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PRIVACY POLICY
Revised: July 9, 2017

This Privacy Policy describes the information thatRenovate Simply, Inc., d/b/a Contract Simply, and its affiliates (“Contract Simply,” “we,” “us” or “our”) may collect through your use of the Contract Simply payments platform, including the website at https://www.contractsimply.com/ and related mobile applications (collectively, the “Service”). It also describes how we may use, disclose and protect information collected through your access to and use of the Service.

For the purposes of this Privacy Policy: the words “such as,” “include,” “includes” and “including” shall be deemed to be followed by the words “without limitation;” and the word “or” is not exclusive.

1.                GENERAL

(a)              Consent. By accessing or using the Service, you consent to the collection, use, disclosure, storage and processing of your information in accordance with: (i) this Privacy Policy; (ii) any related terms of service, end user license agreement, or services agreement, including, but not limited to, the agreement between Contract Simply and the institution through which you obtain access to the Service (collectively, “Service Terms”); and (iii) and as permitted or required by applicable law.

(b)              International. The Service may be hosted or operated in countries other than the country in which you reside. Those countries may have different data protection laws and regulations from those that apply in your home country. By accessing or using the Service, you consent to the transfer, storage and processing of your information outside of your home country. Please be aware that the governments, courts, and law enforcement, security or regulatory agencies of a particular country may be able to obtain access to or disclosure of your information as permitted by the laws of that country.

2.                HOW WE COLLECT AND USE INFORMATION

(a)              Information That You Provide Directly. We may ask for certain information such as your name, company name, postal address, email address, billing contact, payment account information (e.g., bank, credit union or other financial institution account information), telephone number, password, and other information. We may retain any messages you send through the Service, and we may also retain other information you voluntarily provide to us. We use this information to operate, maintain and provide to you the features and functionality of the Service, and as further described below.

(b)              Information Collected or Received from Third Parties. We may receive information about you from third parties. You should always review and, if necessary, adjust your privacy settings on third-party services before linking or connecting them to the Service. We may also collect information about you from our third-party business associates, publicly-available sources and our affiliates.

(c)               Analytics information. We may collect, measure and analyze traffic and usage trends for the Service, and we may use third-party analytics tools to help us (“Analytics Tools”). This allows us to understand, among other things, who is using the Service, how they are using it, and ways to improve the Service. Analytics Tools may use cookies and persistent device identifiers to collect and store information such as time of visit, pages visited, time spent on each page, IP address, and type of operating system used.

(d)              Cookies. When you visit the Service, we may send one or more cookies (small text files containing a string of alphanumeric characters) to your device that uniquely identify your browser and enhance your navigation on the Service. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take), and allow us or our third-party business associates to track your usage of the Service. There are at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions for removal of cookies. A session cookie is temporary and is deleted after you close your browser. You can reset your web browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the Service may not function properly if cookies are disabled.

(e)              Log File. Log file information is automatically reported by your browser each time you access a web page. When you access or use the Service, our servers may automatically record certain log file information, such as your web request, internet protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, and pages viewed.

(f)               Clear GIFs/Web Beacons. Clear GIFs (also known as web beacons) allow for the tracking of a user’s response to an email or usage of a website in a manner that does not reveal personally identifiable information. We may use clear GIFs or similar technologies to assess responses to emails and usage of the Service. For example, we may use clear GIFs to track when emails are opened and which links are clicked by recipients. In some cases, you can disable the ability of clear GIFs to capture information by blocking cookies.

(g)              Device Identifiers. When you access or use the Service using a mobile device, we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device to enhance your navigation on the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

(h)              Advertising Identifiers. Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Advertising identifiers may be modified or disabled by users in the operating system’s settings.

(i)                Location Data. When you access or use the Service, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the Service. Some features of the site, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

(j)                Commercial Communications. We may use the information we collect or receive to communicate directly with you. For example, we may use the information to send you emails containing newsletters, promotions and special offers. We may also use the information to send you service-related notices (e.g., account verification, technical and security notices).

(k)              Use of Certain Service-Type Information. We may use information from cookies, log files, device identifiers, location data and clear GIFs to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (ii) provide custom, personalized content or information; (iii) monitor the effectiveness of the Service; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.

(l)                Authentication and Fraud Detection. We may collect information about you and your interactions with the Service to help protect you from fraud and misuse of your personal information. We may also evaluate your computer, mobile device or other access device to identify any malicious software or activity.

(m)            Use of Information with Your Consent. We may use your information for any other purpose for which you provide consent.

(n)              Combining Information. We may combine any of the information we collect from or about you, from one or multiple sources, and use it in the manner described in this Privacy Policy.

(o)              Other Uses. In addition to other uses disclosed in this Privacy Policy, we may use your information to: (i) provide the Service and customer support; (ii) process transactions and send notices about your transactions; (iii) activate and maintain your account; (iv) verify your identity, including during account creation and password reset processes; (v) resolve disputes, collect fees, and troubleshoot problems; (vi) manage risk and detect, prevent or remediate fraud or other potentially prohibited or illegal activities; (vii) detect, prevent or remediate violations of policies or applicable agreements;  (viii) improve the Service by customizing your user experience; (ix) measure the performance of the Service and improve its content, layout and features; (x) manage and protect our information technology infrastructure; (xi) provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences; (xii) contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging; and (xiii) perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties.

3.                HOW WE MAY SHARE YOUR INFORMATION

(a)              Business Associates and Service Providers. We may share information about you with third-party business associates and service providers that perform services on our behalf in connection with the Service. We may also share information about you with any of our affiliates for purposes consistent with this Privacy Policy.

(b)              Business Change. If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information to a third party or parties in connection with such transaction or change in ownership, including any related due diligence activities.

(c)               Necessary Disclosure. Regardless of the choices you make regarding your information and to the extent permitted or required by applicable law, we may disclose information about you to third parties to: (i) enforce or apply this Privacy Policy or the Service Terms; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect our rights, reputation, safety or property, or that of our users or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; our rights, reputation, safety or property, or those of our users or others; violation of the Service Terms; or as otherwise required by law.

(d)              Sharing Information. We may share certain service-type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear GIFs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks) with our third-party business associates for the purposes described in the section titled “How We Collect and Use Information.” We may also aggregate or otherwise remove personally identifying characteristics from data and share that aggregated, anonymized data with third parties.

4.                HOW WE PROTECT YOUR INFORMATION

We take physical, technological and administrative measures to protect the information you provide through the Service against loss, theft, and unauthorized access, use, disclosure or modification. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Service will not be accessed, disclosed, altered or destroyed. Communications sent to or from the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email.

5.                YOUR CHOICES ABOUT YOUR INFORMATION

(a)              Controlling Your Settings. You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from us by following the unsubscribe instructions in those emails. Note that unsubscribe is not available for certain emails concerning your relationship or dealings with us.

(b)              Do Not Track. At this time, we do not recognize “do not track” signals sent from web browsers. Third-party services that we use may collect personal information about individual users and their activities over time and across different websites. In some cases, you may be able to disable tracking mechanisms, but doing so may disable certain features of the Service. To disable tracking, please consult the documentation for your browser, operating system or mobile device. For some devices, it may not be possible to disable tracking mechanisms.

6.                HOW LONG WE KEEP YOUR INFORMATION

We will retain your information as long as necessary for the purposes outlined in this Privacy Policy, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection, or audit purposes, or as otherwise required by law.

7.                CHILDREN'S PRIVACY

The Service is not directed to children and is intended for use by adults only. We do not knowingly collect personal information from individuals under 13 years of age. If you are under the age of 13, please do not submit any personal information through the Service.

8.                THIRD-PARTY SERVICES AND SERVICES

The Service may reference or provide links to other websites or resources. If you access any website or resources provided by a third party, our Privacy Policy will not apply. Your interactions with such websites and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information.

9.                YOUR CALIFORNIA PRIVACY RIGHTS

Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to privacy@contractsimply.comwith "Request for California Privacy Information" in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide to you via email a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately-preceding calendar year, along with the third parties' names and addresses. Please note that not all personal information sharing is covered by Section 1798.83's requirements.

10.             UPDATES TO THIS PRIVACY POLICY

We may update this policy from time to time, and the updated version of this policy will be effective upon posting. Please check this page to review the most up-to-date version of this policy. By continuing to use the Service after an updated version has been posted, you agree that the new policy will apply to you.