Simple Paywall Privacy Policy

Version 1.0.0
Last updated September 29th, 2018.

This Privacy Policy describes how Simple Paywall, LLC and its affiliates (“Simple Paywall,” “we,” “our” or “us”) collect, use, and share information in connection with your use of our websites (including, but not limited to, https://simplepaywall.com, https://app.simplepaywall.com), services, and applications (collectively, the “Services”).

We may collect and receive information about Simple Paywall users (the “Simple Paywall Users” or “Users of Simple Paywall”) and end users (the “End Users”) of our Services (collectively, “users,” “you,” or “your”) from various sources, including: (i) information you provide through your user account on the Services (your “Account”) if you register for the Services; (ii) your use of the Services; and (iii) from third-party websites, services, and partners. End Users register for the Services through a website utilizing Simple Paywall’s software (the “Publisher”).

We recommend that you read this Privacy Policy in full to ensure you are fully informed. If you have any questions about this Privacy Policy or Simple Paywall’s data collection, use, and disclosure practices, please contact us at privacy@simplepaywall.com.

Information We Collect

Information You Provide

Account Registration

When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number. If you choose to refer a friend to our Services, we may also collect your friend’s email address so that we may send them a referral or promotional code to sign up for our Services.

Payment Information

When you add your financial account or payment information to your Account, that information is directed to our third-party payment processor. We do not store your financial account information on our systems; however, we have access to, and may retain, subscriber or user information through our third-party payment processor.

Communications

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

For End Users, refer to the Privacy Policy set by the Publisher utilizing Simple Paywall’s software for more information on how they access, store, and retain your information regarding communications.

Information We Collect When You Use Our Services

Cookies and Other Tracking Technologies

As is true of most websites and web applications, we gather and store certain information automatically. In addition, when you use our Services, we may collect certain information automatically from your device. This information may include, but is not limited to, internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL.

To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area (“EEA”), the information referenced above in this paragraph may be considered personal information under applicable data protection laws.

Usage of our Services

When you use our Services, we may collect information about your engagement with and utilization of our Services, such as processor and memory usage, storage capacity, navigation of our Services, and system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, develop new features, protect the security and safety of our Services and our users, and provide support. We also use this data to develop aggregate analysis and business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business.

End Users

For End Users, your use of the Services occurs through your engagement and interaction with a Publisher utilizing our Services on, but not limited to, their website, web application, or mobile application. As is true of most websites and web applications, we collect and store certain information about your usage of the Services automatically through Cookies and other tracking technologies.

Information We Receive from Third Parties

Third-Party Accounts

If you choose to link our Services to a third-party account, we will receive information about that account, such as your authentication token from the third-party account, to authorize linking. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

Third-Party Partners

We may also receive publicly available information about you from our third-party partners and combine it with data that we have about you.

How We Use Information

We use the information we collect in various ways, including to:

  • Provide, operate, and maintain our Services;
  • Improve, personalize, and expand our Services;
  • Understand and analyze how you use our Services;
  • Develop new products, services, features, and functionality;
  • Communicate with you, either directly or through one of our partners or Publishers, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes;
  • Process your transactions;
  • Send you text messages and push notifications;
  • Find and prevent fraud; and
  • For compliance purposes, including enforcing our Terms of Service, Terms of Use, or other legal rights, or as may be required by applicable laws and regulations or as requested by any judicial process or governmental agency.

How We Share Information

We may share the information we collect in various ways, including the following:

  1. Vendors and Service Providers
    We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Services, for promotional and/or marketing purposes, and to provide you with information relevant to you, such as product announcements, software updates, special offers, or other information.
  2. Aggregate Information
    Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can’t reasonably be used to identify you.
  3. Third-Party Partners
    We also share information about users with third-party partners in order to receive additional publicly available information about you.
  4. Information We Share When You Sign Up Through a Referral
    If you sign up for our Services through a referral from a friend, we may share information with your referrer to let them know that you used their referral to sign up for our Services.
  5. Analytics
    We use analytics providers such as, but not limited to, Google Analytics. Google Analytics uses cookies to collect non-identifying information. Google provides some additional privacy options regarding its Analytics cookies at http://www.google.com/policies/privacy/partners/.
  6. Business Transfers
    Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information may be transferred to one or more third parties as one of our business assets.
  7. As Required By Law and Similar Disclosures
    We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service or our Terms of Use, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
  8. With Your Consent.
    We may share such information with your consent which is authorized by your use of our Services.

End Users

For End Users, we provide Publishers with limited access to the information we collect from your usage of our Services. The information we share may include, but is not limited to, internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL.

Legal Basis for Processing Personal Information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so. We have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information).

Third-party Services

You may access other third-party services through the Services, for example by clicking on links to those third-party services from within the Services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.

For End Users, we are not responsible for the privacy policies and/or practices of Publishers that utilize our Services. We strongly encourage you to carefully review their privacy policies.

Security

Simple Paywall is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please bear in mind that the Internet cannot be guaranteed to be 100% secure.

Data Retention

We retain information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process the information collected, we will either delete or anonymize it or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further processing until deletion or anonymization is possible.

Access

If you are a registered user, you may access certain information associated with your Account by logging into our Services or emailing privacy@simplepaywall.com. If you terminate your Account, any public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the Publishers and/or other parties listed in the “How We Share Information” section above.

To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit Simple Paywall’s ability to comply with a legal obligation; inhibit Simple Paywall’s ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of intellectual properties, including copyrights, patents or trade secrets or other proprietary business information belonging to Simple Paywall or a third party.

Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of the EEA, you have the following data protection rights:

  • If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by emailing privacy@simplepaywall.com.
  • In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by emailing privacy@simplepaywall.com.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing privacy@simplepaywall.com.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

For End Users, we are not responsible for the privacy policies or practices of Publishers that utilize our Services. We strongly encourage you to carefully review their privacy policies and contact them directly to exercise your data protection rights.

Your Choices

You can use some of the features of the Services without registering, thereby limiting the type of information that we collect.

You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.

Many browsers have an option for disabling cookies, which may prevent your browser from accepting new cookies or enable selective use of cookies. Please note that, if you choose not to accept cookies, some features and the personalization of our Services may no longer work for you and our Services may no longer be available to you.

Children’s Privacy

Simple Paywall does not knowingly collect information from children under the age of 13, and children under 13 are prohibited from using our Services. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can alert us at privacy@simplepaywall.com.

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at anytime, with or without notice, so please review it frequently. Changes to this Privacy Policy will be posted on our websites. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will notify you through our Services, by email, or other communication.

International Data Transfers

Simple Paywall is a global business. We may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.

Contact Us

If you have any questions or concerns about this Privacy Policy, please feel free to email us at privacy@simplepaywall.com.

The data controller of your personal information is Simple Paywall, LLC.