Effective date: February 13, 2024
This Simple ® U.S. State Privacy Supplement (“U.S. State Privacy Supplement”) is only applicable to residents of Colorado, Connecticut, and Virginia (“you”). From July 01, 2024, this U.S. State Privacy Supplement shall be also applicable to the residents of Texas and Oregon (from July 01, 2024, shall be also referred to as “you”). It supplements the information contained in our Simple Privacy Policy. It is delivered on behalf of Simple.Life Apps Inc. (“Simple,” “we,” “us,” and “our”) and governs certain personal data we collect from you.
We have adopted this U.S. State Privacy Supplement to comply with the following legislation:
Please take the time to read and understand this U.S. State Privacy Supplement.
Scope
This U.S. State Privacy Supplement covers personal data collected from or processed about you when you use our website simple.life and its related pages and our mobile application “Simple ®: Intermittent Fasting” (“Simple”, the “app”, or the “application”), including by downloading, installing, registering with, accessing or otherwise using the application (collectively referred to herein as “Use”).
There is other personal data that this U.S. State Privacy Supplement does not cover. In some cases, that personal data may not be subject to the Relevant State Privacy Laws. In other cases, a different privacy notice may apply. Accordingly, this U.S. State Privacy Supplement and/or the privacy rights set out herein may not apply to you or to all of your personal data.
If you are a resident of California, please see our Simple California Notice at Collection and Privacy Notice.
Collection, Processing and Disclosure of Personal Data
The Relevant State Privacy Laws require us to give you information about the categories of personal data we collect and process about you, the purposes for which we collect and process it and the categories of third parties and other entities to whom we disclose it. The table below sets out our relevant practices. Our collection, processing and disclosure of personal data depends on your relationship with us and your interaction with us.
| Category of Personal Data | Categories of Sources From Which Collected | Business or Commercial Purpose for Processing Personal Data | Categories of Third Parties and Other Entities To Whom We May Disclose |
| Identifiers, such as name, unique personal identifier, online identifier, IP address, email address, or account name | Directly from you or automatically when you Use SimpleVia vendors on which we rely | To present to you and others with Simple and its contents and any other information, products or services that you request from us.To provide you with Avo chatbot.To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Simple.To customize our product and service offerings to you, for example, offering pricing personalization and discounts.To communicate with you, such as to notify you about changes to Simple or any products or services we offer or provide through Simple, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiriesTo conduct research, analytics and monitor performance and other metrics regarding Simple and your Use of Simple.To improve, test, and monitor the effectiveness of Simple.To provide personalized content and information to you in relation to Simple and so that we, and third parties on which we rely, can advertise to you.To send marketing and promotional communications to youIn any other way as we may describe when you provide the information or otherwise at your direction or with your consent.As permitted or required by law, including for auditing, fraud and security monitoring purposes. | With our Affiliates.To third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing Simple.To third-party analytics providers and advertising partnersTo affiliated and nonaffiliated entities in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved. In response to legal requests and for purposes of preventing harm. |
| Characteristics of Protected Classifications, such as your sex, age and health information | Directly from you or automatically when you Use Simple | To present to you and others with Simple and its contents and any other information, products or services that you request from us.To provide you with Avo chatbot (upon your consent).As permitted or required by law, including for auditing, fraud and security monitoring purposes. | With our Affiliates.To third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing Simple.To affiliated and nonaffiliated entities in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved.In response to legal requests and for purposes of preventing harm. |
| Commercial information, such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories of tendencies | Directly from you or automatically when you Use Simple | To present to you and others with Simple and its contents and any other information, products or services that you request from us.To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to SimpleTo customize our product and service offerings to you, for example, offering pricing personalization and discounts.To communicate with you, such as to notify you about changes to Simple or any products or services we offer or provide through Simple, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiriesTo conduct research, analytics and monitor performance and other metrics regarding Simple and your Use of Simple. To improve, test, and monitor the effectiveness of Simple.To provide personalized content and information to you in relation to Simple and so that we, and third parties on which we rely, can advertise to you.To send marketing and promotional communications to youIn any other way as we may describe when you provide the information or otherwise at your direction or with your consent.As permitted or required by law, including for auditing, fraud and security monitoring purposes. | With our Affiliates.To third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing Simple.To third-party analytics providers and advertising partners To affiliated and nonaffiliated entities in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved.In response to legal requests and for purposes of preventing harm. |
| Internet or other electronic network activity information, such as browsing history, search history or information regarding interaction with an app or advertisement | Directly from you or automatically when you Use Simple Via vendors on which we rely | To present to you and others with Simple and its contents and any other information, products or services that you request from us.To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Simple To customize our product and service offerings to you, for example, offering pricing personalization and discounts.To communicate with you, such as to notify you about changes to Simple or any products or services we offer or provide through Simple, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiriesTo conduct research, analytics and monitor performance and other metrics regarding Simple and your Use of Simple. To improve, test, and monitor the effectiveness of Simple.To provide personalized content and information to you in relation to Simple and so that we, and third parties on which we rely, can advertise to you.To send marketing and promotional communications to youIn any other way as we may describe when you provide the information or otherwise at your direction or with your consent.As permitted or required by law, including for auditing, fraud and security monitoring purposes. | With our Affiliates.To third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing Simple.To third-party analytics providers and advertising partners To affiliated and nonaffiliated entities in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved.In response to legal requests and for purposes of preventing harm. |
| Geolocation data, such as the state or country associated with your IP address | Directly from you or automatically when you Use Simple | To present to you and others with Simple and its contents and any other information, products or services that you request from us.To provide you with Avo chatbot.To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to SimpleTo customize our product and service offerings to you, for example, offering pricing personalization and discounts. To communicate with you, such as to notify you about changes to Simple or any products or services we offer or provide through Simple, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiriesTo conduct research, analytics and monitor performance and other metrics regarding Simple and your Use of Simple.To improve, test, and monitor the effectiveness of Simple. To provide personalized content and information to you in relation to Simple and so that we, and third parties on which we rely, can advertise to you.To send marketing and promotional communications to youIn any other way as we may describe when you provide the information or otherwise at your direction or with your consent.As permitted or required by law, including for auditing, fraud and security monitoring purposes. | With our Affiliates.To third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing Simple.To third-party analytics providers and advertising partners To affiliated and nonaffiliated entities in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved.In response to legal requests and for purposes of preventing harm. |
| Audio, electronic, visual, thermal, olfactory or similar information, such as your photos | Directly from you | To present to you and others with Simple and its contents and any other information, products or services that you request from us.To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to SimpleTo customize our product and service offerings to you, for example, offering pricing personalization and discounts.To communicate with you, such as to notify you about changes to Simple or any products or services we offer or provide through Simple, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiriesTo conduct research, analytics and monitor performance and other metrics regarding Simple and your Use of Simple. To improve, test, and monitor the effectiveness of Simple.To provide personalized content and information to you in relation to Simple and so that we, and third parties on which we rely, can advertise to you.To send marketing and promotional communications to youIn any other way as we may describe when you provide the information or otherwise at your direction or with your consent.As permitted or required by law, including for auditing, fraud and security monitoring purposes. | With our Affiliates.To third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing Simple.To affiliated and nonaffiliated entities in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved.In response to legal requests and for purposes of preventing harm. |
| Inferences drawn from the information listed above to create a profile about a Colorado, Connecticut or Virginia resident reflecting their preferences, characteristics and other attributes | Directly from you or automatically when you Use Simple | To present to you and others with Simple and its contents and any other information, products or services that you request from us.To provide you with Avo chatbot.To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to SimpleTo customize our product and service offerings to you, for example, offering pricing personalization and discounts. To communicate with you, such as to notify you about changes to Simple or any products or services we offer or provide through Simple, provide you with customer or technical support, and monitor and improve our responses to your and other users’ inquiriesTo conduct research, analytics and monitor performance and other metrics regarding Simple and your Use of Simple.To improve, test, and monitor the effectiveness of Simple. To provide personalized content and information to you in relation to Simple and so that we, and third parties on which we rely, can advertise to you.To send marketing and promotional communications to youIn any other way as we may describe when you provide the information or otherwise at your direction or with your consent.As permitted or required by law, including for auditing, fraud and security monitoring purposes. | With our Affiliates.To third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing Simple.To third-party analytics providers and advertising partners To affiliated and nonaffiliated entities in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved.In response to legal requests and for purposes of preventing harm. |
| Information that may be sensitive personal data, such as health status | Directly from you or automatically when you Use Simple | To present to you and others with Simple and its contents and any other information, products or services that you request from us.To provide you with Avo chatbot.To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to SimpleIn any other way as we may describe when you provide the information or otherwise at your direction or with your consent.As permitted or required by law, including for auditing, fraud and security monitoring purposes. | With our Affiliates.To third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business and who assist us in providing Simple.To affiliated and nonaffiliated entities in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved.In response to legal requests and for purposes of preventing harm. |
Data Retention: Other than as set forth in Section 2: Personal Data Retention of the Simple Privacy Policy, we generally retain your personal data (also referred to in the Simple Privacy Policy as Personal Data) until you delete your Simple account.
To make a request to delete your Simple account, please contact us at [email protected].
Notwithstanding the foregoing, please note that we may retain your personal data for longer periods of time than set forth above, such as in connection with your privacy-related requests and communications with us, if any, as necessary to comply with our legal obligations, to resolve disputes, or to enforce our agreements. Even if we delete some or all of your personal data, we may continue to retain and use anonymized data previously collected that can no longer be used for personal identification.
Targeted Advertising
We may share the following categories personal data with third-party ad-tech providers and others throughout the online advertising ecosystem for purposes of targeted advertising:
Your Privacy Rights
As a resident of Colorado, Connecticut, Virginia, Texas, or Oregon you may have certain rights in relation to your personal data.
Right to Confirm or Access Personal Data
You may have the right to confirm whether we process your personal data and to access such personal data.
Right to Delete Personal Data
You may have the right to request that we delete your personal data that we have collected or received about you. Subject to certain exceptions, we must delete your personal data.
Right to Correct Inaccurate Personal Data
You may have the right to request that we correct inaccurate personal data about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
Right to Opt-Out of Sales of Personal Data
You may have the right to opt-out of the sale of your personal data. We do not sell your personal data for purposes of the Relevant State Privacy Laws.
Right to Opt-Out of Targeted Advertising
You may have the right to opt-out of us processing your personal data for purposes of targeted advertising.
Right to Opt-Out of Profiling
You may have the right to opt-out of the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Obtain a Copy of Your Personal Data
You may have the right to obtain a copy of your personal data that you previously provided to us.
Right to Non-Discrimination
You have the right not to be discriminated against by us for choosing to exercise your privacy rights.
How to Exercise Your Privacy Rights
If you wish to exercise your right to confirm, access specific pieces of personal data we have about you, delete or correct inaccuracies in your personal data, or opt-out of profiling (where relevant), or to obtain a copy of your personal data, please submit a request to us by contacting us at [email protected].
To opt-out of sharing of your personal data for cross-context behavioral advertising purposes, please submit a request to us by contacting us at [email protected].
Information for Authorized Agents
You may be permitted to authorize a person (“Authorized Agent”) to exercise your privacy rights on your behalf. To submit a request to Simple on behalf of another person as an Authorized Agent, please submit a request to us by contacting us at [email protected].
Authenticating Your Requests
We only comply with requests when we can authenticate that you are a resident of Colorado, Connecticut, Virginia, Texas, or Oregon exercising your rights regarding your personal data.
We may need additional information to authenticate your request. We may need additional information about you that we do not already have to be able to authenticate your request. If you provide us with new personal data that we do not already have about you, we will use it solely for the purpose of authenticating your request. We will let you know via email if we need more information from you to authenticate your request. Please reply to our requests promptly.
We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.
If we cannot authenticate your identity, we will let you know.
Responding To Your Requests
We aim to promptly authenticate and respond to your requests within 45 days of receipt but may require a total of up to 90 days to respond to your requests. If we require additional time beyond the initial 45 days after we receive your request, we will let you know within the first 45 days.
We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).
If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision. You can submit a request to appeal a prior decision by contacting us at [email protected].
We will respond to your requests via email. We will contact you at the email address you provided when submitting your request(s).
Limitations
The Relevant State Privacy Laws do not apply in full to all personal data we collected from you. Therefore, even if you are a resident of Colorado, Connecticut or Virginia and submit an authenticated request, we may not be required to comply with your request.
Information provided in response to a consumer request shall be provided free of charge, up to twice annually per consumer. If requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.
Changes to the U.S. State Privacy Supplement
From time to time, Simple may update or revise this U.S. State Privacy Supplement. If there are changes to the terms of this U.S. State Privacy Supplement, documents containing the revised policy will be updated.
How to Contact UsIf you have any questions or concerns about this U.S. State Privacy Supplement, please contact us at [email protected].