Update: December 23, 2019 – California Consumer Privacy Act Update
How We Collect and Use Information
We collect personal information from our website visitors in order to provide you with a personalized, useful, and efficient experience and to respond to your requests. The categories of information we collect can include information that you provide to us. We collect information that you provide to us when you set up an account with us, use our Services, or communicate with us. For example, we may request your personal information (e.g., name, email address, telephone number, message content, and payment information) and your applicable business information when you register for an account or purchase our Service. We may also collect any communications that you exchange with us, as well as any information you provide if you take part in any interactive features of the Service (e.g., promotions, surveys, etc.). We collect information you may provide when providing content or commentary to our service in the form of blog posts, comments, and the like (“User Content”). Please note that User Content is published on our site and will be viewable by the public.
We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also send you Service-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Service, technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you. For more information about your communication preferences, see “Your Choices Regarding Your Information” below.
Information collected through technology
We automatically collect certain types of usage information when you visit our website or use our Service. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information from your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns. In addition, we may also use clear gifs in HTML-based emails to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our visitors. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analyzing and improving the Service. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.
When you access our Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device.
How We Share Personal Information
We may share your personal information in the instances described below. For further information on your choices regarding your information, see “Your Choices Regarding Your Information.”
We may share your personal information with third-party service providers or business partners who help us deliver or improve our service, for example, payment processors, back-office service providers, or other vendors who help us host or store data or measure site traffic. These providers will be given access to your personal information as is reasonably necessary to perform their function under reasonable confidentiality terms.
We may aggregate, or strip information of personally identifying characteristics, and then share that aggregated or anonymized information with third parties.
The Federal Trade Commission has jurisdiction over Simility’s compliance with the Privacy Shield.
In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield organization shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
A core component of using the Simility Service is your provision to us of data related to your company’s customer and transactions (“Customer Data”). Customer Data is owned and controlled by our Customers, and any Customer Data that we maintain or process we consider to be strictly confidential. We collect and process Customer Data solely on behalf of our Customers, and in accordance with our agreements with the Customers. We do not use or disclose Customer Data except as authorized and required by our Customers and provided for in our agreements with our Customers.
Your Choices Regarding Your Information
Email Communications. From time to time, we may send you emails regarding updates to our website, products or services, notices about our organization, or information about products/services we offer that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, or technical or legal notices).
Modifying Account Information. If you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) by contacting us at the email or postal address provided below. Please note that Simility does not own or control the Customer Data uploaded to our Service by our Customers, and cannot modify or delete Customer Data except at the request of our Customer, or as permitted by our Terms of Service.
Online Advertising and Controlling Cookies. In the future, we may permit third-party online advertising networks to collect information about your use of our website over time so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites or apps. Typically, the information we share is provided through cookies or similar tracking technologies. The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org.) If you access our service on your mobile device, you may not be able to control tracking technologies through settings.
Data Protection and Security
Keeping information safe: Simility cares about the security of your information and uses commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
We generally don’t place limits on the types of information that our Clients may provide to us, but do ask our Clients to refrain from providing us with sensitive information such as information they knowingly collect from persons under 13, complete credit and debit card numbers, social security numbers and other government identifiers.
Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Simility, Inc.’s internal processes, Simility, Inc. has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/disputeresolution/submit-dispute/.
An individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Details are at the following link: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Links to Third-Party Websites and Services
Simility’s website and services are intended for use strictly by adults. We do not knowingly solicit or collect personal information from children under the age of 13. If we learn that any personal information has been collected from a child under 13, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 13, please contact us at email@example.com.