Simple takes the privacy of its customers and visitors to its Website very seriously. We understand that you may have questions about how we collect, use, and share your information. This Policy describes the type of information we collect, how we use and share that information, how we protect that information, your choices regarding that information, how you can “Opt-Out” of our policy on sharing customer information, and how you can contact us with any questions.
What Information Do We Collect?
We collect two main categories of information from or about you: Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (collectively, your “Information”).
PII, specifically Nonpublic Personally Identifiable Financial Information, is information that directly identifies an individual, such as name, residential street address or postal address, email address, social security number, date of birth, driver's license number, government issued identification number, phone number, credit card number, bank account or other financial institution account number, and user name and password when you use our website portal to make payments. PII may be public or private information.
Public or Non-Personally Identifiable Information is information about an individual or about categories or groups of individuals that does not identify you individually, such as your IP address, randomly assigned values in "cookies," mobile device identifiers, geo-location, and other technical information. We also collect other information that may not identify you individually, such as your gender, vehicle information, occupation and other employment information, source of income, personal references, and residence-related information such as lease and ownership information, and other information.
For purposes of this Policy statement, Simple treats both PII and Non-Personally Identifiable Information, public or nonpublic, as “your Information.”
We collect Information about you (or generally from our consumers and customers) in primarily these ways: i) directly from you, as submitted on your application through this Website or otherwise; ii) directly from our merchant store where we do business; iii) from our Website and application logs, cookies, web beacons, and similar technologies; and iv) from third-parties, such as your bank, but only with your consent.
We use your Information primarily to underwrite (or verify) the accuracy of your lease application, in order to offer you our RTO products and services. We also use your Information to monitor, improve and ensure quality of service, to contact you, to provide you with offers or information about products and services or the products and services of our affiliates or other third-parties, and to provide you with a personalized website experience.
As part of our information collection process, we may detect additional bank accounts under your ownership. We will consider these additional accounts to be part of the application process. By applying, you authorize us to search for and evaluate bank accounts under your ownership for this purpose.
We do not share with others any of your Information, unless we say so in this Policy, or when we believe in good faith that the law requires it.
How Do We Collect Your Information?
We may collect your Information from you in a variety of ways. For example, we collect information you provide when you seek to lease or buy products from a store where we do business or those companies that have offered a product to you in return for payment from Simple ("Merchant"), or otherwise enter into a contractual arrangement with Simple. We may also collect Personal Information from or about you when you visit a Website or other application owned or operated by Simple or when you otherwise contact us. Also, if you are at a Merchant when you apply for a lease from Simple, a representative of the Merchant may allow you to submit the lease application to us through a kiosk, or portal, on the Merchant's premises.
When you submit a lease application with Simple, we use third-parties to provide us with additional Personal Information about you. For example, if we know your name and postal address, we may use a third-party to provide us with your email address. In addition to what is described below, we use this information for market analysis, marketing and other business purposes, including enforcement of contractual obligations. We may also collect your Information about you from consumer and/or credit reporting agencies, other companies used for identity verification and fraud detection, your personal references, and from our affiliates, subsidiaries, divisions, among others.
In addition to what is described below, we collect your Information through many sources, including from information that you directly have provided to us, as well as from third-parties.
When you visit our websites, we may collect information about your visit and store that information, which are records of the activities on our website. Our servers automatically capture and save the information electronically. Examples of the information that we may collect or that third-parties (including third-parties involved in advertising or anti-fraud operations) may collect while you navigate our website include, but are not limited to:
Cookies also enable advertising. Navigating our website will result in the placement of various advertising-related cookies by third-parties on your computer or device. These cookies allow web servers involved in advertising operations to recognize your browser as you navigate to other websites, and are necessary for the online delivery or placement of certain ads. Some third-parties involved in ad operations may maintain their own proprietary consumer databases that allow them to personally identify or track website visitors.
Cookies generally hold various types of information, including randomly assigned unique identifiers, which allow websites, including websites covered by this Policy, to customize your experiences on the websites and gather information about your navigation of the websites. We may use different kinds of cookies, including HTTP cookies (also known as browser cookies) and Local Shared Objects such as Flash cookies that are built for use with the Adobe® Flash®Player. We may also use similar technologies, such as HTML5 local storage.
You should understand that some features of many websites may not function properly if you block or don't accept cookies.
Other Data Collection Technologies
We may use web beacons, pixel tags, .gif files, and the like, that allow for the collection of information about your interactions on our websites. These technologies may be used, for example, to place advertisements, to understand website traffic patterns and the number of visitors to our website, and to measure the effectiveness of advertisements or our website. Web beacons, and the like, also enable third-parties involved in advertising operations to recognize your browser as you navigate to other websites, and are necessary for the online delivery or placement of certain types of ads.
Social Networks and Widgets
Our website also includes social network or other third-party plug-ins and widgets that may provide information to their associated social networks or third-parties about Simple websites you visit, even if you do not click on or otherwise interact with the plug-in or widget and regardless of whether you have an account or other relationship with these social networks and third-parties. Information is transmitted from your browser and may include an identifier assigned by the social network or third-party, information about your browser type, operating system, device type, IP address and the URL of the web page where the plug-in or widget appears. If you use social network tools or visit social networking websites, you should read their privacy policies to learn what information they collect, use, and share.
Links to Other Websites
Simple websites may contain content, services, advertising and other materials that link to websites operated by third-parties. We have no control over those other websites, and this Policy does not apply to them. We encourage you to refer to the privacy policies of those websites.
How Do We Use and Share Your Information?
We may share your Information with our affiliates, subsidiaries and internally throughout various employees, departments and divisions within Simple.
We may also share your Information with our service providers and other third-parties as described below.
We may also share your Information to meet our obligations to technology and content providers, or as required by law.
We use your Information that we collect from you for many purposes. For example, we use your Information to:
We may also de-identify Information (by removing certain data elements such as name, phone number, date of birth) that we receive from you or from third-parties so that it cannot be used to identify a specific individual.
We may transfer Information covered by this Policy, including PII, in connection with a merger or sale or acquisition (including transfers made as part of insolvency or bankruptcy proceedings) of all or part of Simple’s business or as part of a corporate reorganization, stock sale or other change in control.
Sharing with Corporate Entities, Affiliates and Third-Parties
We also may share your Information with affiliates, subsidiaries, divisions, Merchants, and service providers who provide services to us or on our behalf and agree to only use such information for the purpose for which it was provided and in accordance with this Policy. We may also provide your Information to consumer and/or credit reporting agencies, companies used for identity verification and fraud detection and to third-parties collecting amounts owed to us, including third-parties to whom we assign your account for collection purposes.
If you submit an application through our Website, your Information may be shared with third parties. These third parties may be unaffiliated with Simple so you should be sure to review any third-party privacy policies.
We may also share your Information with select third-party vendors, business partners and other companies so that they can send you promotional materials about goods and services (including special offers and promotions) offered by them. After the information is provided to such third-parties, the subsequent use or disclosure of such information is subject to those third-parties' privacy policies and practices.
We may also use services hosted by third-parties to assist in providing our services and to help us understand our customers' use of our products. A third-party service may collect information sent by your browser as part of a web page request, including, for example, your IP address, the third-party's cookies, or any of the other categories of information itemized under Online Activities, above.
Simple may use "interest-based" ads also known as "online behavioral advertising" or "OBA." Online behavioral advertising is advertising that is directed to you based, at least in part, on your Internet browsing behavior across the web. Although we do not share your Information with the third-parties that conduct advertising operations on our behalf, these third-parties and their affiliates do collect certain information as a result of their "tags" being on our website. The information they collect includes the name (URL) of the web pages you view while on our site, your IP address, time of visit, information about your browser software, information about your device, and randomly-assigned identifiers stored in cookies, which they use to target and serve advertising. Simple uses third-parties that participate in the Digital Advertising Alliance (DAA), which prescribes certain norms of conduct and provides an opt-out for behaviorally targeted ads, as discussed in "Your Options Regarding Personal Information," below.
How Do We Protect Your Information?
We maintain administrative, technical and physical safeguards intended to protect against the loss, misuse, unauthorized access, or disclosure of your Information, in particular your PII. Although we take such precautions seriously, it is impossible for us or others to guarantee the safety and security of your Information.
Will this Policy Change?
Your Options Regarding Personal Information
You may request that we correct, update or amend your Information we hold about you. To update us regarding changes in your Information, please contact us as described below.
You may elect to opt-out of receipt of email and text communications from us by following the instructions provided in such communications or by contacting us as provided below. Even after opting out, you may still receive service-oriented or non-promotional communications from us and promotional communications from other third-parties as a result of their own interactions or transactions with you. Please allow time for us to process your request or contact us should you have any concerns about your opt-out request.
As an alternative to the DAA opt-out, you can also elect to block advertising cookies from first-parties (such as Simple) and from third-parties involved in advertising by using the cookie blocking options built into your browser software. For example, in Internet Explorer 9, you can block both first and third-party advertising cookies by changing the settings in Tools/Internet Options/Privacy/Settings-Advanced/Override Automatic Cookie Handling. As another example, if you are using Firefox 25, you can "uncheck" Accept All Cookies under Firefox Preferences/Privacy-Use Custom Settings For History/Accept Cookies from Sites.
Please note, however, that if you do decide to block certain cookies, some parts of our website may not function correctly.
How Can You Opt-Out or Contact Us?
Your California Privacy Rights
If you are a California resident, you may ask us to refrain from sharing your Information with third parties for their own direct marketing purposes. Please indicate your preference by contacting us as described above. Please also note it may take us thirty (30) days to fully process your request.