Data Subject Rights Policy
Last Revised: January 27, 2019
Simpler App Inc. (“Company” or “we” or “us”) values the privacy rights of its customers, partners, suppliers, vendors and users (“you” or “Data Subject”). As required under applicable privacy legislation and data protection laws, including without limitations, the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) (collectively “Data Protection Regulation”), individuals have certain rights regarding the processing of their personal data (depending on the applicable jurisdiction), this policy is meant to provide you with information regarding your rights.
THE RIGHT TO BE INFORMED
Data Subjects have a right to request a confirmation from us that we process their personal data. In addition, Data Subjects may request to be provided with a copy of the personal data we process, as well as to understand how and why we use this personal data.
THE RIGHT TO BE FORGOTTEN
Data Subject have the right to require us to erase certain personal data, if particular conditions are satisfied: (1) the personal data is no longer needed for the original purpose and there is no new lawful basis for continued processing; (2) you have exercised your right to withdrawn consent (solely if and when consent was the lawful basis for processing), or to object to the processing of personal data, and we have no overriding grounds for the continued processing; (3) the personal data is processed unlawfully; or erasure of personal data is necessary to comply with applicable legislation. You may also require us to request third parties to which we have transferred your personal data, to erase the data as well.
However, the “right to be forgotten” is not absolute. We may reject your request to exercise this right in some circumstances, including where we must retain the data in order to comply with legal obligations; or we must retain the data in order to establish or defend against legal claims, etc., all subject to applicable legislation.
THE RIGHT TO OBJECT TO PROCESSING OF PERSONAL DATA
Data Subject have the right to object to processing of personal data, in the event the basis for processing is our legitimate interests. Notwithstanding the above, we will be permitted to continue the processing if our legitimate interests in this regard override Data Subject rights, interests and freedoms, or when processing is necessary to establish, exercise or defend a legal claim or right, etc., all, subject to applicable legislation.
THE RIGHT TO RESTRICT PROCESSING OF PERSONAL DATA
Data Subject may limit the purposes for which we process its personal data. The right to restrict processing activities may apply when: (1) the accuracy of the data is contested; (2) processing is unlawful and data subject requests restriction instead of erasure; (3) the personal data in no longer needed for the original purpose it was collected, however the data is still required to establish, exercise or defend legal rights; or (4) there are overriding grounds in the context of an erasure request.
Data Subject have the right to require to update personal data which is not correct, as well as to require to inform third parties to which such data was transferred, to correct the data as well.
THE RIGHT TO DATA PORTABILITY
Data Subject have the right to have its personal data sent or "port" to a third-party, subject to the following terms: (1) the personal data was provided by the Data Subject; (2) the personal data is processed automatically; (3) the personal data was processed on the legal bases of contract or consent.