Last updated 6/4/2020
2. From and about whom do we collect Data?
We collect Data from and about the following:
3. How and What Data Do We Collect About You?
We collect data about you directly from you, from other persons, and automatically as you use our Sites and Services.
Information that We Collect Directly From You: We collect information, including personal information, from you when you take the following actions. The type of personal information that we collect from you varies based on your interaction with our Sites and Services.
The type of information that we collect from you includes:
Information We Collect from Other Sources:
We use this data predominantly to determine which portions of our Sites are most useful to visitors and to improve our Sites and our Services. We also may share this data in the aggregate to insurers and advertisers for advertising purposes. Where permitted by applicable law, we may combine this data with data submitted along with your inquiry data; we may share this data with insurers to help them improve their products and services. Please also see “Tracking Tools” below for additional information.
4. How Do We Use The Information That We Collect About You?
We may use your information for one or more of the following business purposes:
We may also use de-identified, anonymized or aggregated Data, including customer information, to provide potential insurers with a general profile of people using our Sites, and to analyze the effectiveness of our Services to customers.
5. How do we share the Data we collect?
Simply Business may disclose Your Data, including personal information, to another entity for a business purpose, or sell Your Data, including personal information, subject to Your right to opt-out of the sale of Your personal information if You are a California Resident (see Your California Privacy Rights).
6. Tracking Technology
We, and certain service providers who analyze the activity of visitors to our Sites on our behalf (“Analytics Vendors”) and advertising providers, may use ‘IP Addresses’, ‘cookies,’ ‘web beacons’, ‘pixel tags,’ and other tracking technologies (described in more detail below) in the Sites and Services, or in our communications with You (“Tracking Technologies”). These Tracking Technologies allows us and the Analytics Vendors and advertising providers to have access to some Data and analysis about You which helps to:
IP Address and Clickstream Data
Our servers may collect Data about the computer or other device you use to access or use the Sites or Services. This Data may include the Internet address of the computer or other device you use when you access or use the Sites or Services. Your computer’s Internet Protocol address, or IP Address, is a number that is automatically assigned to your computer by your Internet Service Provider (“ISP”) whenever you connect your computer to the Internet. When you operate your device to request and receive webpages or other content from our Sites or Services, our servers may log your IP Address. We may also log your domain name, which is a textual identifier for your computer that also may have been assigned by your ISP. We use your IP Address and domain name to help identify you and to gather demographic information about our customers as a whole. We may also record the referring webpage that linked you to us (e.g., of another website or a search engine); the webpages or other content you view on the Sites; the website or webpage you visit after the Sites; the ads you see on the Sites and/or click on; other Data about the type of web browser, computer, platform, related software and settings you are using when accessing and/or using the Sites or the Services; any search terms you have entered on any Site or a referral site; and other web usage activity and data logged by our web servers. We use this Data for internal system administration, to help diagnose problems with our server, and to administer the Sites and the Services. Such information may also be used to gather demographic information, such as country of origin and ISP. We do not typically associate this information with you.
For the avoidance of doubt, some service providers (including Analytics Vendors) may place cookies on your computer or mobile device. If you would like to disable these "third party" cookies, you may be able to turn them off by going to the third party's website.
We may use web bugs (aka “web beacons” or “pixel tags”) or similar technologies in the Sites, Services, and/or in communications with You to enable us to evaluate the Sites and Services usage information about users, upgrade user information, and know whether You have visited a webpage or received a message. A “web bug” is typically a one-by-one pixel, transparent image (although it can be a visible image as well), located on a webpage or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a webpage or e-mail message. A web bug may enable us to relate your viewing or receipt of a webpage or other message to other information about You, including your personal information.
“Do Not Track”
Some third parties have ways (e.g. Browser do-not-track signals) for users to control how online services collect their information. We do not take any action based on these signals.
We may disclose certain information (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audience go here or to opt-out, go to the Facebook ad preferences page)—so that we can better target ads and content to you and others with similar interests on third parties’ websites or media (“Custom Audiences”). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other third parties display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.
Users may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.
7. Third party content and sites
The Sites and Services may contain content that is supplied by a third party, and those third parties may collect information when pages from the Sites and Services are served to you. They may collect information about your online activities across third party websites. In addition, when you are on the Site you may be directed to other sites that are operated and controlled by parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these parties or their sites. We encourage you to note when you leave our Sites and to review the privacy policies of the different websites you visit.
8. Changing information and communication preferences
You are responsible for maintaining the accuracy of the information you submit to us. The Sites may allow you to review, correct or update Data you have provided through the Site’s forms or otherwise, and you also may provide changes by contacting us. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete your Data from our databases and that we may maintain recorded Data on backup media or for other reasons. When you edit your Data or change your preferences on the Sites, information that you remove may persist internally for Simply Business’s administrative purposes.
At the point of submitting your personal details, we collect Your email address to enable insurance organizations to contact you. Additionally, this allows Simply Business’s customer service team to get in touch if any more information is needed. You may opt-out of future marketing communications by contacting us at [email protected] or using the opt-out details set out in one of our marketing emails.
9. Children and COPPA
The Sites and Services are not geared towards children, and use of all of the Sites and all of the Services is limited to legally-competent adults aged 18 and older. Simply Business does not knowingly solicit, collect or maintain any information from children under the age of 13. If you believe that your child under 13 has gained access to the Sites or Services without your authorization and without our permission, please contact us at [email protected].
We use commercially reasonable safeguards to help protect and secure your personal information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can guarantee to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Sites and provide us with your information at your own risk.
12. Contacting Simply Business
Simply Business, Inc. 1 Beacon Street 15th Floor Boston, MA 02108
13. Additional Information for California Residents
Simply Business provides insurance to business customers. We primarily use the information that we collect from and about you for the purpose of providing our insurance services to you; therefore, with the exception of the do not sell and nondiscrimination rights, to the extent that we use your information the course of providing services to you, the rights below do not apply. Nonetheless, we set forth the rights that may apply if we use business contact information outside of the relationship (e.g., if we obtain a list of prospective customers and before we have a relationship with you). If you are a California resident, the California Consumer Protection Act (CCPA) may provide you with additional rights, under certain circumstances, regarding our use of your personal information. This section describes these rights and how to exercise them.
Right to Obtain a Copy of Your Personal Information
California residents have the right to request that Simply Business disclose the specific pieces of information that we collected about you during the past twelve months. You also have the right to information about the following information from the past twelve months.
Deletion Request Rights
California residents have the right to request that Simply Business delete any of your personal information that we collected from You and retained, subject to certain exceptions. Once we receive and confirm Your verifiable consumer request, we will delete or deidentify or aggregate (and direct our service providers to do the same) Your personal information from our records, unless an exception applies.
Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, California residents may submit a verifiable consumer request to us by:
Only you or an authorized agent may make a verifiable consumer request related to your personal information. If you are an agent, you must submit a notarized statement from the resident authorizing you to act as that resident’s agent. We may contact the resident to verify the agency relationship.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information that we collected if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell You why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
You have the right to opt out of the sale of your personal information. As described above, we only share your information upon your request or in connection with targeted advertising, which may be deemed a sale given the breadth of the definition of “sale” under the CCPA.
To exercise the right to opt-out, you (or Your authorized representative) may submit a request to us by:
We allow entities to place cookies on our Sites and Apps to collect information about your interaction with such Sites. This collection of information may be a “sale” under the broad definition of “sale” as defined under the CCPA; to opt out of this sharing please visit: www.optout.aboutads.info and www.optout.networkadvertising.org.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change Your mind and opt back in to personal information sales at any time by:
We will not discriminate against You for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
|Categories of personal information||Do we collect?||Do we disclose for a business purpose(s)||Do we sell?*|
|Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or similar information.||Yes||Yes||Yes*|
|Customer Records: Paper and electronic customer records containing personal information, such as name, products purchased, payment method.||Yes||Yes||No|
|Purchase History and Tendencies: Commercial information including products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.||Yes||Yes||Yes*|
|Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding interaction with our Sites or advertisement, including access logs and other activity information related to the use of our Services.||Yes||Yes||Yes*|
|Geolocation Data: We collect data about your location through our analytics providers and with your consent as described above.||Yes||Yes||No|
|Audio, Video and other Electronic Data: We record calls if you contact our customer service center. We also record your image via CCTV for security purposes if you visit our offices.||Yes||No||No|
|Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences and purchase tendencies, which may be used for targeted advertising.||Yes||Yes||Yes*|
*Harborway Insurance policies are underwritten by Spinnaker Insurance Company and reinsured by Munich Re, an A+ (Superior) rated reinsurance carrier by A.M. Best. Harborway Insurance is a trade name of Simply Business, Inc., which is a licensed insurance producer in all 50 states and the District of Columbia.