CloseSimple Privacy Policy

Last updated 6/13/22

 

CloseSimple (“CloseSimple”, “we”, “us” or “our”) provides Users (as defined below) with web-based proactive and on-demand communication platforms (collectively, the “Services”). Learn more about our Services at closesimple.com (“Website”).

This CloseSimple Privacy Policy (“Privacy Policy”) explains our practices, defines our Users (“you” or “your”) privacy options, and describes how your information is collected and used by CloseSimple. By using the CloseSimple Services, you are agreeing to this Privacy Policy and the CloseSimple Terms of Service (“Terms”) which we may update or amend from time to time as set forth herein. Capitalized words or phrases not defined herein have the meaning ascribed in the Terms. 

 

Description of Users and Acceptance of Privacy Policy

This Privacy Policy applies to users who sign up for or otherwise access the Services, including business entities and natural persons who order our Services (“Customers”); employees, consultants, contractors, agents and/or other representatives authorized by a Customer to access and use our Services (“Customer Agents”); business entities and natural persons who access the CloseSimple Portal, receive text messages or receive email messages through the Services from a Customer or Authorized Agent, but who do not have a direct relationship with us (“Third-Parties”); and those who utilize our Website to learn about our products and services (“Visitors”). Customers, Customer Agents, Third-Parties and Visitors are referred to herein collectively as the “Users.” By visiting, using, signing up, or accessing the Website and Services you acknowledge that you have read, understand, and agree to be legally bound by this Privacy Policy and our Terms. If you do not agree to any of the provisions of this Privacy Policy or any of the Terms, you may not access or use the Services. 

 

Information We May Collect

You may be asked to provide your personal information anytime you are in contact with CloseSimple, or the affiliates or subsidiaries of CloseSimple, or when using the Services, Website or any other website provided by CloseSimple, or its subsidiaries, affiliates, or partners. CloseSimple and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy for purposes of providing the Services to you as well as providing customer service, conducting research, and improving the Services. For more details on why we collect information and how it is used please see “Use of Information” below. Information may also be combined with other information to provide and improve our products, Services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you choose not to do so, in many cases we will not be able to provide you with our products or Services or respond to any inquiries you may have. By voluntarily providing information, including personal information, you are consenting to our use of it in accordance with this Privacy Policy. If you provide personal information to the Services, you acknowledge and agree that such personal information may be transferred from your current location to the offices and servers of CloseSimple and the authorized third parties referred to herein and in our Terms.

 

Here are some examples of the types of information CloseSimple may collect (collectively “Personal Information”):

  • Personal data and identifying information for registration (e.g. name, email address, location);
  • The geographical area in which you use your computer or mobile device, as indicated by an IP address or similar identifier; 
  • Payment processing information, including but not limited to account numbers, routing numbers, and other payment methods;
  • The CloseSimple products and Services that you use; 
  • Access to information stored on your mobile device, including but not limited to access to your camera, files, photograph and any other digital content stored on your mobile device; and
  • Any content that you provide or 3rd party data which may be synced with your account.

 

Some information (which may be deemed personal information in some jurisdictions) may be automatically received and stored as non-identifiable personal information. Such information is collected passively using various technologies and cannot presently be used to specifically identify you. Examples of this non-personal information includes the type of internet browser or mobile device you use, any Website or device from which you have come to the Services, your operating system location data (which is anonymous), your IP address, cookie ID, pages accessed and clickstream, additional session information and timestamps. We may store such non-personal information ourselves or it may be included in databases owned and maintained by our affiliates, agents, or service providers. The Services may use such non-personal information to assist us in providing effective Services and to collect broad demographic information for aggregate use.

 

Cookies

When you utilize the Website or our Services, we strive to make that experience as efficient as possible, and our web server may send data collection and tracking tools such as web beacons, pixel tags, embedded links, cookies and other similar tracking techniques to your computer or mobile device. Cookies are small pieces of information which are issued to your computer or mobile device when you visit a website or access or use a mobile application, and which store and sometimes track information about your use of the Services and Website. A number of cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies may be used to remember you when you return to the Website and will last longer. Some cookies are set by us, and others by third parties who are delivering services on our behalf. In all cases in which we use cookies, we will not collect Personal Information unless we obtain your permission.

 

Most web and mobile device browsers automatically accept cookies. You may change or adjust your settings to prevent this if you wish. Please note, however, that by blocking or deleting cookies you may not be able to take full advantage of the Services. If you have questions about how to change or adjust your settings, please direct those inquiries to the maker of your device or service provider. 

 

Use of Information

In general, Personal Information you submit to us is used either to respond to requests that you make or to aid us in serving you better. We and our service providers may use your Personal Information in various ways, including to:

  • Facilitate the creation of and secure your account on our network;
  • Identify you as a user in our system;
  • Facilitate information delivery between you and your title/escrow company;
  • Provide improved administration of our Website, Services and products;
  • Create, develop, operate, deliver, and improve our products, Services, content, and advertising;
  • Measure and analyze audience traffic and improve the quality of your experience when you interact with our Website and Services, and for other internal purposes;
  • Send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
  • Send you SMS updates about your real estate transaction;
  • Send you administrative e-mail notifications, such as security, or support and maintenance advisories;
  • Send newsletters, surveys, offers, and other promotional materials and for other marketing purposes;
  • Help recognize you as a previous visitor and save and remember your preferences and settings and deliver to you appropriate interest-based content;
  • Understand whether you read email messages and click on links within those messages;
  • Prevent potentially prohibited or illegal activities, comply with applicable law, and enforce our Terms; and
  • For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

 

In addition to the sharing described elsewhere in this Privacy Policy, we may share Personal Information with companies, organizations, or individuals outside of CloseSimple in a de-identified format when we have your consent to do so. We require opt-in consent for the sharing of any sensitive Personal Information. Sensitive Personal Information is a particular category of Personal Information relating to racial or ethnic origins, political or religious beliefs, or sexuality.

 

Use of Other 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. We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where CloseSimple is accessed so that we can better understand customer behavior and improve our products, Services, and advertising.

 

We may collect information regarding customer activities from or relating to the Services, on our Website and mobile application, 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, content, and Services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.

 

If we combine non-Personal Information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

 

Disclosure to Third Parties

At times CloseSimple may make Personal Information available to strategic partners that work with CloseSimple to provide products, Services, or Content, or that help CloseSimple market to customers or Users. Personal information will only be shared by CloseSimple to provide or improve our products, Services, content, and advertising; it will not be shared with third parties for their marketing purposes nor will it in any event be sold to any third party.

 

We share Personal Information with our service providers for the purpose of providing the Services and to companies who provide additional services such as information processing, payment processing, delivering products to you, managing and enhancing user data, providing user service, assessing your interest in our products and Services, and conducting User research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever CloseSimple operates.

 

We will share Personal Information with third party companies, organizations, or individuals outside of CloseSimple if we have a good faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

  • Meet any applicable law, regulation, subpoena, legal process, or enforceable governmental request;
  • Enforce the Terms, including investigation of potential violations;
  • Detect, prevent, or otherwise address fraud, security, or technical issues; 
  • Protect against harm to the rights, property, or safety of CloseSimple, our Users, customers, or the public as required or permitted by law; or
  • For purposes of national security, law enforcement, or other issues of public importance. 

 

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.

 

CloseSimple will not sell or rent your Personal Information.  

 

Retention of Personal Information

CloseSimple will keep your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy and in the Terms unless a longer retention period is required or permitted by law. 

 

Update to Personal Information 

If your Personal Information is incorrect or needs updating, please contact CloseSimple immediately at info@CloseSimple.com.

 

Protecting Your Information

The security of your Personal Information is important to us. When you enter Personal Information on our Website, we encrypt the transmission of that information using TLS encryption. 

 

We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Unfortunately, however, no security system is impenetrable. We cannot guarantee the security of our databases or the security of the databases of our affiliates or third parties with which we may share information, nor can we guarantee that information stored with us will not be stolen while being transmitted over the Internet. Email sent to us may not be secure and you should be careful when determining what information you wish to communicate via email. If you have questions about security on our Website or concerning the Services please contact info@CloseSimple.com. 

 

Third Party Links and Services [and Payment Processing]

This Privacy Policy applies only to our Services and Website. CloseSimple Websites, products, applications, and Services may contain links to third-party websites, products, and services not operated or controlled by us and to which our Privacy Policy does not apply. Such links do not imply that we have reviewed the third-party sites and we suggest contacting those sites directly for information regarding their respective privacy policies. 

 

Our products and Services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices.

 

Additionally, we may use third-party analytics services (for example, Google Analytics, Mixpanel, Braze, and others) to evaluate your use of the Website and/or Services, compile reports on activity, analyze performance metrics, and collect and evaluate other information relating to the Website and/or Services and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By use of the Services, you consent to the processing of data about you by these third-party providers in the manner and for the purposes set out in this Privacy Policy. 

 

[For online payments using credit or debit cards, Apple Pay, PayPal, Venmo and/or Automated Clearing House (ACH) payouts, we use the payment services of PaySimple. We do not store any of your credit card information after you make a purchase.] 

 

Use of Information by You

As part of the Services, we will provide you with information gathered from your website and other devices. It is solely your responsibility to make appropriate disclosures to visitors to your website and devices about the type of information that may be collected and its use. You are solely responsible for implementing and ensuring your own privacy policy which complies with all federal, state, and local laws. CloseSimple is not responsible for any act or omission by you with regard to such information, and CloseSimple’s liability shall be limited pursuant our Terms, and you agree to indemnify, defend, and hold CloseSimple harmless from and against any and all claims, suits or otherwise relating in any way to your use of information provided to you by CloseSimple. 

 

Choices and Exclusions

You may visit the Website and use the Services without providing any Personal Information. If you do not provide the required information, however, you will not be able to use certain Services. 

 

This Privacy Policy does not apply to any Personal Information or other information collected by us other than personal information collected through our Services or on the Website. It does not apply to any unsolicited information you voluntarily provide to us, post, or upload through the Services or through any other means (“Unsolicited Information”). This includes, but is not limited to, information posted to any public areas of the Website. You agree that Unsolicited Information becomes the intellectual property of CloseSimple to the fullest extent permitted by applicable law and agree to assign any and all residual rights or interest that you may have in such Unsolicited Information to CloseSimple. All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution to the fullest extent permitted by law. 

 

Children

We do not knowingly collect personal information from children under the age of 18. If you are under the age of 18, please do not use the Website or Services and/or submit any Personal Information through the Website or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information on any website or service (including the Services) without their permission. 



California Consumer Privacy Act Notice 

 

This California Consumer Privacy Act Notice (“Notice”) is applicable only to California residents (“consumers” or “you”) and only supplements the information provided elsewhere in this Privacy Policy. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

 

Information We Collect

We may collect “Personal Information,” defined as information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Personal Information does not include publicly available information from government records, de-identified or aggregate consumer information,  health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

 

The Personal Information we collect may depend on your relationship to us. We may have collected the following categories of Personal Information from California consumers in the past 12 months:

  • Identifiers, such as name, contact information, online identifiers, Social Security numbers and other government-issued ID numbers; 
  • Personal information, as defined in the California customer records law, such as insurance policy number, education, employment, employment history, and financial information; 
  • Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status; 
  • Commercial information, such as transaction information and history, policies purchased, net worth, income, real and personal property values;
  • Internet or network activity information from visits to our websites or use of our software applications, such as browsing history and interactions with our and other websites and systems; 
  • Geolocation data, to the extent you use our mobile applications and choose to share such data from your device;
  • Professional or employment-related information, such as work history, current and prior employers, and income; and
  • Inferences drawn from any of the Personal Information categories above to create a profile or summary.

 

Sources of Personal Information

We collect some of the Personal Information described above directly from you and your agents, such as through documents you provide, and your interactions with us, including those on our websites and through our systems. We also collect Personal Information from categories of sources such as third parties authorized by you.

 

Use of Personal Information

Depending on your relationship with us, we may use or disclose the Personal Information we collect for one or more of the following business purposes:

  • Facilitate the creation of and secure your account on our network;
  • Identify you as a user in our system;
  • Facilitate information delivery between you and your title/escrow company;
  • Provide improved administration of our Website, Services and products;
  • Create, develop, operate, deliver, and improve our products, Services, content, and advertising;
  • Measure and analyze audience traffic and improve the quality of your experience when you interact with our Website and Services, and for other internal purposes;
  • Send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;
  • Send you SMS updates about your real estate transaction;
  • Send you administrative e-mail notifications, such as security, or support and maintenance advisories;
  • Send newsletters, surveys, offers, and other promotional materials and for other marketing purposes;
  • Help recognize you as a previous visitor and save and remember your preferences and settings and deliver to you appropriate interest-based content;
  • Understand whether you read email messages and click on links within those messages;
  • Prevent potentially prohibited or illegal activities, comply with applicable law, and enforce our Terms; 
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA; and
  • For other purposes permissible under applicable law.  

 

We will not collect additional categories of Personal Information from those identified above or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

By consenting to your title/escrow company's and CloseSimple’s informational SMS updates you agree to receive recurring informational and transactional texts, including requests for reviews. Message frequency varies. 

If you wish to unsubscribe from receiving text messages and notifications, reply with STOP to any mobile message sent or login to your portal and uncheck the "I'd receive text messages..." checkbox.  You understand and agree that alternative methods of opting out, such as using alternative words or requests, will not be considered a reasonable means of opting out. We do not charge for the service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message and data rates may apply.

For any questions, please text HELP to the number you received the messages from. You can also contact us at support@closesimple.com for more information. 

Sharing Personal Information

We do not sell your Personal Information for monetary consideration to anyone. We may disclose your Personal Information to a third party for a business purpose. We do not disclose the Personal Information of consumers under 18 years of age.

 

In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties for a business purpose:

Category A:    Identifiers;

Category B: Personal Information as defined in the California customer records law;

Category C: Protected classification characteristics under California or federal law;

Category D: Commercial Information;

Category H: Audio / Video / Electronic information; 

Category I: Professional or employment-related information; and

Category K: Inferences drawn from Personal Information

 

We share your Personal Information for a business purpose to the following categories of third parties:

  • Our affiliates [and subsidiaries];
  • Service providers and vendors;
  • Third parties whom you authorize us to disclose your Personal Information so we may provide you our products or services; and
  • To other third parties as required or permitted by law.

 

Your California Privacy Rights

If you are a California resident, you may have certain rights with respect to your Personal Information, including the following:

  • The right to know, for a period of 12 months prior to your request:
    • the categories of Personal Information we collected about you;
    • the specific pieces of Personal Information we collected about you;
    • the categories of sources from which we collected the Personal Information;
    • the business or commercial purposes for collecting the Personal Information;
    • the categories of Personal Information we disclosed or sold to third parties, if any, and the categories of those third parties.
  • The right to “opt-out” of our sale of your Personal Information to any third parties;
  • The right, with some exceptions, to have your Personal Information deleted from our possession or control; and 
  • The right to receive equal service and pricing from us even if you exercise any of your privacy rights.

 

If you exercise the right to delete your Personal Information, we may still retain your Personal Information as permitted under applicable law, including but not limited to the following purposes:

  • To provide goods or services you requested;
  • To detect security incidents or other fraudulent or illegal activity;
  • To identify, debug and repair errors and existing impairments to intended functionality;
  • To comply with our legal and regulatory obligations; and
  • To enable other uses compatible with your expectations, or appropriate given the context in which the Personal Information was collected.

 

In addition, California Civil Code Section 1798.83 permits California residents who use our Website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

 

To make a request to exercise any of these rights, or if you have any questions or concerns about your rights, our Privacy Policy or our use of your Personal Information, please contact us at: 

 

CloseSimple, Inc.

219 N 2nd Street

STE 400

Minneapolis, MN 55401

Phone: 1-866-942-5673 (1-866-94-CLOSE)

Website: closesimple.com 

Email: info@CloseSimple.com

 

Only you (or a person registered with the California Secretary of State you have authorized to act on your behalf) may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.  You may make such a request no more than twice during a 12-month period.

 

We shall respond to consumer inquiries within forty-five (45) days and at no cost to you.  We will inform you in writing if we require more time to respond, up to an additional forty-five (45) days.  We may charge a fee to respond to excessive, repetitive, or manifestly unfounded requests, in which case we will provide you with a cost estimate and rationale before completing your request. 

 

We must verify your identity with respect to such inquiries.  Please provide enough information to permit us to locate you in our records. Depending on the nature of the Personal Information at issue and the clarity of your request, we may require additional measures or information from you as part of that verification.  If you have an account with us, we will deliver our written response to that account. If you request delivery of specific pieces of Personal Information, we will select a readily useable format that should permit you to transmit the information to another entity without hindrance. 

 

For California residents under age 18 who have publicly posted content or information, you may request and obtain removal of such content or information pursuant to California Business and Professions Code Section 22581, provided you are registered user of any Website where this Notice is posted.  To make such a request, please send an email with a detailed description of the specific content or information to info@CloseSimple.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that the law may not require or allow removal in all instances, even if requested.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Changes to Our Privacy Notice

We may change or update this Notice from time to time.  When we do, we will post the revised Notice on this page with a new “Last Updated” date. 

 

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

 

Phone: 1-866-942-5673 (1-866-94-CLOSE) 

Website: closesimple.com 

Email: info@CloseSimple.com

Postal Address: CloseSimple, Inc.

219 N 2nd Street

STE 400

Minneapolis, MN 55401

Notice for Individuals Located In EU

The data controller (i.e., who determines the purpose and means of processing your personal data) for the personal data collected from or about Users pursuant to this Privacy Policy is:

 

CloseSimple, Inc.

Attn: Legal

219 N 2nd Street

STE 400

Minneapolis, MN 55401

info@CloseSimple.com

 

Please note that when we collect information about end users, we are acting as a data processor on behalf of our Customers. If you are an end user, please contact the business or individual who sent you the text message.

 

We need to inform users about the legal basis for our processing of their personal data. Our legal basis depend on the context in which the personal data is collected and processed. Generally, we only collect personal data when we need the personal data to perform a contract with users (such as our Terms of Service), when we have consent to do so or when the processing is in our legitimate business interests and not overridden by the privacy or other fundamental rights and freedoms of users (such as when we process personal data to prevent spam or fraud).

 

In some cases, we also may have a legal obligation to collect personal data from users. If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether providing your personal data is mandatory and the possible consequences if you do not provide your personal data.

 

Similarly, if we collect and use personal data in reliance on our legitimate interests (or those of any third party), this interest is typically to provide our Services and communicate with you about our Services and for our legitimate commercial interests, such as responding to queries, improving our site and Services, advising users about new features or maintenance or undertaking marketing activities. We may have other legitimate interests and if appropriate we will make clear our legitimate interests at the relevant time.

 

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided below.

 

For personal data for which we are the data controller and for which applicable law grants you data protection rights, if you would like to review, correct, update, suppress, restrict or delete personal data that you have previously provided to us as or if you would like to receive an electronic copy of your personal data for purposes of transmitting it to another company (where this right to portability is provided to you by law), please submit your request to us as follows:

 

CloseSimple, Inc.

Attn: Legal

219 N 2nd Street

STE 400

Minneapolis, MN 55401

info@CloseSimple.com

 

In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data suppressed from our database or other limitations you would like to put on our use of your personal data. For your protection, we only fulfill requests for the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity and geographic residency before fulfilling your request. We will try to comply with your request as soon as reasonably practicable and within the time periods required by applicable law.

 

Please note that we often need to retain certain personal data for record keeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal data provided until after the completion of such purchase or promotion). Our databases and other records may have residual personal data which will not be removed. We also may not allow you to review certain personal data for legal, security or other reasons.

 

EEA residents have the right to lodge a complaint with a data protection authority about how we process your personal data. Please see https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en for more information.

 

International Transfers of Personal Information

CloseSimple may transfer your personal information to jurisdictions other than the one in which you reside. These other jurisdictions may have data protection laws that are different from the laws of your place of residence (and, in some cases, not as protective).

 

Specifically, our servers are located in countries which may be located outside of the jurisdiction where we collected the data. This means that when we collect your personal information, we may transfer it to or process it in any of the countries in which we do business. Also, some of the third-party service providers with which we may share personal information (as described above) are located in and may transfer personal information to various jurisdictions around the world. When we transfer personal data from the EEA to a jurisdiction outside the EEA, we deploy appropriate technical and organizational safeguards consistent with the requirements of applicable data protection law.

 

Changes

The Services and Website may change from time to time. As a result, we may be required or deem it necessary or desirable to change this Privacy Policy or our Terms. We therefore reserve the right to update or modify this Privacy Policy or our Terms at any time, and from time to time, and with or without notice to you. Any material change will be preceded by a notice posted on the relevant Services. If you disagree with our revisions to the Privacy Policy, you may deactivate your account and discontinue the use of our Services. Please review this Privacy Policy and our Terms periodically, and especially before providing any Personal Information. Your continued use of the Services after any changes or revisions confirm your agreement with such changes or revisions.