Last updated September 29th, 2018.
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”).
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.
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.
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.
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.
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.
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.
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.
We may also receive publicly available information about you from our third-party partners and combine it with data that we have about you.
We use the information we collect in various ways, including to:
We may share the information we collect in various ways, including the following:
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.
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).
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.
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.
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.
If you are a registered user, you may access certain information associated with your Account by logging into our Services or emailing firstname.lastname@example.org. 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.
If you are a resident of the EEA, you have the following data protection rights:
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.
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.
The data controller of your personal information is Simple Paywall, LLC.