Scope

Simio Cloud, LLC (“SimioCloud”) respects the privacy of every individual about whom we either process information or whose information we maintain for use in our product and data-driven marketing services. This privacy notice describes our service offerings and the practices we follow to show that respect.

SimioCloud’s business is using data and technology to drive solutions that help our clients to identify and better market to their existing and prospective donors and customers.

SimioCloud Products and Services

SimioCloud delivers products and services through a cloud-based, technology-driven platform consisting of marketing and advertising solutions to help our for-profit and not-for-profit business clients optimize their customer and donor data, and identify and reach potential new customers and donors using analytical tools and marketing/advertising strategy services. Stated differently, we design and build a consumer database for internal use to create predictive modeling solutions that assist our clients in the creation and execution of custom, optimized marketing campaigns.

When we provide our products and services, we may also process our clients’, and their partners’, information according to our contract’s terms and conditions. In that capacity, we also act as a service provider to our clients.

Personal Information Collection and Use 

Our SimioCloud products and services only contain the types of information required for the intended use of providing data-driven marketing solutions to our clients. 

The consumer information collected by SimioCloud for inclusion in our products and services contains personally identifiable information about individuals and households in the U.S. and are acquired from the following sources:

  • Data from SimioCloud customers: Examples include rosters of individual donors and their associated donation transaction details
  • Data from other information providers: Examples include data aggregators whose business it is to collect and compile non-sensitive personal identifiers and demographic information, collected from publicly-available sources and other sources such as surveys and questionnaires with appropriate notice regarding what information is collected, why it is being used, and with whom it is being shared. SimioCloud also collects summarized or aggregated purchase information and other aggregated or anonymous information.

SimioCloud does not collect, and the SimioCloud products and services do not include, specific details about a purchase, detailed financial information, credit information, medical information or Social Security numbers.  We will not knowingly disclose identifiable information on anyone younger than 18 to third parties for use in marketing solicitations.  We do use information related to minors younger than 18 to identify and remove records about them from our and our clients’ marketing files.  We also use information related to minors younger than 18 in creating additional insights solely related to the adult parent of the minor individual, provided, however, we do not disclose identifiable information about the minor as part of the insights created and included within the adult record (For example, SimioCloud utilizes a flag that denotes “presence of children” and “child age ranges.”)

SimioCloud also uses the Association of National Advertisers’ DMAChoice™ Mail, Telephone, and Email Preference suppression files, as well as state and federal do-not-call lists in developing our marketing and advertising products and services.

The SimioCloud products and services are only made available to and for use by qualified companies, non-profit organizations and political organizations in their marketing, fundraising, customer service, and constituent service and outreach programs. SimioCloud does not provide its products and services to individual consumers.  Our products and services can be used to enhance existing customer and constituent files and acquire lists of suitable consumers for prospecting and fundraising purposes.

Additional Terms and Conditions: For a company to use any of SimioCloud’s products and services, it is required to enter into a contract with us.  The terms of these contracts further govern the use of personal information SimioCloud collects and maintains.

In addition to disclosures of information in the ordinary course of business, we may disclose personal information as necessary to comply with a legal obligation or to respond to a regulator, such as in response to a subpoena.

Offshoring: Where permitted by law, third parties under contract to SimioCloud may have access to the information collected by SimioCloud to assist in processing the data. Some of these third-party contractors may reside outside the United States. 

Your Rights and How to Contact Us

OPT-OUT FROM SIMIOCLOUD PRODUCTS AND SERVICES:

SimioCloud gives consumers the opportunity to opt-out of our database at no cost.

SimioCloud utilizes the Association of National Advertisers’ DMAChoice™ Mail, Telephone, and Email Preference files, as well as the various state registries and the Federal Trade Commission’s Do-Not-Call Registry in developing our data-driven marketing products and services.  Consumers registered with any of these organizations do not need to also opt-out with SimioCloud to prevent the use of their information for prospecting purposes.

Consumers who wish to opt-out of the SimioCloud products and services directly with SimioCloud may complete and submit an opt-out request form by clicking https://www.simiocloud.com/optout/.

Except where otherwise required by law, SimioCloud will also accept opt-outs from certain qualified third parties. To obtain a copy of SimioCloud’s third-party qualification criteria, please email Privacy@simiocloud.com.

California Consumer Privacy Act Rights

The California Consumer Privacy Act (“CCPA” or the “Act”) confers new privacy rights for California consumers and imposes corresponding obligations subject to the Act.  The rights conferred to consumers include:  the right to know what personal information covered businesses are collecting about them and how that information is being used and shared; the right to delete personal information held by covered businesses; the right to stop the sale of personal information by covered businesses; and the right to non-discrimination in service and price when exercising privacy rights.

The following is intended to explain California consumers’ rights and the obligations SimioCloud has under the CCPA.  

RIGHT TO KNOW/REQUEST FOR ACCESS TO PERSONAL INFORMATION

As a consumer under the CCPA, you have the right to request that SimioCloud disclose what personal information we collect, use, disclose, and sell about you.  We call this your “right to know.”

To take advantage of your right to know, you must submit a request by filling out the form at simiocloud.com/ccpa-access-deletion-form/.

You can also submit your request by mail or telephone.

Our telephone number is 1-866-600-3430.

Our mailing address is:

Simio Cloud, LLC
Attention:  CCPA Requests
10155 Westmoor Dr. Bldg. 3, Ste. 135
Westminster, CO 80021

To respond to your right to know request, the CCPA permits SimioCloud to verify your identity.  We will do this by matching the personal information you supply us to the personal information we maintain about you.  In an effort to protect the consumer, we need to have a reasonably high degree of certainty you are the person you claim to be.  This will require that you submit certain personal information for us to compare and match to data we have about you.

To complete the verification process, you will be required to submit a picture of the front and back of your driver’s license as well as a photograph of you (i.e., a “selfie”). Any new personal information (for example, biometric information such as your driver’s license picture and your selfie) that we collect from you as part of your CCPA requests will only be used for the purposes of identity verification and to process your CCPA requests. SimioCloud will delete the new information collected as part of the identity verification process as soon as practical after fulfilling your request.

If we are unable to satisfactorily verify your identity, we will be unable to fulfill your right to know request. In that case, please see the information below concerning SimioCloud’s data collection, maintenance, and sale practices.

 


TYPES OF PERSONAL INFORMATION SIMIOCLOUD COLLECTS

Right to Know about Personal Information Collected, Disclosed or Sold

Business and Commercial Purposes for which Personal Information is Collected:  We collect personal information for our own business and commercial purposes in the creation and ongoing development of our SimioCloud products and data-related marketing and advertising services to our clients.  SimioCloud licenses the categories of personal information described below from the third-party sources categorized below in creating, developing and providing SimioCloud’s marketing and advertising products and services.  SimioCloud licenses personal information, through our delivery of products and services, to the categories of third parties as described in the table below.

Categories of Personal Information Collected

  • Personal identifiers (e.g., name, alias, postal address, IP address, email address, account name, or similar identifiers)
  • Personal Characteristics (e.g., characteristics of protected classifications under California and federal law like race and gender)
  • Personal Property or Buying Activity/Interest (e.g., commercial or transaction information)
  • Internet Activity (interest based on web site type, source URL)
  • Geo Location
  • Employment Information
  • Education Information
  • Inferences (e.g., inferences drawn to create a profile about a consumer reflecting the consumer’s preferences)

Categories of Sources from Which Personal Information Was Collected

Simio Clients

  • Customer and Associated Transactional Information
  • Donor and Associated Transactional Information

Information from Data Brokers

  • Demographic Marketing Information
  • Consumer-Provided Contact Information
  • Telephone Companies
  • Summarized or Aggregated Purchase Information
  • Surveys and Questionnaires (with appropriate notice)

Categories of Third Parties with Which Personal Information is Sold

  • Agriculture, Forestry and Fishing (for example, farm cooperatives)
  • Automotive (for example, car manufacturers and dealerships)
  • Business Services/Agency (for example, data brokers)
  • Communications (for example, wireless carriers)
  • Construction (for example, real estate development companies)
  • Consumer Packaged Goods (for example, companies that sell personal and household products)
  • Education (e.g., colleges and universities)
  • Energy and Utilities (for example, electric and gas companies)
  • Entertainment (for example, movie and television studios and streaming services)
  • Financial Services (for example, banks and investment companies)
  • Government (for example, state and federal agencies and political parties and candidates)
  • Healthcare (for example, hospitals)
  • Insurance (for example, insurance carriers)
  • Manufacturing (for example, consumer product manufacturers)
  • Media and Publishing (for example, magazines, retail catalogs)
  • Non-Profit (for example, charitable organizations)
  • Real Estate (for example, real estate brokerage companies)
  • Retail (for example, department stores, hardware stores)
  • Services-Non Professional (for example, consulting firms)
  • Services-Professional (for example, advertising agencies and financial planners)
  • Sports (for example, professional sports teams)
  • Technology (for example, software and hardware providers, social media platforms)
  • Transportation (for example, railway companies, airlines, rental car companies)
  • Travel and Tourism (for example, cruise lines, hotels, online travel services)

Categories of Service Providers with Whom Personal Information is Disclosed for a Business Purpose

Cloud computing and storage vendors; security contractors; consultants, analysis providers, marketing analytics platforms; programmatic advertising marketplaces/platforms; premium social publishers; measurement platforms; onboarding partners.

 


 

SimioCloud does not collect data directly from consumers for use in our products and services.  Please also note that SimioCloud does not collect biometric information from consumers (except as needed for the verification process in response to an access or deletion request).  Lastly, SimioCloud does not collect sensory information such as voice, visual, thermal, olfactory, or similar sensory information. 

DISCLOSURE AND SALE OF PERSONAL INFORMATION

During the last year, SimioCloud has sold personal information it has collected to our third-party clients for their business purposes.  More specifically, SimioCloud’s products and services include licensing relevant personal information to our clients for the client’s own uses in enabling marketing and advertising campaigns.  SimioCloud does not sell personal information to individual consumers.

During the last year, SimioCloud has disclosed personal information to service providers (e.g., cloud computing and storage vendors; security contractors, consultants and analysis providers), for SimioCloud’s own operational business purposes.

SimioCloud does not knowingly sell personal information about consumers younger than 18 for the purpose of marketing or advertising directly to the minor.  SimioCloud does use personal information from minors younger than 18 to suppress matching records from marketing lists and to facilitate identity verification and fraud prevention. 

RIGHT TO DELETE PERSONAL INFORMATION 

Pursuant to the CCPA, California consumers have a right to request deletion of personal information about them that SimioCloud has collected or maintained.

To take advantage of your right to delete, you need to submit a request by filling out the form at simiocloud.com/ccpa-access-deletion-form/..

You can also submit your request by mail or telephone.

Our telephone number is 1-866-600-3430.

Our mailing address is:

Simio Cloud, LLC
Attention:  CCPA Requests
10155 Westmoor Dr. Bldg. 3, Ste. 135
Westminster, CO 80021

To respond to your right to delete request, the CCPA permits SimioCloud to verify your identity.  We will do this by matching the personal information you supply us to the personal information we maintain about you.  In an effort to protect the consumer, we need to have a reasonably high degree of certainty you are the person you claim to be.  This may require that you submit certain personal information for us to compare and match to data we have about you.

To complete the verification process, you will be required to submit a picture of the front and back of your driver’s license as well as a photograph of you (i.e., a “selfie”). Any new personal information (for example, biometric information such as your driver’s license picture and your selfie) that we collect from you as part of your CCPA requests will only be used for the purposes of identity verification and to process your CCPA requests. SimioCloud will delete the new information collected as part of the identity verification process as soon as practical after fulfilling your request.

If we are unable to satisfactorily verify your identity, we will either request additional information as permitted by the CCPA or provide a limited response (for example, by providing a report with categories of personal information rather than specific pieces of information).  Even assuming a verifiable request, SimioCloud will retain certain personal information as necessary to comply with a legal obligation (including ensuring the deletion request is honored and CCPA record-keeping obligations). In such cases, SimioCloud will retain only the minimum amount of information that does not qualify for a statutory or regulatory exception, and only use the remaining data for the purposes provided by the statutory or regulatory exception.

RIGHT TO OPT-OUT

California consumers have a right to opt-out from SimioCloud selling their personal information for marketing purposes.

To take advantage of your right to opt-out, you need to submit a request by filling out the form at simiocloud.com/optout/.

You can also submit your request by mail or telephone.

Our telephone number is 1-866-600-3430.

Our mailing address is:

Simio Cloud, LLC
Attention:  CCPA Requests
10155 Westmoor Dr. Bldg. 3, Ste. 135
Westminster, CO 80021

 

RIGHT TO NON-DISCRIMINATION

The CCPA protects California consumers who exercise their rights from discrimination.  SimioCloud will not discriminate against consumers who request access to personal information about them, request deletion, or request that SimioCloud opt them out of future sales.

RIGHT TO USE AUTHORIZED AGENTS TO EXERCISE RIGHTS 

The CCPA allows California consumers to use authorized agents to submit requests to SimioCloud on their behalf.  SimioCloud requires that the authorized agent verify its identity and provide written authorization from the consumer to act on the consumer’s behalf.  If the agent is a business, it must also be registered with the secretary of state of the authorized agent’s state of incorporation and provide proof of such registration.

In the case of an authorized agent’s request for access to personal information, the resulting report will be delivered to the consumer directly.  Prior to any release of the report to the consumer, SimioCloud will require the consumer to complete the identity verification process described above to minimize the risk of unauthorized access to personal information and potential resulting harm. 

HOW TO CONTACT US FOR MORE INFORMATION   

If you have questions regarding your rights under CCPA or SimioCloud’s data collection, use and disclosure practices, you may contact us by phone, mail, or email.

Our telephone number is 1-866-600-3430.

Our email address is Privacy@simiocloud.com.

Our mailing address is:

Simio Cloud, LLC
Attention:  CCPA Requests
10155 Westmoor Dr. Bldg. 3, Ste. 135
Westminster, CO 80021

You may also contact the California attorney general.  Please visit https://www.oag.ca.gov/, for more information.

STATISTICAL INFORMATION 

The CCPA requires certain businesses to compile and disclose information regarding their compliance with the CCPA for the previous calendar year.  Beginning in 2021, SimioCloud will provide statistics on the following:

CCPA Reporting Requirements Metrics for Calendar Year ending December 31, 2020
Total Volume of Requests to Know Received To be updated 12/31/20
Number of Requests to Know Fulfilled To be updated 12/31/20
Number of Requests to Know Denied To be updated 12/31/20
Median Number of Days to Respond to Requests to Know To be updated 12/31/20
Total Volume of Requests to Delete Received To be updated 12/31/20
Number of Requests to Delete Fulfilled To be updated 12/31/20
Number of Requests to Delete Denied To be updated 12/31/20
Median Number of Days to Respond to Requests to Delete To be updated 12/31/20
Total Volume of Requests to Opt-Out Received To be updated 12/31/20
Number of Opt-Out Requests Fulfilled To be updated 12/31/20
Number of Opt-Out Requests Denied To be updated 12/31/20
Median Number of Days to Respond to Requests to Opt-Out To be updated 12/31/20

 

This CCPA Privacy Notice is effective December 31, 2019.
Date Last Modified:  December 31, 2019

 

Other Important Information

Accuracy: SimioCloud maintains quality control procedures to ensure the information we compile and process is as accurate and complete as possible. SimioCloud responds promptly to questions from clients and consumers about the accuracy of information.

Security: SimioCloud maintains security procedures designed to keep information we own, license and process from being accessed by any unauthorized person or business. We use a variety of multi-level security systems to control access to our products and services. All users at client locations, as well as all SimioCloud associates, must have the appropriate access codes and be authorized to access certain data and applications.

SimioCloud conducts risk assessments and regular audits on our internal and external information systems to assess our ability to maintain the integrity of client and SimioCloud data. Our enterprise security operations center maintains real-time monitoring for information system vulnerabilities and unauthorized access attempts into our internal systems. We also maintain physical security for our facilities and limit access to certain critical areas of our business.

We take reasonable precautions to ensure that our security procedures are adequate for the protection of our computer systems and data, but this does not eliminate the possibility that our security will be breached. If a security breach causes SimioCloud leadership to believe individual consumers are at actual risk for identity theft or other fraudulent activities that may cause substantial harm or inconvenience to consumers or if such breach otherwise requires public notification, SimioCloud will post a security alert notice on our website (www.simiocloud.com) that will provide relevant information for consumers and SimioCloud clients to consider to protect against fraudulent and other harmful actions that may result from the unauthorized access.

Privacy Policy Changes: From time to time SimioCloud may update and revise our privacy policy based on changes in our business environment and changes to applicable law. We urge consumers and clients to periodically visit our website to understand any changes that may have occurred.

Our privacy policy contains an “effective date” reflecting when the last changes occurred.

 

Effective Date: March 9, 2020