Privacy Policy

[Last Amended: August 18, 2021]

INTRODUCTION

This Privacy Policy (“Privacy Policy”) outlines the privacy practices of Simpler Apps Inc. (“Company”, “we”, “us”, or “our”) and specifically explains what personal data we collect, how such data is used, how we safeguard it and how you may exercise your rights detailed below.

This Privacy Policy governs the processing of data relating to the following individuals (“you” or “your”):

  • “End User(s)”: end users that install one of our apps: “Easy Backup” and “Cleaner Pro” available on iOS and Google Play, (each and collectively shall be defined as “App(s)”);

 

  • “Contacts”: as part of the services we provide (i.e., managing the End Users’ contact or back up features), End Users share their contact list with us. If you are an individual that appears on such list, this Privacy Policy also applies to you.

If you are a California resident, please review our CCPA Privacy Notice in addition to this Privacy Policy.

Please note that this Privacy Policy is an integral part of our Terms of Use (“Terms”). Any definitions used herein but not defined herein shall have the meaning ascribed to them in our Terms.

Simpler Apps Apps, an incorporated company established in the state of California, with registered offices at 1055 West 7th Street, 33rd Floor, Los Angeles, CA 90017, United States of America.

To contact us, see below.

 

  1. TYPES OF PERSONAL DATA WE COLLECT AND HOW WE USE IT

The first type of data we collect is aggregated data, non-identifiable, non-personal data, which may be processed via your use of the Service (“Non-Personal Data”).

The second type of data is individually identifiable data, namely data that identifies an individual, or may with reasonable effort identify an individual (“Personal Data”).

In the event that we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data for as long as it remains combined.

The tables below include the types of data that we collect, how it is used, and our legal basis for processing such data.

  1. Data relating to End Users and/or Visitors

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    2.Data relating to End Users

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    3. Data relating to Contacts

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                   *The in-App opt-out process is described here.

    2. SHARING OR DISCLOSING DATA

We share or disclose personal information to the recipients listed below and in the following events:

 

(i) Affiliate Company

We may disclose or share certain information with our parent company, Lusha Systems Inc., headquartered at 1177 Avenue of the Americas, 5th Floor, New York, NY 10036, United State of America, as well as subsidiaries, joint ventures, or other companies under common control with the Company ("Affiliated Companies") to provide them with accurate and verifiable contacts data that may be used if they constitute relevant business contact information for their own purposes.

You may read Lusha Systems Inc.’s privacy policy here.

 

(ii) Third Party Service Providers:

Our third-party service providers may integrate their code (such as: APIs, cookies, software developer kit “SDK”, etc.) within our App or website, as applicable, for the purpose of providing us with analytic, tracking and statistic reports as well as to help us protect our products’ by detecting fraudulent activity. These third parties may process certain information on you including Online Identifiers, therefore we recommend you review their privacy policy and opt-out options:

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We may permit third parties to use cookies or other tracking technologies to collect information about your online usage activities across our website.

We also use external service providers acting on our behalf:

  • Other companies in our group for providing notices, R&D, Marketing, support and security services

  • Amazon Web Services for the hosting of our Apps and website. Such services are provided by Amazon Web Services, Inc., headquartered at 410 Terry Avenue North Seattle, WA 98109 United States.

(iii) Legal Requirement

We may share information in order to protect legal rights (including intellectual property rights) or to comply with any applicable law, regulation, legal process or governmental request.

(iv) Corporate Transactions

We may share data in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

    3. DATA RETENTION

  • We retain End Users’ data for the duration of their active account on one of our Apps, in accordance with applicable laws.

 

  • Once you ask to delete your account within the app your account all backups are deleted immediately. We retain your correspondences with you in relation to your requests and enquiries for 3 years after termination of our engagement.

 

We may keep personal data hereafter for archival purposes for 5 years following the deletion of the relevant End User account in order to comply with our legal and contractual obligations or to protect ourselves from any potential disputes (as required by laws applicable to record-keeping and to have proof and evidence concerning our relationship, should any legal issues arise following the termination of your account), all in accordance with our Data Retention Policy.

 

  • If you are a Contact: We retain your personal data as long as it remains necessary to provide our services to End Users when we act as their processor (e.g back up the phone book), or until we receive a valid request to erase personal data and then we will not use it in our database used for fraud prevention services (e.g. caller ID).

 

We may, at our sole discretion, delete or amend information from our systems, without providing any prior notice to you, once we deem it is no longer necessary for such purposes.

    4. USER RIGHTS

Data protection and privacy laws provide you with the ability to exercise some rights regarding your personal data that we hold (depending on your jurisdiction). Please review our User Rights Policy for more information regarding you privacy choices and the rights you may have under the relevant data protection and privacy laws in your jurisdiction.

If you wish to exercise your rights, please fill out the Data Subject Request Form (“DSR”) available here.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisory authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.

    5. DATA SECURITY

We take great care in implementing and maintaining the security of the website, Apps and the data that we collect and process.

We employ industry standard procedures and policies to ensure the safety of our Visitors', End Users' and their Contacts' personal data and prevent any unauthorized use of it, as explained detailed in our Information Security Policy.

If you believe that your data was not treated in a way that was not in accordance with this Privacy Policy, or if you believe that someone may have attempted to abuse our Services, please contact us.

Additionally, in the event of a security incident in which we discover your personal data may have been at risk, we will take reasonable efforts to notify you and the applicable authority (if required to do so, subject to applicable laws).

 

    6. CHILDREN

You represent and warrant that you are: (i) at least sixteen (16) years old if you are located in the

Our Apps and website are not directed or intended for use by Children and we do not knowingly collect or solicit information from Children. If we obtain actual knowledge that a user is considered a Child, we will take steps to immediately delete his or her Personal Data. We request that such individuals do not provide Personal Data through the services.

If you become aware or have any reason to believe that a Child has shared any information with us, please contact us (as detailed below) and we will take reasonable steps to ensure that such information is immediately deleted from our databases. 

    7. DATA TRANSFERS

We process data in the United States and in Israel.

For processing data on your behalf, we may transfer data to Israel and / or U.S. Where applicable, we have implemented appropriate safeguards.

If you are a resident of a jurisdiction where the transferring of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.

    8. AMENDMENTS

Except as otherwise described herein, we may at our sole discretion and at any time amend the terms of this Privacy Policy. Such changes shall be effective upon the publication of the amended terms on our website or in the App.

The latest amendment to this Privacy Policy will be reflected in the “Last Amended” heading above. Your continued use of the App, following the amendment of the Privacy Policy, constitutes your acknowledgement of such amendments to the Privacy Policy.

In the event of a material change we will make a reasonable effort to provide you notification of such change.

    9. CONTACT INFORMATION

If you have any questions about the Privacy Policy, please contact us here or:

 

Simpler Apps Apps Apps Inc.

540 President Street, 3rd Floor

Brooklyn, NY, US, 11215

 

Individuals from the EU may contact our EU representative according to Art. 27 GDPR regarding all requests related to data protection and privacy:

 

DP-Dock GmbH

 

Attn: Simpler Apps Apps Inc.

 

Ballindamm 39

 

20095 Hamburg

 

Germany