© 2019 Simplify Networks S/B

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Privacy Policy

Updated 1st May 2019

SIMPLIFY PRIVACY POLICY

 

Simplify (hereinafter referred to as “Simplify”, “we”, “us” or “our”) operates a platform and community marketplace that enables mobile consumers to create, share, discover and subscribe to mobile Internet services around the world, whether through our website or our mobile applications (“Platform”).

 

Simplify refers to Simplify Networks Sdn. Bhd., in which you can address to inside and outside of Malaysia. Simplify Networks Sdn. Bhd. processes payments for providers and clients residing inside and outside of Malaysia and is also responsible for processing your Personal Information in connection with payments services related to use of the Simplify Platform.

 

Simplify collects information about you when you use our mobile applications, websites, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us.

 

This Privacy Policy together with our Terms of Service set out the basis on which any Personal Information we collect from you, or provided by you to us and is intended to inform you about how we process the Personal Information. The Privacy Policy (“Privacy Policy” or "Policy") hereafter applies to persons (“Clients” and “Providers”) anywhere in the world who use our Platform to share, sell and subscribe to our Services.

 

Please read the following terms carefully to understand our views and practices regarding your Personal Information and how we will treat it. By visiting our website, you are accepting and consenting to the practices described in this Policy. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and deactivate your Simplify account.

 

 

DEFINITIONS

 

“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.

 

“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

 

“Data Controller” means Simplify, the company responsible for the use and processing of Personal Information.

 

“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and Simplify.

 

“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

 

 

COLLECTION OF INFORMATION

 

Information that you provide us

 

We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:

 

  • fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information;

  • access or use the Platform, such as to search for or share Hotspots, subscribe or pay for Internet data services, book or pay for any associated services that may be available , post comments or reviews, or communicate with other users;

  • link your account on a Third-Party site (e.g. Facebook) to your Simplify account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorized by you;

  • report a problem with our site or Services;

  • communicate with Simplify; and

  • share information with other clients or providers.

 

Information we collect from your use of our Platform and Services

 

With regards to each of your visits and use on our Platform, we may automatically collect, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:

 

  • Location Information: When you use the Services for Internet, we may collect precise location data about your Internet usage from your Simplify app. If you permit the Simplify app to access location services through the permission system used by your mobile operating system (“Platform”), we may also collect the precise location of your device when the app is running in the foreground or background. We may also derive your approximate location from your IP address.

 

  • Contacts Information: If you permit the Simplify app to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Statement or at the time of consent or collection.

  • Transaction Information: We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged, Internet data used, and other related transaction details.

 

  • Usage and Preference Information: We collect information about how you and site visitors interact with our Services, preferences expressed, and settings chosen. In some cases we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners. While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Simplify services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

 

  • Device Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.

 

  • Call and SMS Data: Our Services facilitate communications between Clients and Providers. In connection with facilitating this service, we receive connection request data, including the date and time of the connection request is made, the parties’ email address, phone numbers, and the content of the connection message.

 

  • Log Information: When you interact with the Services, we collect server logs, which may include information like device Internet Protocol (IP) address, Internet usage data, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.

 

  • Third Party Data: We may, either directly or through Third Parties we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Platform to market and advertise our Services to you on the Platform and Third-Party websites. Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.

 

 

USE OF INFORMATION

 

We use, store and process information about you for the following general purposes:

 

  • to carry out our obligations arising from any contracts entered into between you and simplify; and to provide you with the information, products and Services that you request;

  • to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

  • to enable you to access and use the Platform;

  • to enable you to communicate with other Clients and Providers, including but not limited to by sending them messages or other information during the subscription process;

  • to operate, protect, improve and optimize the Platform, Simplify’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;

  • to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;

  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

  • to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Simplify, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account” section) when you login to your Simplify Account;

  • to administer referral programs, rewards, surveys, contests, or other promotional activities or events sponsored or managed by Simplify or our Third Party business partners; and

  • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.

 

How Simplify Uses and Processes User Communications

 

We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Clients to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that Simplify, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.

 

 

SHARING OF INFORMATION

 

IMPORTANT: When you use the Platform, your data may be sent to Malaysia and possibly other countries where we operate.

 

We may share your Personal Information with selected Third Parties including business partners, suppliers and sub-contractors for the performance of any contract we have entered into with you.

We may transfer, store, use and process your information, including any Personal Information, to countries outside of Malaysia. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

 

Your Personal Information may be disclosed as follows:

  • Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the general public.

  • Your Internet data service or hotspot information will always include some minimum information such as the hotspot name (“SSID”), price, currency and Internet speed rating where the Service is located. Parts of your public profile page may be displayed in other parts of the Platform to other Clients or Providers and/or Third Party platforms for marketing purposes.

  • The Platform allows your public profile and Internet data service or hotspot information to be included in search engines, in which case your public profile and Internet data service or hotspot information will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or Internet data service or hotspot information, Third-Party search engines may not update their databases quickly or at all. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or Internet data service or hotspot information.

  • When you request to connect to an Internet hotspot, your full name, email address and other Personal Information you agree to pass through to the Provider(s) will become visible to the Provider(s) of any Internet data services you subscribe or request to connect. We may also disclose parts of your public profile; other ratings and reviews of you; and any additional information you share with other Clients and Providers. In addition, if you agree to be contacted by the Provider(s) by phone or message before your request is accepted, and the Provider(s) decides to do so, Simplify will call your phone number first, before connecting you with the Provider(s). We will not share your phone number unless there is a confirmed connection; if there is a confirmed connection, your email address will become visible to the Provider(s), who may contact you directly.

  • When your request to connect to an Internet data service or hotspot is accepted by the Provider(s) or when a Client connects to your Internet data service or hotspot, we will disclose some of your Personal Information to the Provider(s). However, your billing and pay out information will never be shared with another user.

  • When a Provider accepts your request to connect to an Internet data service or hotspot, the Provider may elect to use Third-Party services available through the Simplify platform to assist with managing the Internet service. The Provider may use features on the Simplify platform to share information about the Client with that Third-Party service provider for the purposes of coordinating the Internet usage.

  • When a Client uses your Internet data service or hotspot, we may ask you to review the Provider, or the Internet data service quality. If you choose to provide a review, your review may be public on the Platform. Likewise, another Client’s review of you as a Provider or Client may be public on the Platform.

  • You may link your account on a Third-Party social networking site to your Simplify Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage:  

    • some of the information you provide to us from the linking of your accounts may be published on your Simplify Account profile;

    • your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;

    • a link to your public profile on that Third-Party social networking site may be included in your Simplify public profile;

    • other Simplify users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;

    • other Simplify users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s);

    • the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and

    • the publication and display of information that you provide to Simplify through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.

  • We may distribute parts of the Platform (including your Listing) for display on sites operated by Simplify’s business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

  • Simplify may provide your Personal Information to its Affiliates, including Simplify Payments, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy. Simplify Payments may share your Personal Information for (i) their everyday business purposes; (ii) to jointly market products or services to you with other financial Third Parties with whom Simplify Payments has a formal agreement; and (iii) with respect to information about your transactions and experiences only, for their Affiliates’ everyday purposes. You can unsubscribe or opt-out from receiving marketing communications in your settings (in the “Account” section) when you login to your Simplify account.

  • We may also engage Third Parties, who may be located outside of Malaysia, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request (such as Concur and American Express). We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.

  • For any jurisdiction in which we facilitate the Collection and Remittance of Taxes or Opt-in for Host Remittance of Taxes as described in the “Taxes” section of the Terms of Service, Providers and Clients expressly grant us permission, without further notice, to store, transfer and disclose data and other information relating to them or to their transactions, subscriptions and usage, including, but not limited to, personally identifiable information such as Provider’s or Client’s name, transaction dates and usage data, amounts, tax identification number(s), the amount of taxes received by Providers from Clients, or allegedly due, contact information and similar information, to the relevant Tax Authority.

  • You acknowledge, consent and agree that Simplify may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against Simplify; (b) to comply with legal process (for example, subpoenas and warrants); (c) to enforce and administer our agreements with users, such as the Terms of Use and this Privacy Policy; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Simplify, its users or members of the public.

  • We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:

    • providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or

    • we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Simplify’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).

  • In instances where Simplify complies with legal requests for user data without notice to the user for the reasons described above, Simplify will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.

  • We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

 

 

BUSINESS TRANSFERS BY SIMPLIFY

 

If Simplify undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets in which case we may disclose your Personal Information to the prospective buyer. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

 

 

UPDATING AND DELETING YOUR PERSONAL INFORMATION

 

You may review, update, correct or delete the Personal Information in your Simplify profile. If you would like to correct your information or cancel your Simplify Account entirely, you can do so by logging out of your Simplify Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your Simplify Account is cancelled.

 

 

SECURING YOUR PERSONAL INFORMATION

 

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.

 

 

YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

 

The Platform will contain links to other websites not owned or controlled by Simplify. Simplify does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit and we do not accept any responsibility and liability for these policies.

 

 

SPECIAL FEATURES AND PROGRAMS

 

Referral service and requesting references

 

  • The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform. The Platform also allows you to ask your friends and contacts to write a reference for you, to be published on your Simplify profile.

  • We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and Simplify does not collect or retain the contact information that is used to send them.

  • You may also send invitation/request emails via the Platform itself, in which case we will ask you for the contact information to which to send your invitation/request. You can type in the email addresses or other contact information manually, or you can choose to import the contacts in your address book(s). In both cases, we may use and store this information for the sole purposes of allowing you to send your friends and contacts an invitation or request for a reference, and for fraud detection and prevention. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins Simplify in response to your referral.

  • If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.

 

 

CHANGES TO THIS PRIVACY POLICY

 

We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. Any changes we make to our Privacy Policy in the future will be posted on this page and where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

 

It is important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your Simplify Account. You can find out more about how to deactivate your Simplify Account at simplify.network/help.

 

 

FEEDBACK

 

Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at support@simplify.network.