Last updated: February 6, 2018
A. How simplyBrand Collects Information About You
When you use the Services, we collect information sent to us through your computer, mobile phone, or other access device. This information may include your IP address and device information, including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website.
simplyBrand does not direct its websites, mobile app, API, or any of the Services to children. simplyBrand does not intentionally collect information from children. If we become aware that we have inadvertently received personal information from a user under the age of 21 (or any lower age pursuant to applicable law), we will delete such information from our records.
If you create an account or use the Services, we, or our affiliates or vendors acting on our behalf may collect the following types of information:
- Contact information - your name, address, phone number, email address, and other contact information; and
- Financial information - bank account and routing numbers associated with your simplyBrand account.
If you seek permissions to raise digital currency buy and sell limits associated with your simplyBrand account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal information. We may also obtain information about you from third parties such as credit bureaus and identity verification services.
When you use the Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect information about your computer, mobile device, or other access device for fraud prevention purposes, to monitor for possible breach of your simplyBrand account, and to identify any malicious software or other activity that may harm simplyBrand or its users.
Finally, we may collect additional information you may disclose to our Support Team.
- recognize you as a simplyBrand customer;
- customize simplyBrand Services, content, and advertising;
- measure promotional effectiveness; and
- collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
We also use Local Shared Objects, commonly referred to as "Flash cookies," to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud, and to support our sites and services.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of the Services. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies.
C. How simplyBrand Protects and Stores Personal Information
We store and process your personal and transactional information, including certain payment information, where simplyBrand facilities or our service providers are located, including in Japan, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable laws. We employ safeguards such as firewalls and data encryption, physical access controls to our buildings and files, and restricted access to personal information only for those employees who require it to fulfill their job responsibilities.
We store our customers' personal information securely throughout the life of the customer's simplyBrand account. simplyBrand will retain your personal information for a minimum of ten years or as necessary to comply with our legal obligations or to resolve disputes.
D. How simplyBrand Uses the Personal Information We Collect
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:
- provide the Services and requested customer support;
- process transactions and send notices about your transactions;
- resolve disputes, collect fees, and troubleshoot problems;
- prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
- customize, measure, and improve simplyBrand Services and the content and layout of our website and applications;
- deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and
- verify your identity by comparing your personal information against third-party databases.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features of the Services may not be available to you.
We will never sell or rent your personal information to third parties.
Any communications we send to you will either be related to your account or will be related to simplyBrand services or products. In the event simplyBrand sends any communication to you which is not related specifically to your account, simplyBrand will provide you with an "unsubscribe" mechanism through which you may opt out of receiving other similar messages in the future.
E. How Personal Information Is Shared with Other simplyBrand Users
If you use your simplyBrand account to transfer digital currency in connection with the purchase or sale of goods or services, we or you may also provide the seller with your shipping address, name, and/or email to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have given prior consent. If an attempt to transfer digital currency to your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful transfer. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.
In connection with a digital currency transfer between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a simplyBrand customer, that digital currency transfers are enabled, and/or to notify you that you have received digital currency. If you request that we validate your status as a simplyBrand customer with a third party, we will do so. You may also choose to send digital currency to or request digital currency from an email address. In such cases, your username will be displayed in an email message notifying the user of the designated email address of your action. Please note that merchants you interact with may have their own privacy policies, and simplyBrand is not responsible for their operations, including, but not limited to, their information practices.
If you authorize one or more third-party applications to access your simplyBrand account, the information you have provided to simplyBrand may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions made during you use of the Services.
F. How simplyBrand Shares Personal Information with Other Parties
We may share your personal information with the following parties for the following reasons.
Third party identity verification services. This allows simplyBrand to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.
Various service providers. These service providers are those under contract to help with parts of our business operations, such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else;
Partner Financial Institutions. These institutions are those a bank account and routing numbers associated with your simplyBrand account.
Law enforcement, government officials, or other third parties. We may be required to disclose personal information if and when compelled to do so by a subpoena, court order, or similar legal procedure.
Miscellaneous. We may also make disclosures of personal information if we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use.
Before simplyBrand shares your information with any third party, simplyBrand will, to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement requiring that the third party to provide at least the same level of privacy protection as required hereunder.
If you establish a simplyBrand account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a simplyBrand website) will be shared with the owner of the third party website or application and your information may be subject to their privacy policies.
In general, we will notify you of material changes to this policy by updating the last updated date at the top of this page, and we will provide you with explicit notice of material changes as required by law. We recommend that you visit this page frequently to check for changes.
G. Specific Consent by Users in the European Economic Area
If you are located in, or a resident of, the European Economic Area ("EEA"), you specifically and voluntarily consent to the transfer of your personal information to our related entity and service providers in Cayman and USA, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
You may revoke your consent to this section at any time by emailing email@example.com with the subject line "Revoke EEA data consent".
H. Specific Consent by Users in Singapore
If you are located in, or a resident of, Singapore, you specifically and voluntarily consent to the transfer of your personal information to our related entity and service providers in Cayman and USA, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
You may revoke your consent to this section at any time by emailing firstname.lastname@example.org with the subject line "Revoke Singapore data consent".
I. How You Can Contact Us About Privacy Questions
If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page, by emailing email@example.com.