Privacy Policy for Smplifi

About Us

This privacy notice sets out how Smplifi, (hereafter referred to as "Smplifi") uses and protects any personal data that:

1. you provide when you use this website (https://www.smplifiai.com),
2. you provide as a client, business contact, or as someone contacting us for any business-related reason, and,
3. we receive by virtue of acting in the role of a service provider or data processor, working under contract for other organizations.

Smplifi is committed to protecting your personal data; this privacy notice sets out the purposes for which we collect personal data, how we use it, and what your legal rights are in respect to the personal data we hold. If you have a privacy question, you may contact Smplifi's Privacy Officer at smplifiasisstant@gmail.com or by using the links on this page. You may also contact us via telephone. We appreciate the opportunity to address your questions and concerns.

If you are not yet 18 years old or lack the legal authority to form legally binding contracts under applicable law (or permission from your parents or legal guardians), please do not use this Website or Smplifi's services. We do not solicit or knowingly collect any information from visitors under 18 years of age.

Our obligations in relation to personal data depends on the nature of the relationship with you:

When we act as a service provider or data processor, as in (c) above, then we are obliged under contract to our clients to protect personal data and use it only for the purposes for which we have been contracted, but we are not the organization to whom you should direct inquiries or access requests. Our use of personal data in this role is set out in the section entitled "Smplifi as Data Processor."

When you are using this website, or have a direct relationship with us, as in (a) and (b) above, we are the organization responsible for the collection, use, and disposal of that personal data. Our use of personal data in this role is set out in the section entitled "Smplifi as Data Controller."

Smplifi may change this notice from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This notice is effective from Mar 12, 2025.

Smplifi as Data Processor

Smplifi operates its business-to-business chat services ("Services") under an agreement with organizations that engaged Smplifi under contract (hereafter, "Smplifi Customers"), therefore, Smplifi will need to process personal data in order to provide the services in which Smplifi is engaged with Smplifi Customers. As such, Smplifi is fulfilling a task given to us by Smplifi Customers. We receive your personal information from Smplifi Customers, and from you, in order to provide to you the Services contracted by Customer ("Service Data").

Smplifi's role as Data Processor

Processing will always be based on the lawful grounds of our Smplifi Customers. Our processing of your Service Data is governed by the agreement with Smplifi Customers, and our ability and authority to process personal information arises from performing our contractual obligation to provide the Smplifi Customers.

Smplifi acts as a Processor on behalf of the Smplifi Customer. The Smplifi Customer has primary responsibility for interacting with data subjects, (individuals) and the role of Smplifi is generally limited to assisting Smplifi Customers as needed. Smplifi processes Service Data only upon a Smplifi Customer's instruction and has a duty to respect the security and confidentiality of Personal Data, pursuant to the measures outlined in agreements with Smplifi Customers and as required by applicable law.

If you have questions concerning correction of, access to your personal data or information, or the uses of your personal data or information, or complaints regarding these issues, they should be directed to the Smplifi Customer's Privacy Office. Smplifi will promptly notify our Smplifi Customers if Smplifi receives a request from a data subject/individual for access to, correction, amendment or deletion of that Service Data that has been processed pursuant to the Smplifi Customer's use of the Services. Smplifi is not permitted to respond to any such data request.

On the request of the Smplifi Customer, we will disclose to our client our practices in relation to the use and protection of personal data or information. Smplifi undertakes to be transparent regarding its Personal Data processing activities and to provide Smplifi Customers with reasonable cooperation to help facilitate their respective data protection obligations regarding Personal Data. In the event that Smplifi becomes aware of any unauthorized access to or disclosure of Service Data, Smplifi will promptly notify affected Smplifi Customers to the extent such notification is permitted by applicable law.

You can access services provided by Smplifi, subject to the terms of use governing appropriate use of these Services, and the Smplifi Customer's policies including its privacy policies.

Sharing and Disclosure of Information

As mentioned above, Smplifi Customer has retained Smplifi to operate the Services on its behalf, and in that role Smplifi may collect personal data or information. Smplifi is not in the business of selling personal data or information to others. Smplifi may, however, share or disclose information you provide us to other companies and people under the following circumstances:

• Smplifi Customer: As we operate essentially as an extension of Smplifi Customer by facilitating interactive digital conversations, please note that we do share information with Smplifi Customer. We may also share data with Smplifi Customer's third party agents and vendors pursuant to Smplifi Customer's directions, which is subject to Smplifi Customer's Privacy Policies.
• Your Instructions: We may share any information you submit on or to the Services solely for and in connection with the provision of service(s) you have been provided through the Smplifi Customer, from Smplifi.
• Business Transfers: As we continue to develop our business, we might sell or buy assets. In such transactions, Smplifi Customer and user information generally is one of the transferred business assets. If Smplifi or substantially all of Smplifi's assets were acquired, user information would be one of the transferred assets to the party or parties, or their advisors, involved in the transaction as part of that transaction.
• Legal Matters: Smplifi and Smplifi Customer have the right to disclose any personal data about you or your use of the service, or any other information that you submit as we deem reasonably necessary in order to:
  1. Protect the legal rights, property of Smplifi, the Smplifi Customer, their employees, agents, and contractors or clients, including enforcement of its agreements and to respond to any claims.
  2. Protect the safety and security of the Services users or members of the public, including acting in urgent circumstances;
  3. Protect against fraud or for risk management purposes;
  4. Comply with any applicable law, regulation, legal process, or governmental request

Sensitive Information

Smplifi will never directly collect information considered as sensitive personal data (as defined by applicable law). Smplifi may have access to data of a sensitive nature in its capacity as processor of the personal data of its clients, pursuant to the instructions of the Smplifi Customer, subject to the Smplifi Customer's privacy notices, policies and contract with you; and subject to security measures appropriate to the sensitivity of the data.

Smplifi will only collect and process personal data necessary to provide the Services; in the event you provide sensitive information not requested by our Smplifi Customers, and such is recognized or you advise us, it will be destroyed physically and electronically. Smplifi Customers may, pursuant to their privacy policies, collect such information directly or through other third parties.

Smplifi as Data Controller

Why do we collect personal data?

The reasons that we process information about you depends on who you are and how we interact with you.

Business customer, business partner, or prospect:

If you have a contract or other agreement in place with us, we process personal information about you, such as contact information, payment data, or other information required to support the contract or agreement, in order to fulfill the following obligations to you under that contract or agreement to:

• Provision your account on our platform;
• Authenticate you to enable you to access your account on our platform, including additional users of the solution;
• Provide customer service and support, and investigate issues that you raise;
• Deliver our assurance programs and solutions to you, including provision of our seals, where applicable;
• Communicate with you, including via email, about your use of our solutions, obtain your input on new features, functionality, and content, and to provide information about updates to our solutions;
• Collect net promoter score (NPS), satisfaction scores and other feedback, to identify improvement opportunities;
• Communicate with you about Smplifi events, industry or related news; and
• Deprovision your account on our platform.

If you have given us a prior authorization, we will send direct email marketing communications about our solutions. You may unsubscribe from the marketing communications at any time by clicking the "unsubscribe" link in the email communications we send to you.

Our contractual and legal obligations and legitimate interests

We process personal data about you based on our contractual obligations and legitimate business interests for the following purposes, as described above:

• To renew subscription-based solutions you have licensed;
• To provide additional solutions you request to respond to your reasonable requests and to retain you as a customer or partner;
• To better understand the needs of the business communities we aim to serve, we analyze our interactions with you online and offline and store that information in a quantitative way. This helps us continue to improve how we provide information and engage specifically with you, including to help us determine when you might be ready to make a purchase based on repeated interactions with Smplifi. We do not make any automated decisions about you that would result in legal or other similarly significant effects on you;
• To determine whether, when, and the IP address and associated city of, a marketing, sales, or business development email communication we sent was viewed based on our legitimate interest to effectively manage and improve upon such communications with you;
• To understand the business that you work for and your prior experience based on our legitimate interest to tailor our communications with you to improve our engagement with you;
• To understand your business needs based on our legitimate interest to develop and enhance our solutions to address your needs and to make them more relevant to you; and
• To manage our legal, financial, policy and regulatory compliance responsibilities and to demonstrate our compliance upon request.
• Deliver the resources and information you have requested online.

Statistical and research purposes

We may further analyze use of our solutions, and characteristics of the companies that use our solutions (e.g., by size and industry sector) to help us understand and make decisions about customer and market needs, to improve our solutions, to design new solutions, and to inform partnership and business development decisions.

Website Visitors

We process personal data about you that we collect either directly, through forms or data entry fields on our website, or through passive collection by cookies and other data collection technologies.

Business Analytics and Aggregation Program

Smplifi may, pursuant to its contracts some of the Smplifi Customers ("Participating Companies"), aggregate and provide analytics services that process your personal information that allow you to subscribe, and allows you to have access to an intermediation channel to, among other things, be able to enjoy potential benefits, offers, products, and/or services of clients and associates of Smplifi ("Supplier Companies"), in a hyper-personalized manner and in accordance with the terms and conditions accepted by you (the "Program"). All communications, transactions and/or interactions related to the Program will be carried out through these intermediation channels, which include our conversational electronic commerce domain, and its subdomains (the "Sites", and instant messaging applications such as WhatsApp (the "Apps").

Anonymization and Data Analytics

To improve our services while protecting your privacy, we anonymize collected data through a rigorous process that removes all personally identifiable information. This anonymized data is then aggregated and analyzed to identify patterns, trends, and insights about user behavior and service performance. Through this approach, we can make data-driven decisions to enhance our platform without compromising individual privacy. This anonymization process ensures that your individual information remains protected while allowing us to understand broader usage patterns that help us optimize the user experience, identify potential service improvements, and develop new features that better serve our community's needs. We will never attempt to re-identify anonymized data or combine anonymized datasets in ways that could compromise individual privacy.

Keeping and Securing Your Data

We will keep personal information about you for as long as we provide solutions to you, as long as you work for or with us, or as long as we are addressing a concern, question, complaint, or request you have made to us, as applicable to our interactions with you. If we have a contract or other agreement with you, we will follow the retention obligations of that agreement.

We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements. We also may keep data about you for statistical analysis or research purposes.

We take appropriate security measures to protect personal information against loss, misuse, and unauthorized access, alteration, disclosure or destruction. We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information, and will restore the availability and access to data in a timely manner in the event of a physical or technical incident.

International Data Transfers

We may transfer, access, or store personal information about you outside of the European Economic Area ("EEA"), Switzerland, or another country that requires legal protections for international data transfer. When we do, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:

• We may transfer personal information to countries that have privacy laws that have been recognized by the country from which the data are transferred as providing similar protections for the data.
• We may enter into written agreements with recipients that require them, through specific international data transfer sections, to provide the same level of protection for the data.
• We may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred.

Business Information and Links to Other Sites

Business information – In the course of using our solutions, we may ask you to provide business information related to the company where you work. Business information may include information about your company's practices, policies, processes, and supporting documentation. This business information is stored on Smplifi systems, and we use it to provide the solutions you have contracted us to provide and in accordance with the terms and conditions set forth in agreements between Smplifi and your company.

Links to other websites – This Notice applies only to Smplifi practices, technologies, and services. Our online properties may include links to websites and online services that are operated by other companies not under the control or direction of Smplifi. If you provide or submit personal information to those websites or online services, the privacy policies on those websites or online services apply to your personal information. We encourage you to carefully read the privacy policies of any website you visit.

Changes to this Notice

We may make changes to this Notice from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Notice in the future will be posted on this page, and where we change this Notice in ways that also affect how we process personal information about you, where appropriate, we will notify you directly via email or other direct contact with you, and we also will post a notice on our home page that this Notice has changed.

Contact Information

If you have any questions or issues that cannot be addressed through the links provided for access, correction and 'do not sell' above, please contact us at: smplifiassistant@gmail.com

Our office address is: Juan Palomar y Arias 705, Rinconada Margaritas

If you are a resident in the European economic area, please address your inquiries or issues to smplifiassistant@gmail.com.