It's that time of year again, Smiles Davis!

(The time of year where we show up in your inbox to share with you our annual notice of privacy policy updates and remind you about Regulation E.) This time, brought to you by Simple’s pets. Much excitement!

As always, we’ll quickly run you through the changes we’ve made to our privacy policy before diving into the helpful and yet also lengthy Regulation E. As you read through, you’ll get a special treat (illustrations of our pets) as our way of saying thanks for reading. Let’s begin!

Oh hey, privacy policy updates

As you may know, your Simple account was issued and is backed by BBVA Compass (that’s why every email you get from us says that in the footer). Simple’s Privacy Policy and BBVA Compass’ Privacy Practices explain the type of info we collect and how we use it. In short, we don’t sell your data to anyone. Ever. We do use it to meet legal requirements and to make Simple better.

New this year in Simple’s Privacy Policy:

• In the "Information From Other Sources" section, we clarified that we can use info we gather from other sources to verify eligibility for products and services.
• We've changed a few things in the "Information We Collect Automatically from our Services" section:
• In the "Device Information" subsection, we note that we may collect other info from your device to detect and prevent fraud, including your device's battery life, if the device is moving, and its camera capabilities.
• In the "Location Information" section, we clarify that we collect your precise location per your device's permission settings. Also, we note that we may use your IP address to get your approximate location.
• We created a new "Stored Information" section. This section lists out what stored info on your device we can access per your device's permission settings, including your contacts and photos (for things like adding a photo to a transaction, for instance).
• In the "Information Collected by Cookies and Other Tracking Technologies" section, we removed a reference to "other websites" because Simple does not track you across third-party sites.
• In the "Location Information" subsection of the "Your Choices" section, we updated language to match the edit in the "Information We Collect Automatically from our Services" section and also clarify that you can turn off location information collection at any time.
• In the "Analytics and Advertising Services Provided by Others" section we added a bit about how the analytics services we use may use device identifiers to collect info about your use of online services, including your mobile network and time spent in apps. Also, depending on your mobile device capabilities, you may be able to opt out of having certain info collected for behavioral advertising purposes.

Reg E, so helpful and also so long

Regulation E is the bit of banking legalese that lets you know exactly how we handle fraud on customers’ accounts. It’s really important stuff for you to know, which is why we’re required to remind you about it each year. It can also be a bit tough (and frankly, boring) to read, so follow along with us and we’ll translate it into human-speak as we go.

• We presently offer many bank services that may be considered "Electronic Fund Transfers," including, but not limited to, Automated Teller Machine ("ATM") transactions through the STAR®, PLUS® or Allpoint® acceptance marks / networks; point-of-sale ("POS") transactions; ACH transactions, including, but not limited to, direct deposits and preauthorized withdrawals; automated telephone transfers; and online transfers.

Translation: This first bit—so full of acronyms (as legalese is wont to be)—sums up the common ways you can move money into and out of your Simple account through card swipes, transfers, and ATMs.

• Tell us AT ONCE if you believe your Card and/or PIN has been lost or stolen. Telephoning is the best way of keeping your possible losses down. You could lose all the money in your account. If you tell us within two (2) business days after you learn of the loss or theft of your Card and/or PIN, you can lose no more than $50 if someone used your Card and/or PIN without your permission. If you do NOT tell us within two (2) business days after you learn of the loss or theft of your Card and/or PIN you could lose as much as $500.
• Also, if your statement shows transfers that you did not make, tell us at once. If you do not tell us within sixty (60) days after the statement was made available to you, you may not get back any money you lost after the sixty (60) days if we can prove that contacting us would have prevented the loss. If a justified reason kept you from notifying us (appropriate documentation may be required), we will extend the time periods.

Translation: If you think your card has been lost or stolen, block it in the app and let us know by calling us ASAP. Acting fast is important to protect your info and your money. The longer you wait, the more money you might lose. This is a rule designed to prevent common types of bank fraud.

• If you believe that your Card or PIN has been lost or stolen or that someone has transferred or may transfer money from your account without your permission, immediately contact the Customer Relations team at +1 888-248-0632. You may be required to confirm the information provided by writing to us at the following address:

• Simple Finance Technology Corp
  PO Box #28462
  Portland, OR 97228
  Phone: +1 888-248-0632
  https://www.simple.com

Translation: Though it’s definitely not likely, there may be times in which you have to write us a real letter on actual paper (really!) to officially document fraudulent activity on your account. We don’t get a ton of letters here at Simple, so we promise we’ll cherish it forever (and also we’ll work to take care of your situation).

• If you believe an Electronic Fund Transfer transaction was processed in error or was unauthorized, or if you need more information about a transfer listed on your statement or receipt, you must contact Simple no later than 60 days after we sent the FIRST statement on which the problem or error appeared.
• (1) Tell us your name and account number (if any).
• (2) Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information.
• (3) Tell us the dollar amount of the suspected error.
• (4) If you tell us orally, we may require that you send us your complaint or question in writing within 10 business days.
• We will determine whether an error occurred within 10 business days after we hear from you and will correct any error promptly. If we need more time, however, we may take up to 45 days to investigate your complaint or question. If we decide to do this, we will credit your account within 10 business days for the amount you think is in error, so that you will have the use of the money during the time it takes us to complete our investigation. If we ask you to put your complaint or question in writing and we do not receive it within 10 business days, we may not credit your account.
• For errors involving new accounts, point-of-sale, or foreign-initiated transactions, we may take up to 90 days to investigate your complaint or question. For new accounts, we may take up to 20 business days to credit your account for the amount you think is in error.
• We will tell you the results within three business days after completing our investigation. If we decide that there was no error, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation.

Translation: This might sound anticlimactic, but all of those words just let you know what happens when you get in touch with us about suspected fraudulent activity, and what info we’ll need from you in order to investigate. Basically: you get in touch with us, tell us a few important things, and then we figure out what happened, let you know, and work to fix it.

And that wraps things up. Really. Like, we’re done. If you made it this far, rest assured knowing that you know more about the ins and outs of Electronic Fund Transfers regulation than most. (Also, you get one last pet illustration if you scroll down!)

May the rest of your day be free of legalese,

— The Team at Simple