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.
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 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:
30 Shacham, 1st Floor,
Israel 4951726, IL
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 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 amount 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 collected 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 and/or have an account with Somplo
The following table sets out the different categories of cookies we use and the purposes for which we use them, based on information collected Somplo about website visitors or Somplo account`s users:
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:
Information Collected by Other Entities
IMPORTANT: upon processing of payments using 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 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 the 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, the 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.
to track users’ behaviour 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.
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 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 a basis of the user’s consent.
Cookies Opt Out
If you wish, you can choose to remove the abovementioned 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);
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 email@example.com, using the suitable website’s options or by contacting us in any other way convenient for you.
Article 6.1(f): legitimate interests
We process your personal data to prevent any fraudulent actions and to provide you with the desired services. Also, we need some data to enable our Services to run smoothly and give you a pleasant user experience. We use only strictly necessary data under this legal ground.
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 sending 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 anonymise 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 firstname.lastname@example.org.
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 to data processors in accordance with 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:
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 the 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 the 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 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.
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 the 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 organisation or to 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 email@example.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.
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
Last Updated on July 2023
30 Shacham, 1st Floor,
Israel 4951726, IL