Privacy and Security Statement

Published January 6, 2023

Overview
Simply Easier Payments, Inc (“SEP”) recognizes the importance of, and is committed to, safeguarding the privacy and security of the information we collect.  This privacy policy (the “Policy”) is intended to inform you of the types of information SEP collects, as well as our policies and practices regarding collection, use and disclosure of that information through the web pages at https://www.simplyeasier.com (the “Site”) and through SEP’s online payment system (the “System”). 

Please read this Policy carefully, because by using the Site and/or System, you are acknowledging that you understand and agree to the terms of this Policy, and consent to the types of information and the manner in which we may collect, use, and disclose such information. If you do not agree to the terms of this Policy, please do not use the Site or Service.

We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the Policy the date it was updated. We encourage you to review this Policy from time to time to make sure that you understand how any information you provide will be used.  We will provide notice, either on the Site, System, or through other means, of any material changes in these Policies.  Each time you access the Site or use the System, the most recent version of the Policy will apply. Your continued use of the Site or System following the posting of changes to these terms will mean you accept those changes.

Information Collection
Personal Information You Provide to Us
When you use our Site or System, SEP may collect a variety of information provided by you or the merchant to whom you are making a payment. Examples of the types of information we collect include, but are not limited to:

• Your Name
• Payment account information
• Information on product or service you are paying for such as a policy or account number
• User name and password for your SEP account
• Email address or phone number for sending a receipt

We only have access to and collect this information if you voluntarily give it to us by registering for an account, submitting information through the System, completing a payment transaction, or through other direct communication from you.  You can provide or withhold this information at your discretion. However, if the information is required to complete a payment transaction and you decide not to provide that information, the payment transaction will not be completed. If you have an SEP account, you have the ability to modify that information as you wish by logging in, making changes and saving those changes.

Information Collected by Automated Means 
SEP and our service providers collect certain information using cookies. Information we collect in this way may include, but not limited to:

• IP address
• Browser type
• Operating system
• Device type

If you do not want information collected through the use of cookies, most browsers allow you to reject cookies. Please note that if you use your browser settings to modify or block all cookies, you may not be able to access parts of the Site or System and your user experience may be severely degraded. We may share non-personal information obtained via cookies with our advertisers and affiliates.  We have no access to, or control over, cookies stored on you computer by other third parties.

When you use the Site or System, SEP and/or our service providers, may also use a variety of technologies that automatically collect information about how the Site and System is accessed and used (“Usage Information”). Usage Information may include, in part, the IP address from which the Site or System is accessed, browser type, operating system, the page viewed, the time, number of users, and the website you visited immediately before using the Site or System. This Usage Information provides us with information about the use of the Site and System, such as how many visitors visit a specific page on the Site or System, how long they stay on that page, which websites they are coming from and which hyperlinks, if any, they “click” on. Usage Information may also include engagement metrics related to your use of the Site or System, including for example, time spent with particular features.  Usage Information helps us to keep the Site and System user friendly and to provide visitors with readily accessible and helpful information to improve the Site or System. We may also use your Usage Information to troubleshoot issues with access or use of our Site or System. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as personal information.

How Do We Use Your Information
We will use your information to respond to you regarding the reason you contacted us and/or for the purposes identified expressly at the time of collection. We will also use your information as follows:

• Registration – To use certain portions of the System, a user will need to complete a registration form and create an account with us. During registration, a user is required to give certain information (such as a username and email address). This information is used to facilitate your use of the System, and to contact you about the products/services on our Site and/or the System in which you have expressed interest or subscribed to and allow you to easily update your contract information.  
• To Understand Your Interests - For example, we may use your information to better understand what products or services interest you based on information we collect about you and your household.
• To Improve Our Products and Services - We may use your information to enhance our Site and System to serve you better. 
• To Respond to Your Requests, Chats or Questions - This may include responding to your feedback.
• For Security Purposes - This could include protecting our company and our other customers. It may also include protecting the Site or System.
• For Marketing Purposes - We may provide you with information about new products and special offers. We may use your information to serve you ads about products and offers. We may tell you about new features or updates. These might be third-party offers or products we think you might find interesting. 
• To Support Our Products and Services - This could include fulfilling your requests for products or services. It could also include processing purchases or return transactions.
• Law or regulatory obligations - Certain laws and regulations require us to maintain and disclose collected information.  
• Customer Service – Unless you ask us not to, we may contact you via email in the future to tell you about changes to our Service, changes to this Policy and/or new services being offered by us.

By agreeing to our Terms Service and this Policy, you are consenting to our use of your personal information for the purposes listed.  We may also have the right to collect and use your personal information in the above-described manner on the basis of one or more of the following:

• The processing is necessary for the performance of a contract or for entering into a contract with you. Please note that where this is the case, we may not be able to perform or enter into a contract with you unless you provide your personal data;
• The processing is necessary to comply with a legal obligation;

Sharing Information
SEP does not sell or share your information with any parties except as described below:

• With service providers and processing partners who assist us in providing our services and transacting your payment requests
• To protect against and prevent fraud, unauthorized transactions and similar threats
• To comply with legal obligations as we may be required by laws or regulations or judicial processes
• Create and manage your accounts
• Enforce our legal rights
• Comply with industry standards
• Transfer information to a purchaser of SEP, or SEP assets, a merger or acquisition
• With your consent

If we become involved in a merger, acquisition, or any form of sale of some or all of our assets, the Site, our System, and your information as collected, processed, and maintained through our Site and System may be included in the assets sold or transferred to the acquirer.  You agree that we may transfer or assign the information we have collected about you in connection with any such event.   In the event of a bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, we may not be able to control how your personal information is treated, transferred, or used.

When transferring your personal information, we will take all appropriate steps to provide an adequate level of protection for your personal data in accordance with relevant legislation. These steps may include exercising audit and inspection activities in respect of the actions of those third parties in connection with the use of your personal information.

Data Protection, Security and Storage
SEP maintains reasonable administrative, technical and physical safeguards to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. We use SSL encryption, firewalls and physical access controls among other methods. You are responsible for the security of your account user names and passwords.  Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other types of misuse. To protect the confidentiality of personal information maintained in your account, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Site and System by any person using your password. Please advise us immediately if you believe your password has been misused. If you have reason to believe that your interaction with us is no longer secure, if you feel that the security of any account you might have with us might have been compromised, or if you suspect that someone else is using your account, please contact us immediately using the contact information provided below in the “Contact Us” Section.  We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal information. To the extent the law of your jurisdiction allows for notification of a breach via e-mail or conspicuous posting on the Site or System, you agree to accept notice in that form.

Children's Privacy
SEP Site and System are intended for the use strictly by adults. We do not knowingly solicit or collect personal information from users who are not over the age of 13.

Third Party Web Sites and Services
SEP may be accessed by links from other web sites. SEP may link to other web sites. SEP is not responsible for the content or privacy policies and practices of any third party web site.

Changes to Our Privacy Policy
SEP reserves the right to make change to this privacy statement at any time. We will post those changes to this web site.

What if I am a resident of California?
California requires operators of websites or similar services to make certain disclosures to users who reside in California regarding their rights, specifically:

Shine the Light
For clarity, we will not trade, rent, share, or sell your personal information to third parties unless you ask or authorize us to do so. However, if we disclose personal information that is primarily used for personal, family, or household purposes of a California user to a third party for said third party’s direct marketing purposes, we will identify such third party along with the type of personal data disclosed, upon your request. 

For further clarification, please refer to the “Contact Us” section below. Under California law, businesses are only required to respond to a user’s request once during any calendar year.

Do-Not-Track
Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. California law requires that we disclose to users how we treat do-not-track requests. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. We have not yet developed features that would recognize or respond to browser initiated Do Not Track signals in response to California law. In the meantime, there are technical means to prevent some of the tracking. See Section “Information Collected by Automated Means.”

Personal Data Rights
California consumers have the right to request access to their personal data, additional details about our information practices and deletion of their personal information (subject to certain exceptions).  California consumers also have the right to opt out of sales of personal information, if applicable.   We describe how California consumers can exercise their rights under the CCPA below.  Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney.  Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information.  We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information.  We will not discriminate against you if you choose to exercise your rights under the CCPA. 
 

• RIGHT TO KNOW - You may request, no more than twice in a 12-month period, access to the specific pieces of personal data we have collected about you in the last 12 months.  You may also request additional details about our information practices, including the categories of personal information we have collected about you, the sources of such collection, the categories of personal information we share for a legitimate business or commercial purposes, and the categories of third parties with whom we share your personal information. You may make these requests by contacting using the contact information provided below in the “Contact Us” Section.   After submitting your request, please monitor your email for a verification email.  We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.​
• COPIES OF PERSONAL INFORMATION - You may request, no more than twice in a 12-month period, transportable copies of your personal information that we have collected about you in the last 12 months.  You may make these requests by contacting using the contact information provided below in the “Contact Information” Section.   After submitting your request, please monitor your email for a verification email.  We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security. 
• DELETION -You may request that we delete the personal information we have collected about you.  Please note that we may retain certain information as required or permitted by applicable law.  You may make these requests by contacting us using the contact information provided below in the “Contact Information” Section.  After submitting your request, please monitor your email for a verification email.  We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

Individual Data Rights (EU)
The EU General Data Protection Regulation (GDPR) grants individuals who are in the European Union and European Economic Area (EU/EEA) with certain rights, with some limitations. If information is collected from such data subjects, we will establish a system to enable and facilitate the exercise of data subject rights related to:

• Information access;
• Objection to processing;
• Objection to automated decision-making and profiling;
• Restriction of processing;
• Data portability;
• Data rectification;
• Data erasure. 

If you would like to exercise the above GDPR rights in connection with the personal data we hold about you, please submit a written request using the information provided in the “Contact Us” section below. Our privacy team will examine your request and respond to you as quickly as possible.

Please note that we may still use any aggregated and de-identified personal information that does not identify any individual and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How We Store Your Information/International Data Transfers
By using the Site and System you consent to the transfer of information to anywhere where the Site, System or our service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

We are a US based company and by accessing the Site or System, you grant us express consent to transfer your personal information to US servers. If you do not wish for us to transfer your personal information to the US, please contact us using the information in the “Contact Us” section below. 

This Policy sets out the privacy principles we follow with respect to transfers of personal information from the European Economic Area (EEA) to the United States, including personal information we receive from individuals residing in the EEA who visits our Site and/or who may use of our System or otherwise interact with us.
Please note that for users located in the EEA, the term personal information used in this Policy is equivalent to the term “personal data” under applicable European data protection laws

Miscellaneous
This Policy and our privacy practices will be subject to the laws of the United States. Please note that our servers are located in the United States. We make no representation that this Policy and our practices comply with the laws of any other country or jurisdiction. Users of the Site or System who reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using the Site or System, you consent to the transfer, processing, and use of your information outside of your country.

Contact Us
If you have any questions about this Policy, please contact via email us at:
support@simplyeasier.com
or,
Simply Easier Payments, Inc.
P.O. Box 2936
Durham, NC 27715

To exercise any of your rights in this Policy please contact us in writing, via email or postal mail as indicated above, so that we may consider your request under applicable law. Please be aware that your request may not be accepted for review unless you provide the following:

• The name, user ID, pseudonym, email address, or other identifier that you have used to use the Site or Service, or if you are not a registered user of the Service, or have not otherwise previously interacted with us, your first and last name and an address where we can correspond with you.
• State or Country in which you are located.
• Clear description of the information or content you wish to receive or to be deleted or corrected, or the action you wish to be taken; and
• Sufficient information to allow us to locate the content or information to be deleted, removed, or corrected.

For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request.

In addition, please note that, depending on the nature of your inquiry, request, or complaint, we may need to verify your identity before implementing your request and may require proof of identity, such as in the form of a government issued ID and proof of geographical address.

We will attempt to comply with your request as soon as reasonably practicable.