This page set forth the privacy policies and practices of Simpli and its affiliated companies within the ValueClick Marketing Network (“ValueClick Network” “ValueClick” “we” or “us”).

Please read this privacy policy carefully since by visiting a ValueClick Network site and sharing information with one our companies you agree to be bound by the terms and conditions of this Privacy Policy unless you offer different terms which are accepted by ValueClick, Inc. in writing. For more information about the ValueClick Network and other ValueClick companies please visit www.ValueClick.com.

CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS.
Effective January 1, 2005, companies that collect personally identifiable information (“PII”) from California residents and disclose such information to third parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided or (2) provide a mechanism by which a consumer may opt-out of having their information shared with third parties. We have elected the second option and you may request that your PII not be shared with third parties by sending your request, including your full name, email address and postal address: Simpli.com, Attn: SB 27 Officer, P.O. Box 5600, Westlake Village, CA 91361.

STATEMENT OF RESPONSIBLE ONLINE MARKETING

The ValueClick Network’s information usage practices are based on two beliefs: first, that protecting user privacy is essential to the growth and prosperity of the Internet; second, that a personalized web experience can provide significant benefits to Internet end users if done properly. In accordance with these beliefs, the ValueClick Network creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.

If you have questions or concerns regarding this statement, email us at privacy@Simpli.com.

CONSUMER PRIVACY

I. INFORMATION WE COLLECT: INDIVIDUAL INTERNET CONSUMERS

A. Personally Identifiable Information (PII).
The ValueClick Network sites are designed to promote and facilitate the business of the ValueClick companies with advertisers and marketers. These sites are not directed towards individual Internet consumers nor do they seek any PII from such consumers. PII may be collected should a consumer contact a ValueClick company on his/her own initiative or respond to a ValueClick advertisement and provide any PII. Under no circumstances does the ValueClick Network request or collect sensitive PII such as an Internet user’s medical/health conditions; racial or ethnic origin; political, religious or philosophical beliefs or affiliations; trade union membership or sex life.

From time to time, however, ValueClick may host response forms for one of our advertisers which will ask the Internet user to provide PII (e.g. name, address, zip code, email address, gender, and birth date). All information provided will be shared with the advertiser. We also may collect PII through co-registrations, i.e., when an Internet user registers on a third party site and agrees to receive offers from ValueClick.

B. Non-Personally Identifiable Information (Non-PII).
When a consumer responds to or views an Internet advertisement served by a ValueClick company (such as through third-party websites or email solicitation) or visits a ValueClick Network site, we send a cookie and/or gif file (“Cookies”) to assign an anonymous, unique identifier to the end user's Internet browser. Cookies are small data files commonly used on the Internet to help optimize and personalize the Internet end user experience and identify repeat visitors to websites.

The function of these Cookies is to provide ValueClick with information for the purpose of paying third-parties commissions when an Internet user clicks on a link, creates a lead, or makes a purchase on an advertiser's Web site; and also to optimize and personalize the Internet user’s experience. If the Internet user re-visits the advertiser's site directly, ValueClick is able to continue to track the user’s activities on the advertiser's site and reward the third-party website that referred the user. We reserve the right to retain all ad delivery and reporting data as long as may be reasonably necessary for accounting and audit purposes.

Like most standard website servers, we use log files to collect Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, and date/time stamp. We use the information to analyze site usage, administer the site, understand usage and navigation trends in aggregate, and determine the relevance of content. This information, however, is not linked to any personally identifiable information.

We also may use Internet browsing and online purchase data associated with an anonymous identifier to develop a predictive statistical user profile of the end user's needs and interests. ValueClick does not use Cookies or log files to collect end users' names, physical addresses, email addresses, phone numbers, credit card numbers, social security numbers, or any other information which can be used to identify a specific person. We may match the IP address and user profile with email address data obtained separately in order to better target campaigns to meet user’s interests, but will not share this information with third parties.

For improved audience targeting, some ValueClick Network sites use marketing technology that allows advertisers to add non-personally-identifying demographic information, such as age, gender, area code, or ZIP code, to the non-identifiable profile data. Thus, there is no direct connection between an end user's online choices and his or her personal identity.

II. INFORMATION SHARING

The ValueClick Network may make any PII provided in responding to an advertisement available to the company sponsoring the advertisement, as well as to other trusted third parties in accordance with the terms of this privacy policy. As a result, you may receive information on additional products, services and offers that may be of interest to you.

The ValueClick Network and/or our marketing partners may enhance and/or merge PII about consumers who have opted-in to receive marketing communications with commercially-available third party data collected from other sources in an effort to ensure that the messages being sent to the consumer in online and/or offline marketing programs are relevant to their interests. In the event we enhance and/or merge such personally identifiable information with data collected from other sources, we will take reasonable steps to maintain the integrity and quality of that information.

The ValueClick Network may share PII (including information that has been enhanced with information from other sources) with advertisers, third party marketers, our affiliated entities for their online and/or offline marketing programs or in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of any of the ValueClick Network companies. While ValueClick strongly encourages clients and partners to adopt responsible approaches to online marketing, ValueClick is not responsible for the information practices of clients or their partners. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may differ from ValueClick's policy.

The ValueClick Network may release account and any other personal information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law; enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of ValueClick or others. This includes exchanging information with other companies and organizations for fraud protection.

III. CONSUMER CHOICE AND ACCESS

A. Opting Out.
Some ValueClick Cookies have an "opt-out" option. This process does not remove the ValueClick Cookie from your system; it simply replaces it with an opt-out Cookie that does not contain any unique identifiers. If this site provides such a process it is detailed below.

Simpli’s Cookies do not have an "opt-out" option, yet you still have the option of blocking the use of Cookies by changing a setting in your Internet browser. Please see your browser supplier's website for details on how to do this.

B. Accessing Consumer Information.
Because they are not directed towards individual Internet users, most ValueClick Network sites do not maintain a process for an individual consumer to review and/or request changes to any PII collected. This site does not maintain a process for an individual consumer to access his/her PII.

IV. SECURITY

The ValueClick Network employs industry standard security measures to ensure the security of all data. Any data that is stored on ValueClick's servers is treated as proprietary and confidential and is not available to the public. ValueClick has an internal security policy with respect to the confidentiality of customer and other data, allowing access only to those employees or third parties who have a need to know such information for the purpose of effectively delivering ValueClick products and services by means of user login and password requirements. The ValueClick Network routinely evaluates its data security practices to identify security threats or opportunities for improvement.

No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of ValueClick to intercept or access transmissions or private communications unlawfully. While we strive to protect your PII, ValueClick cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with a ValueClick Network company.

V. CONSENT AND CHANGES

The ValueClick Network may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will post those changes on this page and update the effective date so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. Except as otherwise required by law, modifications to this Privacy Policy will not affect the privacy of data collected by ValueClick prior to the effective date of the policy change unless we provide you direct notice and the opportunity to opt-out of such proposed change.

VI. CHILDREN’S PRIVACY AND SPAM

The ValueClick Network is very sensitive to the issue of children's privacy and makes every effort to protect the privacy of children using the Internet. ValueClick's web site, products, and services are not developed for or directed at children. Children (persons under the age of 18) are not eligible to do business with us and we do not collect personal information from any person we actually know is under the age of 13. If you believe your child has provided the ValueClick Network with any personally identifiable data by registering at a ValueClick web site, please email us at privacy@Simpli.com to have them removed.

The ValueClick Network is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our policy to prohibit the sending of unsolicited or "Spam" e-mail by ValueClick or any of its marketing partners.

Please note that under the CAN-SPAM Act, an advertiser is required to provide an opt-out mechanism for consumers to unsubscribe from future emails about the advertiser. Although not required to by law, many email marketers also include an opt-out mechanism to enable consumers to be removed from their mailing list. This has caused some confusion for consumers in opting out. The table below clarifies which opt-out mechanism you should use for commercial emails.

To receive no further emails . . .

Opt-Out Mechanism to Use

VII. DATA PROCESSING/SAFE HARBOR

The European Union (“EU”) maintains strict privacy laws. These rules differ significantly from US laws. To reconcile these differences, the US and the EU have created a Safe Harbor that defines mutually acceptable privacy operations. ValueClick, Inc. adheres to the Safe Harbor principals. For more information see www.export.gov/safeharbor.

By providing information to ValueClick Network sites, you acknowledge that they operate in the United States and agree to (i) permit ValueClick to transmit and use your User information anywhere necessary, including across international boundaries, to affect the services and transactions provided by this Site; and (ii) that such use by ValueClick shall be subject to the terms and conditions stated in this Privacy Statement and applicable Terms and Conditions and Policies.

VIII. NETWORK ADVERTISING INITIATIVE

ValueClick, Inc. is a member of the Network Advertising Initiative (“NAI”). The NAI is a group of third party network advertisers committed to increasing consumer confidence and contributing to the growth of electronic commerce. We, along with other members of the NAI, are committed to providing consumers with a clear explanation of what data we collect, how we use them, and why the use of data can benefit consumer's experience online. For more information about the Network Advertising Alliance please go to http://www.networkadvertising.org/.

IX. LIMITATION OF LIABILITY, THIRD PARTY INFORMATION & LANGUAGE

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE TERMS AND CONDITIONS AND POLICIES (INCLUDING LIMITATIONS ON DAMAGES, AND ARBITRATION OF DISPUTES). YOU AGREE THAT Simpli’ LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE GREATER OF THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY Simpli OR $250 TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.

You also agree that you have provided notice to, and obtained consent from, any third party individuals whose personal data you supply to Simpli with regard to: (a) the purposes for which such third party's personal data has been collected; (b) the intended recipients or categories of recipients of the third party's personal data; (c) which of the third party's data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. It is the express will of the parties that this agreement and all related documents have been drawn up in English. C'est la volonté expresse des parties que la présente convention ainsi que les documents qui s'y rattachent soient rédigés en anglais.

CONTACT US

For more information or if you have questions or concerns regarding the ValueClick Network Privacy Policy, please email us at privacy@Simpli.com or you can send correspondence to the following address: Simpli, Privacy Officer, 30699 Russell Ranch Road, Suite 250, Westlake Village, CA 91361.