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

Henuezka 5/2,

Office 104,

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”).

It should be clarified that you are not legally required to provide Somplo with any of your personal data. Somplo will not collect your personal data unless you choose to voluntarily provide it to Somplo by email, by using or accessing any of Somplo’s Services, by participating in surveys, or by filling in online registration forms. The types and amount of personal data collected from these activities may change according to your use of Somplo’s Services.

Throughout your use of Somplo’s Services, Somplo may collect, store, use, and share Information such as your IP address (which includes receipt identification of your non-precise geographical location for aggregated website usage analytics), the operating system and browser type used by you, the web pages viewed by you through your use of Somplo’s Services, identification of your use patterns and interactions with Somplo’s Services including the number of times you were exposed to Somplo’s Services during a specific timeframe, the type of advertisements viewed by you through Somplo’s Services, your click-throughs rate, your content navigation and the time and date you used Somplo’s Services, etc. These types of Personal Data will be collected mainly by browser cookies and usage tracking as explained herein. You can learn more about the purposes of data processing in the following Section (“Use of Information”).

With respect to the data captured from 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 use the personal data we collect only for the purposes listed in this Policy. We may share your personal data with third parties solely for the purposes listed herein.

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:

Purposes	Type of Information	Legal Grounds	Third Parties Recipients
(a) providing the Services for the clients, including the provision of the dashboard with measurement of advertising performance; (b) preventing any fraudulent actions or intervention of the malware and improving our technical and information security measures; (c) improving, 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, Gcore
(d) providing means for creating relevant advertisements based on clients’ actual use of Somplo’s Services and tailor-made to your interests, at the request of the website or advertiser (e) allowing you use features of Somplo’s Services, when you choose to do so, by optimizing and analyzing your uses	Identifiers: IP address, user agent, ping to server, device information and the time of the ad’s view.	Your consent (Article 6(1)(a)) to receive cookies from the website showing you the ad We are relying on DSPs that validate that the user consented to see the ads and data collection.	Cloudflare, AWS, Gcore
(f) processing your privacy preferences obtained via TC String in connection with the IAB Transparency and Consent Framework Special Purpose 3 (“Save and communicate privacy choices”)	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, Gcore

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. Payment information: requisites for payments	Performance of a contract (Article 6(1)(b))	Cloudflare, AWS, Gcore
(b) communicating with clients regarding the provision of Services.	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))	Cloudflare, AWS, Gcore
(c) 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))	Cloudflare, AWS, Gcore

In addition, Somplo may transfer Information to third parties (such as research/data aggregation companies and publishers) for marketing, analytic, 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.

Cookies and Web Beacons

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.

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), 9(2)(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 prevent any fraudulent actions or intervention of the malware, ensure the security and functionality of our Service, debug and develop our Service, conduct service-related communications, and measure advertisement and content performance.

Besides, we use this legal basis to process your privacy preferences obtained via TC String in connection with the IAB Transparency and Consent Framework Special Purpose 3 (“Save and communicate privacy choices”). For all the above-mentioned, 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 of 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.

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 use your Information on the basis of the performance of the contract (i.e., our Terms of Service) to provide Services and communicate with you.

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.
Twitter (X Corp., USA; Twitter International Unlimited Company, Ireland): to follow our news on social media. You may read Twitter’s Privacy Policy here.
Facebook (Meta Platforms Inc., USA): to follow our news on social media. You may read Facebook’s Privacy Policy here.
LinkedIn (LinkedIn Corporation, USA): to follow our news on social media. You may read LinkedIn’s Privacy Policy here.
Cloudflare (Cloudflare Inc., USA): to help improve the performance, speed, and security of our 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
Gcore (G-Core Labs S.A., Luxembourg): to help improve the performance, speed, and security of our Services. You may read Gcore’s Privacy Policy here

We may disclose some of your personal data to other service providers, including our contractors.

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.

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. Somplo will be allowed to request further personal data in order to process such a request. 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 July 2024

Headquarters

30 Shacham, 1st Floor,
Petah Tikva,
Israel 4951726, IL

PRIVACY POLICY

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