Privacy Policy

1. Introduction

This Privacy Policy describes how SimplAI Product LLC (“SimplAI Product,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you visit simplaiproduct.com (the “Site”), submit a form on the Site, sign up for our email list, request a demo, or otherwise interact with the Site.

This Privacy Policy applies only to the Site. It does not apply to the THREADS PM application or to data you submit while using that application. Your use of the THREADS PM application is governed by a separate Beta Terms and Conditions agreement, which contains its own data and confidentiality provisions.

By using the Site, you acknowledge that you have read and understood this Privacy Policy. We may update this Privacy Policy at any time by posting a revised version at this URL. The revised Privacy Policy takes effect upon posting. Your continued use of the Site after a revision is posted constitutes your acceptance of the updated Privacy Policy.

2. Who We Are

SimplAI Product LLC is a Virginia limited liability company. Our contact information is:

• Mailing address: 585 Grove St, STE 145 PMB 761, Herndon, Virginia 20170, United States
• Email: info@simplaiproduct.com

3. Geographic Scope of This Policy

During the beta period, the Site and the THREADS PM application are offered only to users located in the United States and Canada. We do not direct the Site to users in the European Economic Area, the United Kingdom, Switzerland, or any other jurisdiction outside the United States and Canada, and we do not knowingly collect personal information from users located in those jurisdictions through the Site.

If you are located outside the United States or Canada, please do not use the Site or submit personal information to us through the Site.

4. Personal Information We Collect

We collect personal information that you provide to us directly through the Site, and information that is collected automatically when you visit the Site.

4.1 Information You Provide Directly

We collect the following categories of personal information when you choose to provide it through a form on the Site:

• Contact form submissions: your name, email address, company name, and the contents of your message.
• Email signup submissions: your name and email address.
• Demo request submissions: your name, email address, and company name.

We do not collect payment information through the Site. We do not collect government-issued identifiers, financial account numbers, health information, or other categories of sensitive personal information through the Site.

4.2 Information Collected Automatically

When you visit the Site, we and our service providers may collect certain information automatically through cookies, pixels, and similar technologies. This information may include:

• Your IP address and approximate location derived from it.
• Device and browser information, including operating system, browser type and version, device type, and screen size.
• Usage information, including the pages you view, the time and duration of your visit, the page that referred you to the Site, and the links you click.
• Cookie identifiers and similar technical identifiers.
• Recordings of how you interact with the Site, including mouse movements, scrolls, clicks, and the pages you view, captured by our analytics provider Microsoft Clarity. These recordings exclude form fields you type into and other content the recorder is configured to mask, but they do reconstruct a video-like view of your visit.

We do not collect biometric data through the Site. We do not use the Site to make automated decisions that produce legal or similarly significant effects about you.

4.3 Children

The Site is intended for business users and is not directed to children. We do not knowingly collect personal information from anyone under the age of 16 through the Site. If you believe a child has submitted personal information to us, please contact us at info@simplaiproduct.com and we will delete the information.

5. How We Use Personal Information

We use the personal information described above for the following purposes:

• To respond to inquiries you submit through the contact form.
• To send you information you request, including demo scheduling, beta access information, and related follow-up communications.
• To send marketing communications about THREADS PM, the THREADS framework, related products, events, and educational content, where you have signed up for our email list.
• To operate, maintain, secure, and improve the Site.
• To analyze how the Site is used so we can improve content and performance.
• To prevent fraud, abuse, and security incidents involving the Site.
• To comply with legal obligations and enforce our Website Terms of Use.

We rely on the following legal bases for processing personal information of Canadian users under PIPEDA and Quebec Law 25: your consent when you submit a form or sign up for our email list; our legitimate business interests in operating, securing, and improving the Site; and compliance with legal obligations. You may withdraw consent at any time as described in Section 9 below.

6. Cookies and Analytics

We use cookies and similar technologies on the Site. A cookie is a small text file stored on your device that helps the Site remember information about your visit.

6.1 Categories of Cookies We Use

• Strictly necessary cookies: required for the Site to function. These cannot be turned off.
• Analytics cookies: help us understand how visitors use the Site so we can improve it.
• Functional cookies: remember choices you make on the Site, such as form preferences.

6.2 Analytics and Marketing Service Providers

We use the following third-party services to operate the Site, send email, and analyze usage. These providers process personal information on our behalf under contractual obligations:

• Web analytics: Microsoft Clarity, which provides website usage statistics, heatmaps, and session recordings of visitor interactions with the Site.
• Email marketing and form processing: HubSpot, which hosts our contact form, demo request form, email signup form, and email marketing list.
• Hosting and infrastructure: Microsoft Azure, with primary data storage in the United States.

6.3 Your Cookie Choices

The Site does not currently use a cookie consent banner. Cookies, including those set by Microsoft Clarity and HubSpot, are placed on your device when you visit the Site. You can control cookies through your browser settings. Most browsers allow you to refuse all cookies, accept only first-party cookies, or be notified when a cookie is set. Refusing cookies may affect how the Site functions for you.

If you wish to opt out of Microsoft Clarity's analytics specifically, you can do so by enabling the “Do Not Track” setting in your browser, by using a browser extension that blocks Clarity, or by contacting us at info@simplaiproduct.com to request that we exclude your visits from Clarity tracking.

7. How We Share Personal Information

We do not sell personal information collected through the Site. We do not share personal information collected through the Site for purposes of cross-context behavioral advertising or targeted advertising as those terms are defined under the Virginia Consumer Data Protection Act.

We share personal information only in the following circumstances:

• Service providers. We share personal information with the third-party providers identified in Section 6.2 and with other vendors that support Site operations, in each case under contracts that limit their use of the information to the services they provide to us.
• Legal requirements. We may disclose personal information if required to do so by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of SimplAI Product, our users, or others.
• Business transfers. If SimplAI Product is involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction. We will provide notice before personal information is transferred and becomes subject to a different privacy policy.
• With your consent. We may share personal information for any other purpose that we describe to you and to which you consent.

8. Data Retention, Storage, and Security

8.1 Retention

We retain personal information collected through the Site only for as long as necessary for the purposes described in this Privacy Policy or as required by law. Specifically:

• Contact form, email signup, and demo request submissions are retained while the inquiry is open and for a reasonable follow-up period afterward, generally not more than three years from your last interaction with us, unless you ask us to delete them sooner or unless we are required to retain them longer to meet legal or contractual obligations.
• Email subscribers can unsubscribe at any time. After you unsubscribe, we retain a record of the unsubscribe request to honor your choice and to demonstrate compliance.
• Analytics data is retained for the period set by our analytics provider, generally not more than 26 months.

8.2 Storage

Personal information collected through the Site is stored on systems operated by our hosting and service providers, primarily in the United States.

8.3 Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These safeguards include access controls, encryption in transit, vendor security review, and limits on who can access personal information. No method of transmission over the internet or electronic storage is fully secure, and we cannot guarantee absolute security.

8.4 Data Breach Notification

If we become aware of a security incident affecting personal information that creates a real risk of significant harm under PIPEDA, a risk of serious injury under Quebec Law 25, or that triggers notification obligations under Virginia or other applicable law, we will notify affected individuals and regulators in accordance with the timelines required by those laws. We maintain an internal record of qualifying security incidents.

9. Your Privacy Rights

9.1 Rights Under the Virginia Consumer Data Protection Act

If you are a Virginia resident, you have the following rights with respect to personal information we control about you:

• Right to confirm and access. You may ask us to confirm whether we are processing personal information about you and to provide a copy of that information.
• Right to correct. You may ask us to correct inaccuracies in your personal information.
• Right to delete. You may ask us to delete personal information you provided to us or that we obtained about you.
• Right to portability. You may ask us to provide a copy of the personal information you provided to us in a portable, readily usable format.
• Right to opt out. You may opt out of the processing of personal information for purposes of targeted advertising, the sale of personal information, or profiling that produces legal or similarly significant effects. We do not engage in any of these activities through the Site, but we honor opt-out requests as a matter of practice.
• Right to appeal. If we decline to take action on your request, you may appeal that decision by contacting us at info@simplaiproduct.com with the subject line “Privacy Appeal.”

9.2 Rights Under Canadian Federal Law (PIPEDA)

If you are a Canadian resident outside of Quebec, you have the following rights under the Personal Information Protection and Electronic Documents Act:

• Right of access. You may ask us to confirm what personal information we hold about you and how it is being used and disclosed.
• Right to correction. You may ask us to correct inaccurate or incomplete personal information.
• Right to withdraw consent. You may withdraw consent to our collection, use, or disclosure of your personal information, subject to legal or contractual restrictions and reasonable notice.
• Right to challenge compliance. You may file a complaint with us about how we handle personal information, and you may also contact the Office of the Privacy Commissioner of Canada.

9.3 Rights Under Quebec Law 25

If you are located in Quebec, you have the following rights under the Act respecting the protection of personal information in the private sector, as amended by Law 25:

• Right to be informed. You have the right to know what personal information we collect, why we collect it, and how it is used.
• Right of access. You may request a copy of personal information we hold about you.
• Right to rectification. You may ask us to correct inaccurate, incomplete, or ambiguous personal information.
• Right to data portability. You may request a copy of computerized personal information you provided to us in a structured, commonly used technological format.
• Right to de-indexation and cessation of dissemination. You may ask us to stop disseminating your personal information or to de-index it where dissemination causes you injury or contravenes the law.
• Right to withdraw consent. You may withdraw consent to our processing of your personal information at any time.
• Right regarding automated decision-making. Where we use personal information to render a decision based exclusively on automated processing, you have the right to be informed of that fact and to submit observations. The Site does not currently use automated decision-making of this kind.

Privacy Officer. Quebec Law 25 requires us to designate a person responsible for the protection of personal information. Our designated Privacy Officer is:

• Name: Grant Elliott
• Title: Chief Executive Officer
• Email: info@simplaiproduct.com

9.4 How to Exercise Your Rights

To exercise any of the rights described above, contact us at info@simplaiproduct.com with the subject line “Privacy Request.” Please describe the right you wish to exercise and provide enough information for us to verify your identity and locate your information. We will respond within the time periods required by applicable law, generally within 30 days of receiving a verifiable request, with the possibility of an extension where permitted.

We do not charge a fee to process your request unless it is excessive, repetitive, or manifestly unfounded. We will notify you in advance if a fee will apply.

You will not be discriminated against for exercising any of your privacy rights.

10. Do Not Track Signals

Some browsers transmit “Do Not Track” signals. We do not have a Site-wide response to these signals because there is no consistent industry standard for how to interpret them. However, Microsoft Clarity, our analytics provider, honors browser “Do Not Track” settings, so visitors who enable that setting will not have their sessions recorded by Clarity. Other than this, we treat all visitors consistently as described in this Privacy Policy.

11. Third-Party Links

The Site may contain links to third-party websites and services that we do not operate. This Privacy Policy does not apply to those websites or services. We are not responsible for the privacy practices of third parties, and we encourage you to read their privacy policies before providing personal information.

12. THREADS PM Beta Application

The Site provides links to the THREADS PM beta application. The application is a separate product with its own terms and privacy practices. Data you submit to the application, including any inputs that may be routed to third-party large language model providers, is governed by the Beta Terms and Conditions posted at simplaiproduct.com/beta-terms, not by this Privacy Policy.

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the Effective Date at the top of this policy and post the updated version at simplaiproduct.com/privacy. For material changes, we will provide additional notice, which may include a banner on the Site or an email to subscribers.

Your continued use of the Site after the updated Privacy Policy is posted constitutes acceptance of the updated terms, consistent with our Website Terms of Use. If you do not agree with the updated Privacy Policy, you should stop using the Site.

14. How to Contact Us

If you have questions about this Privacy Policy, wish to exercise a privacy right, or believe we have not handled your personal information appropriately, please contact us:

• SimplAI Product LLC
• Attn: Privacy
• Address: 585 Grove St, STE 145 PMB 761, Herndon, Virginia 20170, United States
• Email: info@simplaiproduct.com

If you are not satisfied with our response, you may also contact the appropriate regulator:

• Virginia residents: the Office of the Attorney General of Virginia.
• Canadian residents (federal): the Office of the Privacy Commissioner of Canada at priv.gc.ca.
• Quebec residents: the Commission d’accès à l’information du Québec at cai.gouv.qc.ca.

15. Governing Law

This Privacy Policy is governed by the laws of the Commonwealth of Virginia, without regard to its conflict-of-laws principles. Any disputes arising out of or relating to this Privacy Policy are subject to the exclusive jurisdiction of the state and federal courts located in Virginia, except that this provision does not limit the rights of Canadian users under PIPEDA or Quebec Law 25 to bring claims in their home jurisdictions where applicable law so provides.