Privacy Policy
Privacy Policy
The Simplyg.com, Privacy Policy was updated: June 17, 2019
Simplyg.com (the “Company”) respects the privacy concerns of the users of its website, https://www.simplyg.com and the services provided therein (the “Site”). The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information may be used.
Please also review the Terms of Use which also govern use of this Site and Platform.
International Users: All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Personal information, relating to Simplyg.com services, regarding individuals who reside in a member state of the European Economic Area and Switzerland. Simplyg.com uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland. Simplyg.com, Inc., as a global company, has different jurisdictions which are responsible for the personal information which they collect and which is processed on their behalf by Simplyg.com. For example, point of sale information in our Retail entities outside the U.S. is controlled by our individual respective Retail entities in each country. Simplyg.com Online Store related personal information may also be controlled by legal entities outside the U.S. as reflected in the terms of each service.
Simplyg.com abides by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. To learn more about the APEC Certification and Dispute Resolution, please click on the TRUSTe seal.
EU-U.S. Privacy Shield Participation: The Company abides by the EU-U.S Privacy Shield Framework (“Privacy Shield”), and with the U.S. Department of Commerce that we adhere to the Privacy Shield Principles. The Company is committed to applying the Privacy Shield Principles to all personal information received from countries in the European Economic Area (EEA) in reliance on the Privacy Shield. To learn more about the Privacy Shield, visit the U.S. Department of Commerce’s Privacy Shield website.
Under the Privacy Shield, the Company is responsible for the processing of personal information it receives and subsequently transfers to a third party acting for or on its behalf. The Company is liable for ensuring that the third parties we engage support our Privacy Shield commitments.
The U.S. Federal Trade Commission has regulatory enforcement authority over the Company’s processing of personal information received or transferred pursuant to the Privacy Shield Framework.
To learn more about the Privacy Shield, visit the U.S. Department of Commerce’s Privacy Shield website.
General Data Protection Regulation (GDPR) - European Representative: Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Simplyg.com, Inc., has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:
- Sending an email to [email protected]
- Using EDPO’s online request form at https://www.edpo.brussels/contact
- Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
What personal information we collect: When you create an Simplyg.com, ID, apply for or purchase a product, download a software update, register for a class at a Simplyg.com Store, connect to our services, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information and credit card information.
When you share your content with family and friends using Simplyg.com products, send gift certificates and products, or invite others to participate in Simplyg.com services or forums, Simplyg.com may collect the information you provide about those people such as name, mailing address, email address, and phone number. Simplyg.com will use such information to fulfill your requests, provide the relevant product or service, or for anti-fraud purposes.
In certain jurisdictions, we may ask for a government issued ID in limited circumstances including when setting up a wireless account and activating your device, for the purpose of extending commercial credit, managing reservations, or as required by law.
Use of Information: We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which Simplyg.com is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Simplyg.com or a third party to whom it may be necessary to disclose information.
The personal information we collect allows us to keep you posted on Simplyg.com latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences.
We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.
We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Simplyg.com ID account holders.
From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Simplyg.com you may not opt out of receiving these communications.
We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Simplyg.com, Inc.’s products, services, and customer communications.
If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs.
As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of the Company’s internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.
The Site’s various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give us contact information such as your name, mailing and/or e-mail address, demographic information such as your age and gender, and personal preference information such as your preferred software and interests. Information submitted at the time of submission will be used by the Company only as necessary for our legitimate business interests, including without limitation the improvement of our products, services and the contents of the Site. The Company may also share such information with our associated business and promotional partners to further those interests. Personally identifiable information is never sold or leased to any third parties. With your permission, we may use your contact information to send you information about our company and products. You may always opt-out of receiving future mailings as provided below. The Company does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.
The Company may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Site, or anyone else that could be harmed by such activities.
The Company may also be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Please also note that third-parties who provide and/or publish content via the Company’s Simplyg.com Service shall be deemed the data controllers for any personal data contained in the content uploaded by any such party to the Company’s Simplyg.com Service (“Third-Party Content”) and any other personal data processed in relation to such Third-Party Content. This privacy policy only concerns the processing for which the Company is data controller. If you have any questions regarding personal data contained in the Third-Party Content, please contact the third-party provider responsible for such Third Party Content.
Source of your personal information where they are not collected from you: We may have received your personal information from other persons if that person has shared their content with you using Simplyg.com products services, sent gift certificates and products, or invited you to participate in Simplyg.com services or forums. We may also validate the information provided by you when creating a Simplyg.com ID with a third party for security and fraud prevention purposes.
For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.
Collection and Use of Non-Personal Information: We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
- We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an Simplyg.com, Inc. product is used so that we can better understand customer behavior and improve our products, services, and advertising.
- We may collect information regarding customer activities on our website, for Simplyg.com, Stores and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.
- We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.
- With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.
If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
Use of Cookies and other technologies: Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using our Site easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.
Simplyg.com websites, online platform and services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.
Disclosure to Third Parties: At times Simplyg.com may make certain personal information available to strategic partners that work with Simplyg.com, to provide products and services, or that help Simplyg.com market to customers. For example, when you purchase and activate your iPhone, you authorize Simplyg.com and your carrier to exchange the information you provide during the activation process to carry out service. If you are approved for service, your account will be governed by Simplyg.com and your carrier’s respective privacy policies. Personal information will only be shared by Simplyg.com to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.
Simplyg.com and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Simplyg.com more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the Simplyg.com Online Store. Knowing your country and language − and if you are an educator, your school − helps us provide a customized and more useful shopping experience. Knowing someone using your computer or device has shopped for a certain product or used a particular service helps us make our advertising and email communications more relevant to your interests. And knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your operating system, set up your service, and provide you with better customer service.
If you want to disable cookies and you’re using the web browser, go to preferences and then to the privacy pane to manage your preferences. On your mobile device, go to Settings, then, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of the Simplyg.com website will not be available once cookies are disabled.
Service Providers: Simplyg.com shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Simplyg.com operates.
As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Simplyg.com, Inc. may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on the Simplyg.com website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format, customers can read and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
Third‑Party Sites and Services: Simplyg.com websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties − for example, a third‑party phone app.
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
If you purchase a subscription in a third party website or app, we may create a Subscriber ID that is unique to you and the developer or publisher which we use to provide reports to the developer or publisher that include information about the subscription you purchased, and your country of residence. If you cancel all of your subscriptions with a particular developer or publisher, the Subscriber ID will reset after 180 days if you do not re-subscribe. This information is provided to developers so that they can understand the performance of their subscriptions.
Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.
Links to External Sites: The Company is not responsible for the content or practices of third party websites that may be linked to the Site. The Company is also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective privacy policy and practices prior to disclosing any information.
Bulletin Boards and Chat Areas: Guests of the Site are solely responsible for the content of messages they post on the Company’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. When you use some Simplyg.com products, services, or applications or post on a Simplyg.com forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.
If you or anyone else using Family Sharing logs on to a device that is owned by a third party, any information shared within your Family—including calendar, location, photos, and purchases—may be downloaded on to that third-party device thereby disclosing any such shared information. Please take care when using these features.
The existence of Automated Decision-Making, Including Profiling: Simplyg.com does not take any decisions involving the use of algorithms or profiling that significantly affects you.
Integrity and Retention of Personal Information: Simplyg.com provides the ability for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.
Access to Personal Information: You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your account. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if Simplyg.com is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Online tools for the exercise of access, correction, or deletion requests are available on a regional basis by signing into your Simplyg.com account. Where the online tool is not currently available for access requests in your region, a request may be made directly to the Contact Us form.
Protection of Personal Information: Simplyg.com takes the security of your personal information very seriously. Simplyg.com online services such as the Simplyg.com Online Store and Platform protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by Simplyg.com, we use computer systems with limited access housed in facilities using physical security measures.
Choice/Opt-Out: The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please complete the Contact Us form including a copy of the undesired email to the request, and “state you wish to be removed from the mailing list.”
Transfer of Information Across National Borders: Our site and various information we collect are operated on servers located in various jurisdictions, including the United States. When you access or use the Site and/or our services, personal information about you may be transferred outside the country in which you are situated to these other locations. The Company’s policies ensure that such personal information is protected to the same standard when processed by any Company entity or office around the world. We also ensure that appropriate contracts containing standard data protection clauses approved by the European Commission to protect that information and the rights of individuals are in place with any and all third-party service providers we may use.
Others: It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Simplyg.com to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Children Age 16 and Under: The Company recognizes the special obligation to protect personally identifiable information obtained from children age 16 and under. AS SUCH, IF YOU ARE 16 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 16 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.
Simplyg.com nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:
- Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
- Know the sites your kids are visiting and which sites are appropriate.
- Look for Website privacy policies. Know how your child’s information is treated.
- Check out the FTC’s site for more tips on protecting children's privacy online
Location-Based Services: To provide location-based services on Simplyg.com products, Simplyg.com and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your Simplyg.com computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Simplyg.com and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.
Some location-based services offered by Simplyg.com, such as the “Find My iPhone” feature, require your personal information for the feature to work.
Your Access to and Control Over Your Personally Identifiable Information: At any time, and only once per calendar year, or as otherwise required under applicable law, users may contact Company to review the personally identifiable information that Company has collected about you. If you discover any errors, please notify Company and the information will be corrected. To review the personally identifiable information that company has collected about you, please complete the Contact Us form, with the subject line: “Personal Information Review Request.” Users may also request that Company delete a user account(s) or, if you have not established a user account, your email address, and any related data at any time. If you wish to delete your user account(s), please complete the Contact Us form with the words “Delete Account” in the subject line. If you do not have a user account and wish to delete your email address or other personally identifiable information that you might have provided through your use of the Site, any Games, and/or any Services, please complete the Contact Us form with the words “Delete My Information” in the subject line.
You may also choose to confirm that the Company does not use your personal information in certain ways and/or to otherwise “opt out” of certain uses of that personal information, including without limitation (i) when your personal may to be disclosed to a third party unrelated to the Company and/or parties directly related to providing your Services and/or (ii) when your personal information may be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. If you wish to limit your personal data in either such way or have other questions about how the Company may use your personal data, please contact us at: complete the Contact Us form the words “Privacy Shield Request” in the subject line.
Your California Privacy Rights: California Civil Code Section 1798.83 permits California residents to request from companies conducting business in California a list of third parties to which the company has disclosed personally identifiable information during the preceding year for direct marketing purposes. Company has not and will not share your personally identifiable information with third parties for their direct marketing purposes; accordingly, it will not maintain such a list of third parties. If you are a resident of California and want additional information confirming how Company does not share your personally identifiable information with third parties for their direct marketing purposes, you may contact us at: complete the Contact Us form with the words “California Privacy” in the subject line of your email.
Contact Information for Complaints or Concerns: If you have any complaints or concerns about the Company or about this privacy statement, please contact:
Via site form: complete the Contact Us form
Information provided by you via general e-mail inquiries to the Company such as your e-mail address is used only to respond to your inquiries in the ordinary course of business and is never shared with third parties.
If you are a resident of the EU and have an unresolved data privacy concern or personal information collection, use, or disclosure concern, you may file a complaint/inquiry with us as provided above. If we have not addressed your Privacy Shield inquiry to your satisfaction, please contact our third-party dispute resolution provider – DMA Privacy Shield Program at: https://thedma.org/resources/consumer-resources/privacyshield-consumers/. Simplyg.com commits to cooperate with DMA for any unresolved data privacy shield inquiries. This is provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Our Companywide Commitment to Your Privacy. To make sure your personal information is secure, we communicate our privacy and security guidelines to Simplyg.com employees and strictly enforce privacy safeguards within the company.
Security/How Your Personally Identifiable Information Is Protected: Security for all personally identifiable information is extremely important to us. We have implemented technical, administrative and physical security measures to attempt to protect your personally identifiable information from unauthorized access and improper use. We also protect your personally identifiable information offline. Only employees who need the information to perform a specific job (for example, customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment. We continually review all such measures and update them when appropriate. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to Company, you accept that you do so at your own risk.
Your Acceptance of These Terms: By using the Site, you accept the policies and restrictions set forth in this Online Privacy Policy. If you do not agree to this policy, please do not use the Site. This Online Privacy Policy may be revised from time to time by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Online Privacy Policy to which you are bound.
Simplyg.com Last Updated: June 17, 2019
