Privacy Policy

Last updated: January 23rd, 2023

Headquarters for Simple, Inc., a California corporation with its principal offices at 11622 El Camino Real, San Diego, CA 92130 United States, ("HQ Simple", “HQSimple”, "us", "we", or "our") operates the www.hqsimple.com website (the “Site”) and provides employer of record, payroll, human resources consulting, and related services (the "Service"), which is available through the Site.

This Privacy Policy informs you of how information about you is collected, used and disclosed by us when you access our Site and our Service. By using the Service and Site, you agree to the collection and use of your information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy

Policy have the same meanings as in our Terms of Service.

Information Collection

While accessing our Site and/or using our Service, we collect and store certain information about you. Some of this information can be used on its own or in combination with other information to identify you ("Personal Information"). Below is a list of types of Personal Information that we may collect and use when you apply for, or use any of our products or services.

Type of personal information	Description
Contact	Your name, addresses, e-mail addresses, phone numbers and other ways in which to contact you
Payment	Payment card number, expiration date, security code and billing address. Routing and account number.
Transactional	Details about the transactions you carry out and the payments to and from your accounts with us
Contractual	Details about the products or services we provide to you
Locational	Data we get about where you are. This may come from your mobile phone or the place where you connect a computer to the internet. It may also include locations where you used your card.
Behavioral	Details about how you use our Services and Site
Technical	Details on the devices and technology you use
Communications	What we learn about you from communications between us.
Public and third-party records	Details about you that are in public records and information about you that is publicly available on the internet. We also collect information about you which we receive from other companies, such as (without limitation) credit reference or fraud protection agencies (see below for more information).
Usage data	Other data about how you use our products and services
Documentary data	Details about you that are stored in documents in different formats, or copies of them. This could include things like (without limitation) your passport, driver’s license, photographs, or birth certificate.
Consents	Any permissions, consents or preferences that you give us

Where we collect personal information

We may collect personal information about you or your businesses from any of these sources:

Data we collect when you use our products or services

Payment and transaction data
Profile and usage data (including, without limitation, your security details, app or your website browser settings, marketing choices and data from the devices you use to connect to our Platform so we can provide you with our products or services).
We also use cookies and other internet tracking software to collect data while you are using our website or mobile apps (or any other device as described in more detail below

Data from third parties

Companies and business partners that introduce you to us
Our service partners, such as PSP partners as defined in HQ Simple’s terms
Our third-party vendors, including (without limitation) those that help us authenticate your identity
Social networks and other technology providers (for instance, when you click on one of our Facebook, Instagram, LinkedIn, or Google advertisements)
Fraud prevention agencies
Other financial services companies (to fulfill a payment or other service as part of a contract [which they have] with you, or to help prevent, detect and prosecute unlawful acts, money laundering, and fraudulent behavior)
Public information sources such as (without limitation) Companies House
Third-party agents, suppliers, sub-contractors and advisers
Market researchers
Firms providing data services
Government, law enforcement agencies, authorities and regulatory bodies to help HQ Simple comply with its legal obligations;

Cookie Usage

Please refer to our Cookie Policy for more information.

Information Use

Below is a list of the ways that we may use your personal information and our reasons for doing so:

What we use your personal information for	Our reasons
Serving you
Managing our relationship with you or your business Developing and carrying out marketing activities Studying how our customers use products and services from HQ Simple Communicating with you about our products and services	Fulfilling HQ Simple’s contract with Users When it is HQ Simple’s legal duty When Users consent to it When it is in HQ Simple’s legitimate interest: Keeping our records up to date Working out which of our products and services may interest you and telling you about them Developing products and services, our pricing for them, and types of customers that may want to use them Asking for your consent when we need it to contact you
Improving our business
Testing new products Improving our products and services Managing how we work with other companies that provide services to us and our customers Developing new ways to meet our customers’ needs and grow our business	Fulfilling HQ Simple’s contract with Users When it is HQ Simple’s legal duty When Users consent to it When it is in HQ Simple’s legitimate interest: Being efficient about how we fulfill our legal and contractual duties Asking for your consent when we need it to contact you Developing products and services, our pricing for them and types of customers that may want to use them. This may include sending questionnaires and surveys as well as requesting feedback from existing customers
Marketing and events-related communications
Communicating HQ Simple’s products, services, invite you to participate in events or surveys, or otherwise communicate with you for marketing purposes with the consent requirements of applicable law	When Users consent to it When it is in HQ Simple’s legitimate interest: Being efficient about how we fulfill our legal and contractual duties
Managing our operations
Delivering HQ Simple’s products and services Making and managing payments Managing fees and charges due on user accounts Collecting and recovering money that is owed to HQ Simple	Fulfilling HQ Simple’s contract with Users When it is HQ Simple’s legal duty When Users consent to it When it is in HQ Simple’s legitimate interest: Being efficient about how we fulfill our legal and contractual duties Complying with rules and guidance from regulators
Crime prevention and managing risks
Identifying, investigating, reporting and preventing fraud, money laundering and other crime Managing risk for us and our Users Complying with laws and regulations Investigating and responding to complaints and feedback	Fulfilling HQ Simple’s contract with Users When it is HQ Simple’s legal duty When Users consent to it When it is in HQ Simple’s legitimate interest: Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect Being efficient about how we fulfill our legal and contractual duties Complying with rules and guidance from regulators
Business management
Operating our business in an efficient and proper way, including managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit Carrying out our obligations arising from and exercising our rights set out in our contracts	When it is HQ Simple’s legal duty When it is in HQ Simple’s legitimate interest: Being efficient about how we fulfill our legal and contractual duties Complying with rules and guidance from regulators Fulfilling HQ Simple’s contract with Users

Communications

We may contact you with newsletters and other marketing information that may be of interest to you. You may opt out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. Please note that we may still send you transactional or administrative messages related to the Service even after you have opted out of receiving marketing communications.

Information Sharing with Third Parties

We will only share your information with the third parties listed below for the purposes described above in the “Use of Your Information” Section, unless otherwise noted at the point of collection:

Third-party agents, partners, and service providers who are only permitted to use your information as we allow, which may include contacting you on your behalf, and are required under law or contract to keep your personal information confidential. Information is shared to help us provide the Service.
Government agencies and taxing authorities, as required to provide the Service, including but not limited to the Internal Revenue Service, federal, state and local tax agencies, and state and federal regulatory agencies.
Insurance carriers and other third parties, as needed to carry out the Benefits Service
Banking and financial institutions.
Certain parties as necessary to respond in good faith to legal process where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.
Legal and financial advisors and auditors
The following third-parties under the circumstances described below:

we may share business or personal information with credit bureaus, and we may share information with certain companies, banks and organizations for purposes such as fraud prevention or determining eligibility for the Service;
if you participate in a referral program, the referral email and referral link sent to any Referred Leads may include your first name;
if there is a sale of HQ Simple (including, without limitation, a merger, stock acquisition, sale of assets or reorganization), or in the event that HQ Simple liquidates or dissolves, we may sell, transfer or otherwise share some or all of our assets, which could include your information, to the acquirer;
we may share de-identified personal information with academic institutions to perform research, under controls that are designed to protect your privacy—including requiring such institutions to operate under confidentiality agreements and mandating that published findings contain only de-identified and aggregated data;
from time to time, we may share reports with the public that contain anonymized, aggregate, de-identified information and statistics; and
we may share your information with certain other third parties with whom you, your Client, or your Client’s accountant partner expressly authorize us to share your information

How long we keep your personal information

We will keep your personal information as long as you are a User of HQ Simple.

We may keep your personal information for up to 10 years after you stop being a customer. The reasons we may do this are:

To respond to a question or complaint, or to show whether we gave you fair treatment
To study customer data as part of our own research
To comply with legal rules that apply to us about keeping records. For example, the Money Laundering Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 require us to retain certain data for a minimum of 5 and a maximum of 10 years.
We may also keep your data for longer than 10 years if certain laws mean that we cannot delete it for legal, regulatory, or technical reasons.

Security

The security of your Personal Information is important to us. However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you. You are also a key stakeholder in making sure that your Personal Information is protected. If you become aware of any breach of security or privacy, please contact us immediately.

International Transfer

Information collected while you use the Site and/or Service, including your Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the information, including your Personal Information, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such Personal Information represents your agreement to that transfer.

Link To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

We do not knowingly collect Personal Information from Children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verifiable parental consent, we will take steps to remove that information from our servers.

California Privacy Rights

This section provides additional details about the personal information we collect about California consumers as well as the rights of California consumers under the California Consumer Privacy Act (CCPA).

California residents that have an established business relationship with us can request a notice disclosing the categories of Personal Information we have shared with third parties during the preceding calendar year for the third parties’ direct marketing purposes. To make such a request from us, if entitled, please use the contact information listed below.

Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:

the categories and specific pieces of personal information we have collected about you;
the categories of sources from which we collected the personal information;
the business or commercial purpose for which we collected the personal information;
the categories of third parties with whom we shared the personal information; and
the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.

Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place. As described in Advertising, we do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site visitors.

Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and Service that you do not wish such operators to track certain of your online activities over time and/or across different websites. We do not support Do Not Track requests at this time.

To submit a request to exercise any of the rights described above, you may contact HQ Simple at legal@hqsimple.com. We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required.

Changes To This Privacy Policy

This Privacy Policy is effective as of the “LAST REVISED” date specified at the top of this Privacy Policy and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, and/or by placing a prominent notice on the Site and/or Service.

Questions or Concerns Regarding the Privacy Policy

If you have questions or concerns regarding privacy using our Service, please contact us at: legal@hqsimple.com.

For European Union Residents:

We collect, process, use and are responsible for certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation (EU) 2016/679 (GDPR) which applies across the European Union and EEA (including in the UK), and the Data Protection Act 2018 (together with the DPA).

For individuals residing in the EU please contact our EU Representative with any requests you may have either by emailing legal@hqsimple.com or addressing it to the Data Privacy Lead at 11622 El Camino Real, San Diego, CA 92130 United States.

Data Transfers from the EU, UK and Switzerland

When transferring data from the European Union, the European Economic Area, the UK, and Switzerland, HQ Simple relies upon the Standard Contractual Clauses.

HQ Simple commits to cooperate with EU and UK data protection authorities and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU, the UK, and Switzerland in the context of the employment relationship.

Under applicable privacy regulation, as of May 25, 2018 you may have some or all of the following rights in respect of your personal information:

to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;
to rectify inaccurate personal information;
to erase your personal information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim;
to challenge processing which we have justified on the basis of our legitimate interest;
to object to decisions which are based solely on automated processing or profiling;
to obtain a portable copy of your personal information, or to have a copy transferred to a third party controller; or
to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.

In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection. You also have the right to withdraw your consent to the processing of your information at any time. We may ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. We reserve the right to charge a fee where permitted by law. We may also decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.