PRIVACY POLICY

(last updated and effective January 1, 2017)

www.simple123.com

Thank you for visiting our web site. This is a web site of Best Response Strategies, LLC and its affiliates (also referred to as “BRST,” “us,” or “we”). We welcome you to www.simple123.com, and its associated pages (collectively, the “Site”). BRST is a provider of communication services connecting manufacturers, distributors, and brokers with potential business customers (collectively, along with the Site, referred to herein as the “Service” or “Services.” For clarity, the “Services” include access to the Site, and separate references to the Site may be provided for emphasis.)

Our address is:

We can be reached via e-mail at [email protected] or you can reach us by telephone at (800) 946-1520.

This policy tells you how we may use certain information that might be collected at the Site. Please read this policy before using the Site or submitting any information. By using the Site, you are accepting the practices described in this privacy policy statement. We reserve the right to make changes to this policy from time to time. You are encouraged to review the privacy policy whenever you visit this Site to make sure that you understand how any information you provide will be used.

The privacy practices in this privacy policy are for this Site only. If you follow links to other web sites, please review the privacy policies posted at those sites. We do not control the privacy policies or practices of third parties, whether advertisers, retailers, or other businesses to which we may provide referral links or other access. Embedded videos, social media, or other content may also be subject to third party policies.

Personal and Non-Personal Information

Personal information is information that is reasonably identifying of a natural person or individual, and includes information such as names, addresses, email addresses, certain telephone numbers, etc. The Site does not automatically recognize any personal information from browsing the site without registration. We may collect non-identifying or non-personal information, such as the date of a visit, an originating domain name, browser type, and pages browsed, as discussed in detail below.

In general, this Service is offered to businesses, such as manufacturers, distributors, brokers, and their customers, and not individual persons as consumers. Registration is required to use the Site, which involves the voluntary submission of information such as the name of the business, addresses, telephone numbers, payment or accounting information, and email addresses, along with any business contact information (name, address, telephone number, email address) you may provide in identifying an authorized representative of such a business. We use this information in order to provide the Service. With respect to such business, we also collect information from voluntary communications or correspondence with our customer service representatives. For example, we do collect the names (and email addresses) of those who communicate with us, and other information that may be submitted voluntarily. We may also require information that relates to our provision of the Service, such as payment information provided during registration. We will inform you what information is needed to complete a transaction or activity. If you are unwilling to provide required information, you will be unable to complete the transaction.

When you voluntarily provide information, you consent to BRST’s use of the information as described in this policy. If you do not want BRST to have this information for any reason, then please do not submit it to the Site. Please also do not submit unsolicited personal information, for example, by sending us an unsolicited email with a home address, or other such unsolicited personally identifiable information; we may not expect such a submission and may not be able to protect it.

Personal information does not include information that may have once been personal information, but has been encoded, anonymized, or aggregated to be non-identifying, or that has become publicly available information, and where such information has not otherwise been combined with non-public personal information.

In use of the Site, we may collect non-identifying or non-personal information. This is information that is not personally identifying or linked to an individual person. This information may include a user’s internet protocol (or “IP”) address, browser types, operating systems, prior or referring domain names, navigation or browsing patterns while using the Site, stored cookies, anonymous aggregated data not linked to individual users, etc. For example, non-personal information might be a search record for distributors of a certain product.

BRST may also collect information about your business, whether publicly available, received from third parties, such as marketing services or public databases, from general use patterns of the Site, or such information that may have been provided by you.

How we use information

We may use this type of information:

We may also use the information in other ways for which we provide specific notice at the time.

In your use of the Service, if you provide information to another user or other third party, we have no control over such user or third party and are not responsible for the actions of that user or third party. Such a user or third party may disclose personal information or take other actions that are inconsistent with this policy.

Information may be modified or aggregated by us or we may create derivative works from such information to distribute to our users or other third parties in a form that does not include personal information.

We do not sell or otherwise disclose personal information except as described in this notice.

Cookies and other Tracking Technology

"Cookies" are small computer files which are automatically saved by a browser when you are connect to a website or remote server, so that the website can recognize you upon your return to the website and tailor your experience based on your earlier use of the site. Cookies enable the website to remember the actions and preferences of a user (such as login, language, font size and other display preferences) over a period of time, so the user does not have to keep re-entering information whenever visiting, or browsing from one page to another.

"Action tags" (also known as Web Beacons, Trackers, or Bugs) are invisible pixel .gif files placed on web pages that are used to track web navigation to those pages. BRST does not use action tags.

BRST uses a cookie for each computer that visits its Site. The cookie is integral to the customer experience and is necessary to use the Service. It allows BRST to customize the Site presentation based on your accounts and history of use. While cookies, including BRST's, can be disabled, if you disable our cookie you will not be able to use the full functionality of the Site.

Such cookies may be used to keep track of the user’s input when filling out forms, such a shopping cart, authenticating registered users for logging in, for recording preferences selected by the user, or preferences for a third party social plug-in content-sharing, if selected by the user.

Please note, however, that third party internet advertisers or service providers may use cookies, even with their advertising on the Site. BRST is not responsible or liable for the policies and practices of these third parties, and it is your responsibility to review them and decide if you are satisfied with their protections.

Cookies are often used with interest-based advertising. Advertising networks are third parties who may direct interest-based advertisements to users based on information about online activities that have been recorded with cookies or other technologies. Some such advertisers may participate in industry programs hosting opt-out features, such as that provided with the Digital Advertising Alliance's consumer choice page:

http://www.aboutads.info/how-interest-based-ads-work

http://www.aboutads.info/choices/

You can also control the acceptance of cookies through the settings of your browser preferences. Web browsers may be set up to reject some or all cookies, such as rejecting the cookies of third party internet advertisers. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. When you turn on the Do Not Track function in your browser, we stop collecting the information from your browser that allows us to tailor advertisements and other content specifically to you that is based on your visits to our advertising partners’ websites. Specifically, we stop collecting information from the unique browser cookie that links your browser to visits to third party sites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked. Remember that this is just our Do Not Track policy, and we can’t and don’t make any promises about how third parties react when you set this signal on your browser.]

Security

BRST knows that users care about how personal information is protected and used. BRST makes reasonable efforts to keep personal information confidential, by use of physical, operational, or technical security measures. Only authorized employees, agents, and contractors (who have agreed to keep personal information confidential) have access to personal information.

When reasonably appropriate, BRST may also use industry standard security measures, such as secure communication protocols like secure socket layer or transport layer security. We will periodically consider new security technologies and will utilize them as we consider they are needed.

However, as effective as these measures may be, no security system is impenetrable. BRST does not warrant or guarantee the security of information in its databases, nor does it guarantee that the information you choose to supply will not be intercepted while you transmit it from your computer, as it passes over the Internet, and ultimately to the BRST Site and information systems.

Disclosures

For clarity, we may share personal information in confidence with third parties when reasonably necessary to perform a service or to provide a product that you have requested. We may also share personal information with government or private third parties when: (1) permitted or required by law; (2) investigating, preventing, or trying to protect against actual or potential crime, fraud, or unauthorized transactions; or (3) to comply with court orders, subpoenas, or other legal requirements. We do not sell personal information to third parties, such as for their marketing purposes.

We may freely publicize or share non-personal information, such as anonymous or aggregated data, with any third party. For example, we might advertise the number of distinct visitors to the Site.

Special Note Regarding Minors

The Site is not intended to be used by minors. We do not knowingly collect personal information from children 13 or under on our Site. In general, if you are a minor, your parent or guardian should review this Site on your behalf and you should not submit any personal information to us. If a child under 13 submits personally identifiable information and we learn that the information is the information of a child under 13, we will attempt to delete the information as soon as possible. We encourage all parents to monitor their child's use of the Internet and to discuss online safety with their child.

Questions

BRST is committed to customer service and privacy. If you have any questions, comments or concerns regarding our Privacy Policy and its implementation, please do not hesitate to email us at the address provided above. You may also reach us from your mobile phone anytime by texting "HELP" (without the quotes) to 71280, calling Customer Service at (800) 946-1520 or via our web site at www.simple123.com/.

To stop receiving text messages from us, you can opt-out of the program by texting "STOP" (without the quotes) to 71280. You will receive a one-time opt-out confirmation message. After that, you will receive no further messages from us. You may opt-out of this program at any time. Message and Data Rates May Apply. Message Frequency is dependent on user activity. This program supports the following carriers: T-Mobile©, U.S. Cellular©, Sprint, Nextel, Boost, AT&T, Alltel, Verizon Wireless, Virgin Mobile.



YOUR CALIFORNIA PRIVACY RIGHTS

(California Users)

As noted above, the Service is directed to businesses and not individual persons. To the extent an individual person uses the Service, and is a resident of California, then this section may apply.

FOR RESIDENTS OF CALIFORNIA ONLY. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of customers' personal information with third-parties. These businesses are required to accept requests for disclosures of these policies from customers but are only required to honor one request per calendar year. Businesses have thirty (30) days to respond to each inquiry to the designated address. Each inquiring customer will receive an explanation of the categories of customer information shared and the names and addresses of any third-party businesses. In limited circumstances, customers' failure to submit requests in the manner specified will not require a response from the business.

If you are a current BRST customer in California, you may request such information from BRST by sending an email correspondence noting your name, address, and email address. You must also include a request that BRST provide such information to you using the following or similar verbiage. "I request that BRST provide its third-party information sharing disclosures required by section 1798.83 of the California Civil Code." The same request may be made by regular mail by sending the above information to:

We can be reached via e-mail at [email protected] or you can reach us by telephone at (800) 946-1520.

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