PRIVACY POLICY
General
Somplo Ltd. (“Somplo”) is a digital advertising technology company. Somplo values and respects your privacy, either as a visitor of Somplo’s website, or as a viewer of advertisements based on products and/or technology of Somplo, or as a client of Somplo’s advertising system platform.
This Privacy Policy provides a full disclosure regarding the information and data collected from you by Somplo through the website http://somplo.com, email addresses hello@somplo.com, support@somplo.com, our social media accounts such as Twitter, Facebook, LinkedIn (“social media accounts”), phone and video calls, and via cooperation in our offices, or that you provide through mobile or web services or mobile or web software, and the way such information is used by Somplo on its website, via advertisements which use Somplo’s technology or on products across a variety of websites and/or applications owned by third-party publishers and advertisers (“Somplo’s Services”).
By using or accessing any of Somplo’s Services via any sort of electronic device, you agree to the Privacy Policy of Somplo outlined herein. The use of your information collected via Somplo’s Services is subject to this Privacy Policy, as so you are advised to review this Privacy Policy carefully.
Depending on your role as a visitor of Somplo’s website, or as a viewer of advertisements based on products and/or technology of Somplo, or as a client of Somplo’s advertising system platform, Somplo may collect a different dataset about you. You can learn more about the data that is being collected in the section “Use of Information”, where you can find a spreadsheet dedicated to your role.
You may contact us using the following details:
Headquarters
30 Shacham, 1st Floor,
Petah Tikva,
Israel 4951726, IL
Somplo Ukraine
Gagarinske plato 5,
Office 1004,
Odesa, UA
Our external Data Protection Officer: Privacity GmbH
Address: Neuer Wall 50, 20354 Hamburg, Germany
Our email: hello@somplo.com, support@somplo.com
Somplo participates in the IAB Europe Transparency and Consent Framework and сomplies with its Specifications and Policies. Somplo’s number within the framework is 1005.
Personal Data
Personal Data means any information relating to you and helping identify you (directly or indirectly) such as your name, last name, your address, email, phone number, location data, etc. (the “Information”).
We may collect different types of Information in connection with our Website and services and process it in accordance with this Policy. We may collect your Information through the Website, email, social media accounts, via other ways of communication, and from third parties. It should be clarified that you are not legally required to provide Somplo with any of your personal data.
We detailed the types of personal data processed, legal bases we rely on to do so and third parties with whom we may share your personal data in the “Use of Information” section of this Policy.
With respect to the data we collected and processed about you, we act as a data controller or joint controller.
We do NOT use automated decision-making and profiling based solely on automated processing, which produces legal effects concerning individuals or similarly significantly affects them.
We do not sell your data. We do not intentionally collect and process any sensitive personal data.
Use of Information
If you are our Website Visitor
The Information collected by Somplo about website visitors may be processed for the purposes of:
Purposes | Type of Information | Legal Grounds | Third Parties Recipients |
(a) enabling the functionality of the website; (b) preventing any fraudulent actions or intervention of the malware and improving our technical and information security measures; (c) improving, updating, fixing and operating of Somplo’s website; | Identifiers: IP address, data obtained from the cookies. Usage data: access time, address of the requested page, information about the user’s browser (or another program through which the website is accessed), etc. | Our legitimate interest (Article 6(1)(f)) | Third Parties Recipients are described in the corresponding table in the “Cookies and Other Tracking Technologies” section of this Policy |
(d) tracking users’ behavior for analytical purposes; (e) allowing you to use features of Somplo’s website, when you choose to do so by optimizing and analyzing your uses; | Identifiers: IP address, data obtained from the cookies. Usage data: access time, address of the requested page, information about the user’s browser (or another program through which the website is accessed), etc. | Your consent (Article 6(1)(a)) | Third Parties Recipients are described in the corresponding table in the “Cookies and Other Tracking Technologies” section of this Policy |
(f) requesting a demo via the website; (g) when you contact us via the form on the website for more information about Somplo Services. | Identifiers: full name, email address, phone number, company name, the content of the message (any additional information you choose to share with us), data obtained from the cookies. Usage data: access time, address of the requested page, information about the user’s browser (or another program through which the website is accessed), etc | Performance of a contract (Article 6(1)(b))
Your consent (Article 6(1) (a))
*When you provide us with personal data to book a demo, this action can be considered a request to establish or fulfil a contract with Somplo In case of uncertainty, we rely on a legitimate interest (Article 6(1)(f)), e.g. to provide support. | AWS, and Third Parties Recipients are described in the corresponding table in the “Cookies and Other Tracking Technologies” section of this Policy |
If you saw the advertisement operated by Somplo
The Information collected by Somplo about viewers of advertisements based on products and/or technology of Somplo may be processed for the purposes of:
Purposes | Type of Information | Legal Grounds | Third Parties Recipients |
(a) measure advertising performance (in alignment with the IAB Europe TCF Purpose 7) to provide the Services for our clients, including the provision of the dashboard with measurement of advertising performance. | Identifiers: IP address, user agent, ping to server, device information and the time of the ad’s view. | Our legitimate interest (Article 6(1)(f)) | Cloudflare, AWS, Fastly, IO River |
(b) develop and improve services (in alignment with the IAB Europe TCF Purpose 10) including updating, fixing and operating all of current and future Somplo’s Services. | Identifiers: IP address, user agent, ping to server, device information and the time of the ad’s view. | Our legitimate interest (Article 6(1)(f)) | Cloudflare, AWS, Fastly, IO River |
(c) ensure security, prevent and detect fraud, and fix errors (in alignment with the IAB Europe TCF Special Purpose 1). | Identifiers: IP address, user agent, ping to server, device information and the time of the ad’s view. | Our legitimate interest (Article 6(1)(f)) | Cloudflare, AWS, Fastly, IO River |
(d) deliver and present advertising and content (in alignment with the IAB Europe TCF Special Purpose 2). | Identifiers: IP address, user agent, ping to server, device information and the time of the ad’s view. | Our legitimate interest (Article 6(1)(f)) | Cloudflare, AWS, Fastly, IO River |
(e) save and communicate privacy choices including the processing of your privacy preferences obtained via TC String (in alignment with the IAB Europe TCF Special Purpose 3).
| Identifiers: IP address, user agent, ping to server, device information and privacy choices. | Our legitimate interest (Article 6(1)(f)) Processing the TC String in this case means that the choices you make regarding the purposes and entities listed in this notice are saved and made available to those entities in the form of digital signals (such as a string of characters). Our legitimate interests include enabling both this service and those entities to respect such choices. For more information, please consult IAB Europe’s Transparency and Consent Framework. | Cloudflare, AWS, Fastly, IO River |
If you have an account with Somplo
The Information collected by Somplo about clients of Somplo’s advertising system platform may be processed for the purposes of:
Purposes | Type of Information | Legal Grounds | Third Parties Recipients |
(a) negotiations, signing contracts, issuing invoices for our Services; | Contact information: full name, company name, email, phone number, address, any additional information you choose to share with us. Payment information: requisites for payments | Performance of a contract (Article 6(1)(b)) | AWS |
(b) creation and maintenance of an account; | Full name, company name, email, phone number, account password. | Performance of a contract (Article 6(1)(b)) | AWS |
(c) adding other users to the account; | Full name, company name, email, phone number, account password. | Performance of a contract (Article 6(1)(b)) | AWS |
(d) communicating with clients regarding the provision of Services, also via “Chat” and “Support” functions on the Platform; | Contact information: full name, email, phone number, social media page address. Message information: any information if it contains personal data. | Performance of a contract (Article 6(1)(b))
Legitimate interest (e.g. to provide you customer support) (Article 6(1)(f)) | AWS, Hubspot, Intercom, Instantly |
(e) sending you marketing materials about Somplo’s and Somplo’s partners’ products and services (such as emails, in-account tips, and notifications, etc.). | Contact information: full name, email address, phone number Identifiers: IP address, device information. | Your consent (Article 6(1)(a)) | AWS, Hubspot, Intercom, Instantly |
IAB Europe Transparency and Consent Framework
Please note that even though Somplo participates in the IAB Europe Transparency and Consent Framework as a Vendor, we do not collect, process or share any additional personal data of individuals served ads created using Somplo’s Services.
Transferring Information to Third Parties
In addition, Somplo may transfer Information to third parties (such as research/data aggregation companies and publishers) for marketing, analytics, and advertising purposes in order to better target your needs and create a relevant experience for you during your use of Somplo’s Services. Somplo may also transfer or assign the Information as part of a merger, sale, or other change of control in Somplo. Somplo will not sell personal data, and no Information will be disclosed to any third party except as provided in this Privacy Policy, in the applicable law and/or subpoena issued by the competent authority.
Information Collected by Other Entities
Some Information Somplo receives may be collected by third parties across several web domains you visit and applications you use, as Somplo obtains information from third parties which include clients that combine Somplo’s Services in their website or app, research entities and data management platforms. This Privacy Policy shall apply also to such Information collected by third parties. However, Somplo can’t control and is not responsible for Information collected by third parties, therefore, you should read the privacy policies of websites you visit that use Somplo’s Services in order to better understand which information such third parties collect and how it is used.
IMPORTANT: upon processing of payments using the services of a payment processor, such payment provider may collect your e-mail address, phone number, billing address, phone number, credit card details and expiry date, and other personal data it considers as necessary for the provision of services. Such collection of personal data is regulated under the rules and policies of payment processors. We are not responsible and hold no liability regarding your personal data collected by third-party websites. We advise you to access the payment processors’ websites carefully and always check their policies and rules regarding the collection of your personal data.
Social Media Information
We manage the Company’s official pages on various social media sites including, but not limited to, Facebook, LinkedIn, Instagram and YouTube. We can collect the information, including for marketing purposes, when you interact with us via our social media accounts by following our official pages, posting comments, or reacting to our content.
When you contact us via our social media accounts for assistance or leave us feedback regarding the provision of services, we can collect this information for further communication purposes. You can find a detailed description of the personal information that we may collect from you above in the ‘Use of Information’ section of this Policy.
Please note that depending on the social media platform, additional processing operations may be conducted by the operators of these platforms. We advise checking social media platforms’ privacy policies and rules regarding the collection of your personal data on their side.
Cookies and Other Tracking Technologies
This section relates to the use of cookies on Somplo’s website (https://somplo.com/) when you are a website visitor. This section does not apply in cases where you saw an advertisement operated by Somplo.
Some of the Information may be collected during your use of Somplo’s Services by log files, pixels or web beacons and browser cookies, as hereby specified.
Pixels or web beacons are small files that are files stored on apps or web pages used to track your use of and behavior in such apps or pages;
Log files are used to follow the actions taken during your use of web pages and applications and collect data such as the browser used by you, your content navigation and the time and date you use such pages and applications.
Browser cookies are small text files stored on the hard drive of your device and are generally used to (a) follow the internet pages and advertisements you were exposed to (b) record your online navigation (c) regulate the advertisements you receive.
There are two types of browser cookies divided in accordance with the category of provider, namely:
First-party cookies: cookies that are placed on the Website by the host of the domain the user is visiting which we have put in.
Third-party cookies: cookies that are placed on the Website by domains other than the one the user is visiting. As a variety of features necessary to ensure the personalised and convenient experience of the user may not be delivered by Somplo itself, third-party cookies are used.
We use both the first-party and third-party cookies. Such use may involve the transmission of information from us to you and from you to a third-party website or us.
Depending on the functionality of cookies we use three main types of cookies, including those placed by the third-party services:
Necessary: enable users to use the website by providing basic functions, e.g., ensuring security. The website cannot function properly without these cookies.
Analytics: these cookies are used to collect information about how users interact with our website (e.g., page visits and page load speed). These cookies are sometimes placed by third-party providers of web traffic analysis services.
Marketing: these cookies are used to track the visitor’s interest in a particular product, to measure the number of unique visits, and recognize returning users, and to deliver a targeted advertisement to users. These cookies are placed by us and selected third parties and enable adverts to be presented to you on third-party websites.
We use cookies and other tracking technologies for a number of purposes, namely:
- to track users’ behavior for analytical purposes;
- to enhance user experience; prevent any fraudulent actions or intervention of the malware and improve our technical and information security measures;
- to enable the functionality of the Site.
We use cookies under Article 6 of the GDPR based on the following grounds:
- a) consent of the user;
- b) legitimate interest of the Company.
We collect the necessary and preferential cookies on the basis of our legitimate interest, namely:
- to check if the user’s browser supports cookies;
- for load balancing (in order to optimize user-experience);
- to preserve user session state across page requests;
- to prevent cross-site request forgery (for security purposes);
- to detect if the visitor has accepted a marketing category in the cookie banner.
Necessary cookies are always active. Preferential cookies are off unless, for example, the user chooses to manage their preferences in another way. In this case, the preferential cookies turn on automatically to ensure the request of the user. Other cookies, namely the analytics cookies, are used only on the basis of the user’s consent.
The table below provides information about the cookies that may be used on our website (https://somplo.com/) when you are a website visitor, including details about the specific cookies, their category, retention period, the company that sets them, and other relevant information:
Cookies Opt Out
If you wish, you can choose to remove the above mentioned browser cookies stored on the web browser on your device (and if you have more than one you may do so on each of them) or refuse to accept further browser cookies by Somplo. The relevant browser cookies will be coming from one of the following domains: http://somplo.com, http://somp.me. However, if you choose to decline Somplo’s browser cookies, you may be unable to access certain parts of Somplo’s Services.
Most web browsers are by default set to accept cookies. However, you can still choose to set your browser to block or delete cookies. To modify the settings of your browser, follow the instructions included in the following links:
- Google Chrome (https://support.google.com/chrome/answer/95647?hl=en);
- Safari (https://support.apple.com/en-gb/guide/safari/sfri11471/mac);
- Opera (https://help.opera.com/en/latest/web-preferences/);
- Microsoft Edge (https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d);
- Mozilla Firefox (https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer).
Most web browsers collect fingerprint data according to its own practices and policies. We do not process such data and are not responsible for its collection and processing.
Legal Grounds for Processing
We collect and process your personal data in accordance with the provisions of the GDPR.
GDPR provides an exclusive list of lawful bases allowing us to process your personal data. During personal data processing we rely only on four of them, namely:
Article 6.1(a): consent
We collect the information you choose to give us, and we process it under your consent for marketing purposes.
You may withdraw your consent to the processing of your personal data at any time. Please remember that the withdrawal of consent does NOT automatically mean that the processing before the withdrawal is considered unlawful.
You may withdraw the consent to the processing of your personal data by sending us an email at support@somplo.com, using the suitable website’s options, or by contacting us in any other way convenient for you.
Article 6.1(f): legitimate interests
Under this legal ground, we process your personal data to:
- measure ad performance (IAB Europe TCF Purpose 7);
- develop and improve products (IAB Europe TCF Purpose 10);
- ensure security, prevent and detect fraud, and fix errors (IAB Europe TCF Special Purpose 1);
- deliver and present advertising and content (IAB Europe TCF Special Purpose 2).
Besides, we use this legal basis to process your privacy preferences obtained via TC String in connection with the IAB Europe Transparency and Consent Framework Special Purpose 3 (“Save and communicate privacy choices”).
For all the above-mentioned purposes, we use only strictly necessary data under this legal ground, and comply with other applicable GDPR requirements.
Article 6.1(b): performance of a contract
We require the minimum amount of your Information that is necessary to provide you with our Services.
Article 6.1(c): legal obligation
We process your Information to fulfill the applicable legal obligations arising mainly from the GDPR. In the event that you send us the request to fulfill the rights granted by the GDPR, we may ask you for some Information we already have to identify you and achieve compliance with the applicable law. If necessary and allowed by law, we may request additional information to identify you to proceed with your data subject request.
Data Security, Integrity, and Retention
We store and process your Information until we do not need it for any of the purposes defined in this policy unless longer storage is required or expressly permitted by law.
In any case, we store personal data we obtained from you, as described under the ‘Use of Information’ section, for no longer than 3 years from the last time we communicated with you.
We store identifiers and usage data for the period specified in the ‘Cookies’ section.
Your messages left within the social media platforms will be kept visible as long as the privacy policies of these platforms promise you.
We may not delete or anonymize your data if we are compelled to keep it under Article 30 of the GDPR and other applicable laws for the retention period prescribed by law or this Policy.
You may request to delete your Information by sending us an email at support@somplo.com.
We have implemented appropriate organizational, technical, administrative, and physical security measures that are designed to protect your personal data from unauthorized access, disclosure, use, and modification. We regularly review our security procedures and policies to consider appropriate new technology and methods.
Data Sharing and Disclosure
We may share your Information as a data controller with data processors in accordance with the provisions specified hereafter.
There are many features necessary to provide you with our Services that we cannot complete ourselves thus, we seek help from third parties. We may grant some service providers access to your personal data, in whole or in part, to provide the necessary services.
Therefore, we may share and disclose your Information to other data processors:
- Google (Google LLC, USA): to analyze data about how our Services are used in order to improve their functionality. You may read Google LLC’s Privacy Policy here.
- Cloudflare (Cloudflare Inc., USA): to help improve the performance, speed, and security of our website and Services. You may read Cloudflare’s Privacy Policy here
- AWS (Amazon Web Services EMEA SARL, Luxembourg): to build a scalable and flexible infrastructure that allows us to easily adjust our services to your needs. You may read AWS’s Privacy Policy here
- Fastly (Fastly Inc., USA): to help improve the performance, speed, and security of our Services. You may read Fastly’s Privacy Policy here.
- IO River (IO River Ltd., Israel): to help improve the performance, speed, and security of our website. You may read IO River’s Privacy Policy here.
- Hubspot (HubSpot, Inc., USA): for conducting communication with data subjects. You may read Hubspot’s Privacy Policy here.
- Intercom (Intercom R&D Unlimited Company, Ireland): for conducting communication with data subjects. You may read Intercom’s Privacy Policy here.
- Instantly (Foo Monk, LLC, USA): for conducting communication with data subjects. You may read Instantly’s Privacy Policy here.
We may disclose some of your personal data to other service providers, including our contractors and employees. To the extent applicable to us by law, we ensure the compliance of our contractors and employees with GDPR and other applicable laws and regulations.
For transfers to countries that do not fall under requirements of Article 45 of the GDPR on the adequacy of the level of protection, we may transfer your personal data to third countries outside the EU and the EEA under Article 46 of the GDPR with the appropriate safeguards, including the standard contractual clauses (SCC).
We disclose your personal data to countries outside the EU and the EEA in compliance with the standard contractual clauses (SCC) approved by the European Commission in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of natural and legal persons. We put supplementary measures in place when transferring data outside the EU and the EEA, where appropriate, for example, such as conducting transfer impact assessments (TIA) when necessary.
Children’s Privacy
Children under the age of 13 years may be exposed or use Somplo’s Services, although they are not intended for them. You must be at least 13 years old in order to use any of Somplo’s Services. Somplo does not knowingly collect Information from Children under the age of 13 years. By using Somplo’s Services, you represent that you are older than 13 years.
Your Rights
Somplo is committed to GDPR compliance. If you are a resident of the European Economic Area, you have the following rights with respect to data for which Somplo is the Data Controller:
When we act as a joint controller with regard to particular processing of personal data, you may exercise your rights under the GDPR in respect of and against other joint controllers and us.
Rights under the GDPR
- right of access means that you may ask us to send you a copy of your personal data collected together with information regarding the nature, processing, and disclosure of that personal data;
- right to rectification means that you may ask us to update and correct the false data, missing or incomplete personal data;
- right to erasure (to be “forgotten”) means that you may ask us to delete your personal data collected, except insofar it is prohibited by appropriate laws;
- right to restriction of processing means that you may ask us to restrict processing where:
your personal data is not correct or outdated;
the processing is unlawful.
- right to object to the processing means that you may raise objections on grounds relating to your particular situation;
- right to data portability means that you may ask us to transfer a copy of your personal data to another organization or you;
- right to withdraw the consent when your personal data is processed under your consent (see section “Grounds for processing”).
right to lodge a complaint with a supervisory data protection authority pertaining to the processing of your personal data.
If you are an EU resident, you may submit the complaint to the supervisory authority of your place of residence within the EU. You may consult the list with contact details of supervisory authorities here
Accessing and Deleting Your Personal Data
If, by any chance, you have provided Somplo with personal data by using Somplo’s Services, you may send Somplo an email to support@somplo.com, and request access to, correct or delete any personal data. In accordance with law, Somplo will request further personal data in order to process such a request, if necessary. Where there is an exception under the law whereby Somplo can refuse such a request, a written explanation for the refusal will be provided.
At any time, you are entitled to withdraw your consent to this Privacy Policy by sending Somplo an email to support@somplo.com and stop using all of Somplo’s Services, but such withdrawal will affect and most likely prevent the ability of Somplo to provide you with Somplo’s Services.
You have the right to submit the complaint to the supervisory authority of your place of residence within the EU or to the data protection authority. However, we would appreciate a letter with feedback from you: we want to make your experience as pleasant as it can be and will be happy to discuss your concerns.
Changes and Updates:
Please note that this Privacy Policy may be changed and amended at any time. Your continued use of Somplo’s Services is deemed to be acceptance of any terms of a newer version of this Privacy Policy provided it was published. Please make sure to review the last updated version of this Privacy Policy from time to time in order to stay informed of the last effective version of this Privacy Policy.
Contact Details
If you would like to contact Somplo due to complaints regarding the breach of this Privacy Policy or any applicable law, you may contact Somplo at the following email address: support@somplo.com .
Last Updated on September 2025