Privacy Policy
Last updated: (02/04/2023)
This Privacy Policy (The “Policy”) applies to the Website and/or application (The “Platform”) owned and operated by Simly (The “Company”) a company duly incorporated and registered in the Commercial register of the DIFC under number CL5941 and established at the following address Unit 02, Level 7, Gate Village Building 10, Dubai International Financial Centre in its capacity of controller of the personal data.
The Company recognizes the importance of your privacy.
The Company shall use your name and other information which relates to you in the manner set out in this Privacy Policy. The Company will only collect information where it is necessary to do so and the Company will only collect information if it is relevant to its dealings with you.
The Company will only keep your information for as long as the Company is either required to by law or as is relevant for the purposes for which it was collected.This Policy tells you what personal information we collect and how we use it. The Company may change this Policy from time to time, in its sole discretion, as discussed in section ‘10. Changes to This Policy’ below. By registering an account or otherwise using or visiting the Platform, viewing any , product, software, tool, data feed, and/or service, by submitting personal date to the Company or the Company’s (collectively The “Service”), you understand and agree to the terms of this Policy and you consent to the Company’s use of your personal data in the manner set out in this Policy including all services provided used by the Company or third parties to verify your identity.
If you have an unresolved privacy or data use concern that the Company has not addressed satisfactorily, please contact the Company directly at hello@simly.io or find more information under section ‘5. Your rights’.The Company is committed to your privacy. This Policy explains how we collect, use, disclose, retain, and protect your personal information.
1. Data collected by the Company
1.1. Personally-Identifiable Information
Your personally identifiable data (first name, last name, email, billing information such as credit card number and billing address) is processed by the Company when you specifically and knowingly provide it to the Company, for example when you sign up for the newsletter or chat, create an account, request more information on contact us page of the Company, respond to a survey or questionnaire and provide personal information such as your email address, name, phone number or other information. Where applicable, personally identifiable information includes personal data as defined in applicable law.
Your data is collected and processed to: administer your account, process your orders, verify and carry out financial transactions in relation to payment you make online (including without limitation payment verification and fraud protection), undertake direct marketing, audit the downloading of data from the Platform, identify visitors on the Platform, carry out research on the Company’s users’ demographics, and/or send you information which the Company deems you may find useful or which you have requested from the Company (including information about the Company’s, its newsletters, sales or promotions), provided you have indicated that you have not objected to being contacted for these purposes.The Company will use your personal data only for the purposes indicated above.By giving your personal data to the Company, you agree to it being transferred to its commercial partners, who may be located in a country outside the European Union ("EU") where other standards of data protection might apply, including companies whose intervention as data processors, acting on behalf and under the control of the Company, is required to accomplish the purposes indicated above.Subject to the above, the Company will not disclose, sell, rent or exchange such personal data to any other organization or entity, unless you are first notified and expressly agree, or as otherwise required by law.The Company undertakes to respect the provisions of the EU General Data Protection Regulation regarding personal data of users of the Platform residing in the EU and that have access to the Platform, irrespective of whether a payment is required or not.Your actual order details may be stored on the Company’s server but for security reasons cannot be retrieved directly by the Company. However, you may access this information by logging into your Account on the Platform. There you can view the details of your placed orders that have been completed, those which are open and those which are shortly to be dispatched; and administer your address details, bank details and any newsletter to which you may have subscribed.
This Policy does not apply to the privacy practices of third parties that the Company does not own or control, including but not limited to any third party websites, services, applications, online resources to which this Platform may link or otherwise reference (collectively Third Party Services or “TPS”) that you may access through the Services. The Company does not consider personally identifiable information to include information that has been anonymized so that it does not allow a third party to identify a specific individual. The Company collects and uses your personally-identifiable information to provide the services, operate and improve the service, provide customer service, perform research and analysis aimed at improving the products, service and technology, and display content that is customized to your interests and preferences.You may always choose not to provide personally identifiable information, but if you choose so, certain parts of the Service may not be available to you. If you have registered an account with the Company, you will have agreed to provide your personally identifiable information in order to access the services. This consent provides the Company with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use the Platform.
1.2.Log information and non-Personally-Identifiable Information
Every time you log in to the Platform, information is sent from your browser to the Company’s server log files, where it will be saved. The information transferred includes: time and date of visit to the Platform, viewed pages, IP address, URL of site that referred you to Platform, how much information has been stored and which browser you have been using.The information stored in this log file is then used to improve the use of the Platform by making the navigation more user-friendly, finding errors quickly and directing The Company’s server’s capacity to where it is needed most.You agree and acknowledge that by using the Platform, you are giving the Company permission to analyze and use protocol data to develop and optimize your navigation on the Platform.The Company may collect and aggregate non-personally identifiable information which is information that does not permit you to be identified or identifiable either by itself or in combination with other information available to a third party. This information may include information such as a website that referred you to us, your IP address, browser type and language, hardware types, geographic location, and access times and durations. The Company also may collect navigational information, including information about the service content or pages you view, the links you click, and other actions taken in connection with the service. The Company uses this information to analyze usage patterns as part of making improvements to the Service.
1.3. Sensitive Personal Data
Subject to the following paragraph, the Company requests from you not to send , and not to disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise to the Company.In the event you send or disclose any sensitive personal data to the Company while submitting content to the services, you consent to the processing and use of such sensitive personal data by the Company in accordance with this Policy. If you do not consent to such processing and use of such sensitive personal data, you must not submit such content to the Company. 1.4. Cookies, Pixels and Local StorageThe Company may collect information using cookies, which are small data files stored on the hard drive of your computer or mobile device by a website. The Company may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience when using the Services.The Company uses two broad categories of cookies: (1) first party cookies, served directly by the Company to your computer or mobile device, which are used only to recognize your computer or mobile device when it revisits any site or application that is party of the Services; and (2) third party cookies, which are served by service providers on sites or applications and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
2. Cookies
2.1. General rules
The Company and its partners use cookies or similar technologies as action tags to analyze trends, administer the Platform, track users’ movements around the Platform, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.Cookies are small text files that are placed on your computer in order to identify your web browser and the activities of your computer on the Platform and other websites. The Company may use cookies to monitor how you are using the Platform, to help it improve its online offerings or to determine the popularity of certain content. Furthermore, the Company sends a "session cookie" to your computer when you log in to the Platform. These session cookies allow the Company to recognize if you visit multiple pages during the same browser session, without needing to re-enter your login information multiple times. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. Please be aware that for technological reasons if you decline the use of cookies you will be unable to login to the Platform.Action tags also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Company’s Platform, including advertisements, or email sent on the Company’s behalf, may contain action tags. The Company may select and use from time to time different third parties to track the use of the Platform through action tags.The cookies used by the Company may be used to store any personal information. The Company’s cookies may be traced back to an individual user with extensive research. Once a cookie is activated, it is given an ID number, which is solely used for internal reference and may be used to identify the user and access personal information, such as your name or IP address.Cookies from specific business partners are allowed by the Company for the purpose of tailoring their adverts to your tastes and browsing habits, therefore these cookies may be stored on your computer when you visit the service. These cookies are temporary/permanent cookies, which will be automatically deleted from your computer at the end of their lifespan. Third party cookies have the sole purpose of allowing the company’s partners to advertise Services that may interest you.If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking on the pop-up that will show upon your visit. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.You agree and acknowledge that by using the Platform, you hereby give permission for my user information to be stored on cookie files. I also allow these files to remain on my computer after I have ended my browser session so they may be used upon my next visit to the Platform. I reserve the right to retract this permission by changing my browser setting to refuse cookies.
2.2. Type of Cookies
The Services use the following types of cookies for the purposes set out below:Strictly Necessary Cookies: These cookies are essential to provide you with services available through the Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of the sites or applications and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.Functionality Cookies: These cookies allow the Services to remember choices you make when you use a site or application, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of your account or preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Services.Performance Cookies: These cookies are used to collect information about traffic to the services and how users use the services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to, the websites that referred them, the pages visited, what time of day they visited, whether they have visited before, and other similar information. The Company uses this information to help operate the services more efficiently, to gather broad demographic information and to monitor the level of activity on its services.The Company uses Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how the services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookiesYou can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.htmlYou can prevent the use of Google Analytics relating to your use of the services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GBTargeting Cookies / Advertising Cookies: These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
2.3. Disabling Cookies
Google AdWords Conversion Tool : Privacy information of the provider(https://goo.gl/CUUMgi), Link to Opt-Out(https://goo.gl/ghZWnt).On www.youronlinechoices.com you can read more about cookies and the individual providers. There you can also opt out of usage-based online advertising through one or more tools. To go directly to the preference manager, please click here.
2.4. Facebook Custom Audiences
In the context of usage-based online advertising, the Company also uses communication tools of Facebook, in particular custom- and website custom audiences. Basically, a non-reversible and non-personal checksum (hash value) is generated from your usage data, which can be transmitted to Facebook for analysis and marketing purposes. For website custom audiences the Facebook cookie is addressed. For more information on the purpose and scope of the data collection and further processing and use of the data by Facebook and your options to protect your privacy, please refer to the privacy policy of Facebook, which you can see here. If you want to object to the use of Facebook website custom audiences, you can do so here.
2.5. Pixel Tags
The Company may also use pixel tags (which are also known as web beacons and clear GIFs) on the Services to track the actions of users on the Platform . Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the services, so that the Company can manage its content more effectively. The information the Company collects using pixel tags is not linked to the users’ personal data.
2.6. Do Not Track Signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Company currently does not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
3. Collected Information uses
Except as disclosed in this Policy, the Company does not share your personal information with any outside parties.The Company will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, which may include:
- to operate, maintain, and improve the Services;
- to manage your account, including to communicate with you regarding your account;
- to operate and administer any promotions you participate in on any site or application;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- with your consent, to send you marketing emails about upcoming promotions, and other news, including information about products and services offered by the Company and its affiliates.
The Company retains information about your marketing preferences for a reasonable period of time from the date you last expressed interest in the content, products or services, such as when you last opened an email from the Company. The Company retains information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.Subject to obtaining your consent, the Company may contact you by email with details about the Company, other offered Services, sales promotions, direct marketing (including opinion and market research), newsletter and other information related to companies in the Company’s group or the Company’s business partners.If you wish to unsubscribe yourself from receiving the newsletter, you may, at any moment, opt out by clicking on the unsubscribe link, present at the bottom of the page of all the emails sent to you from the Company, by sending an email to the Company to hello@simly.io.You may opt-out of receiving such information at any time: such marketing emails tell you how to opt-out. Please note, even if you opt out of receiving marketing emails, the Company may still send you non-marketing emails. Non-marketing emails include emails about your account with the Company (if you have one) and our business dealings with you;to process payments you make via the Services; and as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce the Policy; and (d) to protect the rights of the Company, privacy, safety or property, and/or that of you or others.
The Company may share this information with service providers who perform services on our behalf, such as those services listed above, or other services like processing information requests, displaying stored data you access, to assist the Company in marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service they provide, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose.The Company may also use information you provide to better serve you, and, if you have given your consent to the Company to do so, to send you email or text messages concerning offers from its partners and other third parties that may interest you. If you do not wish to receive marketing emails, you may adjust your Personal Information Preferences as described below or follow the unsubscribe or stop instructions included within each communication. The Company uses MailChimp as a marketing automation platform. By submitting the information you provide to the Company, you acknowledge that the information will be transferred to MailChimp for processing in accordance with their Privacy Policy and Terms.Should your data stored by the Company be incorrect, it will correct it. In this regard, you can write to the Company at the address listed in section ‘7. How Does A User Change Or Update Information’ or contact them in any other way. In addition, customers can view the data in their account that the Company has stored about them and correct it if necessary.
4. Disclosure
As a general rule, the Company shall not disclose any of your personally identifiable information except under one of the following events:- you have granted the permission, including the permission granted by your acceptance of this Policy;- the Company determines in good faith that it is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena;the Company has to share your information to provide the product or service you have requested provided that such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by the Company. The Company may share the non-personally identifiable information that it gathers, in aggregate form only, with advertisers and other partners.
5. Your rights
Pursuant to the applicable laws, you have the right to access and restrict your data which the Company may hold or process about you, to request rectification of any incorrect data relating to you free of charge and to object to the collection of personal data used in this Platform by the Company. Therefore, you have the right to ask the Company to stop using your personal data for direct marketing purposes by contacting the Company by email at hello@simly.io.If your personal data changes, or if you no longer desire the Company’s Platform, you may correct, update, amend, delete/remove, ask to have it removed from a public forum, directory or testimonial on the Platform of the Company or deactivate it by making the change in your account or by emailing the Company at hello@simly.io, that will respond to your request within a reasonable timeframe.Your information will be retained for as long as your account is active, as needed to provide you services and in order to use your information as necessary to comply with the legal obligations of the Company, to resolve disputes, and enforce the agreements of the Company. You can also consult or modify your personal data by clicking on “my account” available on the Platform. Personal data (address, email, telephone number…) may be transferred to third parties exclusively for delivery purposes of the ordered Services. Personal data may be transferred to commercial partners of the Company in the event you have granted the Company the authorization to do so.The Service may contain links to other websites not owned or operated by the Company. Please be aware that the Company is not responsible for the privacy practices of such websites and that this Privacy Policy applies solely to data collected by the Company.
6. Children’s Policy
The Terms of service clearly provide that Users must be (i) 18 or older, or (ii) 13 and older if either (a) an emancipated minor, or (b) he/she possess legal parental or guardian consent. The Company does not knowingly collect personally identifiable information from users under 13. In the event that the Company learns that it has collected any personal information from a user under the age of 13, it will attempt to identify and delete that information from its database.
7. International Usage
The Service is owned by the Company and may be accessed in Europe and abroad. For data protection purposes, the Company is the controller and, unless otherwise noted, is also the processor of data. Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction.The Company has also contracted with third party service providers to manage the logistics and customer support for an optimal 24/7 service. Some data needs to be disclosed and transferred to these third parties to ensure the fulfillment of the service. All third parties involved have been engaged under a binding confidentiality agreement and have limited access to the Company’s database for the purposes of providing support.
8. Security and Encryption
The Company generally follows and abides by accepted industry standards to help protect your personal information. You acknowledge that no method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while the Company endeavors to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that it collects online, it cannot guarantee its absolute security. The service has security measures in place designed to protect against the loss, misuse and alteration of the information under the control of the Company. It uses standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All service information is maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. You are responsible to keep your password secure. If you have reason to believe that your interaction with the Company is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify the Company of the problem by contacting it at hello@simly.io.
9. Changes to This Policy
The Company reserves the right to update this Policy and change the terms of this Policy at any time.In the event the Company makes any material changes, a notice will be sent to you by email to your specified email in your account prior to the change becoming effective. We encourage you to review this policy whenever you visit the Platform.