Privacy Policy

Go Simple Go Smart LLC · DRAFT 2026-08-08 · not yet effective

DRAFT — DO NOT PUBLISH BEFORE COUNSEL REVIEW.

The Terms of Service define “Privacy Policy” as a binding document and incorporate it by reference, but no such document has ever existed at any URL. This draft was written to close that gap and to be consistent with what the Terms already say — it is not a substitute for a policy drafted by your attorney.

Every bracketed item below is a fact I do not have and must not invent. Sections marked in red are substantive gaps, not wording choices.

Effective date: [TO BE SET ON PUBLICATION]
Entity: Go Simple Go Smart LLC, 106 Calendar Ave #214, La Grange, IL 60525 [address carried over from the Terms — verify against the LLC’s registered address]

This Privacy Policy explains how Go Simple Go Smart LLC (“we,” “us,” “Vendor”) handles information in connection with the GSGS Legal and GSGS Health services (the “System”). Capitalised terms not defined here have the meaning given in our Terms of Service. Where this Policy and the Terms conflict, the Terms govern.

1. Information we handle

Customer Data. As defined in the Terms, Customer Data is data in electronic form input or collected through the System by, from, or for a Customer, including by or for that Customer’s Users. In the ordinary operation of GSGS Legal and GSGS Health this includes medical records and related health information about individuals who are not our customers — typically a law firm’s client, or a provider’s patient.

Account and contact information. Names, business email addresses, telephone numbers, and billing details of Customers and Users.

Website information. [SPECIFY: what this site collects — server logs, IP addresses, analytics, cookies, form submissions. This site currently has a contact form; identify any analytics or tag installed before publication.]

GAP — HIPAA. The Terms of Service contain no reference to HIPAA, no Business Associate provisions, and no defined treatment of protected health information, despite the service being built to retrieve medical records. Counsel must determine whether Go Simple Go Smart LLC acts as a Business Associate, whether Business Associate Agreements are required with provider customers, and what this Policy must say as a result. This draft deliberately makes no HIPAA compliance claim.

2. How we use information

We use Customer Data to provide the System — locating providers, retrieving records, and delivering them to the Customer’s secure portal — and to support, maintain, secure, and improve the service, to bill for it, and to communicate with Customers and Users about it.

3. Aggregate and anonymised data

The Terms of Service (Section 4.6) permit us to use, reproduce, sell, publicise, or otherwise exploit Aggregate Data in our sole discretion. “Aggregate Data” means Customer Data from which personally identifiable information and the names and addresses of the Customer and its Users and customers have been removed.

GAP — disclosure of a commercial right. This is an existing right in your signed Terms, reproduced here because a privacy policy that omitted it would be materially incomplete. Counsel should confirm (a) whether de-identification is performed to a defined standard, (b) whether this right is compatible with the health-data context and any applicable state law, and (c) whether it should be narrowed.

4. When we share information

We share Customer Data with the Customer that provided or requested it and its authorised Users; with providers and record sources as necessary to make an authorised request on the Customer’s behalf; and where required by law or legal process.

[SPECIFY: subprocessors and vendors — hosting, storage, email, payment, analytics. A privacy policy is expected to describe these categories.]

We do not sell Customer Data. Aggregate Data is addressed in Section 3 above.

5. Retention and deletion

The Terms provide that we may permanently erase Customer Data if a Customer’s account is delinquent, suspended, or terminated for thirty (30) days or more.

[SPECIFY: retention period for Customer Data during an active relationship, for account records after termination, and for website logs.]

6. Security

We maintain administrative, technical, and physical safeguards designed to protect information in the System. Consistent with the Terms, no method of transmission or storage is completely secure, and we do not warrant that data will not be exposed or disclosed through errors or the actions of third parties.

[SPECIFY: encryption in transit and at rest, access controls, and any audit or certification you can substantiate. Do not state a control you cannot evidence.]

7. Individual rights

Most individuals whose health information moves through the System are not our customers; their records are handled at the direction of a Customer acting under an authorisation. Requests to access, correct, or delete such records should be directed to the law firm or provider that holds the relationship.

[SPECIFY: rights under applicable state law and how to exercise them. Illinois is your home state; determine whether CCPA/CPRA and other state regimes apply based on where Customers and individuals are located.]

8. Children

The System is a business service and is not directed to children. [CONFIRM: records retrieved may relate to minors — counsel should confirm how this section should read.]

9. Changes to this Policy

We may update this Policy from time to time. The Terms of Service provide that our posted policies may be updated, and continued use of the System is governed by the Terms as they and the policies then stand.

10. Contact

Questions about this Policy may be sent to legal@gosimplegosmart.com, or by mail to Go Simple Go Smart LLC, 106 Calendar Ave #214, La Grange, IL 60525.

[NOTE: the Terms designate this address for contractual notices, which are deemed received 72 hours after sending. Confirm the mailbox exists and is monitored before publication.]

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