PRIVACY POLICY

Smpl Global Limited, legal entity, duly incorporated in Seychelles under the company number 239007, having its registered office at House of Francis, Room 303, Ile Du Port, Mahe, Seychelles together with its affiliated companies (hereinafter collectively referred to as “Smpl”, “we” and/or “us”)

In this document, Smpl explains how we collect, process and store Personal data. In this document, Smpl explains how we collect, process and store Personal data (hereinafter referred to as “you”) at the our website, telegram app and/or mobile app (hereinafter referred to as the “Website”) .

1. DEFINITIONS

   For the purposes of this document, the terms below have the following meanings:

   “Consent” means freely given, specific and unambiguous indication of your agreement to the processing of your Personal Data by Smpl.

   “Controller” means a natural or legal person, which alone or jointly determines the purposes and means of the processing of Personal data.

   “Data subject” means an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to their Personal data. You are a Data subject in the meaning of the GDPR.

   “Personal data” means any information relating to you that helps us directly or indirectly identify you as a Data subject.

   
   

2. TYPES OF PERSONAL DATA IN OUR POSSESSION

   Personal data that we may collect, store and process includes:

   • Contact info that you provide to us by filling in forms on the Website and/or mobile app or any other information you might submit to us via the Website and/or mobile app email, telephone, and/or Live Chat, including the following: name (first name, surname), e-mail, phone number, address (registered address and/or address of actual operation), other necessary data (CV, links to the social media (LinkedIn, Facebook), cover letter);

   • Financial information (form of payment, payment card number or bank account number, details of transactions, payment server, salary, income and assets);

   • Record  of  correspondence whether via the Website and/or mobile app (Customer support), email, telephone or by any other means;

   • Details, necessary to provide KYC by us: ID (national passport or governmental ID, foreign passport and/or driving license), date of birth, proof of address (Utility bill, bank statement, rent agreement), source of funds/source of wealth, legal form, registration number, an extract of registration and its issue date, Power of Attorney for an authorized person;

   • Details of your visits to the Website and/or mobile app, including traffic data, precise location data, activity logs(launches, taps, clicks, scrolling information) and other communication data;

   • Information we get from your devices (IP address, portfolio website, cookies, computer model, operating system and its version, serial numbers, mobile device ID, your contact lists, crash data);

   • Responses to marketing campaigns from us.

     
     

3. LAWFUL USAGE OF PERSONAL DATA

   Smpl will legally use and process your personal information and other data together with other information, in the following way:

   • as a legal obligation according to the applicable legislation, AML/KYC regulations and/or any other specific law that is relevant to the Smpl business activity;

   • in our own legitimate interests for commercial and business reasons. Please note that the processing of Personal data is necessary and we will perform a relevant balancing test to ensure that such processing is lawful and conducted only for specific and legitimate purposes, e.g. anti-fraud measures, risk management, network security, customer support, service personalisation and web analytic;

   • under the terms of the contract, Smpl entered into with you (by your acceptance of Smpl T&C) and any third party (by signing relevant documents). However, processing of your Personal data is strictly limited to legal requirements stated in the above-mentioned agreements.

   • upon receiving your Consent only for the period and purposes limited to your Consent in our possession.

     
     

4. PURPOSES OF PERSONAL DATA PROCESSING

   • Processing your transactions, including card and online payments;

   • Setting up and managing your account, verification of your identity (both face-to-face and not face-to-face);

   • Complying with our legal and regulatory duties;

   • Complying with risk management procedures and monitoring transactions for the purpose of preventing fraud, money laundering and scamming;

   • Identification of system problems and administration of the Website and/or mobile app;

   • Involving you in surveys and polls relating to the services we provide;

   • Providing you with information about promotional offers and the products and services available.

     
     

5. SHARE OF PERSONAL DATA

   We share your Personal data with:

   • The Affiliates of Smpl “Affiliates” for the purpose of this Privacy Policy include all direct or indirect parent and subsidiary enterprises of Smpl, its joint venture partners, their related companies and companies under the same control. We may share your Personal Data with our Affiliates for set-up, verification and management of your account, for marketing research and data analysis, to conduct relevant risk management and comply with legal and regulatory obligations.

   • Third Parties (electronic money institutions, payment service providers, customer services, software providers, KYC providers, CRM system providers, marketing agencies, digital optimization systems and other trusted partners). For the deposit and withdrawal of your funds, we use various payment services and transmit your Personal data to them. Smpl is always keen to give users the best service possible. One of the ways of doing this is to use customer service software providers. Smpl also uses data analysis, research and surveys to identify and satisfy users needs via different digital optimizations systems. To assist Smpl in dealing with this issue, we may also transfer some part of your Personal Data to relevant marketing agencies. Smpl also uses third-party solutions to provide verification procedure of its users. In addition, we also use CRM system providers in order to proceed with your applications to our job openings. All of the above-mentioned entities will receive only the data they require for the provision of services and compliance with their legal and regulatory obligations. For the protection of your Personal data, relevant measures will be taken by Smpl prior to the transfer of data to the above-mentioned parties.

   • International data transfers. Smpl runs its business activity worldwide (except for “Restricted areas” as stipulated in the T&C). However, some countries outside the European Economic Area (“EEA”), do not have effective laws regarding data protection.

     To ensure the appropriate level of protection, we add relevant contractual clauses, designed to offer the same level of protection of Personal data as within the EEA. We would like to emphasize that Smpl makes every effort to ensure the protection of Personal data while cooperating with any third parties. In addition, we try to secure your rights and information, by verifying whether the data is processed in accordance with the GDPR standards and other legal requirements.

     
     

6. STORAGE OF PERSONAL DATA

   We store your Personal data in the data centres within the European Economic Area. While your information is being transferred to the data centres we limit its processing to a strictly necessary extent, in keeping with the procedures aimed at ensuring the network and information security. In addition, the security of any transfer of data is helped by using computer security incident response teams (CSIRTs), computer emergency response teams (CERTs) and other means to ensure a high level of protection.

   Moreover, data centres use Operational Metrics (traffic data, cryptographically hashed file samples, click stream information, logged snippets of transmitted content, IP trust scores and other server activity data and all analytic products derived therefore).

   
   

7. RETENTION OF PERSONAL DATA

   Smpl will legally store your Personal data for the relevant retention period. Thus, such information will be processed until you delete your account on the Website and mobile app and further within the reasonable period, in accordance with the terms of AML/KYC procedures, regulatory requirements and any other applicable legislative grounds.

   
   

8. RIGHTS OF DATA SUBJECT

   GDPR entitles you to a range of specific rights with regard to your Personal data. Please make sure you examine the following list with due care. In addition, we would like to stress that some rights relate to specific circumstances only.

   1. Right to be informed regarding your Personal data. By this Privacy Policy, Smpl tries to highlight the most crucial issues concerning the security of your Personal Data to keep you informed. If the Privacy Policy is in any way changed, then this page will be updated accordingly.

   2. Right to access. It is your right to receive information from us regarding whether we are using your Personal data. You are also entitled to ask us to clarify which of your Personal data we have. In addition, you may request a copy of the Personal data which is being processed.

   3. ​ Right to alter incorrect data. You have a right to change inaccurate Personal data in our possession.

   4. Right to have the data removed. You are entitled to erase your Personal data in our possession due to specific circumstances. Those would be if the data is no longer necessary for the stated purposes, you withdraw your Consent to data processing, your Personal data has been unlawfully used, there are no overriding legitimate grounds to process your information and/or your Personal data is to be erased for legal reasons. However, please, note that Smpl is not bound to comply with such a request if processing of your Personal data is necessary to exercise the right of freedom of expression and information, comply with a legal obligation in the public interest, exercise official authority and/or establish, exercise or defend legal claims.

   5. Right to restriction of processing. You have the right to request the suspension of your Personal data being processed, for example, if the accuracy of the data is being questioned.

   6. Right to data transfers. You are entitled to transfer your Personal data in our possession to any other Data Controller. You also have a right to receive a report on your Personal data from Smpl in a structured, commonly used and machine-readable format. While transferring the above- mentioned data to you, Smpl will take all security measures necessary to ensure your Personal data

      is securely transmitted by using end-to-end encryption or any other strong authentication measures.

   7. Right to object. You have the right to object to the processing of your Personal data. However, where legitimate grounds to use your information outweigh your interests and rights, Smpl reserves the right to continue such processing.

   8. Right not to be subject to automated decision-making. You are entitled not to be subjected to automated decision procedures. Smpl ensures that all important matters relating to your Personal Data are either resolved by our team or by any engaged third party.

   
   

9. EXECUTION OF DATA SUBJECT RIGHTS

   To exercise any of the above-mentioned rights, you must provide us with a special request. Should you wish to make such a request, please, contact us via the following e-mail address: [email protected]

   Your application should include adequate identification details and appropriate documents to support your request. Smpl will deal with your concerns within 30 (thirty) calendar days and reply to you regarding each issue.

   If you do not receive a response to your request within the stipulated time period or are not satisfied with our processing of your Personal data, you are entitled to apply to your local data protection authority:

   
   

10. CONSENT

    By registering on the Website and/or mobile app as a user of Smpl and/or using our services, you Consent to the processing of your Personal Data by Smpl and to the terms and conditions of this Privacy Policy. Please, make sure you understand all your rights and obligations stated here and in the T&C.

    
    

    You Consent that Smpl may process information about you on your behaviour and your activity for marketing and advertising purposes, including but not limited to:

    • Marketing: based on your communication preferences, you consent that Smpl may use your email in order to send you marketing communications, including our newsletter, in order to inform you about our events; to deliver targeted marketing and to provide you with promotional offers based on your communication preferences. We use Personal data about your usage of our Platform and your contact information to provide marketing communications, including but not limited to promotions, special offers and other information, personalize promotional offers, in particular, based upon their activity and their transaction history in order to use push notifications. You can opt out of our marketing communications at any time. We send administrative or account-related information to you to keep you updated about our news or inform you of relevant security issues or updates to the Platform, changes of the Terms & Conditions or to this Privacy Policy or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your Account that may affect how you can use our Platform.

11. FURTHER INFORMATION

    Smpl always aims to make its users aware of their rights and obligations. Please, make sure you read carefully this Privacy Policy, T&C and other legal documents on the Website and/or mobile app.

    If you have any doubts regarding our services or need any additional assistance, do not hesitate to contact us via the following e-mail: [email protected]

12. UPDATE

Our Website policies and its content may be revised, modified, updated, and/or supplemented at any time. If we change this Privacy Policy, we will take steps to notify all users of the amendments, as well as to post the updated policy thereupon.

If we consider that your rights may be affected by any such changes, we will request you to confirm your consideration and acceptance prior to continue our relationship with you.

Last update of this Privacy Policy: 25.09.2024