Welcome to Simplyk! We hope that you will appreciate using our “Services”, which includes visiting our “Website” at https://app.simplyk.io/ or any subdomain thereof or using our “Platform” that allows “Organizations” to obtain online donations, administer event ticketing, organize peer-to-peer campaigns, publish volunteer opportunities and receive payments from Members and Contributors. In using our Services, you will fall into one of the following categories:
- “Contributor”: You are making a payment to the benefit of an Organization via the Platform and / or you are registering for tickets to an Organization’s event.
- “End User”: You are a user authorized by an Organization to use the Services through that Organization’s Account.
- “Member”: You are a Contributor or a Volunteer who has created an Account on the Platform. Please note that as a Contributor or a Volunteer, you are not obligated to create an Account.
- “Visitor”: You are visiting an Organization’s website and you fill in your name and email address on the form that is powered by Simplyk, but you ultimately decide not to complete the form.
- “Volunteer”: You are contributing without charge or compensation to an Organization and you have been referred and matched through the Platform.
- “Website Visitor”: You are browsing our Website.
In this Policy, each of a Contributor, End User, Member, Visitor, Volunteer or Website Visitor may be referred to as “you” or “your”. Please also note that these definitions are not exclusive – for example, it is possible to be both a Contributor and a Website Visitor.
Key Elements of this Policy
Here are the key elements of this Policy so you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your personal data. By submitting any personal data to us via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy.
Before we get started with the details, here are a few terms we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. These include: (1) the “GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; (2) “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada; and (3) the California Consumer Privacy Act (“CCPA”) which applies to our activities in the United States in certain circumstances. Simplyk is committed to adhering to all these applicable Data Protection laws.
“Personal data” – this is information we collect from you or about you and which is defined in the GDPR as “any information relating to an identified or identifiable natural person.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Under PIPEDA and the CCPA, the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information.
About Us and Contacting Us
The Services are owned and operated by 9355-0861 Québec Inc., the Quebec corporation that owns and operates the Simplyk Platform (“Simplyk”) and that is located in Montreal, Canada at the address listed below. Where this Policy refers to “Simplyk”, it may refer to 9355-0861 Québec Inc. and / or its shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns, depending on the context.
Under the GDPR, Simplyk is a “data controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can email:
Simplyk Privacy Officer
Here is the mailing address for you as well:
Simplyk Privacy Officer
917 Mont-Royal Avenue East
Montreal, Quebec, H2J 1X3
You have the following rights regarding your personal data held by Simplyk, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. Nevertheless, exercising certain of these rights may affect your ability to use some or all of the Services.
- The right to withdraw your consent for Simplyk to process your personal data at any time;
- The right to have your personal data erased from Simplyk’s records;
- The right to access your personal data and any relevant information around its processing and use;
- The right to have a copy of your personal data given to you in an easy-to-read format so that you can transfer it to another data processor;
- The right to have your personal data corrected or updated if you believe it is inaccurate or out of date;
- The right to opt out of marketing communications we send you at any time;
- The right to know whether Simplyk sells or shares your personal data (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarification;
- The right to demand that Simplyk not sell your personal data;
- The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law; and
- The right to refuse any marketing or advertising targeted at you by Simplyk.
If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above or refer to certain relevant sections further in this Policy.
Personal Data Collected from You and What We Use It For
In the table below, please find all the personal data we may collect from you directly, what we use it for, and the legal basis under the GDPR for us having and processing this personal data. Under PIPEDA, the legal basis is your informed consent, and by submitting this personal data you acknowledge having granted this consent to Simplyk.
Where you have provided personal data further to the contract between you and us, if you fail to provide such data or withdraw your consent to use such data, we will no longer be able to provide certain Services to you.
Personal Data Collected About You from Third Parties and What We Use It For
Sometimes we get personal data about you from third parties. This table explains the details about this personal data – what it is, where it came from, what we do with it, and the legal basis for us having and processing this personal data under the GDPR. Under PIPEDA, the legal basis is your informed consent.
To the extent that analytics identifiers are generated from third parties, these may be considered personal data collected from third parties, and you can find details about that further below in this Policy.
Sensitive Personal Data
We do not collect any of what the GDPR considers sensitive personal data from you, unless you voluntarily submit it either via the Website’s chat function or feedback form, by sending an Organization a message via the Platform or by email, which we encourage you not to do.
Who We Transfer Your Personal Data To
We routinely share some of your personal data with certain types of third parties who are identified in the table below along with what they do with it. Some of those third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area — please see the “Transfer of Your Personal Data Outside of the European Economic Area” further down in this Policy for more information including on how we safeguard your personal data when this occurs.
We will never share your personal data with other third parties except under these circumstances. We do not sell your personal data to any third party for direct marketing purposes or any other purpose.
Tracking Technology (“Cookies” and Related Technologies)
Simplyk uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) in connection with the Services and by interacting with the Services you agree to their use. Cookies are small text files placed on your computer or device when you visit a website or use an online service, in order to track use of the site or service and to improve the user experience by storing certain data on your computer or device.
- to enable your signing-in to the Platform;
- to facilitate the proper functioning of the Services;
- to facilitate online advertising, as described more fully below in this Policy;
- to provide general internal and user analytics on the Services and to conduct research to improve the content of the Services using analytics programs listed above in this Policy; and
- to assist in identifying possible fraudulent activities.
Please note that deleting or blocking certain cookies may reduce your user experience by requiring you to re-enter certain information, including information required to use our Services. Furthermore, deleting certain cookies may prevent certain functions, or the entirety of the Services, from working at all.
Simplyk Advertising and Opting Out
Simplyk uses certain advertising networks to provide advertising to you. Specifically, we use Google AdWords and Display Network and Facebooks Ads and by visiting the Website, you consent to their use. Specifically, Simplyk uses the remarketing features of Google AdWords’ interest-based advertising, which displays Simplyk advertisements that should be of particular interest to you based on your browsing and activity history interacting with the Website. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these advertisements to you. Additionally, Simplyk also uses Facebook Ads to serve you advertisements for Simplyk when you are on Facebook. You may prevent this type of advertising by deleting the appropriate Google or Facebook cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google or Facebook advertising by adjusting your Google and Facebook ad settings or by using the WebChoices online opt-out tool.
Email Communications and Compliance with Anti-Spam Laws
You may unsubscribe from the Simplyk mailing list or emails that you receive from Organizations via Simplyk (as described above) at any time, by following the link at the bottom of the Simplyk or Organization emails. Other types of emails, such as emails related to the Platform and emails that you will receive from Organizations with your tax receipts will not have an opt-out option as they are necessary for the use of the Services.
Simplyk’s practices with regard to its email are designed to be compliant with anti-spam laws, specifically the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23). If you believe you have received email in violation of these laws, please contact us using the contact information further up in this Policy.
How We Protect Your Personal Data
We have implemented very strict technical and organisational procedures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws require us to do so, and within the time frame required by the applicable Data Protection Law.
Simplyk uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Simplyk uses Amazon Web Services and Heroku, both recognized leaders in secure data, for hosting of the Services and related data, and storage of data, including personal data.
Finally, all information, including personal data, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer and transactions. You can use your browser to check Simplyk’s valid SSL security certificate.
Transfer of Your Personal Data Outside of the European Economic Area (EEA)
For our European users, we endeavour to keep your personal data inside the EEA. However, certain of our data processors (and Simplyk) are in other countries where your personal data may be transferred. However, these countries are limited to countries with particular circumstances that protect your data, specifically:
- The United States. Your personal data is only transferred to companies in the United States that: (1) have signed agreements with us or have informed us that they are GDPR-compliant; and (2) have concluded the Standard Contractual Clauses for the transfer of personal data outside the EEA.
That’s it! You have the right, however, to refuse to have your data transferred outside the EEA. Please contact our Privacy Officer to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Services.
Supervisory Authorities and Complaints
If you are in the EEA, under the GDPR you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy Officer, or if you would like to make a complaint directly about Simplyk’s data practices, we invite you to contact the supervisory authority in your country. If you are in the U.K., you should contact the Information Commissioner’s Office who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF). If you are in France, you should contact the Commission Nationale de l'Informatique et des Libertés who is the supervisory authority there. Their contact information can be found here.
Your personal data will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will only retain your End User Account Information for as long as you have an account with us. Please note that Simplyk reserves the right to retain some of your personal data for a reasonable time in order to satisfy our legal obligations or under a legal procedure of any sort.
Simplyk does not use any automated decision-making processes in providing the Services.
Children’s Privacy Statement
The Services are not intended for children under the age of 16. We do not knowingly collect any personal data from a child under 16. If we become aware that we have inadvertently received personal data from a person under the age of 16 through the Services, we will delete such information from our records.
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy, and we will update it no less than once every 12 months. You can always find the most updated version at this URL, and we will always post a notice on the Website if we make significant changes. If you have an End User or Member Account, we will also email you to tell you the Policy has been updated, and what the important changes are.