its Services, invite You to participate in our events, surveys; send your suggestions and requests via our forms, or otherwise communicate with You for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by Privacy and Electronic Communications Regulations (“PECR”) and other applicable law. When we collect your business and contact details through your participation at trade shows or other events, we may use the information to follow-up with You regarding these events, send You information that You have requested on our product and Services, and with your permission, include You on our marketing information campaigns. 
 
 

7. HOW WE SHARE PERSONAL DATA

Simpliciter may share your Personal Data to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Policy and our Terms and Conditions, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our Users and the public. 

We share Personal Data with a limited number of our Service Providers. We have Service Providers that provide services on our behalf, such as website hosting, data analysis, information technology, and related infrastructure, customer service, e-mail delivery, and auditing services. These Service Providers may need to access Personal Data to perform their services. We authorize such Service Providers to use or disclose Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. 

We may disclose information in the aggregate form to third parties relating to user behavior in connection with the actual or prospective business relationship with those third parties, such as advertisers and content distributors. 
We will encourage our service partners to adopt and post transparent privacy policies. However, the use of your personal information by our service partners is governed by their privacy policies and is not subject to our control. You acknowledge that we are not responsible for the violations caused by our service partners.

We share Personal Data with third-party business partners when this is necessary to provide our Services to our Users. 
We share Personal Data with Members as necessary to maintain a Member account and provide the Services. When Viewers receive Space from Members, we display Member’s information to the relevant Viewer. The use of Personal Data by an authorized third-party including Loom, Youtube, Google is subject to the relevant third party’s privacy policy.    
In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.

We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety, and property of Simpliciter, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

8. EUROPEAN UNION and UNITED KINGDOM PRIVACY INFORMATION (“GDPR PRIVACY”)

Your Rights and Choices Under the GDPR
Simpliciter undertakes to respect the confidentiality of your Personal Data and to guarantee You can exercise your rights.
You have the right under this Privacy Policy, and by law if You are within the UK or EU, to: 
  • Right of Access: You have the right to obtain confirmation from us as to whether or not Personal Data concerning You are processed, and, where that is the case, You have the right to request and get access to such Personal Data.
  • Right to Rectification: You have the right to request rectification by us of inaccurate Personal Data and You have the right to provide additional Personal Data to complete any incomplete Personal Data.
  • Right to Erasure (“Right to be Forgotten”): In certain cases, You have the right to request from us the erasure of your Personal Data.
  • Right to Restriction of Processing: You have the right to request from us restriction of processing, for a certain period and/or for certain situations.
  • Right to Data Portability: You have the right to receive your Personal Data from us in a structured format and You have the right to (let) transmit such Personal Data to another controller.
  • Right to Object: In certain cases, You have the right to object to the processing of your Personal Data, including with regards to profiling. You have the right to object to the further processing of your Personal Data in so far as such data has been collected for direct marketing purposes.
  • Right to be Not Subject to Automated Individual Decision-Making: You have the right to not be subject to a decision based solely on automated processing.
  • Right to Filing Complaint: You have the right to file complaints with the applicable data protection authority on our processing of your Personal Data.
  • Right to Compensation of Damages: In case we breach applicable legislation on the processing of your Personal Data, You have the right to claim damages from us for any damages such breach may cause to You.
 
Exercising of Your GDPR Data Protection Rights
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. If You are a resident of United Kingdom, You may complain to Information Commissioner’s Office (ICO) regarding your data protection rights. If You are a resident in the European Economic Area (EEA), please contact your local data protection authority in the EEA. However, we would be appreciated to deal with your concerns before You apply to a Data Protection Authority.
You may exercise your rights of access, rectification, cancellation, and opposition by simply contacting us. Please note that we may ask You to verify your identity before responding to such requests. If You make a request, we will try our best to respond to You as soon as possible.
 

9. CCPA PRIVACY

Your Rights and Choices Under the CCPA
Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:
  • Right to notice: You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access / the right to request: The CCPA permits You to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
  • The right to say no to the sale of Personal Data: You have the right to ask the Company not to sell your Personal Data to third parties. You can submit such a request by visiting our Website.
  • The right to know about Your Personal Data: You have the right to request and obtain from the Company information regarding the disclosure of the following:
    • The categories of Personal Data collected
    • The sources from which the Personal Data was collected
    • The business or commercial purpose for collecting or selling the Personal Data
    • Categories of third parties with whom We share Personal Data
    • The specific pieces of Personal Data we collected about You
  • The right to delete Personal Data: You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
  • The right not to be discriminated against: You have the right not to be discriminated against for exercising any of your Consumer’s rights, including by:
    • Denying goods or services to You
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to You
    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if You are a California resident, You can email us or contact us via ###
The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
 
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA.
If You wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, You may do so by following the instructions below.
 
Website
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
  • From Our “Cookie Consent” notice banner
  • Or from Our “CCPA Opt-out” notice banner
  • Or from Our “Do Not Sell My Personal Information” notice banner
The opt out will place a cookie on your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by your browser, You will need to opt out again.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.
 
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to your interests:
  • “Opt-out of Interest-Based Ads” or “Opt-out of Ads Personalization” on Android devices
  • “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
 
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third-party websites do keep track of your browsing activities. If You are visiting such websites, You can set your preferences in your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
 
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact us using the contact information provided to You, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

10. SECURITY AND RETENTION

We are making reasonable efforts to provide You with an appropriate level of security at the risk associated with the processing of your Personal Data. We take organizational, technical, and administrative measures designed to protect your Personal Data against unauthorized access, destruction, loss, alteration, or abuse. Your Personal Data may only be accessed by a limited number of personnel who need access to such information in order to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have a reason to believe that your interaction with us is no longer secure (for example, if You think your account is compromised), please contact us immediately.
If You are a User, we retain your Personal Data as long as we are providing the Services to You. We retain Personal Data after we cease providing Services to You, even if You close your account, to the extent necessary to comply with our legal and regulatory obligations. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data due to our contractual commitments to our financial and business partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
We also take measures to delete your personal information or keep it in a form that does not permit identifying You when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of Services requested by or provided to You, the nature and length of our relationship with You, possible re-enrollment with our products or Services, the impact on the Services we provide to You if we delete some information from or about You, mandatory retention periods provided by law and the statute of limitations.
 

11. COOKIE POLICY

Cookies are small text files stored in a computer’s web browser memory. They help website providers with things like understanding how people use a website, remembering a user’s login details, and storing website preferences. This article explains how we use cookies and other similar technologies to help us ensure that our Services function properly, prevents fraud and other harm, and analyze and improve the Services in accordance with our Policy. 
 
a. How We Use Cookies 
Cookies play an important role in helping us provide personal, effective, and safe Services. We use cookies on our Website. We change the cookies periodically as we improve or add to our Services, but we generally use cookies for the following purposes:
To Operate Our Services: Some cookies are essential to the operation of our Website and Services. We use those cookies in several different ways, including:
  • Authentication
  • Performing payment transactions
  • Site Features and Services
  • Performing location submissions 
To Analyze and Improve Our Services: Cookies help us understand how to make our Website, Space and Services work better for You. Cookies tell us how people reach our Website, and they give us insights into improvements or enhancements we need to make to our Website and Services.
For Better Advertising: Cookies can help us provide more effective advertising on our Website. For example, we might use a cookie to help to prevent You from seeing the same advertisement multiple times or to measure how many times an advertisement is viewed or clicked on.
 
b. How We Use Other Technologies
Third Party Analytics: We use Google Analytics which uses cookies and similar technologies, to collect and analyze information about the use of the Services and report on activities and trends. This service may also collect information regarding the use of other sites, apps, and online resources. You can learn about their practices on their website. Please refer to the table below for more on how we use third-party analytics.

First Party Cookies

Cookie Name Categories of Cookie Retention Period
cookielawinfo-checkbox-analytics Strictly Necessary 1 year
cookielawinfo-checkbox-functional Strictly Necessary 1 year
cookielawinfo-checkbox-necessary Strictly Necessary 1 year
cookielawinfo-checkbox-others Strictly Necessary 1 year
cookielawinfo-checkbox-performance Strictly Necessary 1 year
cookielawinfo-checkbox-advertisement Strictly Necessary 1 year
_ga Performance 14 months
_ga_V7VZMNN8KY Performance 14 months
_gat_UA-216671899-1 Performance 1 minute
_gcl_au Performance 3 months
_gid Performance 1 day
CookieLawInfoConsent Strictly Necessary 1 year
viewed_cookie_policy Strictly Necessary 1 year

Third Party Cookies

Cookie Name Cookie Provider Categories of Cookie Retention Period
IDE doubleclick.net Functionality 14 months
__Host-GAPS accounts.google.com Functionality 14 months
_ga google.com Marketing/Analytics 14 months
NID google.com Marketing/Tracking 6 months
_ga_3WTQFP9ECQ google.com Marketing/Analytics 14 months
_gid google.com Functionality 1 day
G_ENABLED_IDPS www.linkedin.com Strictly Necessary 14 months
bscookie www.linkedin.com Functionality/Security 1 year
JSESSIONID www.linkedin.com Functionality/Security Browser session
bcookie linkedin.com Functionality/Security 1 year
lang linkedin.com Functionality/Security Browser session
lidc linkedin.com Functionality/Preferences 1 day
UID scorecardresearch.com Marketing/Analytics 14 months
Ct0 twitter.com Performance 6 hours
guest_id twitter.com Targeting/Advertising 14 months
guest_id_ads twitter.com Targeting/Advertising 14 months
guest_id_marketing twitter.com Targeting/Advertising 14 months
personalization_id twitter.com Targeting/Advertising 14 months

c. How to Manage Cookies
Your web browser may allow You to change your cookie preferences, including to delete and disable cookies. Please consult the help section of your web browser to understand your options, but please note that if You choose to disable the cookies, some features of our Website or Services may not operate as intended.

12. INTERNATIONAL DATA TRANSFERS

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about You to recipients in countries other than the country in which the Personal Data was originally collected, including to the United Kingdom. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.
 

13. USE BY MINORS

The Services are not directed to individuals under the age of eighteen (18) for California residents and sixteen (16) for United Kingdom citizens and they shall not provide Personal Data through the Services. If you have reason to believe that anyone minor has provided us with any personal information, please contact us. 
 

14. UPDATES TO THIS POLICY AND NOTIFICATIONS

We may change this Policy from time to time to reflect new services, changes in our Personal Data practices, or relevant laws. The “Last Updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Website. We may provide You with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our Website and, if You are a User, by contacting You through Simpliciter, e-mail address.
 

15. LINKS TO OTHER WEBSITES

The Services may provide the ability to connect to other sites. These sites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest You review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website, or the privacy practices of the operator of the website.
 

16. JURISDICTION

Simpliciter focuses on multinational compliance regulations including but not limited to United Kingdom General Data Protection Regulation (“UK GDPR”), General Data Protection Regulation brought by the European Union (“GDPR”), and United States Privacy Laws to make sure privacy is a “go-to” rather than a thing to be worried. You have the right to request further information on our personal data processing activities based on your country’s laws. 
 

17. CONTACT US

If You have any questions or complaints about this Policy, please contact us at ###.

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