Last updated: 2019-12-06
Simpli Assets Ltd. (“we” or “us”) operates the simplipleasures.com online retailer (“SimpliPlay”). We respect the privacy of all of our customers, and all other parties who may visit SimpliPlay (together “Users”), and are committed to protecting such personal information.
Personal Information Collected
When you visit SimpliPlay, we automatically collect certain information about your device, including information about your web browser, device, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse SimpliPlay, we collect information about the individual web pages or products that you view, parameters relating to particular pages visited, date and time of such access, operations undertaken during such visit, time spent on each page, location information, and internet addresses or search terms which referred you to SimpliPlay, and other general information on how you interact with SimpliPlay (“Device Information”). The Device Information is collected anonymously and we do not link it with your personal information.
We collect Device Information through the following ways:
- “Log files” track actions occurring on SimpliPlay, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse SimpliPlay.
Additionally when you make a purchase or attempt to make a purchase through SimpliPlay, we collect certain information from you, including your name, billing address, shipping address, payment information, email address, and phone number (“Order Information”).
Use, Disclosure, and Consent
We use Order Information to fulfil orders placed through SimpliPlay (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use Order Information to:
- communicate with you as may be required to ensure you receive a high level of service;
- verify your identity and screen orders for potential risk or fraud;
- provide you with information or advertising relating to our products or services
- meet regulatory requirements; and
- any other legal reasons as may apply to your use of SimpliPlay from time to time
We use Device Information to assist us in screening for potential risk and fraud (in particular, your IP address), and more generally to evaluate, improve, develop and optimize our services. We may also use Device Information to map and forecast general industry trends and other analytical information.
Except as explicitly specified below, we will obtain your express or implied consent to collect, use or disclose any Personal Information. You can provide consent orally, in writing, electronically or through an authorized representative. You provide us with implied consent where our purpose for collecting, using or disclosing Personal Information is necessary for the provision of our services or would be considered obvious or reasonable in the circumstances. Your consent may also be implied where you have received notice and a reasonable opportunity to opt-out of having the Personal Information used, and you have not provided us with notice of your opting-out, including but not limited to use for mail-outs, marketing or fundraising.
We may collect, use or disclose your Personal Information without your consent in the following circumstances:
- when permitted or required by law;
- in an emergency that threatens an individual's life, health, or personal security;
- when the Personal Information is available from a public source;
- when we require legal advice from a lawyer;
- for the purposes of collecting a debt or protection from fraud; or
- other legally established reasons.
Third Party Service Providers
In some instances, we will share your Personal Information with third party service providers for the purposes listed above, including:
- Shopify - we use Shopify to power SimpliPlay - you can read more about how Shopify uses your Personal Information here.
- Google - we use Google Analytics to help us understand how our customers use SimpliPlay - you can read more about how Google uses your Personal Information here.
- Klaviyo – we use Klaviyo to help us manage your information to provide us with insights on how to better serve you – you can read more about how Kalaviyo uses your Personal Information here.
As set out above, we use your Personal Information to provide you with targeted product and marketing information that we believe may be of benefit to you.
For more information about how targeted advertising works, please see the following online resource provided by the Network Advertising Initiative.
You can opt out of targeted advertising by using the links below:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal.
Storage, Changes, and Removal of Personal Information
Your Personal Information may be stored electronically in our database, including databases hosted by relevant third party service providers, or in hardcopy format. We will only retain Personal Information for the time necessary to fulfill the identified purposes or an applicable legal or business purpose. Please note, when you place an order through SimpliPlay, we will maintain your Order Information for our records unless and until you ask us to delete this information.
We will use appropriate security measures when destroying your Personal Information such as shredding documents or deleting electronically stored information.
If you would like to correct inaccuracies in your Personal Information, please contact firstname.lastname@example.org, and we will make every effort to honor such request in a timely manner. For privacy protection purposes, we will need to verify your identity before deleting or otherwise modifying your Personal Information.
At any time, you may request that we remove your Personal Information from our records, and we will deleted such Personal Information within seven (7) days of receipt of such request
We are committed to ensuring the security of your Personal Information and may use passwords, encryption, firewalls, restricted employee access or other methods, at our reasonable discretion.
While we strive to use commercially acceptable means to protect the Personal Information, you acknowledge and agree that no method of transmission over the Internet, or method of electronic storage is 100% secure. We make no guarantee as to the absolute security of the Personal Information.
In the unlikely event that our system is breached, and any Personal Information has been compromised, we will notify such local authorities as may be required within seventy two (72) hours of the breach, and will also use our best efforts to notify you, using the most current contact information that we have on file.
We are not responsible for any failure to notify you based on incorrect or outdate contact information.
Do not track
Access to Personal Information
To submit a question to us about the collection or use of the Personal Information, please email us at: email@example.com and insert “Privacy Information Question” in the subject header.
If requested, we will provide you with a copy of any of your Personal Information in electronic form, which may include the following related information:
- what Information we are storing;
- where it is being stored; and
- for what purpose we are storing it.
Additionally, if you are a European resident, please note that we are located in Canada and your Personal Information may be processed in any country where we engage service providers. If you are located in the European Economic Area (“EEA”), we comply with the provisions of the General Data Protection Regulations that protect your Personal Information. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your Personal Information. As such:
- we may transfer your Personal Information to countries that the European Commission has approved as providing an adequate level of protection for Personal Information; or
- where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to such transfer. You will have the right to withdraw this consent at any time.
Links to other websites
Your Legal Rights
Under applicable data protection laws you have rights in relation to your Personal Information that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing such data is your consent) to withdraw consent.
You can learn more about your legal rights at:
If you are not happy with any aspect of how we collect and use your Personal data, you have the right to complain to the Office of the Information and Privacy Commissioner for British Columbia.
If you are a parent or guardian and you are aware that your minor child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from minors without verification of parental consent, we will take steps to remove that information from our servers.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at firstname.lastname@example.org or by mail using the details provided below:
Simpli Assets Ltd.
Attn: Clayton Ferguson
[Re: Privacy Compliance Officer]
707 Courtney Street, #404
Victoria, B.C. V8W0A9, Canada