Privacy Policy

Last Updated June 26, 2019



INTRODUCTION

Welcome to A Simple Model LLC’s (“ASM”) privacy policy. ASM (referred to as “we”, “us” and “our”) respects your privacy and is committed to protecting your personal data. This privacy policy informs you about how we look after your personal data and provides information about your privacy rights and how the legislation protects you. We can be contacted regarding this privacy policy through the contact form on the contact page (https://www.asimplemodel.com/contact.aspx). We are the data controller responsible for your personal data.

ABOUT THIS PRIVACY POLICY

This privacy policy aims to give you information on how ASM collects and processes your personal data through your use of this website, including any data you may provide to us through this website.

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.

CHANGES TO this PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review and so it is important that you check this policy from time to time in order to read any amendments which we have made. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. CATEGORIES OF DATA WE COLLECT Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different categories of personal data about you, which we have grouped together as follows:

- identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;

- contact data includes billing and delivery addresses, email address and telephone numbers;

- financial data includes bank account and payment card details;

- technical data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;

- usage data includes data about how you use our website and services; and

- marketing and communications data includes your preferences in receiving marketing communications from us and our third parties and your communication preferences.

Professional history data includes education history and scores, employment history and CV’s;

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that personal data when requested, we may not be able to perform the service we are, or are trying to, provide to you. In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect personal data from and about you including through:

Direct interactions. You may provide us, directly or through uploading onto our website, with your identity, contact, financial, educational or employment data by filling in forms, submitting your CV or by corresponding with us via our website, phone, email or otherwise. This includes personal data you provide when you subscribe to a plan or create an account with us.

Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when and in the manner the relevant legislation allows us to. Most commonly, we will use your personal data in the following circumstances:

- to remember information so that you will not have to re-enter it during your next visit of the website;

- to provide custom personalized content and information;

- to monitor the effectiveness of the website and our marketing campaigns;

- to monitor aggregate metrics such as total number of visitors, users, traffic and demographic patterns;

where we need to perform the service we are providing to you;

- to communicate with you about ASM services;

- to carry out marketing and keep you informed of new services;

- to diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses or user IDs;

where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and where we need to comply with legal or regulatory obligations.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us as described below.

CHANGE OF PURPOSE

We will only use your personal data when and in the manner the relevant legislation allows us to. Most commonly, we will use your personal data in the following circumstances:

- to remember information so that you will not have to re-enter it during your next visit of the website;

- to provide custom personalized content and information;

- to monitor the effectiveness of the website and our marketing campaigns;

- to monitor aggregate metrics such as total number of visitors, users, traffic and demographic patterns;

where we need to perform the service we are providing to you;

- to communicate with you about ASM services;

- to carry out marketing and keep you informed of new services;

- to diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses or user IDs;

- where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and where we need to comply with legal or regulatory obligations.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us as described below.

COOKIES, WEB BEACONS, AND OTHER SIMILAR TECHNOLOGIES

Our website uses “cookies” and “web beacon”, “log files” technology. We use cookies and web beacons to distinguish you from other visitors, track your IP address and usage of our site, and to identify the name of the website from which you linked to our website. This information is used for fulfilling contracts with our business partners, and to help us serve you better by improving our website design, as well as our products, services and promotions. We do not otherwise track any information about your use of other websites. Non-personal data or anonymised/pseudonymised information obtained through cookies and web beacons may be shared with or obtained by service providers on our behalf.

A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available. A web beacon is a small string of code that represents a clear graphic image and is used in conjunction with a cookie.

When you visit our website, we may use both a session and a persistent cookie. This ASM placed cookie may contain information (such as a unique user ID) that is used to track your usage of our website and in some cases, your email address. Your email address is only saved in this ASM-placed cookie if you register with us. The web beacon allows us to capture certain additional types of information about a visitor’s actions on our website, such as a visitor’s cookie number, the time, date, duration and number of page views, a description of the page where the web beacon is placed, and the details about any items that were purchased.

If you register with us, this ASM-placed cookie allows us to recognise you when you return to our website and provides you with access to your account information. We may also use cookies to monitor and maintain information about your use of our website. If you have not saved your information with or ordered from us, we may monitor and maintain information about your use of our website in a manner that does not identify you.

We may use Flash Cookies (also known as Local Stored Objects) or other similar technologies. A Flash cookie is a small data file placed in a computer using Adobe Flash technology that may be built into your computer or downloaded by you to your computer. We use these technologies to personalise and enhance your online experience, facilitate processes, personalise and store your settings. Flash cookies may help our website visitors to, for example, set volume preference associated with a video experience. They help us improve our sites by measuring which areas are of greatest interest to customers. We do not use Flash cookies for marketing or behavioural targeting purposes. Flash cookies are different from browser cookies and the cookie management tools provided by your browser will not remove Flash cookies. If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain features and services that make your online experience more efficient and enjoyable.

You can disable cookies at any time by using your browser options; however, if you turn off cookies, we will not be able to track your purchases or enable you to make a purchase from our Website. In addition, we will not be able to recognise you as a registered user to allow you access to your account information. You can find out more about cookies by following this link: https://ico.org.uk/for-the-public/online/cookies/.

CHILDREN'S PRIVACY

We do not knowingly collect any data from anyone under 16 years of age. Our website and services are not intended for children under 16 years of age. If you are under 16, do not use or provide any data on this website or on or through any of its features/register on the website or provide any data about yourself to us, including your name, address, telephone number or email address. If we learn we have collected or received personal data from a child under 16, we will delete that data. If you believe we might have any data from or about a child under 16, please contact us at Peter@ASimpleModel.com.

WHO ELSE MAY HAVE ACCESS TO YOUR INFORMATION

We will not rent or sell your personal data to third parties outside of ASM, however, your personal data may be shared with third parties in the following ways;

- with ASM’s controlled subsidiaries and affiliates;

- with other users whom you have designated;

- any information or content that you voluntarily post to the website or to our Facebook page will automatically be available to the public and we may publicly post your reviews and comments online on our website or App, or link your reviews to third party websites; and/or we may aggregate or otherwise strip data of all personally identifying characteristics of our data and may share that aggregated, anonymized data with third parties;

- we may at any time transfer or assign all information, including personal data, to a third party in the course of corporate divestures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings;

- where this is required by law;

- where we determine it is necessary to conform to the law, comply with legal process or investigate, prevent, or take action regarding suspected or actual illegal activities;

- to enforce our terms of use, take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our website; or

- to exercise or protect the rights, property or personal safety of ASM, our users or others.

To best serve you, we may share your personal data with service providers that provide support services to us, including, but not limited to, PayPal for the purposes of processing payment information. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your data in any manner other than in helping us to provide you with the services available from ASM.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specific purposes and in accordance with our instructions.

COUNTRIES HAVING ACCESS TO YOUR PERSONAL DATA

We store and process your personal data on our computers and servers in the United States. We protect your personal data by maintaining physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. Whenever we transfer your personal data out of the European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it, by ensuring at least one of the following safeguards is implemented:

- where we transfer your personal data to a non-EEA country we do so under a transfer agreement which incorporates the standard contract clauses and ensures a level of protection acceptable to the European Commission. For more information, please see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en;

- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; and/or where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us at Peter@ASimpleModel.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

LINKS TO OTHER WEBSITES AND SERVICES

Our website may include links to websites, content, plug-ins or applications that are maintained by third parties (“Linked Sites”) and are not controlled by ASM and to which this privacy policy does not apply. ASM is not liable for the content of these Linked Sites, or for the offers, products or services offered by the Linked Sites. ASM advises you to carefully read the privacy policy of every website that you visit to determine how they will handle any personal data they collect from you, given that these rules can differ from our privacy policy.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

RETENTION OF YOUR PERSONAL DATA

We will only retain your personal data for as long as it is necessary to provide our services or to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

YOUR RIGHTS

You have the right to:

request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your personal data to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms;

request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it; and

withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To exercise any of the rights as listed above, please contact us at Peter@ASimpleModel.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or if additional copies of your personal data are requested. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific data from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, or to update us with your data-sharing preferences or to update your personal details, you may contact us through the contact form on the contact page (https://www.asimplemodel.com/contact.aspx).

MAKING COMPLIANT

We pride ourselves on excellent customer service, but if you would like to make a complaint about the way we have collected or used your personal data, please contact us through the contact form on the contact page (https://www.asimplemodel.com/contact.aspx).

If you are unhappy about the way we have handled your complaint and/or you would like to take the matter further or make a complaint directly to our regulator without contacting us first, you can do so by contacting your local regulator where you are based in the EEA.