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: 

Stephan Zimprich

Fieldfisher Tech Rechtsanwaltsgesellschaft mbH

Address: Amerigo-Vespucci-Platz 1, 20457 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:

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:

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:

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:

1. a) consent of the user;
2. 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 February 2026