Data Processing Addendum (DPA)

Data Processing Addendum (DPA)

Data Privacy Policy

EFFECTIVE DATE: 26th December 2023

SMPL-C, Inc. and its subsidiaries (“SMPL-C” or “we”) process personal data to carry on its business, in compliance with all applicable U.S. and international data protection laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”) and the California Consumer Privacy Act of 2018 (“CCPA”). This privacy notice contains information on what personal data we collect, what we do with it and what rights you have.


This Privacy Policy describes what personal information SMPL-C collects on its websites, how we handle such information, and the rights of data subjects. It does not apply to information collected on any third-party website or application that may link to or be accessible from our websites. SMPL-C is not responsible for the privacy policies or data collection, use and disclosure practices of third-party websites. Please read this Privacy Policy carefully. By accessing or using any of our websites or services, you agree to this Privacy Policy.

Personal Data

“Personal Data” is information that identifies an individual or relates to an identifiable individual, including name, postal address, telephone number, email address, payment information, education, profile picture and social media account ID. We may receive your Personal Data from you or from other sources, such as data companies, public databases, joint marketing partners or social media platforms. In addition, if you elect to connect your social media account to your website account, certain Personal Data from your social media account will be shared with us, which may include Personal Data in your profile or your friends’ profiles. If you disclose to us any Personal Data relating to other people, you are telling us that you have the authority to share that information and to permit us to use it as described in this Privacy Policy.

Processing of Personal Data

SMPL-C, Inc. is the controller of your Personal Data, unless we agree otherwise. We may process Personal Data:

To perform our contractual obligations towards you, for example:

  • To respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service;
  • To send you changes to our terms and conditions or marketing communications;
  • To personalize your experience on the Services by presenting products and offers tailored to you;
  • To comply with our legal obligations such as tax reporting or regulatory requirements;
  • For our legitimate interests, for example to prevent fraud, to ensure network and information security, to transmit personal data to our affiliates for internal administrative purposes, to perform direct marketing activities, and to report possible criminal acts or threats to public security to a government authority;
  • For the performance of a task carried out in the public interest; and/or
  • If we have obtained your prior consent.

To the extent that we process any special categories of personal data (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation) relating to you, we will do so because:

  • The data has been manifestly made public;
  • The processing is necessary for the establishment, exercise or defense of a legal claim;
  • The processing is necessary for reasons of substantial public interest; and/or
  • You have given your explicit consent to us to process that information.

Disclosure of Personal Data

Your Personal Data may be disclosed:

  • To our affiliates, for the purposes described in this Privacy Policy;
  • To our third-party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services; and
  • To third parties, to permit them to send you marketing communications, consistent with your choices;
  • To comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons;
  • To enforce our terms and conditions;
  • To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and/or
  • To a third party in the event of any merger, sale, bankruptcy, reorganization, joint venture or other disposition of all or any portion of our business, assets or stock.

Other Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:

  • Browser and device information;
  • Information collected through cookies, pixel tags, and/or other technologies;
  • Demographic information and other information provided by you that does not reveal your specific identity; and
  • Information that has been aggregated in a manner that it no longer reveals your specific identity.

If we are required to treat Other Information as Personal Data under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Data.

Use and Disclosure of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

  • Through Your Browser or Device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Services function properly.
  • Using Cookies. Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie. If you do not accept cookies, you may experience some inconveniences in your use of the Services.
  • Using Pixel Tags and Other Similar Technologies. Pixel tags (also known as “web beacons” and “clear GIFs”) may be used to track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, compile statistics about usage of the Services and response rates, and other purposes.
  • Analytics. We reserve the right to use Analytics tools, which in-turn use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. These services may also collect information regarding the use of other websites, apps and online resources.
  • IP Address. Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, administering the Services or to derive your approximate location.

We may use and disclose Other Information for any purpose except where we are restricted under applicable law. In some instances, we may combine Other Information with Personal Data; if we do, we will treat the combined data as Personal Data as long as it is combined.

Onward Transfer of Your Personal Data

If we transfer your Personal Data to a country outside the EEA, the UK or Switzerland that does not offer adequate protection to your Personal Data, we will put in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection rules. You may request additional information in this respect by exercising your rights as explained below.

Data Minimization, Integrity and Retention

We only collect and process as much Personal Data as needed for specific purposes identified in this Data Privacy Policy and do not use it in any way that is incompatible with those purposes. We will only retain Personal Data for as long as necessary to fulfill the purpose for which it may lawfully be processed or to comply with legal, regulatory or internal policy requirements.

Your Rights

You have a right to:

  • Access and obtain a copy of your Personal Data as processed by SMPL-C;
  • Request the correction of your Personal Data if you believe that any information we hold about you is incorrect or incomplete;
  • Object to the processing of your Personal Data;
  • Request the erasure of your Personal Data;
  • Request restrictions on the processing of your Personal Data; and
  • Withdraw your consent where SMPL-C had obtained your consent to process Personal Data (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).

These rights may be subject to exemptions. If we do not comply with your request, we will explain why.

Exercising Your Rights

You may opt out from:

  • Receiving electronic communications from us by following the instructions contained in each such email.
  • Our sharing of your Personal Information with affiliates for their direct marketing purposes by visiting the Opt-out form at
  • Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes by visiting the Opt-out form at

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

To exercise your other rights, you may send an email to

If you are not satisfied with how we process your Personal Data, please raise any concerns by contacting our Data Protection Officer at If you are not satisfied with our response, you have the right to make a complaint to the competent data protection authority.

California Consumer Privacy Act

This section provides additional information regarding the CCPA and supplements the disclosures and information throughout this Privacy Policy. The commitments in this section apply only to individuals covered by the CCPA and are subject to certain exceptions laid out in the CCPA.

The Personal Data we generally collect, use, and disclose regarding California residents, as well as the categories of sources of such information, are described above in the “Disclosure and Use of Personal Data” section. SMPL-C does not sell California residents’ Personal Data and will not do so without providing an opportunity to opt-out.

The CCPA establishes a right for covered individuals to request that a company disclose any Personal Data about them that company collects, uses, discloses or sells, and to request the deletion of Personal Data the company has collected or maintained. If you believe you have such a right and would like to exercise that right with respect to SMPL-C, please send the request by email to with “California Request to Know” or “California Request to Delete” in the subject line. For a “Request to Know,” please specify what Personal Data you would like to know, including any specific pieces of Personal Data you would like to access. For a “Request to Delete,” please specify what Personal Data you would like to have deleted (which may be all your Personal Data). You may also utilize an authorized agent to exercise your CCPA rights on your behalf. You may not be discriminated against because you exercise any of your rights under the CCPA.


We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately in accordance with the “Contact Information” section below.

Changes to Our Privacy Policy

We may amend this Privacy Policy from time to time. We encourage you to revisit this page periodically to read the current version of this Statement in effect.

Data Protection Officer

To communicate with our Data Protection Officer, please do so by emailing us at

Contact Information

If you have any questions or comments about this Privacy Policy, please contact us by emailing us at