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Privacy Policy

Last Revised: 2 December 2022

This Privacy Policy (hereinafter referred to as the “Policy”) explains how “SIMPLER GROUP LTD” including its Greek subsidiary company “Simpler Single Member P.C” (hereinafter referred to as “Simpler”, “we” or “us”), acting as the Processor, processes your personal data (hereinafter referred to as “Data”).

For any question regarding the processing of your Data, do not hesitate to contact us by

- emailing support@simpler.so
- writing to Simpler Group Ltd., 128 City Road,  EC1V 2NX, London, United Kingdom

1. A few words about Simpler

Simpler is the simplest way to shop online since you are only 1 click away from checkout, in a passwordless way. Simpler makes the buying experience fast, secure, and much simpler, across hundreds of retailers and from any channel . Through a Simpler account you can also manage all your Simpler orders in your dashboard. While Simpler is essential for online shoppers, it is also a game changer for businesses who wish to increase their sales, by offering their customers the ultimate shopping experience, allowing them to checkout in seconds from anywhere.

2. What is personal data?

Personal data is any information that relates to an identified or identifiable living individual (e.g., name, surname, home or email address, IP address, cookie ID, location data, T.I.N. etc.). Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.

3. What is Personal Data Processing?

Data processing covers a wide range of operations performed on personal data, including by manual or automated means. It includes the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.

4. What Data does Simpler process?

We only collect the Data we actually need for our specified purposes. We periodically review the Data we hold and delete anything we don’t need. The Data we process may include, but is not limited to:

  • Name, age;
  • Phone, email, postal address;
  • Payment card number, CVC code, expiration date, which are encrypted in accordance with PCI DSS standard by our authorised payment service provider;

    Simpler will not collect or retain any of your payment information which is included but is not limited to your credit or debit card number, bank account details.
    ‍
  • Purchase amount, currency, purchased product and size, date and location of purchase;
  • Transaction and purchase history;
  • Cookies, IP address, browser, account log-in credentials, device type, location data;
  • T.I.N., Tax Office, ID/Passport number;
  • Work experience, qualifications, professional certification;

5. For what purpose does Simpler process your data?

  • To register and manage your Simpler account;
  • When you authorise us to store information about you in connection with Simpler Checkout;
  • ‍To fulfill the orders and the returns you make via Simpler;
  • If you sign up to become one of our (merchant) customers by entering into an agreement with Simpler;
  • When you submit your ID and/or for purposes of verification;
  • For the proper functioning of our website;
  • To answer the questions you submit via the contact form;
  • To hire employees and collaborate with partners;
  • To satisfy the requests, regarding the exercise of your rights, that you submit either via our website;
  • To improve our services;
  • For crime and fraud prevention, detection, and related purposes;
  • To contact you electronically about promotional offers, events, products, and services which we think may interest you;
  • For retargeting purposes.

6. What is the legal basis for the processing of your Data by Simpler?

The processing of your Data is carried out according to: the service agreement you have with us; your consent, where required; our obligations arising from the law (e.g., tax legislation, etc.); our legitimate interest.

7. Who are the recipients of your Data?

The recipients of your Data are the staff of Simpler as well as its partners, who have committed themselves to maintain the confidentiality of the Data they receive in the context of either providing their work or services. Simpler will not collect or retain any of your payment information which includes but is not limited to your credit or debit card number, CVC code and expiration date. Any payment related data will be handled by our 3rd party payment service provider which facilitates all Simpler's payment services. More information about the way our payment service provider collects and further processes your personal data you can find here.

As a rule, Simpler does not transmit your Data to third parties except when clearly required by the current legislative/regulatory framework.

8. How do we ensure that our partners respect your Data?

Our partners have agreed and are contractually bound in writing :

  • to keep confidentiality, and bind their staff, with the respective obligations;
  • not to transfer data to third parties without our written permission;
  • to undertake organisational and technical data security measures for the protection of Data;
  • to inform us of any incident relating to the breach of your Data;
  • upon termination of the contractual relationship with the Partner, the Partner may retain any acquired Customer Data and hereafter take over complete liability, as per their data privacy policy;
  • to comply with the legal framework for the protection of Personal Data, in particular with the General Data Protection Regulation (GDPR).

9. Does Simpler send your Data outside the EEA?

To deliver services to you, it is sometimes necessary to share your personal information outside of the European Economic Area (the EEA). This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.
‍
If we transfer your personal information outside the EEA, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to assess the laws and practices of the destination country and relevant service provider and the security measures that are to be taken as regards the data in the overseas location; Alternatively, we use standard data protection clauses. 

10. For how long does Simpler keep your Data and when does it delete it?

We keep your Data only for the time required to fulfill the purpose for which we have collected them, unless a time extension is required due to our legal claims or legal obligations. 
‍
The Data collected by the Cookies, are deleted according to the Cookies page.

11. Is your Data safe?

Simpler is committed to safeguard your Data and has taken the necessary and appropriate organisational and technical measures to protect them from any form of accidental or improper processing. These measures shall be reviewed and amended, as necessary.

12. What are your rights?

You have the right to :

  • information about the processing of your personal data;
  • obtain access to the personal data held about you;
  • ask for incorrect, inaccurate or incomplete personal data to be corrected;
  • request that personal data be erased when it’s no longer needed or if processing it is unlawful;
  • object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation;
  • request the restriction of the processing of your personal data in specific cases;
  • receive your personal data in a machine-readable format and send it to another controller (data portability);
  • request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision.

13. How can you exercise your rights?

You can exercise your rights by posting the Application form available here and send it either to Simpler's address in London (Kemp House, 160 City Road, London EC1V 2NX) or by email at support@simpler.so. If you hold a Simpler account, you can alternatively use the e-form found here and submit it online.

14. When does Simpler respond to your requests?

Simpler responds to your requests free of charge, without delay and in any case within (1) one month from the time it receives your request. However, if your request is complex or there is a large number of your requests, it will let you know within the month if it needs to receive an extension of another (2) two months to respond to you.
‍
If your requests are manifestly unfounded or excessive, due to their recurring nature, Simpler may impose a reasonable fee, taking into account the administrative costs of providing the information or performing the requested action, or refusing to comply with the request, justifying its answer to you.

For more information you can send an email at support@simpler.so.

15. Does Simpler use automated decision making, including profiling during the processing of your Data?

Simpler may use automated decision-making, including profiling, for marketing purposes or for the performance of a contract with you, where allowed by applicable laws or if based on your consent. However, if the decision produces legal effects concerning you or significantly affects you in a similar way, you have the right to obtain human intervention, express your point of view or to contest the decision based solely on automated processing, including profiling. 

16. What is the applicable law during the processing of your Data by Simpler?

Applicable Law is the UK Law, as formulated in accordance with EU and UK data protection legislation. Competent Courts for any disputes arising in connection with Your Data are the Courts of London, UK. 

17. Where can you go to check if your rights have been respected?

If you do not receive a response within the stipulated deadline (one month with - subject to extension - two months) or the response you receive is unsatisfactory or the issue has not been resolved, you can lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) or the data protection supervisory authority in the country in which you live or work where you think we have infringed data protection laws.

18. How will you be notified of any changes to this Policy?

Simpler updates this Policy whenever necessary.  If there are significant changes in the Policy or in the way we process your Personal Data, we will publish on our website (https://www.simpler.so/) the update of this before the changes are made in force and we will notify you in any convenient way. Simpler encourages you to read this Policy regularly to know how your Data is protected.

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