Last Revised: January 23, 2022

We respect your privacy and are committed to protecting it through this privacy policy (“policy”).

This policy describes the types of information we may collect from you or that you may provide when you visit www.simpbay.com (“Website”) and our practices for collecting, using, keeping, protecting, and disclosing that information.

This policy applies to information we collect:

• On the Website (including desktop and mobile versions).
• In email, text, and other electronic messages between you and us.
• When you interact with the Website’s advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
• When you interact with the Website through third-party social media platforms.

It does not apply to information collected:

• offline or through any other means, including on any other website operated by any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from (or on) the Website.

Please read this policy carefully to understand our’s policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you agree to this policy and consent to our collection, use, disclosure, retention, and protection of your personal information as described in this policy. We may change this policy on one or more occasions. We will consider your continued use of the Website after we makes changes as your acceptance of the changes, so please check this policy frequently for updates.

1. Statement regarding minors

The Website is not intended for anyone under 18-years old. You will only access the Website or register for an account if (1) you are at least 18-years old and (2) have reached the age of majority where you live. We prohibit all persons who do not meet the age requirements from accessing the Website. Minors must not access the Website or use its services.

We do not knowingly collect or solicit any information or data from minors or allow minors to register for the Website. The Website and its content are not directed at minors. If we learn that we have collected personal information from a minor, we will delete that information as quickly as possible. If you believe that we might have any information from or about a minor, please contact us at [email protected].

2. What types of information do we collect about you and how is it collected?

We may collect several types of information from and about users of the Website, including information:

• by which you may be personally identified, including your email address (if you send us an email), IP address, or any other information that we collect that is defined as personal or personally identifiable information under applicable law (“personal information”);
• that is about you but individually does not identify you, including any optional information you provide about yourself; and
• about your Internet connection, the equipment you use to access the Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through the Website may include:

• Information that you provide by filling in forms on the Website. We may also ask you for information when you report a problem with the Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.

Information We Collect through Automatic Data Collection Technologies

As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and Internet connection, including your IP address, operating system, and browser type.
• Information about your mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include personal information, but we may keep it or associate it with personal information we collect in other ways or receives from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by allowing us to:

• Estimate the Website’s audience size and usage patterns.
• Store information about your preferences, thus allowing us to customize the Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Website.

The technologies we uses for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. But if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website. If you want to learn more about cookies, please visit allaboutcookies.org.
• Web Beacons. Pages of the Website (and our emails) may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages (or opened an email) and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). If you want to learn more about web beacons, please visit allaboutcookies.org/web-beacons/.

We do not collect personal information automatically, but it may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control third-party tracking technologies or how third parties use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

3. How do we use your information?

We use information that we collects about you or that you provide to us, including any personal information:

• To present the Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purposes for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To notify you about changes to the Website or any products or services we offer or provide through it.
• To monitor and analyze trends, usage, and activities in connection with the Website for marketing or advertising purposes.
• To personalize the Website content, features, or advertisements.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may use the information we have collected from you to allow you to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

4. With whom do we share your information?

We may disclose aggregated information about our users and information that does not identify any individual without restriction.

We may disclose personal information that we collect or you provide as described in this policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Website’s users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To enforce or apply the Terms-of-Use Agreement and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.

5. How do you access and correct your information?

You may send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

6. How do we protect your personal information?

We havec implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

7. Do Not Track Policy

Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.

8. Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make that request, please send an email to [email protected].

9. Your Nevada Privacy Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: [email protected]. However, please know that we do not currently sell data triggering that statute’s opt-out requirements.

10. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use that anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

11. Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [email protected]. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

12. Links to Other Websites

The Website contains links to other websites. Please be aware that we are not responsible for the content or privacy practices of those other websites. We encourage you to be aware when you leave the Website and to read the privacy statements of any other website that collects personally identifiable information.

13. Changes to Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page.

14. Contact Information

To ask questions or comment about this policy and our privacy practices, please contact us at [email protected].