Privacy Policy
Effective Date: 04.06.2023
Cimply, LLC (“Company”, “we”, “us”, or “our”) respects the privacy of everyone (“Site Visitors”, “clients”, “partners”, “users”, “you”, “your”) that accesses our services, digital properties, or otherwise engages in any activities with us where your personal information is disclosed. We know that your personal information is valuable to you and are committed to protecting your information, which is any information that makes it possible to identify an individual, as well as your right to privacy.
This Privacy Policy defines how we handle the collection, retention, deletion, and security of personal information in the context of our day to day business activities as you interact with us through digital properties, our website, applications, systems, and any online applications or services related or connected hereto as well as in-person meetings, conferences, client services, or any other business activities where your information is collected and stored in our databases (“The Sites”).
It also is intended to explain the conditions under which Company uses and discloses that personal information, and your rights in relation to that personal information.
Information Collected
Cimply gathers personal information from the Sites only to the extent needed in conducting our regular business activities. When you browse or interact with our Sites, subscribe to our services or contact us through electronic or non-electronic form submissions you are voluntarily sharing personal information with us.
We also gather various types of data that we collect automatically through the use of first and third-party tags on our digital properties. This may include, but is not limited to, the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the Sites the user interacts with before arriving at our Sites, while navigating our Sites, and immediately after leaving our Sites. It may also include various technical aspects of user’s computer or browser and users browsing habits that are collected through cookies, beacons, pixels, and other similar technologies (“Digital Tracking Technologies”).
In collecting data about your interactions with our Sites, we may also include a unique identifier associated with your session on our Sites along with any other information you make public to us. We may also, in the course of doing business, collect information from third-parties to enhance our understanding of you.
Use of Information
Cimply uses personal information collected in the course of doing business to provide services, improve our products, present relevant events, communicate with clients or prospects, personalize content, distribute news, evaluate job applications, assess client opportunities, publish content, enforce terms of use, enforce contractual agreements, audit, manage corporate reporting, comply with applicable laws, and complete work as directed by our clients.
We may analyze this personal information gathered from or about users to help us better understand how the Sites are used and optimize our delivery of relevant content.
We may keep personal information that has been disclosed to us on file for the purposes of contacting you with relevant offers, products, or services.
We also use personal information for diagnostics on our Sites to ensure proper functionality, optimize our publications, improve user experience, benchmarking performance, identify and detect fraud, improve security, and to understand user journeys.
How Your Data is Processed
Cimply manages your data under the premise of Fair Information Privacy Practices and seeks wherever possible to pursue a policy of data minimization. This means that we only collect, store, and process the minimum amount of information we feel is necessary to conduct business. This is to ensure that your data is processed in ways that minimize security and privacy risks while allowing us to provide the highest level of service to you.
If, in the course of doing business, we require a third-party to manage the processing of our data, they are contractually obligated to manage personal information provided by Cimply with at least the same level of care, confidentiality, and protocols as outlined in this agreement.
Disclosure of Personal Data
When necessary to work with third-parties or subcontractors, Cimply prohibits its contractors, affiliates, vendors and suppliers (“Partners”) from disclosing any personal information received from us, other than in accordance with this Privacy Notice. Cimply partners are required to sign confidentiality agreements that specify the contracted purposes for which personal information can be used before accessing personal information. These purposes are always in accordance with this Privacy Policy.
From time to time, we may also release the anonymized and aggregated information gathered from the users, to authorized partners, subsidiaries, or affiliates.
When necessary, we may disclose your information to help investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Cimply LLC, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. We will notify you, if permitted, before undertaking such disclosures.
We reserve the right to transfer all information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of the Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred information will be subject to this Privacy Notice, or to a new privacy notice if you are given notice of that new privacy notice and are given an opportunity to affirmatively opt-out of it.
International Data Transfer
You understand that The Company, as of the date hereof, is based in the United States. If you are located outside the United States, you understand and acknowledge that your country has enacted data privacy laws that are different from the laws of the United States. For example, the European Commission has issued only a limited adequacy finding with respect to the United States that applies solely if and to the extent that companies self-certify and remain self-certified under the EU/U.S. Privacy Shield program.
Otherwise, transfers of personal data from the EU to the United States can be made on the basis of Standard Contractual Clauses approved by the European Commission or other appropriate safeguards permissible under the applicable laws. If you are located in the EU or EEA, the Company may receive, process and transfer your Personal Data onward to third-party service providers solely on the basis of appropriate data transfer agreements or other appropriate safeguards permissible under the applicable laws. If we do so, any contractual agreement we enter into with a third-party will be at least as strict as the terms set forth in our contractual agreement with the originating controller.
If applicable, you can ask for a copy of the appropriate data processing agreements underlying the transfer of your Personal Data by reaching out to the resource center info at the bottom of this agreement.
Public Forums
If you engage in any public forums and disclose personal information, you should be aware that it can be collected by others. We are not responsible for any information disclosed by you in a public forum whether hosted by Cimply or another provider.
Links to Third Party Sites
We neither own nor control third-party technology and applications accessible through the Sites and cannot control how they manage personal information gathered by their technology. However, Cimply makes every effort to ensure that any partner operating in our ecosystem uses a similarly strict policy surrounding it’s handling and use of personal information and is considered trusted and reputable within their area of expertise.
Thus, this Privacy Notice does not apply to personal information gathered by the third parties that operate them. Before visiting a third-party, or using a third-party application, whether by means of a link on the Sites, directly through the Sites or otherwise, and before providing any personal information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for those Sites or applications, and should take those steps necessary to, in those users’ discretion, protect their privacy
Social Networking
Throughout the Sites we may provide links to use your social media logins to access information or interact with Cimply. When you use your social media logins to access resources through Cimply Sites you are giving us permission to access your profile and any relevant personal information exposed in your profile. We act in accordance with the privacy policies and guidelines of these social networks to the best of our ability. However, you should be aware that the privacy settings of your public profiles through these sites is under your control and should be managed from those social networks directly. Disconnecting your social account from our Sites should be done through your social network provider.
Security
In all cases where the storage, transmission, or disclosure of personal data is necessary, warranted, or required, we take all reasonable precautions to ensure it is properly handled, encrypted, and securely transferred. We have implemented safeguards and procedures to protect and secure personal information and have protocols in place in the event of a breach. Even though we make every effort to protect your data, we cannot guarantee that unauthorized people, entities, or organizations will not gain access to it.
Data Retention
Cimply retains user data for as long as necessary to continue serving our business relationship with you. We operate with a data minimization strategy which ensures that we retain as little personal information about you as we can to satisfy the business need for retaining it. In some cases it is important for us to continue to retain information after a business relationship has ended for legal protection, analysis, records, or for other critical business reasons.
If you wish to have your data deleted from our systems, please send a request to the contact information at the bottom of this policy. We will make every effort to remove your personal data from our systems on request or in connection with our contractual obligations to you.
You may also request amendments to our records in the event of an inaccuracy or incomplete profile.
In the event of a successor organization due to a merger, acquisition, bankruptcy or other sale of all or a portion of Company’s assets, Cimply reserves the right to transfer all information in its possession to a successor organization. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred information will be subject to this Privacy Notice, or to a new privacy notice if you are given notice of that new privacy notice and are given an opportunity to affirmatively opt-out of it.
Children
We do not intentionally collect or keep information about users under 18 years of age. If you believe that a person under the age of 18 has personal data in our system, please reach out to our contact information at the bottom of this policy and we will make every effort to remove it from our systems.
Your Rights
You have the right to review, access, correct, amend, or delete personal information we hold about you. You have the right to obtain confirmation of whether we are processing personal data related to you, request review of your data, and verify its accuracy. You do not have to justify the request of your data from us.
Cimply will make good-faith efforts to provide access to your information. In order to do so we may inquire as to the reason for your request in order to better ascertain the issue at hand and to better assist you in the fulfillment of your request. We may also make reasonable attempts to verify your identity in order to protect your data from unauthorized access. If we cannot sufficiently verify your identity, we will not release your information to protect your personal data.
There are extraordinary circumstances where we may restrict access to your data. If the expense or burden of providing your personal data is disproportionately higher than the risks to your privacy, if the information you are requesting would expose confidential commercial information, if providing your information would interfere with countervailing public interests, or where your information is processed strictly for statistical or research purposes.
Additionally, we may restrict access to your information if access would:
- interfere with law enforcement or a private cause of action
- violate the rights or interests of others would be violated
- breach another professional privilege or obligation
- hinder or interfere with an employee security investigation
- Expose information about organizational succession planning or corporate reorganization
- Expose confidential information necessary for monitoring, inspecting, or regulating functions connected with sound management
- Expose confidential information related to future or ongoing negotiations
In any case where we deny your request, it is our obligation to justify that decision to you and to provide you with a point of contact for further inquiries.
In fulfilling your data request, we may charge a fee to obtain and grant you access to your data. If we determine this is necessary, we will always attempt to do so at a reasonable cost and one commensurate with the level of effort associated with the request.
We do reserve the right to set some reasonable limits to repetitive requests for personal information based solely on timing, frequency, and level of effort. These are assessed on a case by case basis and are not intended to be restrictive, but to protect us from undue burden. In most cases we aim to respond to requests as part of our regular reporting and reconciliation activities, so long as those do not constitute an excessive delay to you.
Unsubscribe or Opt Out
All users and/or visitors to our Sites have the option to discontinue receiving communication from us. To discontinue or unsubscribe to our website please send an email that you wish to unsubscribe to [email protected]. If you wish to unsubscribe or opt-out from any third party websites, you must go to that specific website to unsubscribe and/or opt-out.
California Privacy Rights
Cimply values customer privacy and aims to address consumer concerns related to privacy according to the most conservative standards we can reasonably fulfill. In most cases California Privacy Rights as it relates to our Privacy Policy should be similar to any other state resident from which we collect information. However, for the sake of transparency, we have specified California Resident Rights explicitly in this section of our policy.
If you are a California resident, you may ask us to disclose what personal information we have about you and what we do with that information. You may also request to delete your personal information, to direct us not to sell or share your personal information, to correct inaccurate information that we have about you, and to limit businesses’ our and disclosure of your sensitive personal information:
- Right to know: You can request that a we disclose to you: (1) the categories and/or specific pieces of personal information we have collected about you, (2) the categories of sources for that personal information, (3) the purposes for which the we use that information, (4) the categories of third parties with whom we discloses the information, and (5) the categories of information that the we sells or disclose to third parties. You can make a request to know up to twice a year, free of charge.
- Right to delete: You can request that we delete personal information we collected from you and tell our service providers to do the same, subject to certain exceptions (such as if the we are legally required to keep the information).
- Right to opt-out of sale or sharing: You may request that we stop selling or sharing your personal information (“opt-out”), including via a user-enabled global privacy control. We cannot sell or share your personal information after we receive your opt-out request unless you later authorize us to do so again.
- Right to correct: You may ask us to correct inaccurate information that we have about you.
- Right to limit use and disclosure of sensitive personal information: You can direct us to only use your sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested.
You also have the right to be notified, before or at the point we collect your personal information, of the types of personal information we are collecting and what we may do with that information.
If you wish to exercise any rights as a California Resident, please contact us directly at the contact information at the bottom of this policy. We will not discriminate in any way for exercising these rights.
Changes to Privacy Policy and Your Consent
Cimply reserves the right to make changes to this privacy policy as needed or at our discretion. In most cases, you will be notified to these changes through updates to this page. However, if we make material changes that involve loosening of our policy to allow for more uses of your data we will notify you through email and/or through a prominent announcement on our site as well as by email, if that has been made available to us.
Contact
In order to contact us with questions, explanations, details, opt-out, or to make any request in relation to your personal data, please reach out to:
Cimply LLC
Legal Department
8 The Green, STE B.
Dover, DE 19901
(682) 302-4446