I. Personally-Identifiable Information and Non-Personally Identifiable Information.
Simple Change Wellness LLC (also referred to herein as “Simple Change”) may collect two different types of information, Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII”). PII that we collect is information that identifies you as an individual – and includes your name, address, telephone number, e-mail address, credit card information, billing address and shipping information. Non-PII is aggregated information, demographic information, IP addresses, user behavior data from web interaction metrics tools and other information that does not reveal your specific identity. PII and Non-PII may be collected anytime you access or use a Simple Change website. PII and Non-PII may also be collected by Simple Change during in-person discussions, telephone conversations, and electronic or other written communications. Simple Change also collects information via cookies; blocking cookies may render you unable to access certain Simple Change products, services, or websites.
Simple Change uses PII to respond to your inquiries, provide you with services you have requested, keep you informed of services Simple Change thinks may be of interest to you, and otherwise personalize your experience with Simple Change, and other reasons. Simple Change does not sell or lease PII about you to others, and may in some cases be liable for so doing under the Privacy Shield Framework outlined below. Simple Change will provide your e-mail address to affiliates or users who refer you to us, or through whom you create a Simple Change account. Simple Change shares your PII with Simple Change affiliates and third parties contracting with Simple Change to provide services to you, including financial institutions. Simple Change employees, along with our customer service and software partners, also have access to PII as part of their job in providing services to You. Simple Change may also share PII when required by law, or when you have expressly requested Simple Change to do so. Simple Change reserves the right to disclose and use your PII if Simple Change believes it is necessary to: (a) respond to legal process, e.g., a subpoena; (b) respond to a law enforcement agency’s request; (c) enforce the Terms; or (d) protect the rights, privacy, safety, property, or operations of Simple Change or third parties;
Because Non-PII does not personally identify You, Simple Change reserves the right to use and disclose to third parties Non-PII for any purpose.
Simple Change reserves the right to change this privacy notice, which changes will become effective upon posting of the revised notice on www.simplechange.com or upon emailing of the changes to You at the email address You provided to Simple Change, or as required by law.
II. Links to or From Other Sites.
Except where expressly stated by Simple Change, Simple Change is not affiliated or associated with operators of any third party websites that link to or are linked from any Simple Change-maintained website. Simple Change disclaims any responsibility for the accuracy or content of information found on third party websites that link to or are linked from any Simple Change website. Simple Change disclaims any responsibility for the security of any information (including without limitation credit card and personally identifiable information (“PII”)) that you may provide to any third party. Simple Change reserves the right, at any time and in its sole and absolute discretion, to block links to any Simple Change-maintained website through technological or other means without prior notice.
III. Information; Registration; User Names and Passwords
As a Simple Change website user, you will be required to create an account with Simple Change. You warrant that the information you provide Simple Change is truthful and accurate, and that you are not impersonating another person. You are responsible for maintaining the confidentiality of any password you may use to access your Simple Change account, and you agree not to transfer your password or User name, or lend or otherwise transfer your use of or access to your account, to any third party. You are fully responsible for all transactions with, and information conveyed to, Simple Change under your account. You agree to immediately notify Simple Change of any unauthorized use of your password or User name or any other breach of security related to your account. You agree that Simple Change is not liable, and you will hold Simple Change harmless, for any loss or damage arising from your failure to comply with any of the foregoing obligations.
IV. EU-US and Swiss-US Privacy Shield Frameworks.
Under the Privacy Shield, you have the right to access, correct, or delete your personal data. You also have the right to limit Simple Change’ use of your data – including the right to opt-in or out of receiving communications from Simple Change. To exercise any of these rights, please send an email to [email protected]
Third party data transfer. Simple Change may be liable for the transfer of EU and/or Swiss personal data to third parties acting as our agents unless we can prove we are not responsible for the event given rise to the damages.
The Choice Principle. Note that we may be required to release personal data of EU and/or Swiss individuals in response to lawful requests by public authorities including to meet national security and law enforcement requirements.
Simple Change has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. Under certain limited conditions, individuals in the European Union or Switzerland may have the right to invoke “last resort” binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission. The Federal Trade Commission has jurisdiction with enforcement authority over Simple Change’ compliance with the Privacy Shield.