Policy Effective Date: May 1, 2020

SimplePin values the privacy of the users, and others who visit and use the Service (collectively or individually, “You” or “Users”).

By registering for, accessing, browsing, or using the service, you acknowledge that you have read, understood, and agree, effective as of the date of such action, to the information handling practices described in this Privacy Policy.

This Privacy Policy is incorporated into and is subject to the SimplePin Terms of Service [US - CA]. Your use of the Service and any personal information you provide through the Service are subject at all times to this Privacy Policy and the Terms of Service.

We made sure that finding our privacy policy had to be as simple as the platform itself. That is why you can always find it on our website at Simplepin.com. Need something more one to one? Then do not hesitate to send us an email to Privacy@simplepin.com.

TABLE OF CONTENTS

1. THE INFORMATION WE COLLECT

2. THE WAY WE USE INFORMATION

3. WHEN WE DISCLOSE INFORMATION

4. YOUR CHOICES, RIGHTS AND RESPONSIBILITIES

5. OUR COMMITMENT TO DATA SECURITY

6. OUR COMMITMENT TO CHILDREN'S PRIVACY

7. INTERNATIONAL VISITORS

8. IN THE EVENT OF MERGER OR SALE

9. CHANGES AND UPDATES TO THIS PRIVACY POLICY

10. YOUR RIGHTS TO ACCESS DATA

11. HOW TO COMPLAIN

12. CLASS ACTION WAIVER

13. CONTACT INFORMATION

1. The Information We Collect;

Personal DataUser-Provided Information, including Personally Identifiable Information (PII): Due to the nature and scope of our product, you may provide to SimplePin what is generally called “personally identifiable” information (such as your name, email address, postal mailing address, home/mobile telephone number, etc.) when using the Service, such as when you register an Account on the Service, log in to the Service, or use the Service and functionality of the Service. As permitted by applicable law in the country from which you access our Website and use our services, we may collect, use, store and transfer different kinds of Personal Data about you. We have grouped these into the following categories of “Personal Data”:

Contact Data: such as email addresses, home address, apartment number, city, state, zip code, email address, and telephone numbers.

Financial Data: such as: card numbers, security codes, expiration dates, and billing address, bank account information, routing numbers, credit cards, your financial institution login information. However, please note that payment methods (e.g., credit card number and/or PayPal and/or bank account details) are not collected by us directly, but by third party secure payment service providers as outlined in our Terms of Service.

Identity Data: such as first name, maiden name, last name, other names used, date of birth, driver’s license number, social security number (or other government issued ID numbers), username or similar identifier.

Marketing and Communications Data: such as your preferences in receiving marketing from us and our third-parties and your communication preferences.

Technical Data: such as Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.

Transaction Data: such as details about payments to and from you, and details regarding the services that you have subscribed to in relation to our Services, third party information related to transaction processing, identity check, fraud prevention and detection, and the like.

Usage Data: such as information about how you use our Website, products and services.

Use of Information Across Parties for the Service: In using the Service, the information we collect can be considered PII, and may be shared between SimplePin and a third party for the Service we are providing.

We may obtain information, including personally identifiable information from third parties and sources other than the Service, such as advertisers or social media networks for which you have approved our access to information. If we combine or associate information from such other sources with personally identifiable information that we collect through the Service, we will treat the combined information as personally identifiable information in accordance with this Privacy Policy.

When we share information with (to) a 3rd party, we do so because it is necessary to perform our contractual obligations or ensure the Service works for you.  Such Personal Information is then subject to that third party’s own data collection, use, and disclosure policies. We do ensure that we work with known, quality partners, but should you wish to know more about the specific privacy policies of these providers, including whether these providers may collect or share Personally Identifiable Information between providers, you may enquire with us using the procedures described below.

In this context, third parties may collect personally identifiable information about a user’s online activities, over time and across different sites, services, and applications, when that user uses our site, service, or application.

Cookies Information: When you access the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. SimplePin may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. SimplePin site uses cookies to maintain active user sessions, However, persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings.

Response to Do Not Track Signals: Certain web browsers may provide an option by which you may have the browser inform websites or internet services you visit that you do not wish to have information (which may or may not contain PII) about your activities tracked by cookies or other persistent identifiers across time and across third-party Internet websites, online or cloud computing services, online applications, or mobile applications. These are commonly called “do not track” signals. SimplePin site requires cookies to maintain active user sessions, and therefore SimplePin does not act on Do Not Track requests.

Third Party Web Beacons: To bring you the best experience and product set possible, we may also implement and integrate third party content, such as advertising, on the Service that uses “clear gifs,” “web beacons,” or other similar techniques, and which may allow the third party content provider to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third party content displayed on or through the Service.

Other System Information Automatically Collected: When you access the Service or open one of our HTML emails, we may automatically record certain information from your system by using different types of tracking technology. This “automatically collected” information may include your Internet Protocol address, a unique device or user ID, the version of software installed, system type, the content and pages that you access on the Service, and the dates and times that you visit the Service.

2. The Way We Use Information

The main reason we gather this information is to provide you with the best user experience possible. We want to create a customizable, smooth, safe, efficient and fun experience. Therefore, we need to allow ourselves to use your personal information to:

• Provide all the services and support you need.
• Notify you about your network activity and transactions.
• Solve disputes, troubleshoot problems and collect any fees.
• Prevent fraud, stop beforehand any illegal activities, and enforce our User Agreement.
• Create account connections between third-party platforms/accounts and your SimplePin one.
• Improve our content by customizing and personalizing our approach, as well as measuring and refining our services and website layout.
• Update you about our new products, content and services.
• Perform all duties required by law, as well as compare information and verify accuracy with third parties.

SimplePin uses the information that you provide or that we collect to operate, maintain, enhance, and provide all of the features and services found on the Service as well as to track user-generated content and Users to the extent necessary to comply as a service provider with the Digital Millennium Copyright Act.

We will use your email address and other provided contact information, without further consent, for administrative communications such as notifying you of major Service updates, for customer service

purposes, to address copyright infringement or defamation issues, or to contact you regarding any content, resumes, Job Posting and other materials that you have posted to, transmitted through, or downloaded from the Service.

SimplePin uses all of the information that you provide or that we collect to understand the usage trends and preferences of our Users, to improve the way the Service works and looks, and to create new features and functionality.

SimplePin may use “Automatically Collected” information and “Cookies” information, alone or in combination with other information we have collected from you, to: (a) personalize the service, such as remembering your information so that you will not have to re-enter it during your visit or the next time you access the Service; (b) provide customized third party advertisements, content, and information, (c) monitor aggregate site usage metrics such as total number of visitors and pages accessed; (d) provide such metrics to Users as they pertain to such User’s content; and (e) track your entries, submissions, and status in any Job Posting, promotions or other activities.

SimplePin may use your email address or other personally identifiable information to send (a) messages about the Service, such as when you receive communications from another User, (b) promotional messages related to the Service and the activities of third parties we work with, and (c) employment related inquiries through the Service on behalf of other Users from whom you have opted to receive communications. Generally, you have the ability to unsubscribe from further communications from a User of the Service, through links provided in the messages sent on behalf of such User.

SimplePin acknowledges that you have the right to access your personal information. With respect to personally identifiable Information provided by an enterprise client of SimplePin to SimplePin, we collect such information under the direction of that client and have no direct relationship with the individuals whose personal information we process. If you are a customer of such a SimplePin client or channel partner and would no longer like to be contacted by such company, please contact that company directly. If you seek access or want to correct, amend, or delete inaccurate data, you must direct to request to that company (the data controller). If requested to remove data, we will respond within the timeframe required by relevant laws, including any available extensions. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by our service agreements with our enterprise clients.

3. When We Disclose Information

‍How We Share Information Within the SimplePin Network

‍We may need to share some of your personal information with our third-party payment provider including contact information, sign-up date, number of transactions you have done and other similar verification metrics such as your social graph activity could be provided to companies or users when you do a transaction with, on or through SimplePin. Doing this allows a seller to share your information with us, like your cellphone number or SimplePin username when purchasing off that seller.

Nevertheless, SimplePin does not have access and therefore we will never disclose your credit card or bank account number to anyone you pay or pays you through our payment provider Payrix, on the SimplePin platform.

How We Share Personal Information With Other Parties

SimplePin does not share your personally identifiable information with other organizations for their marketing or promotional uses without your prior consent.

We could share your personal information with:

In the case of bankruptcy, companies that would plan to merge or acquire SimplePin Inc. would be allowed to access your personal information. Clarifying that we would require that this Privacy Policy be respected in its entirety concerning your data.

In the case that your personal information is planned to be used in contrast to this policy, we will send you a prior notice and the chance to let us know your preferences, If applicable.

If SimplePin is compelled to share your information by a subpoena, court order or related legal procedures to the government, law enforcement or other third parties. Only when it is necessary to comply with the law. Suspect of illegal activity or the investigation of any violation of the SimplePin User Agreement will also be motives for sharing.

Third party service providers that give a service to you or who supply fraud detection services or equivalent on behalf of the seller.

Other SimplePin users that are involved in the transaction may have access to certain information, depending on the privacy settings of each SimplePin transaction.

Our Service providers, who are under contract to help us with the proper functioning of the SimplePin platform, this includes as an example, preventing fraud and processing payments, as we are a service provider and do not process any payments. We have all our relevant service providers agree to contracts that dictate seriousness and the exclusive use of your personal information for services related to us and never their own benefit.

With your consent or under your direct request to do so, we may share your information with third parties of your choice, them being account connections with other third-party platforms or accounts.

In relation to this Privacy Policy, the term “account connection” is understood as a connection that you have authorized or enabled between a SimplePin and non-SimplePin account, payment instrument or platform that you legally control or own. When this kind of connection is authorized, SimplePin will exchange your personal and similar information directly. Some examples of account connections are linking your SimplePin account to a social media platform, messaging or financial services, if you were to provide a company with your SimplePin log-in, make a payment or have a merchant charge your SimplePin account.

Let’s say you want to connect your SimplePin account to another financial account, through a third-party or directly, we may access your account information and/or transactions. If you decide to create an account connection, we may be able to use your information obtained from third-party services. A clear example of this would be that you decide to connect your SimplePin account with a social media platform, when this happens, we will receive your personal information from the other company and use it only in a way consistent with this privacy policy.

Any information that we ever share with a third-party company will be paired with an account connection and the information may be disclosed in accordance with the other party’s privacy practices.  We highly recommend that before authorizing any account connections, review the third party’s privacy notice to know how they will get access to your personal information.

We do not send your personal information to any third-party platforms, unless we have an explicit authorization from your part to do so. When you decide to share your information with these types of platforms, we no longer in SimplePin have any control of your information and it becomes the responsibility of the third party using it.

We may disclose User information to affiliated companies or other businesses or persons who: provide web site hosting, maintenance, and security services; fulfill orders; conduct data analysis and create reports; offer certain functionality; and assist SimplePin in delivering or improving the Service and creating new features. These disclosures are generally made under terms comparable to this Privacy Policy, and the recipients are limited to using the information for the purposes for which the information was provided and only to the extent necessary to complete the intended work.

SimplePin may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena, or warrant in the manner required by the requesting entity.

SimplePin also reserves the right to disclose User information that we believe, in good faith, is appropriate or necessary: to take precautions against liability; to protect SimplePin from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Service; or to protect the rights, property, or personal safety of SimplePin, our users, or others.

4. Your Choices, Rights and Responsibilities

Right Not To Share Information:  You may, of course, decline to share your personally identifiable information with SimplePin, in which case SimplePin will not be able to provide to you some of the features and functionality found on the Service. You may update or correct your user information and preferences at any time by accessing your account preferences page through the Service. Please note that while changes to your Account are reflected promptly in active user databases, we may retain all information that we collect or that you provide for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics. Please note also that once you have publicly shared information, it may be re-shared by other users, and your subsequent modification or removal of that information will not necessarily affect copies previously propagated by others.

To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information.

Right to Correct, Update, Delete Personal Information:  You have the right to ask us to change, correct, or delete Personal Data.  You may also ask us to delete and remove Personal Data where there is no good reason for us to continue to process it. If you choose to ask us to delete and remove your Personal Data SimplePin may not be able to provide to you some or all of the features and functionality found on the Service.  Please note, we may not always be able to comply with your request for erasure and in such circumstances, will notify our reasons to you.  If you choose to ask us to alter, remove or delete your Personal Information you may contact us in one of the following ways: a) using the messaging functionality in your user account to contact us directly, if available, b) emailing us at: Support@SimplePin.com. We will respond to you in writing within the time frame required by the relevant law.

Your Responsibilities:  You are responsible for maintaining the secrecy of your unique password and account information at all times.

5. Our Commitment To Data Security

‍SimplePin uses certain physical, managerial, and technical safeguards designed to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to SimplePin, and you do so at your own risk. SimplePin cannot guarantee that information you provide or that we collect may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If SimplePin learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. SimplePin may post a notice on the Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at Support@SimplePin.com.

6. Commitment To Children's Privacy

‍If you are under 13 years of age, then you may not use or access the Service at any time or in any manner.

Protecting the privacy of young children is especially important. For that reason, SimplePin does not knowingly collect or maintain personally identifiable information from persons under 13 years-of-age. If SimplePin learns that personally-identifiable information of persons less than 13-years-of-age has been collected on or through the service, then SimplePin will take the appropriate steps to delete this information.

If you are the parent or legal guardian of a child under 13 who you believe has registered an Account on the Service, then please contact SimplePin at dpo@SimplePin.com to have that child’s Account terminated and information deleted.

7. International Visitors

‍For users visiting the service from the European Economic Area (EEA) or any other non-U.S. territories, please note that any data you enter into the Service will be transferred outside the European Economic Area or such other non-U.S. territory for use by SimplePin and its affiliates for any of the purposes described herein. In addition, because SimplePin operates globally, we may make information we gather available to worldwide business units and affiliates. By providing any data on the Service, you hereby expressly consent to such transfers of your data to the United States or other countries.

8. In The Event Of Merger Or Sale

‍In the event that SimplePin is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from Users as part of that merger, acquisition, sale, or other change of control.

9. Changes And Updates To This Privacy Policy

‍This Privacy Policy may be revised periodically and this will be reflected by an updated publication date at the top of this Privacy Policy. Please revisit this page to stay aware of any changes. In general, we only use your personal information in the manner described in the privacy policy in effect when we received that personal information. Your continued use of the service constitutes your agreement to this Privacy Policy and any future revisions.

For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information you have provided to us, we will make reasonable efforts to notify you and obtain your consent before implementing revisions with respect to such information.

10. Your Rights To Access Data (For Data Subjects In The EEA).

‍Data subjects in the EEA have the following rights with respect to their Personal Data:

‍Right to Information: The right to know what Personal Data we hold about you and how we use it.

‍Right to Access: The right to be provided with a copy of your Personal Data (subject to certain restrictions).

Right of Rectification: The right to require us to correct any incomplete or inaccurate Personal Data we hold about you, though we may need to verify the accuracy of the new data you provide to us. If you have a user account with us, you also have the option of correcting your information directly in your account.

‍Right to erasure/be forgotten: This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. Note, however, that we may not always be able to comply with your request for erasure and in such circumstances, will notify our reasons to you.

‍Right to restrict processing: The right to require us to restrict processing of your Personal Data, i.e., you can request that we suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to request data portability: In certain circumstances, you have the right to request the transfer of your Personal Data to you or to a third party in a commonly used machine-readable format. Note, however, that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

‍Right to object to processing: You have the right to object to the processing of your Personal Data in the following circumstances: (i) at any time to your Personal Data being processed for direct marketing (including profiling); or (ii) in certain other situations, to our continued processing of your Personal Data, e.g., our processing of your Personal Data when such processing is based on our legitimate interests. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

‍Right to withdraw consent at any time: You have the right to withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right not to be subject to a decision based solely on automated decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. However, your right does not apply if: (i) you gave us your explicit consent to use your personal data to make our decision; (ii) we are allowed by law to make our decision; or (iii) our automated decision was necessary to enable us to enter into a contract with you.

‍Method for Requesting Information Pursuant to Your Rights

‍Upon request, SimplePin will provide you with information about whether we hold any of your personal information. If you would like to exercise any of the data subject access rights in the table above (each, an “Access Request”) please send an email to Support@SimplePin.com, and we will send you a Data Subject Access Request Form. We will respond to your request within a reasonable timeframe.

No Fee Usually Required. You will not usually be required to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

‍What We May Need from You.  Once we receive your Access Request, we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

‍Time Limit to Respond.  We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. How To Complain

All Data Subjects. If you have any complaint about the treatment of your Personal Data, or inquiries regarding our data practices, please contact us as set forth in Section 14 so we may resolve any query or concern you have.

‍Data Subjects Based in the European Economic Area. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) country where you work, normally live or where any alleged infringement of data protection laws occurred.

13. No Class Actions.

YOU AND SIMPLEPIN AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

14.Contact Information

Please contact SimplePin with any questions or comments about this Privacy Policy, your personal information, and our third-party disclosure practices or your consent choices at: SimplePin, Inc., Legal Department 8954 SE Bridge Road Hobe Sound, FL 33455, or by email: Support@SimplePin.com. We will strive to respond to your inquiry within 30 days of its receipt.