u s state privacy supplement
U.S. State Privacy Supplement
This Simple Move U.S. State Privacy Supplement (“U.S. State Privacy Supplement”) is only applicable to residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia (“you”). It supplements the information contained in our Simple Move Privacy Policy. It is delivered on behalf of Simple.Life Apps Inc., a Delaware corporation with registration no. 7688095 and registered address at 8 The Green, Ste A, Dover, County of Kent, DE 19901, USA (“Simple Move”, “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:
- Colorado Privacy Act (“CPA”),
- Connecticut Data Privacy Act (“CTDPA”),
- Virginia Consumer Data Protection Act (“VCDPA”),
- Oregon Consumer Privacy Act (“OCPA”),
- Texas Data Privacy & Security Act (“TDPSA”),
- Delaware Personal Data Privacy Act (“DPDPA”),
- Indiana Consumer Data Protection Act (“INCDPA”),
- Iowa Consumer Data Protection Act (“ICDPA”),
- Kentucky Consumer Data Protection Act (“KCDPA”),
- Maryland Online Data Privacy Act (“MODPA”),
- Minnesota Consumer Data Privacy Act (“MCDPA”),
- Montana Consumer Data Privacy Act (“MTCDPA”),
- Nebraska Data Privacy Act (“NDPA”),
- New Hampshire Data Privacy Act (“NHDPA”),
- New Jersey Data Privacy Act (“NJDPA”),
- Rhode Island Data Transparency and Privacy Protection Act (“RIDTPPA”),
- Tennessee Information Protection Act (“TIPA”), and
- Utah Consumer Privacy Act (“UCPA”).
All of the above are collectively referred to as the “Relevant State Privacy Laws”.
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 moves.simple.life and its related pages, the Simple Move onboarding, quiz and checkout pages hosted on the simple.life domain, and our mobile application “Simple Move” (“Simple Move”, 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 California Notice at Collection and Privacy Notice.
- If you are a resident of Washington, Nevada or Connecticut, please also see our Consumer Health Data Privacy Notice, which covers consumer health data under the Washington My Health My Data Act, Nevada SB 370 and the consumer health data provisions of the CTDPA.
Sensitive Data and Your Consent
Simple Move asks you for information about your health and body — including movement and mobility limitations, joint discomfort, balance and posture concerns, pregnancy status, chronic conditions, injuries, symptoms, and your height, weight and BMI — so that we can build and adapt your movement practice plan. Under most of the Relevant State Privacy Laws this is “sensitive data”, and we will ask for your consent before we process it. Where the law of your state requires consent, we will not process your sensitive data without it. You may withdraw your consent at any time by contacting us at support@simplemoves.life or through the App settings, and we will stop processing your sensitive data as soon as practicable and in any event within 15 days of your request. Withdrawing consent may mean we can no longer provide a personalised practice plan.
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, and whether we sell it or process it for targeted advertising. 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 | Sources From Which Collected | Purpose for Processing | Categories of Recipients | Sold or Used for Targeted Advertising? |
|---|---|---|---|---|
| Identifiers, such as name, unique personal identifier, online identifier, IP address, email address, or account name | Directly from you; automatically when you Use Simple Move; via vendors on which we rely (attribution, app stores, payment providers) | Create, authenticate and manage your account; deliver the App and your movement practice plan; communicate with you and provide support; security and fraud prevention; research and analytics; personalised content and advertising; marketing communications; as permitted or required by law. | Affiliates; service providers and vendors (cloud hosting, email delivery, customer support, analytics, attribution, crash reporting); advertising partners; parties to a merger, acquisition, financing, reorganisation or sale of assets; regulators, courts and law enforcement where required by law or to prevent harm. | Yes — targeted advertising, and “sale” in the states noted below |
| Demographic data — age, sex or gender, and country or state of residence | Directly from you, or automatically when you Use Simple Move | Confirm eligibility (18+); adapt the movement content; language, currency and tax treatment; analytics; as permitted or required by law. | Affiliates; service providers and vendors strictly necessary to operate the App. Not disclosed to advertising partners. | No |
| Commercial information, such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies | Directly from you, or automatically when you Use Simple Move | Provide and administer subscriptions, receipts and refunds; tax and accounting; fraud prevention; communicate with you about your purchase; analytics; personalised content and advertising; marketing communications; as permitted or required by law. | Affiliates; service providers and vendors (cloud hosting, email delivery, customer support, analytics, attribution, crash reporting); advertising partners; parties to a merger, acquisition, financing, reorganisation or sale of assets; regulators, courts and law enforcement where required by law or to prevent harm. | Yes — targeted advertising |
| Internet or other electronic network activity information, such as browsing history, search history or information regarding interaction with an app or advertisement — including session starts and completions, screens viewed, in-app events, email and push interaction, crash logs and diagnostics | Automatically when you Use Simple Move; via analytics, attribution and crash-reporting vendors | Operate, secure, debug and improve the App; measure performance; run experiments; analytics; personalised content and advertising; as permitted or required by law. | Affiliates; service providers and vendors (cloud hosting, email delivery, customer support, analytics, attribution, crash reporting); advertising partners; parties to a merger, acquisition, financing, reorganisation or sale of assets; regulators, courts and law enforcement where required by law or to prevent harm. | Yes — targeted advertising |
| Geolocation data, such as the state or country associated with your IP address. We do not collect precise geolocation | Directly from you, or automatically when you Use Simple Move | Determine applicable content, language, currency, pricing and tax treatment; security and fraud prevention; analytics; advertising measurement; as permitted or required by law. | Affiliates; service providers and vendors (cloud hosting, email delivery, customer support, analytics, attribution, crash reporting); advertising partners; parties to a merger, acquisition, financing, reorganisation or sale of assets; regulators, courts and law enforcement where required by law or to prevent harm. | Yes — coarse location only |
| Audio, electronic, visual, thermal, olfactory or similar information, — a profile photo or avatar, if you choose to upload one | Directly from you | Display your profile within the App and, where applicable, to your coach and the other participants of your group. | Affiliates; service providers and vendors strictly necessary to operate the App. Not disclosed to advertising partners. | No |
| Inferences drawn from the information listed above to create a profile about a resident of a state listed above reflecting their preferences, characteristics and other attributes. | Directly from you, or automatically when you Use Simple Move | Personalise the App and the content we show you; measure and improve marketing performance; build advertising audiences; analytics; as permitted or required by law. | Affiliates; service providers and vendors (cloud hosting, email delivery, customer support, analytics, attribution, crash reporting); advertising partners; parties to a merger, acquisition, financing, reorganisation or sale of assets; regulators, courts and law enforcement where required by law or to prevent harm. | Yes — targeted advertising |
| Sensitive data — health-related information, being self-reported movement and mobility limitations, back, hip, knee and other joint discomfort, balance and posture concerns, pregnancy status, chronic conditions, injuries, symptoms, energy, sleep and stress levels, and height, weight and BMI | Directly from you, with your consent where required | Solely to build, personalise and adapt your movement practice plan, to select the appropriate intensity level and seated or standing variants, and to support safe use of the movement content. We do not use it for targeted advertising or to build advertising audiences, and we do not sell it. | Affiliates; service providers and vendors strictly necessary to operate the App. Not disclosed to advertising partners. | No |
Data Retention
We retain each category of personal data for the period, or according to the criteria, set out below. These periods supplement Section 2 (Personal Data Retention) of the Simple Move Privacy Policy.
| Category | Retention period or criteria |
|---|---|
| Account and profile data | For the life of your account. Deleted following account deletion, subject to removal from backups within 90 days. |
| Sensitive data (health-related onboarding answers) and practice history | For the life of your account. Deleted following account deletion, subject to removal from backups within 90 days. Deleted promptly on withdrawal of consent. |
| Payment and transaction records | 7 years from the transaction, to meet tax, accounting and audit obligations. |
| Support and complaint correspondence | 3 years from closure of the request. |
| Consent, opt-out and rights-request records | For as long as necessary to honour your choice, and thereafter as evidence of compliance. |
| Advertising and analytics identifiers and event data | Up to 25 months, after which the data is deleted or aggregated. |
| Records needed to establish, exercise or defend legal claims | Until the applicable limitation period expires. |
To make a request to delete your Simple Move account, please contact us at support@simplemoves.life or delete your account in the App settings.
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.
Sale of Personal Data
We do not sell your personal data for monetary consideration. However, most of the Relevant State Privacy Laws — including those of Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island and Texas — define a “sale” to include disclosing personal data to a third party for other valuable consideration. Our disclosures to advertising partners described below may constitute a “sale” under those laws. In Indiana, Iowa, Kentucky, Tennessee, Utah and Virginia, where “sale” is limited to disclosure for monetary consideration, we do not sell your personal data. You have the right to opt out of both sale and targeted advertising, and we explain how below. We do not sell sensitive data in any state.
Targeted Advertising
We may share the following categories of personal data with third-party ad-tech providers and others throughout the online advertising ecosystem for purposes of targeted advertising:
- Identifiers
- Commercial Information
- Internet or other electronic network activity information
- Geolocation data
- Inferences drawn from personal data such as preferences, characteristics and behaviors
We do not use or disclose your sensitive data, including your health-related data, for targeted advertising, and we do not use it to build advertising audiences.
Your Privacy Rights
As a resident of one of the states listed at the start of this U.S. State Privacy Supplement you may have certain rights in relation to your personal data. Not every right below is available in every state, and we note where a right applies only in particular states.
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. See “Sale of Personal Data” above for our position in each state, and “How to Exercise Your Privacy Rights” below for how to opt out.
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. We do not currently use profiling to make decisions of that kind about you.
Right to Obtain a List of Third Parties (Oregon and Minnesota)
If you are an Oregon resident, you may request a list of the specific third parties to which we have disclosed your personal data, or to which we have disclosed any personal data. If you are a Minnesota resident, you may request a list of the specific third parties to which we have disclosed your personal data.
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 Withdraw Consent
Where we process your personal data on the basis of your consent, including your sensitive data, you may withdraw that consent at any time. Withdrawing consent is as easy as giving it, and we will stop the relevant processing within 15 days of your request.
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 support@simplemoves.life.
To opt out of targeted advertising or the sale of your personal data, you may use the universal opt-out signal as described above, or email us at support@simplemoves.life. You do not need an account with us, and you do not need to write from the email address linked to your account, to submit an opt-out request.
Information for Authorized Agents
You may authorize a person (“Authorized Agent”) to exercise your privacy rights on your behalf. To submit a request to Simple Move on behalf of another person as an Authorized Agent, please submit a request to us by contacting us at support@simplemoves.life. We may require the Authorized Agent to provide written permission signed by you, and we may require you to confirm that you granted permission. An Authorized Agent may also submit an opt-out request on your behalf, including through a universal opt-out signal.
Authenticating Your Requests
We only comply with requests when we can authenticate that you are a resident of one of the states listed above exercising your rights regarding your personal data. This does not apply to requests to opt out of targeted advertising or the sale of your personal data, or to requests to withdraw consent, which we honour without authentication.
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 will act on a request to opt out of targeted advertising or the sale of your personal data as soon as practicable and, where the law of your state sets a deadline, within that deadline — which is 15 days in Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon and Texas.
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 Decline — Your Right to Appeal
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 support@simplemoves.life. We will respond to your appeal in writing within 45 days of receipt, or within 60 days where the law of your state allows, explaining the reasons for our decision. If we deny your appeal, we will provide you with a method through which you may contact your state Attorney General to submit a complaint.
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 one of the states listed above 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 Move 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 Us
If you have any questions or concerns about this U.S. State Privacy Supplement, please contact us at support@simplemoves.life, or contact our data protection officer at dpo@simple.life.