Privacy Policy

Last updated: April 5, 2023

Your privacy is extremely important to us. We provide this notice to explain our privacy practices and the choices you can make about the way your information is collected and used.

This Privacy Policy relates to information collected by SimpleBlue, LLC, DBA Copper Monkey (referred to in this Privacy Policy as "Copper Monkey" "we" or "us" or "our") through your use of our website and our Services, features, and information available on our website (which are collectively referred to in this Privacy Policy as the "Service").

It describes the policies governing our knowing collection, use, and disclosure of information. In order to ensure your privacy, information we collect is used only in the manner and for the purposes described below.

1. Overview

PLEASE READ THIS PRIVACY POLICY CAREFULLY. This Privacy Notice is subject to and governed by the Copper Monkey Terms of Service (the "Terms").

By accessing or using our website you acknowledge that you have read, understand, and agree to be bound by the terms of this Privacy Policy and the website Terms of Use. The terms used in this Privacy Policy have the same meanings as in the Terms, unless otherwise defined in this Privacy Policy. You also agree that you are expressly and affirmatively consenting to our use and disclosure of the information that you provide, and consenting to receive emails, as described below in this Privacy Policy.

2. Anonymous User Information

Copper Monkey collects some anonymous information each time you visit CopperMonkey.com so we can improve the overall quality of your online experience. We may collect your IP address, referral data, and browser and platform type as well as the date and time of your visit. You do not have to register with Copper Monkey before we can collect this anonymous information. We do not collect any unique information about you (such as your name, e- mail address, etc.) except when you specifically and knowingly provide such information. We use Non-Personally Identifiable Information to troubleshoot, administer the Website, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities.

Copper Monkey does not require you to share information that identifies you personally, such as your name or email address, to browse the Copper Monkey website. Like most standard Website servers, we use log files to collect and store the anonymous user information described in this privacy policy. We analyze this information to examine trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. Copper Monkey may present links in a format that enables us to understand whether they have been followed. We use this information to understand and improve the quality of the Copper Monkey website and services. We may also share this information with authorized third-party service providers and advertisers to measure the effectiveness of our online advertising and content.

3. Personally Identifiable Information

Some activities on Copper Monkey, such as creating an account, subscribing to a service, making a purchase, signing up for email alerts or lists, responding to surveys, making a support request, submitting content, sending correspondence, or purchasing a product or service from us or our partners, may require you to provide personal information. This information may include first and last name, email address, phone number, date of birth, or other personally identifiable information listed in Section 14. If you order a product or service from us or our partners, you may be required to provide your credit card number, expiration date, authentication, and other related information. These activities are optional. If you choose not to provide information that is mandatory for a particular activity, you will not be allowed to participate in that activity.

4. Cookies

We use a feature of Internet web browsers called a "cookie," which is a small file that is sent to your computer when you visit a website. This enables us to store user preferences and track user trends and search patterns. We use cookies to improve the quality of the Copper Monkey services and to better understand how users interact with us. We do not and cannot use Cookies to retrieve individual personally identifiable information about you from your computer unless you knowingly and willingly provided such information. The cookie technology we use cannot obtain information from your hard drive or pass on a computer virus. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Copper Monkey features or services may not function properly without cookies.

5. How We Use the Information We Collect

Copper Monkey does not sell or rent any of your Personal Information.

Copper Monkey may use both Anonymous Information and Personal Information we collect about you or that you provide to us for the following purposes:

• To maximize usability of the Platform and present you with the Platform and associated content.
• To provide you with the Products or Services that you request from us. If you inquire about our Products or Services, we will use the contact information you give us to communicate with you about the Products or Services available.
• To provide, inform, and improve customer support.
• To notify you about changes to our Platform or any Products or Services
• To provide you with information about your account
• To fulfill our obligations and enforce our rights determined in any contracts entered into between you and Copper Monkey, including for billing purposes
• To personalize our Services, product offerings, and advertising
• To detect, diagnose, or resolve any Service or other technical issues
• To maintain security of the Platform, Services, user accounts or Information, or any software, hardware or any other service or infrastructure owned or operated by Copper Monkey
• To communicate with you concerning our products and Services, including for marketing purposes
In any other way indicated when you provide the Personal Information
• To fulfill any purpose for which you provide it
• For any other purpose, with your consent
• To analyze how our products and Services are used
• To develop and improve our Platform and Services
• To develop new products and Services
6. How Long We Keep Your Information

We will retain your Personal Information only as long as reasonably necessary, at our determination, to fulfill the purposes for which we collected it and consistent with applicable law. This includes for the purposes of complying with any legal, regulatory, tax, accounting or reporting requirements and for any other purposes described in this Privacy Policy.

We strive to limit our retention of personal information for the least amount of time needed. The criteria we may use to determine the specific retention period of personal information include the type of information; the reason for collection; our reasonable business purposes for processing the information; and whether retention or deletion of the information is necessary to comply with legal obligations.

We may retain your Personal Information for a longer period of time if there is a complaint associated with or submitted by you or if we reasonably believe there is a prospect of litigation related to our relationship with you.

7. Information Security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. We restrict access to your personally identifying information to employees who need to know that information in order to operate, develop or improve our services.

8. Information Sharing

We may share personally identifying information with other companies or individuals in any of the following limited circumstances. Note that Copper Monkey does not sell any of your Personal Information.

• We have your consent.
• We provide such information to trusted businesses or persons for the sole purpose of processing personally identifying information on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Privacy Policy and appropriate confidentiality and security measures.
• We may share your Personally Identifiable Information with Third Party Service Providers to fulfill orders, process credit card payments, deliver packages, send email, analyze data, provide marketing assistance, provide search results, and provide customer service. We may release personal information to credit card companies to process payments for items ordered or to banks to process payments to affiliates.
• When required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a criminal investigation, a court order, or legal process served on our website.
• We may also share your personal information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Copper Monkey' terms of use, or as otherwise required by law.
• If you have an account, we may share the information submitted under your account among all our services in order to provide you with a seamless experience and to improve the quality of our Services. We will not disclose your account information to other people or non-affiliated companies, except in the limited circumstances described in this Policy or with your consent.
• We may store and process personal information collected on our site in the United States or any other country in which Copper Monkey or its agents maintain facilities. By using our services, you consent to the transfer of your information among these facilities, including those located outside your country.
• Copper Monkey may use third party service providers to serve ads and emails on our behalf. These companies may use technologies to measure the effectiveness of ads and emails and use information about your visits to Copper Monkey so that we can provide a better experience to you. For this purpose, we may also provide these third-party service providers anonymous information about your site navigation.
• We may disclose information to third parties who assist us in providing our services to you. For example, we may engage third parties to make improvements on our site, to offer new products and to allow us to customize your experience on the Site. However, they are obligated not to disclose or use the information for any other purpose.
9. Correspondence

If you contact Copper Monkey, we may keep a record of that correspondence and we may collect your email address. We may collect any information, including Personal Information, that you provide to us in any correspondence.

10. Third Party Information Gathering

Copper Monkey includes content and ads from third parties that may perform user activity tracking other than that described herein. These other sites may place their own cookies on your computer, collect data or solicit personal information. For more information about each third-party content provider, cookies, and how to "opt-out", please refer to such third-party advertiser's privacy policy.

Copper Monkey contains links to other sites on the Web. Please be aware that Copper Monkey is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each Website that collects personally identifiable information. This privacy statement applies solely to information collected by the Copper Monkey site.

11. Google Analytics and Advertising Features

The Site may have Google Analytics and Advertising Features implemented. These may include Demographics and Interest reporting, Remarketing, or other available reporting features. These features collect data using Google advertising cookies and anonymous identifiers. Copper Monkey and third-party vendors use these first-party cookies to assess the success of online marketing campaigns and improve usability and performance on the Platform. You can see Google Analytics' available opt-outs for the web at https://tools.google.com/dlpage/gaoptout.

12. Children's Privacy

Copper Monkey does not knowingly request or collect personally identifiable information online or offline contact information from users under 18 years of age nor do we knowingly use or share personal information from users under 18 years of age with third parties.

13. California Privacy Rights

California residents have certain rights regarding their Personal Information. California law requires us to identify these rights to you. Subject to exceptions, you have:

• The right to know the categories of Personal Information that we have collected and the sources from which we obtained the Information.
• The right to know the business purposes we have for sharing Personal Information.
• The right to know the categories of third parties with whom we have shared Personal Information.
• The right to access the specific pieces of Personal Information we have collected, and the right to request the deletion of your Information.
• The right to opt-out of the sale of your Personal Information, as a "sale" is defined under the California Consumer Privacy Act of 2018 ("CCPA"), and in some cases the sharing of your Personal Information. (Note that Copper Monkey does not sell your Personal Information.)
• The right to correct your Personal Information.
• The right to restrict processing of sensitive Personal Information, such as social security numbers, passport numbers, racial or ethnic origin, and financial account and payment card information.
14. Personal Information Collected

We may collect the following Personal Information about you:

• Identifiers such as name, account name, Internet Protocol address, email address, postal address, or other similar identifiers
• Personal Information categories described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as a name, address, telephone number, or credit card number
• Commercial Information such as products or Services purchased
• Professional or employment-related information such as your business or company information
• Internet or other similar network activity such as information on a consumer's interaction with a website, application, or advertisement.
• Geolocation data
• Inferences drawn from other Personal Information
15. Categories of Personal Information Disclosed for a Business Purpose

We may disclose the following categories of Personal Information for a business purpose:

• Identifiers
• Personal Information categories described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Commercial Information such as products or Services purchased
• Professional or employment-related information
• Internet or other similar network activity
• Geolocation data
• Inferences drawn from other Personal Information
16. Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request certain information regarding Copper Monkey' disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact Copper Monkey at the email address in Section 17 below.

17. How California Residents Can Exercise Your California Rights under the CCPA

You or your authorized agent may submit a consumer rights request to us by email at privacy@coppermonkey.com Please use "CCPA CONSUMER REQUEST" as the subject line of the email. Prior to responding to your request, we will need to verify your identity and the identity of your authorized agent, if applicable. If we are unable to verify your identity through reasonable means and with the information you provide, we may ask follow-up questions. Copper Monkey will not discriminate against you for exercising any of your CCPA rights.

18. Your Choices About Information

We may send you emails informing you about new products and Services that we believe may be of interest to you. If you consented when registering to receive offers or information from us and our partners, we may occasionally call or send you direct mail about products and Services.

If you no longer wish to receive marketing or promotional communications from us, click on the "unsubscribe link" provided in such communications or send us an email to unsubscribe@coppermonkey.com.

If you opt out of receiving marketing/promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

19. Sale of Assets

In the event that another company acquires all or substantially all of the assets related to the business of Copper Monkey, we reserve the right to include any or all stored personal information among the assets transferred to the acquiring company.

20. Changes to Privacy Policy

We reserve the right to amend or revise this privacy policy from time to time. We may update our Privacy Policy from time to time. We advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page. Use of information that we gather now is subject to the privacy policy in effect at the time the information is used.