CloseSimple Privacy Policy

Last Updated: May 18, 2020

CloseSimple provides Users (as defined below) with a web-based email and text messaging platform with a mobile application (collectively, the “Services”).  Learn more about our Services at closesimple.com (“Website”).

By using the CloseSimple (“CloseSimple”, “we”, “us” or “our”) Services, you are agreeing to this Privacy Policy (“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 receive text messages through the Services form 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 of Service. If you do not agree to any of the provisions of this Privacy Policy or any of the Terms of Service, 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 CloseSimple, 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 chose 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 our Terms of Service.

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

  1. Personal Data and Identifying Information for registration (e.g. name, email address, location);
  2. The geographical area in which you use your computer or mobile device, as indicated by and IP address or similar identifier; 
  3. Payment processing information, including but not limited to account numbers, routing numbers, and other payment methods;
  4. The CloseSimple products and Services that you use; 
  5. 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 you mobile device; and
  6. 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. Example of this non-personal information includes the type of internet browser or mobile device you used, 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 Data 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 authorized service providers may use your Personal Data in various ways, including to:

  • facilitate the creation of and secure your Account on our network;
  • identify you as a user in our system;
  • provide improved administration of our Website, Services and products;
  • provide the products and Services you request;
  • measure and analyze audience traffic and improve the quality of your experience when you interact with our Website and Services;
  • send you a welcome email to verify ownership of the e-mail address provided when your Account was created;
  • 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 your appropriate interest-based content;
  • understand whether our users read email messages and click on links within those messages;
  • prevent potentially prohibited or illegal activities, comply with applicable law and enforce our Terms of Service; and
  • for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

These service providers will have access to your personal information in order to provide these Services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the Services. We use demographic information to better understand our Users and improve our products and Services.

We also use personal information to help us create, develop, operate, deliver, and improve our products, Services, content, and advertising, and for loss prevention and anti-fraud purposes.

We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate Services. For example, we may use date of birth to verify the age of account holders to ensure they are of legal age to use the Services we provide.

We may also use personal information for internal purposes such as auditing, data analysis, and research to improve CloseSimple products, Services, and customer communications.

We may also share or disclose your personal information with our affiliates and subsidiaries. We may share or disclose your personal information to protect our Users; to maintain the security of our Services; to detect, prevent, or report fraud, criminal activity, or violations of our terms of service/use; to protect the health and safety of our Users or the general public; and to protect our rights and property.

Some Websites may belong to ad networks that use your browsing history across Websites to choose which ads to display on their sites; the displayed ads may include advertising for CloseSimple. Websites may also offer their own opt-out methods for interest-based advertising.

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.

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

  1. Meet any applicable law, regulation, subpoena, legal process, or enforceable governmental request.
  2. Enforce applicable Terms of Service, including investigation of potential violations.
  3. Detect, prevent, or otherwise address fraud, security, or technical issues.
  4. Protect against harm to the rights, property, or safety of CloseSimple, our Users, or the public as required or permitted by law.

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 accessed from 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 Users 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.

We may collect and store details of how you use our Website and Services, including search queries. This information may be used to improve the relevancy of results provided by our Services. Except in limited instances to ensure quality of our Services over the Internet, such information will not be associated with your IP address.

With your explicit consent, we may collect data about how you use your device, the applications and Website in order to help our developers improve the apps, Services and Website.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

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 potential customers. 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.

CloseSimple shares personal information with companies who provide 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 (including the Services), and conducting User research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever CloseSimple operates.

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for CloseSimple to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our Terms of Service or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

CloseSimple is not in the business of selling or renting your information. Your information will only be shared when necessary to provide Services, enforce the Terms of Service, as otherwise required by law, or in cases where you have provided your explicit consent. 

Retention of Personal Information

CloseSimple will keep your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and Terms of Service unless a longer retention period is required or permitted by law. If your personal information is incorrect or needs updating, please contact CloseSimple immediately at support@CloseSimple.com and we will be happy to assist.

Protecting Your Information

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 which we may share information with, nor can guarantee that information stored with us will not be stolen while being transmitted over the internet. Specifically, 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 support@CloseSimple.com

Third Party Services and Payment Processing

CloseSimple Websites, products, applications, and Services may contain links to third-party websites, products, and services. Our products and Services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

Additionally, we may use third-party analytics services (for example, Google Analytics 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. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.  

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 of Service, 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 Data 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. 

Links to Other Sites

This Privacy Policy applies only to our Services and Website. Our Services and Website may contain links to other web sites not operated or controlled by us, to which our Privacy Policy does not apply. The links from the Service and Website 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. 

 

California Privacy Notice

CloseSimple’s California Privacy Notice (“California Privacy Notice”) applies to the processing of Personal Information of residents of the State of California (“California Consumers”) as required by the California Consumer Privacy Act of 2018 (“CCPA”).  “Personal Information”, as used in this California privacy Notice means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

If you are a California Consumer, this California Privacy Notice explains your privacy rights and is intended to inform you at or before the time that you provide us with your Personal Information how and why we process your Personal Information. If this California Privacy Notice and any provision in the rest of our Privacy Policy conflict, then this California Privacy Notice controls for the processing of Personal Information of California Consumers.

Your California Consumer Privacy Rights

CCPA offers California Consumers the following key privacy rights:

  • Right to Access Information: You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it and the third parties and service providers with whom we share it.
  • Right to Request Deletion: You have the right to request that we delete certain Personal Information that we have collected from you.
  • Right to Notice of Financial Incentive: If we offer a financial incentive or price or service difference in exchange for your Personal Information, we will notify you in advance before collecting your Personal Information for this purpose and explain how you can opt in to the financial incentive or price or service difference.
  • Right to Opt-Out of Sale of Personal Information to third parties: CloseSimple does not sell your Personal Information to third parties. If this policy changes, we will notify you and provide you with information about how to opt out of sale of your Personal Information by us. Sharing your Personal Information with our service providers is not a sale of your Personal Information because we make sure that our service providers are contractually obligated to use the Personal Information only to provide services to us and not sell it.

Our Notice at Collection of Personal Information

For CCPA purposes, As used in this Notice at Collection of Personal Information, the term Third-Party” means a person or business who receives a test message through our Services or a third-party, but do not have a direct relationship with CloseSimple.

CloseSimple generally acts as a “Business” with respect to your Personal Information, which means that CloseSimple determines how and why the Personal Information that CloseSimple collects from or about you is processed. When CloseSimple is handling Personal Information about Third Parties on behalf of our Users, CloseSimple is acting as a “Service Provider”, which means that CloseSimple can only use your Personal Information for specified purposes and as permitted in our contract with our Customer.

This Notice at Collection of Personal Information describes our Personal Information collection practices when we are acting as the Business, including a list of the categories of Personal Information we collect, the purposes for which we collect Personal Information and the sources from which we collect Personal Information. If you have more questions about information collected from or about Third Parties, please contact the company from which you receive text messages because they are the “Business” for CCPA purposes.

The following table lists categories of Personal Information that generally match the categories in the definition of Personal Information in CCPA. We indicate for each listed category the specific types of Personal Information in the category that we collect and why we collect it. We provide information about how we use and disclose Personal Information above in this Privacy Policy.

CCCPA CATEGORY OF PERSONAL INFORMATION

A. Identifiers

EXAMPLES OF WHAT WE COLLECT

Name, postal address, email address, unique identifier, Internet Protocol address, account name, and similar identifiers.

We do not collect your social security number, driver’s license number or passport number.

We do not collect your insurance policy number, education, employment history, medical information, or health insurance information.

WHY WE COLLECT PERSONAL INFORMATION

We collect your name, telephone number(s), email address(-es) and contact address when you create an account, an account is created for you or you complete a transaction. If you choose to create an account, we assign a username and one or more unique identifiers to your account.

We collect your IP address and your Device ID automatically.

We also collect this Personal Information

  • To troubleshoot problems
  • To learn how Users interact with our Site and Services
  • To improve our products and services and develop new features
  • To customize your experience
  • To promote our products and services
  • To communicate with you

CCCPA CATEGORY OF PERSONAL INFORMATION

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

EXAMPLES OF WHAT WE COLLECT

Name, signature, address, telephone number and current employer and work address.

EXAMPLES OF WHAT WE COLLECT

We collect your name, phone number, email address and contact address when you create an account, an account is created for you or you complete a transaction. If you choose to create an account, we will assign a username and one or more unique identifiers to your account.

We collect your IP address and your Device ID automatically.

We also collect this Personal Information

  • To troubleshoot problems
  • To learn how Users interact with our Site and Services
  • To improve our products and services and develop new features
  • To customize your experience
  • To promote our products and services
  • To communicate with you

CCCPA CATEGORY OF PERSONAL INFORMATION

C. Protected classification characteristics under California or federal law

EXAMPLES OF WHAT WE COLLECT

We do not collect information about legally-protected classifications, including race, national origin, citizenship, marital status, gender, sexual orientation/identity, medical condition, AIDS/HIV status, genetic information, military or veteran status, religion, disability, political affiliations or activities or status as a victim of domestic violence, assault or stalking.

EXAMPLES OF WHAT WE COLLECT

N/A

CCCPA CATEGORY OF PERSONAL INFORMATION

D. Commercial information

EXAMPLES OF WHAT WE COLLECT

Records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

EXAMPLES OF WHAT WE COLLECT

We create records of the Services purchased or considered, as well as your purchasing history in order to provide you with the Services that you have purchased and to offer other products that may be useful to you. You provide payment and billing information when you purchase our Services but we do not collect and store your bank account number, credit card number, debit card number – this information is collected by our third party payment processor and not shared with us.

CCCPA CATEGORY OF PERSONAL INFORMATION

E. Biometric information

EXAMPLES OF WHAT WE COLLECT

We do not collect information about your physiological, biological or behavioral characteristics.

EXAMPLES OF WHAT WE COLLECT

N/A

CCCPA CATEGORY OF PERSONAL INFORMATION

F. Internet or other similar network activity

EXAMPLES OF WHAT WE COLLECT

Browsing history, search history, information on a California Consumer’s interaction with online services and digital advertisements.

EXAMPLES OF WHAT WE COLLECT

We collect information about your browsing history, search history and information regarding your interaction with customer portals, websites, applications or advertisements automatically when you use our Site and Services.

CCCPA CATEGORY OF PERSONAL INFORMATION

G. Geolocation data

EXAMPLES OF WHAT WE COLLECT

Physical location or movements from GPS, WiFi and/or Bluetooth (when a device’s operating system settings allow collection).

EXAMPLES OF WHAT WE COLLECT

We collect your IP address automatically. We may be able to determine your general location based on the IP address.

CCCPA CATEGORY OF PERSONAL INFORMATION

H. Audio, electronic, visual, thermal, olfactory or similar information.

EXAMPLES OF WHAT WE COLLECT

Recorded telephone calls and photographs.

EXAMPLES OF WHAT WE COLLECT

If you contact us via telephone, we may record the telephone call. We will notify you if a call is being recorded at the beginning of the telephone call. We do not collect any thermal, olfactory or similar information. We collect your photograph if you choose to give it to us through your account.

CCCPA CATEGORY OF PERSONAL INFORMATION

I. Professional or employment-related information

EXAMPLES OF WHAT WE COLLECT

Depending on how and why you use the Site or Services, we may collect information about your current employer who or that is the Customer or prospective customer.

EXAMPLES OF WHAT WE COLLECT

We may use information about your position and your current employer (who or that is the Customer or prospective customer) to understand more about you in order to provide you with relevant information to promote our products and services, to deliver advertising, some of which is targeted based on your online activity and inferred interests, and to communicate with you.

CCCPA CATEGORY OF PERSONAL INFORMATION

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))

EXAMPLES OF WHAT WE COLLECT

We do not collect information about the institutions you have attended or the level of education you have attained.

EXAMPLES OF WHAT WE COLLECT

N/A

CCCPA CATEGORY OF PERSONAL INFORMATION

K. Inferences drawn from other categories (A. – L above) to create a profile about a California Consumer

EXAMPLES OF WHAT WE COLLECT

Profile reflecting your preferences and characteristics.

EXAMPLES OF WHAT WE COLLECT

We may analyze your actual or likely preferences through the Personal Information we collect and process as described in our Privacy Policy.

CloseSimple does not sell your Personal Information to third parties and accordingly, we do not provide you with information about how to opt-out of sale of your Personal Information

HOW TO SUBMIT A REQUEST TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS

To submit a request to exercise your privacy rights:

  • Send an email to support@closesimple.com

Please note:

  • We may (and in some cases are required to) verify your identity before we can act on your request to exercise your privacy rights.
  • We may not honor part or all your request – for example, certain information we collect may be exempt from this California Privacy Notice, such as public information made available by a government entity or information covered by another privacy law. Please also note that Personal Information collected in many types of business to business transactions is exempt from most of CCPA’s requirements until January 1, 2021. We will explain why we do not honor your request when we respond to you.

A different California law permits California residents to request a notice disclosing the categories of Personal Information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. At this time, CloseSimple does not share Personal Information with third parties for their direct marketing purposes.

 

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
Attn: Legal
215 Kentucky Ave S
Minneapolis, MN 55426
support@closesimple.com

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

We need to inform users about the legal bases for our processing of their personal data. Our legal bases 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, which can be found at closesimple.com/terms), 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
Attn: Legal
215 Kentucky Ave S
Minneapolis, MN 55426
support@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 recordkeeping 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 of Service. We therefore reserve the right to update or modify this Privacy Policy or our Terms of Service 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 of Service periodically, and especially before providing and personal information. Your continued use of the Services after any changes or revisions individuate your agreement with such changes or revisions.