Pronto Holdings LTD (d/b/a Simplesat) and its affiliates and subsidiaries (collectively, “Simplesat,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Privacy Policy”) to describe to you our practices regarding the personal information that Simplesat collects, uses, and shares in connection with the “Site”), our surveys, our marketing communications, and our other products and services (together simplesat.io and any other websites operated by Simplesat that link to this Privacy Policy (collectively, with the Site, the “Service”). 

Simplesat reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy. Your continued use of the Service following posting of changes constitutes your acceptance of such changes.

  1. COLLECTION OF PERSONAL INFORMATION
    1. Personal information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
      • Contact details, such as your first and last name, email and mailing addresses, residence, postal code, and phone number.
      • Business data, such as the company you work for, company description and job title.
      • Profile data, such as your username and password that you set to establish an online account with us.
      • Survey data and feedback, such as the ratings, comments, support requests, and other feedback you provide in connection with the Service.
      • Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
      • Payment and transactional data, such as the information needed to complete your orders and registrations on or through the Service (including payment preferences, and billing and shipping information), and information about services you have purchased from us.
      • Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communications.
      • Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
    2. Personal information from third party platforms. If you use the Service to connect with a third party platform through one of our integrations, we may collect information about you including any information or contacts that you choose to import to the Service.
    3. Personal information collected automatically. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our Service and other sites and online services, such as:
      • Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, precise geolocation, general location information such as city, state or geographic area, and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
      • Usage data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
    4. Cookies and similar technologies. Like many online services, we use cookies and similar technologies to facilitate our automatic data collection. For more information, see our Cookie Policy.
    5. Personal information about others. Users of the Service may have the opportunity to refer colleagues or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

  2. USE OF PERSONAL INFORMATION

Simplesat may use your personal information for the following purposes or as described in this Privacy Policy or at the time of collection:

  • To Provide Our Products and Services. This could include fulfilling your requests for products or services and operating the Service. For example, we may use your personal information to provide you with the content, features, products and services that you request; establish, maintain, and monitor your account on the Service; process your transactions; display your content or share your information with our integration partners or other users; understand your interests, personalize your experience on the Service, and deliver information about products and services relevant to your interests; respond to your inquiries and requests for customer support, including to investigate and address your concerns and monitor and improve our responses.
  • For Marketing and Advertising. We and our service providers and business partners may use your personal information to provide you with information about products, services, or promotions that may be of interest to you on the Service or other sites or services. For example, we may use cookies or other online tracking technologies to provide customized advertisements, content, and information; monitor and analyze the effectiveness of marketing activities; and track your entries, submissions, and status in any promotions. These might be third party offers we think you might find interesting. These communications may come in the form of interest-based advertising using information gathered across multiple websites, devices, or other platforms. For more information, see our Cookie Policy.
  • Research and Development. We use personal information to understand and analyze the usage trends and preferences of our users to make our Service and other products and services better and to develop new features and functionality. For example, we may use cookies or other online tracking technologies to analyze web traffic and monitor usage. For more information, see our Cookie Policy.
  • To Create Anonymous Data. We may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
  • To Communicate with You. We may use your personal information to communicate with you about the Service (including by sending announcements, updates, security alerts, and support and administrative messages). 
  • To Process Your Transactions. We may use your personal information to process payments by credit card, bank transfer, or other means. We work with the third-party payment processor Stripe for these purposes, who will receive personal information in order to process transactions. 
  • To Comply with Laws and Regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
  • For Compliance, Fraud Prevention, Safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Service, products and services, business, databases and other technology assets; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Service; and (e) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  • With Your Consent. In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

  1. SHARING OF PERSONAL INFORMATION

    In addition to the specific situations discussed elsewhere in this Privacy Policy, Simplesat may share your personal information in the following circumstances: 

    1. Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or are otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
    2. Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.
    3. Legal Compliance and Professional Advisors. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service. We may also disclose personal information to our professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
    4. Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Platform. Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy.
    5. Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Service so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Service, or on other websites. Our advertising partners may also use hashed customer lists that we share with them to deliver ads to you and similar users on their platforms.
    6. Business partners. We may jointly offer events, promotions, or any other product or service offerings with third party partners or our clients, which may be your employer. The personal information that you submit through an event, promotion, or other product or service offering may be combined and transmitted with other personal information about you. Third party partners or clients may collect information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a third-party partner or client, the information that you provide may be shared with us and with that identified third party.
    7. Public Forum and Messaging. The Service may provide you with the opportunity to post comments, messages, or reviews in a public forum. If you decide to submit personal information at these locations, that information will be available to the public or other users of the Service.

  1. SECURITY OF PERSONAL INFORMATION

    No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. 

  1. YOUR CHOICES

    You can make the following choices regarding your personal information:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Correct. Update or correct inaccuracies in your personal information.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our lawful basis as the basis of our processing of your personal information that impacts your rights.
  • Delete. Delete your personal information.

If you would like to exercise any of these rights, please submit your request to the address listed in the section titled “CONTACTING US” below. When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.

Please note, we may need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.

  1. OPTING OUT

    You can make the following choices to opt out of certain activities regarding your personal information:

    1. Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our products and services, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your account, to fulfill orders for products and service you have requested, or deliver notifications directly to you through the Service.
    2. Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Removing or disabling cookies might adversely impact your ability to use our Site effectively. Enabling cookies ensures a smoother experience when you use our Site. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also view our Cookie Policy for additional information and choices related to the technologies we use.
    3. Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Service, or on other websites. If you wish to limit third parties’ collection of information about your use of our Platform, you can opt-out of such at the Digital Advertising Alliance or Network Advertising Initiative in the U.S., the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE SERVICE. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
      Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. See our Cookie Policy for more information. You can also limit collection of your information for behavioral advertising by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for behavioral advertising purposes.
    4. Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

  1. OTHER SITES AND SERVICES

    The Service may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use. 

  1. NOTICE TO EUROPEAN USERS 

    The information provided in this “Notice to European Users” section applies only to individuals in the European Union, the European Economic Area or the United Kingdom (collectively, “Europe”).

      1. Personal Information. Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
      2. Lawful basis for processing. Simplesat is required to inform you of the lawful basis of our processing of your personal information, which are described in the table below. If you have questions about the lawful basis of how we process your personal information, contact us at the address listed in the section titled “CONTACTING US” below. 
    Processing Purpose (see the “USE OF PERSONAL INFORMATION” section above for details about each processing purpose) Lawful Basis
    • To Provide Our Products and Services.
    • To Communicate with You. 
    • To Process Your Transactions. 
    • To Process Your Payment for Products and Services.  
    Processing is necessary for the performance of a contract. Processing is necessary to perform the contract with us governing our operation of the Sites or the provision of the Service, or to take steps that you request prior to engaging our services. Where we cannot process your personal data as required to operate the Service on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.
    • To Comply with Laws and Regulations. Processing is necessary to comply with our legal obligations.
    • Research and Development.
    • To Create Anonymous Data.
    • For Compliance, Fraud Prevention, and Safety.
     
    Processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you.
    • With Your Consent.  Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Service.
    • For Marketing and Advertising.  Processing is based on your consent where that consent is required by applicable law.Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business, and showing you tailored relevant content.

    We will use your personal information only for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. 

    PLEASE NOTE WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.

    1. Retention. Simplesat retains your personal information: 
      • For so long as your account is active or as needed to provide you with the Service or to fulfill our contractual obligations;
      • As necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; and
      • For so long as is necessary for the purposes for which we collected such personal information.
    2. Your Rights. European data protection laws give you certain rights regarding your personal information, which are explained in the “YOUR CHOICES” section above. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here
    3. Transfer Mechanisms. If we transfer your personal information out of Europe to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at [email protected] for further information about any such transfers or the specific safeguards applied.

  1. CONTACTING US

If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at:

Pronto Holdings LTD (d/b/a Simplesat)
Attn: Simplesat Privacy Agent
[email protected] 

Last Updated: September 22, 2020

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