SIMPLI PRIVACY POLICY

EFFECTIVE DATE 12 SEPTEMBER 2008

This page set forth the privacy policies and practices of Simpli.com, which is owned by Simpli, Inc. (”Simpli” ”Site” ”we” ”our” or ”us”). Please read this privacy policy carefully since by visiting this Site and sharing information us, you agree to be bound by the terms and conditions of this Privacy Policy. Simpli, Inc. is a wholly owned subsidiary of ValueClick, Inc. For more information about ValueClick, Inc. or any of its subsidiaries or affiliates, please visit www.ValueClick.com.

STATEMENT OF RESPONSIBLE ONLINE MARKETING

Our 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. We provide this Privacy Policy to outline our practices and procedures with respect to information collection and use to enable you to make an informed decision about sharing information with us.

If you have questions or concerns regarding this statement, email us at privacy@search123.com.

CONSUMER PRIVACY

I. INFORMATION WE COLLECT: INDIVIDUAL INTERNET CONSUMERS

A. Personally Identifiable Information (PII)
Simpli generally does not seek any user data collected with an intention to identify or contact a person such as: name, address, telephone number or e-mail address (”PII”) from its consumers. PII may be collected when consumers, of their own initiative, contact us and provide PII. We will only use such PII to respond to such customer contact.

B. Non-Personally Identifiable Information (Non-PII)
As part of our on-going efforts to ensure the best possible experience for all of our users, we may use log files, web beacons and cookies to collect data from our Site. Data collected are non-personally identifiable information and may include IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity (Non-PII). Non-PII collected is used for various purposes, which include, without limitation, marketing, advertisements performance monitoring, service operation optimization, maintenance of service quality. We also use Non-PII to enhance our services to our business partners and clients and it enables us to provide general statistics to our business partners and clients regarding use of our services.

”Log files” track actions occurring on our Site and collects data including your IP address, browser type, Internet service provider, referring and exit pages, platform type, date-time stamp, click data and types of advertisements viewed.

”Web beacons” are electronic files that may be used to track your navigation of a website or collection of sites, the completion of transactions, submittal of applications and browsing behavior.

”Cookies” are text files that are stored on your Internet enabled device (which includes your computer, BlackBerry or other PDA). Cookies are used to improve the experience web users have when they see web advertisements and ensure that when a web user clicks on an advertisement, they are sent to the correct click-through destination. We may use Cookies for purposes which include estimating the total reach of an advertiser's product or service.

There are many misconceptions about Cookies, some of which we will try to address in this policy. Cookies cannot erase your hard drive or otherwise damage your computer and do not tell us an e-mail address or any other PII. We doe not and cannot use Cookies or web beacons to retrieve PII from your computer.

A useful resource on understanding Cookies may be found at http://www.allaboutcookies.org .

II. INFORMATION SHARING

We may share any Non-PII with third parties or any ValueClick, Inc. subsidiary or affiliate ("ValueClick Entities"). Such third parties or ValueClick Entities use and retain such Non-PII and may combine such Non-PII with any PII that that you chose to provide when registering or transacting with such third parties’ or ValueClick Entities’ websites which will be used and held in accordance with the terms of their privacy policies.

Please be aware that the websites of our advertiser clients as well as any third party websites linked to our Site also may be collecting information from you. Such information may include non-personally identifiable information through the use of Cookies and other technology. Please be aware that such third parties may combine such non-personally identifiable information with any personally identifiable information you may choose to provide when registering and transacting with such websites. Although we choose our business partners and clients carefully, Simpli is not responsible for the privacy practices of websites operated by such third parties. You should check the applicable privacy policies of such websites you visit to determine how they handle any information they collect from you

III. CONSUMER CHOICE AND ACCESS

You may stop Simpli's collection of Non-PII by using the settings in your Internet browser or browser add-ons to block our Cookies. Please see your browser supplier's website, or your browser add-on supplier's website, for details on how to do this.

IV. SECURITY

We employ reasonable measures to ensure the security of all information and we routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.

V. CONSENT AND CHANGES

We may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will post the revised Privacy Policy 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.

VI. 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 us, you acknowledge that we operate in the United States and agree to (i) permit us to transmit and use your information anywhere necessary, including across international boundaries, to affect the services and transactions provided by this Site; and (ii) that such use by us shall be subject to the terms and conditions stated in this Privacy Policy and applicable Terms and Conditions.

VII. DIGITAL POLICY FORUM

ValueClick, Inc. is a member of the Digital Policy Forum ("DPF"). The DPF is made up of online marketing, analytics, advertising, publishing, and email companies that are committed to examining and developing responses to important privacy and consumer protection issues in emerging media.

VIII. 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 this Privacy Policy, please email us at privacy@search123.com or you can send correspondence to the following address: Simpli, Privacy Officer, 30699 Russell Ranch Road, Suite 250, Westlake Village, CA 91362.




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