LAST UPDATED: February 28, 2021

SIMM Associates, Inc. is a Service Provider under the California Consumer Privacy Act. A Service Provider processes personal information on behalf of other businesses. We are not subject to the CCPA.

SIMM Associates, Inc. will not sell your information.

SIMM Associates, Inc. may independently collect and use (process) information about you (referred to as your “personal information”). This notice describes how we collect personal information and how we use, share and protect it. It also explains your rights regarding your personal information that we collect from you and how you can contact us.

Since this notice contains important information, we encourage you to read it. Please use the links to access detailed information. If anything is not clear, please contact us via email at [email protected]

WHO COLLECTS YOUR PERSONAL INFORMATION

SIMM Associates, Inc. is a Service Provider processing personal information shared with us by our clients. In most cases, it is our clients that collect your personal information by communicating directly with you. There are very limited circumstances, when processing accounts on behalf of our clients, in which we will collect and process certain personal information depending on how you interact with us.

INFORMATION THAT WE COLLECT

In order to fulfill our services to our clients, or to meet a legal obligation, we may need to collect and use certain personal information. If you do not provide the information that we request, we may not be able to communicate with you effectively. Some of this information we collect directly from you either in person or via a website, application or social media. We also collect personal information about you from other publicly available sources.

When we receive personal information about you from different sources, we may combine or link that information. Linking different sources of information enables us to provide a better customer support service.

WHEN WE COLLECT PERSONAL INFORMATION FROM YOU

We collect personal information when you:

1. communicate with us via telephone, email or text and update personal information about you
2. communicate with us via our website or through social media, or
3. contact us for assistance

PERSONAL INFORMATION WE COLLECT

We collect personal information from you, which might include:

1. Name, date of birth or country of residence
2. Contact information such as email address, telephone number, address
3. Account details such as user name, password and unique user ID
4. Payment information such as debit or credit card details
5. Employment history, salary
6. Details of your contact with us including recordings of any telephone calls
7. Information about another individual. If you disclose any personal information relating to other people to us in connection with our providing service to our clients, you represent that you have the authority to do so and to permit us to use the information in according with this Privacy Policy.

We also collect personal information from other sources:

1. Our clients
2. Publicly available data bases

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for legitimate business purposes as described further below.

Servicing our clients:

We may use your personal information to provide our clients you with the functionality of our services. We may also use personal information to send you administrative information, such as changes in our terms, conditions and policies. We will engage in these activities to manage our contractual relationship with our client and/or to comply with a legal obligation.

Customer service:

If you contact us, or we contact you, we will use your personal information for the purpose of providing you with assistance, handling enquiries and complaints. We will engage in these activities to manage our contractual relationship with our clients, for our legitimate business reasons and/or to comply with a legal obligation.

Our business purposes

We use the personal information we hold about you to accomplish our business purposes, including:

1. To service our clients
2. To conduct data analysis, for example, to improve the efficiency of our services
3. To conduct audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements, and/or
4. To monitor for fraud and security purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft

We engage in these activities to manage our contractual relationship with our clients, to comply with a legal obligation, and/or because we have a legitimate interest.

Security:

We may use information collected from monitoring our websites, online services and emails to protect you, our employees and our partners. This information may be passed to the police or to other appropriate authorities. We will engage in these activities to comply with a legal obligation or because we have a legitimate interest.

HOW WE SHARE PERSONAL INFORMATION

We share your personal information as necessary to complete any transaction or provide any service our clients have requested. We do not share personal information with unaffiliated third parties at this time. The following are categories of recipients with whom we might share your data.

Our Clients

We share your information with the specific client(s) from whom we were engaged to interact with you.

Third party service providers:

We use third party service providers to assist us in fulfilling our obligations to our clients. These may include the provision of customer support, web hosting providers, customer data management, technology providers, companies that coordinate mailings, delivery companies, payment processors, data analysis firms and email service providers. We seek to use service providers who are able to provide appropriate data privacy and security standards.

Business transactions, legal reasons and law enforcement:

We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

We may also disclose personal information to comply with legal obligations (such as paying taxes); to respond to requests from government or other public authorities; to protect the rights, privacy, safety or property of SIMM Associates, Inc., you or others; and to permit us to pursue available remedies or limit the damages that we may sustain. These legal obligations and government requests can include laws and authorities outside your country of residence.

USES AND DISCLOSURES OF OTHER INFORMATION

We may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine other information with personal information. In those instances, we will treat the combined information as personal information while it is combined.

YOUR RIGHTS TO YOUR PERSONAL INFORMATION

You may request to access, correct or remove your personal information that we collect from you. Personal information that we may possess that was given to us by our clients may only be accessed, corrected or removed by communicating directly with our client. You also may request to receive an electronic copy of your personal information to transmit it to another company (to the extent this right to data portability is provided by applicable law). In each case, we may require you to prove your identity and/or provide further information in order to identify your information. We will respond to your requests consistent with applicable law.

Accessing your personal information

You may ask to see what information we hold about you that we collected from you and to receive an explanation about how we process your data by using the “contact us” form on our website.

Correcting your personal information

If we hold personal information about you that we collected from you that is incorrect, you have the right to tell us that it is incorrect and ask us to amend it. We will do this consistent with applicable law. If you would like to correct your personal information, please send an email to [email protected].

Removing your personal information

To the extent allowed by law, you may ask us to remove or delete your personal information we have collected from you from our database. If you wish to have your personal information removed from our database, please send an email to [email protected]

Information collected by our clients

SIMM Associates, Inc. is a Service Provider processing personal information shared with us by our clients. In most cases, it is our clients that collect your personal information by communicating directly with you. You may contact them directly to access, correct or remove information you may have provided directly to them.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

OTHER IMPORTANT INFORMATION

We take the security of your information very seriously. This section outlines our technology practices to keep your information protected.

How we protect your information

We use various security measures and tools, such as firewalls, to help protect against the loss, misuse and alteration of the personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive personal information, except through secure portals such as our payment portal on our website.

How we retain your personal information

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods for payment card information and age-verification information include:

• The length of time we have an ongoing relationship with you and provide the services to you (for example, for as long as you have an account with us or keep using the services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Third-party services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which our services link. The inclusion of a link on the services does not imply SIMM Associates, Inc.’s endorsement of the linked site or service.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the services. Your use of the services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

SIMM Associates, Inc., located at 800 Pencader Drive Newark, DE 19702, is the company responsible for collection, use and disclosure of your personal information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at [email protected], or:

SIMM Associates, Inc.
PO Box 7526
Newark, DE 19714