SimpleDirect Privacy Policy

Last Updated 09/01/2020

This Privacy Policy applies to your access and use of all SimpleDirect products and services (together, the “SimpleDirect Services” or “Services”), that are made available through our websites including but not limited to www.getsimpledirect.com, www.simpledirectapp.com, www.getccino.com, and www.simpledirectpro.com, as well as through certain downloadable mobile applications (collectively, the “Site”).

This Privacy Policy describes the information that we gather from you, how we use and disclose your information, and the steps we take to protect your information. By using the Services, you consent to the privacy practices described in this policy.

This Privacy Policy is incorporated into and is subject to the SimpleDirect Terms of Use. Capitalized terms that are not defined in the Privacy Policy have the meaning given to them in the SimpleDirect Terms of Use.

The Information That We Collect:

• Personal Information When you use the Services, you may provide and we may collect information about you or that can be used to identify you, including your name, e-mail address, mailing address, mobile phone number, age, gender, date of birth (“Personal Information”). For example, you may provide us with Personal Information when you register for a SimpleDirect account, when you fill out forms or fields on the Site, when you participate in online surveys, and when you contact us or request information about us, this Site and our Service (whether by email or other means).
• Sensitive Financial Information When you use the Services, you may provide and we may collect certain additional sensitive information including your social security number, financial information, financial account information and other similar types of information (“Sensitive Information”). In addition:
• When you use certain Services, you may be asked to fill in and submit a form that collects your personal financial information, including but not limited to your current income level, current expenses, investable assets;
• When you use certain of the Services (such as the Loan Prequalified Offers service), you authorize SimpleDirect to send your information to certain third party partners on your behalf and you authorize these partners to obtain consumer reports and related information about you from one or more consumer reporting agencies.
• Cookies Information When you use the Services, we may send one or more Cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device. We may use both Session Cookies and Persistent Cookies. A Session Cookie disappears after you close your browser. A Persistent Cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent Cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your Cookie settings. If you delete, or choose not to accept, Cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.
• Automatically Collected Information When you visit the Site, use the Services, or open an email from SimpleDirect, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including your IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Services. When you use the Site on a mobile device, we may also collect the physical location of your device by, for example, using satellite, cell phone tower or wireless local area network signals.
• Third Party Web Beacons and Third Party Buttons We may implement third party advertising or other content on the Site that may use clear gifs or other forms of web beacons, which allow the third party content provider to read and write Cookies to your web browser in connection with your viewing of the third party content on the Site. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow a third party to collect information about you through their browser Cookies, even when you do not interact with the button. Information collected through web beacons and buttons is collected directly by third parties, and SimpleDirect does not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
• Other Sources We may also obtain information about you from third party sources, such as our partners or advertisers. We may also, at your direction, receive information from third party services that provide a mechanism to share information you have provided to the third party through the use of an application program interface (API), such as Facebook Connect or the Twitter API. If we combine or associate information from other sources with your information that we collect through the Services, we will treat the combined information in accordance with this Privacy Policy, the Terms, and applicable law.

How We Use the Information We Collect: Your information is an integral part of our operations, and we use it in a variety of ways in providing the Services and operating our business. For example:

• We use the information that you provide to operate, maintain, enhance and provide all of the features of the Services and to enable third parties to provide additional services to you
• We use the information that you provide to understand and analyze the usages trends and preferences of our users, to improve the Services, to create new features and functionality, and to improve fraud detection and information security.
• We may use your e-mail address or other Personal Information (a) to contact you for administrative purposes such as customer service, (b) to address intellectual property, right of privacy or defamation issues related to content you have posted on the Services, and/or (c) to send you promotional materials, offers, and/or messages related to the Services and the activities of third parties we work with. Generally, you can opt-out of receiving promotional communications, through links provided in the messages, or by updating your account preferences through the Services.
• We may use Cookies Information and Automatically Collected Information to: (a) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Services; (b) provide customized advertisements, content, and information; (c) monitor and analyze the effectiveness of Services and third party marketing activities; (d) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (e) track your entries, submissions, and status in any promotions or other activities.

When We Disclose Information: We disclose your information in connection with providing the Services and the operation of our business. For example: