Last updated November 19, 2015
Why We Collect Personal Information
We may collect information about you through your use of the Services to provide you with a superior and personally relevant user experience. The information we collect can be personal or non-personal in nature, and may be used alone or in the aggregate with that of other Users. Your Personal Information (defined below), for instance, may be used in some cases to recommend products of interest directly to you, and in other cases for market research purposes that support our efforts to deliver a more valuable service to our community of users. For example, we may use your Personal Information to contact you with announcements, newsletters and promotional materials related to our Services. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See “Changing or Removing Information” below for further information.)
What Information We Collect
In the course of using the Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you; personally identifiable information may include, but is not limited to, your name, phone number, email address and mailing address (individually or collectively, “Personal Information”). We collect your Personal Information in connection with your registration to join our Services.
We also collect other information that you may provide as part of registration and the administration and personalization of your user experience (e.g., without limitation, zip code and user preferences) (“Non-Identifying Information”). Certain Non-Identifying Information would be considered a part of your Personal Information if it were to be combined with other identifiers (e.g., combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (e.g., your viewing preferences).
When you launch any of our Services from a mobile device, we collect your device type, the unique device ID issued by Apple, Inc. for your mobile device (“Device ID”) and Internet Protocol (“IP”) address, if applicable. We use the Device ID to make it possible to authenticate and understand use of our Services. As part of your use of the Services, we collect and store the files you upload, download or access through the Services.
Cookies and Other Technologies
As is standard practice on many websites, our website use “cookies” to help us study traffic patterns on our website and understand the effectiveness of our marketing communications. A cookie is a small string of text that a website can send to your browser. Other types of cookies exist, but the cookies we use in connection with our Services can only identify your browser and cannot retrieve any other data from your hard drive, pass on computer viruses, or capture your email address. Cookies can reveal, for instance, which pages on our website are the most popular, how much time visitors are spending there, and how they are interacting with the content on these pages. You have the option to disable cookies by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to view or use all portions of website due to limited functionality.
When We Disclose Your Information
Within the Services
As a User you may create your own profile and transmit information through the Services. When you do so, the information that you share is available to Users in your particular circle of Users, but is not available to Users outside your particular circle of Users. We are not responsible for the activities of other Users or other third parties with whom you choose to provide your Personal Information or otherwise.
With Third Parties
We may share aggregated information that includes Non-Identifying Information with third party providers with whom we have a strategic relationship. The information shared with these third parties may be used to support user trend analyses and demographic profiling but will not contain your Personal Information.
With our Service Providers and Vendors
Disclosure of your Personal Information and Non-Identifying Information may also occur where we employ third party companies and individuals to facilitate our Services (e.g., without limitation, improvement of our Services’ features, user account authentication), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. These third parties may have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Under Special Circumstances
At times, we may disclose information about you to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of us or a third party, to protect the safety of the public or any person or to prevent or stop activity we may consider to be or to pose a risk of being, any illegal, unethical or legally actionable activity. We also reserve the right to disclose Personal Information and/or Non-Identifying Information that we believe, in good faith, is appropriate or necessary to enforce our Terms of Service.
We do not rent, sell or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes.
Our Policy Toward Children
SimplyCircle does not knowingly collect information from, or provide services to, children under the age of 13. Furthermore, we do not target our service to children under these ages, nor will we ever knowingly communicate with children under 13.
IF YOU ARE UNDER 13 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER.
If you are the parent or legal guardian of a child under 13 who uses the Services, then please contact us at support@SimplyCircle.com to have that child’s information deleted.
If you are the parent or legal guardian of a child under 13 whose group uses the Services, we may ask you for optional information about your child (e.g., name, age, your relationship to your child). You should not submit information about children under 13 unless you are the parent or guardian of that child or have the permission of the parent or guardian.
How We Protect Your Personal Information
As a general rule we use your information, including personal information, solely to provide the Services, and we don’t usually look at your information. However, during the process of developing and troubleshooting the Services, it may be necessary to look at pieces of your information to improve the Services or resolve a problem or dispute. Also, when you write us to request support, our customer support representatives may look at your information in order to assist you. We may also access and use your information to compare information for accuracy and verify it with third parties or to comply with applicable law or legal process.
No one in our company has access to your payment card or PayPal account information. Payment card information is handled by third parties, and they have committed to process your payment card information in a secure, PCI compliant manner. SimplyCircle does not store payment card details in its databases.
We take your privacy very seriously and employ administrative, physical and electronic measures to safeguard your information from identity theft and unauthorized access. We cannot, however, ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We do not and will not, at any time, request your credit card information, your account ID, login password or national identification numbers in a non-secure or unsolicited communication (e.g. via e-mail, telephone, iOS device). You are responsible for maintaining the secrecy of your unique password and account information at all times.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting through the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
SimplyCircle uses SSL to secure transmission of data between our servers and your browser. Secure Sockets Layer, or SSL, is an encryption technology that provides secure communications over the Internet. It does this by verifying that the server to which you are connected is actually the one it claims to be. It also encrypts all transactions between the parties communicating. Encryption is the scrambling of information as it is transmitted over the Internet to protect your confidentiality. Personal information passing between your computer and SimplyCircle services is encrypted. This means that while your information is in transit it is scrambled so that only SimplyCircle and the third party service providers we leverage to run our service can reassemble it in its original text format.
We retain information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service and take other actions permitted by law.
Changing or Removing Information
As a User, you may update or delete the Personal Information in your profile by logging into your account. You may also email us at privacy@SimplyCircle.com to request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Links to Other Websites
Our Services may contain links to other websites and online services. If you choose to click on an advertisement or another third party link, you may be directed to that third party’s website or service. The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or services. These other websites or services may place their own cookies or other files on your computer or mobile devices, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use.
Merger, Sale or Bankruptcy
In the event that we are acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our Users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used.
Your California Privacy Rights
S.B. 27, California Civil Code Section 1798.83, allows users who have provided personal information to us to request information about our disclosures of personal information to certain types of third parties. To request that information, please contact us at SimplyCircle Inc., 1525 Miramonte Ave. #3673, Los Altos, CA 94024.
S.B. 568, titled “Privacy Rights for California Minors in the Digital World” allows California minors a right to delete content that they posted to a website, social media profile, or online service while under the age of 18. To request removal of any such content, please contact us at email@example.com