Last updated: September 23, 2026
We at Simply Ltd. (“we”, “us”, “our” or “Simply”) are committed to protecting any data that we collect concerning you when you use or register on our website located at www.hellosimply.com (the “Site”) or by using our applications and online products, such as “Simply Piano”, “Simply Guitar”, “Simply Draw”, “Simply Sing”, “Simply Tune” and “Piano Maestro by JoyTunes” or any other application or software by Simply (collectively, the “Apps”).
Please note that this Privacy Policy applies to the information that we collect through the Site and the Apps. Please note that your use of our services provided through the Apps (the “Service”) is subject to the Terms of Use.
By using our Site or the Apps you agree to the use of the data that we collect in accordance with this Privacy Policy, as may be amended from time to time.
We encourage you to read this Privacy Policy carefully and reach out to us if you have any further questions.
Any Personal Data you provide is given voluntarily, and with your consent - where such consent is required under applicable data protection laws. You acknowledge that you are not under any statutory obligation to provide us with Personal Data. However, we may need to collect or receive certain Personal Data in order to provide, operate, secure, and manage the Services. If you do not provide us with the necessary Personal Data, we may be unable to fulfill certain purposes, such as enabling the use of specific features, as further described in Section 2 of this Privacy Policy – Data Sets We Collect And For What Purpose – which details the purposes for which each set of Personal Data is collected.
This Privacy Policy further includes or incorporates specific information required under applicable data protection laws for residents of certain jurisdictions, including but not limited to:
If you are located in the EEA or UK, this Privacy Policy further details our lawful basis for processing Personal Data, information regarding cross-border data transfers, your rights related to the Personal Data we process, as well as additional information we are required to disclose to you under the EU and UK General Data Protection Regulations (collectively, “GDPR”).
If you are a US resident, please also review Section 11 of this Privacy Policy which serves as a Notice at Collection as required under the California Consumer Privacy Act (“CCPA”) and other US privacy laws, and further details the categories of information collected and additional information regarding our privacy practices, including your rights under the CCPA and other US privacy laws.
Simply Ltd. is incorporated under the laws of the state of Israel and, unless otherwise explicitly mentioned in the table below, is the “data controller” (as such term, or equivalent, is defined under applicable data protection legislation) of the personal information collected through the Services which is subject to this Privacy Policy. Meaning, we control the processing of personal information under this Privacy Policy and decide upon the purpose and means of collection and processing.
For any questions, inquiries or concerns related to this Privacy Policy or the processing of your personal information, you may contact us as follows:
By Email: dpo@hellosimply.com
By Mail:
Simply Ltd.
22 Isserles St., Tel Aviv-Jaffa, Israel
Attn: Data Protection Officer
Representative for Data Subjects in the EU and UK Contact Information:
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative, Prighter, or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/17743967545
You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.
During your interaction with our website and Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type and model of your mobile device, operating system and its version, device language settings, app version, general country location, date and time of use, etc.
We may also collect from you, directly or indirectly, during your access or interaction with Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified in the table below.
We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).
The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:
Data set: In order to register and create an account through our App, we will collect the Personal Data that you are required to provide us during the registration process, such as your full name, email address, password, age/age range or year of birth, and nickname. Additionally, if you sign up via your social media account (i.e., Apple, Google, or Facebook), we may have access to certain information that you allow the relevant social media provider to share with us. For teacher account under the Piano Maestro application we will also collect the address. You represent and warrant that you will not provide us with inaccurate, misleading, or false information. If you purchase a family subscription, we may also use your account information to identify you and provide you with account access across our Apps. The account holder may add additional users and create their profile under their name or nickname assigned by the account holder, as well as age range or year of birth. If you add to your account an individual user which is considered as a “child” under applicable laws you do not need to provide the child actual name, nicknames or made-up names work just as well. Inputting a name simply helps you and us distinguish between multiple profiles under your account; the birth year or age allows for age-appropriate content customization.
Purpose and operations: This information will be processed for the purpose of performing our contract with you, to set up your account with us and enable you to use our Services. as well as create a designated user for each user you have created a specific profile for under your account and attribute the applicable progress and learning data for such user. Age or age range is used to customize the Services and offer appropriate content or instructions. If you purchase a family subscription, we will also process your account information to identify you and provide you with account access across our Apps. In addition, we may process your Personal Data for our legitimate interests, for example, to send you marketing and promotional messages and offers related to our Services. You are able to unsubscribe from receiving such correspondence from us by contacting us at: dpo@hellosimply.com. Please note that if you choose to unsubscribe from direct marketing, we may still retain your contact details and send you relevant service-related information such as invoices and subscription rates.
Lawful basis: The registration information is processed to perform our contract with you, including to provide account access across our Apps in connection with a family subscription, and the direct marketing is subject to our legitimate interest.
Data set: If you voluntarily contact us, you may be required to provide us with certain information such as your name and email address (“Contact Information”) and any additional information you decide to share with us.
Purpose and operations: We will use this data to respond to your inquiry.
Lawful basis: We process such Contact Information subject to our legitimate interest and the performance of a contract with you, if your inquiry relates to a contractual relationship with us. We may keep such correspondence if we are legally required to.
Data set: We may apply push notification based messages token. If you wish to stop getting push notifications, you may do so simply by disables push notifications on your device’s settings or uninstall the app.
Purpose and operations: This information will be processed to allow us to send push notification to users from our server.
Lawful basis: As the token is Non-Personal Data it does not require a lawful basis.
Data set: This data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the App when utilizing our Service, the time and date of your use of the Service, and other statistics. In addition, when you download and install one of our Apps, we may collect a unique identifier generated by AppsFlyer, which allows us to recognize user activity across our different Apps and support our marketing, attribution, and campaign effectiveness analysis.
Purpose and operations: In most cases, this data will not include Personal Data, however we treat this information as Personal Data as we may be able to reasonably identify you. We use the AppsFlyer identifier to help us track user journeys across our Apps and for marketing-related purposes, including measuring and optimizing our campaigns.
Lawful basis: We process this data set for our legitimate interest in protecting our App and Services. where we use the Unique Identifiers for marketing purposes we will do so subject to consent where required under applicable law.
Data set: As part of our Services, we collect data related to your learning progress, including the lessons and phases you have completed, songs you have played (or drawn/sung, as applicable), your success scores, and detailed performance analytics (such as notes played correctly or incorrectly, as determined by our audio analysis). We may also collect information regarding which courses or topics you have selected, your position within a given lesson, and your course preferences.
Purpose and operations: This information is processed for the purpose of performing our contract with you and enabling you to use our Services effectively, including tracking your progress and providing you with feedback. In addition, we process this data for our legitimate interest of understanding user engagement, improving our Services, and optimizing our educational content.
Lawful basis: The progression and learning data is processed to perform our contract with you. The internal analysis and service improvement activities are subject to our legitimate interest.
Data set: During your use of the App, we may collect information to personalize your experience, such as your song selections, preferred genre, reasons for using the App (e.g., why you chose to learn piano, guitar, singing, or drawing), your prior experience level, and your personal goals. We may also collect your name, age, gender, location, favorite artists, and musical preferences. Some of this information is collected through multiple-choice selections and some through open-text responses.
Purpose and operations: We use this data, together with information derived from your use of the App (including your age and location), to assign you to an appropriate difficulty level, create user profiles, recommend future songs or content suited to your skill level, and otherwise personalize and enhance your experience with our Services.
Lawful basis: The personalization data is processed to perform our contract with you and to provide you with a tailored experience. Additionally, we process this data subject to our legitimate interest of improving and optimizing our Services and content recommendations.
Data set: As part of our Services, you may be required to provide input using your device's microphone. In order to access your microphone, you will need to grant us permission through your device settings. Please note that, in some cases, audio recordings collected through our Services are not expected to include any human voice at all and therefore would not ordinarily be considered Personal Data. Nevertheless, we may still treat such recordings as Personal Data where we can reasonably associate them with you or your account, or where doing so helps us apply a consistent level of privacy and security protection. The manner in which audio data is collected and processed may vary depending on the specific App you are using, as described below: Simply Sing: Audio recordings captured through your microphone are sent to our servers to provide AI-powered feedback. Certain recordings may also be uploaded to our servers for model training and quality assurance purposes. We may also analyze vocal expression data, such as volume and confidence levels. Please note that audio recordings are not made available to users for playback or download. Simply Piano: Audio captured through the microphone is processed locally on your device. We do not currently store raw audio recordings on our servers; however, we may do so in the future to enhance and improve our audio analysis capabilities. On our servers, we retain information regarding which songs were played, your performance scores, and analysis of the audio (such as which notes were missed) in order to assess how lessons align with your progress. Simply Guitar: Audio is captured through your microphone and all processing is performed live on your device. We track information regarding the sounds played for the purpose of performance analysis and feedback. Simply Draw: You may choose to share images with "Tom," our AI-powered feature that provides feedback on your artwork. Tom may also send video content to you, and you may provide voice comments regarding content you would like to see. Voice recordings submitted in this context are retained for up to 90 days and may be reviewed by our team to identify additional content ideas and improve our Services. As part of our services, you may provide input using your device's microphone and provide us with Audio data using the microphone. In order to access your microphone we will need you to provide us with the permission to access the microphone through the device settings.
Purpose and operations: We process Microphone and Audio Data for the purpose of performing our contract with you and providing you with the core functionality of our Services, including real-time feedback and progress tracking. Additionally, where audio data is used for quality assurance, or service improvement, such processing is subject to our legitimate interest. Where applicable, audio processing that requires server-side storage and model training, relies on your consent, as provided through your device permissions.
Lawful basis: The Microphone and Audio Data is processed to perform our contract with you. Quality assurance, and service improvement activities are subject to our legitimate interest. Accessing your device's microphone is subject to your consent as provided through your device settings. Using the data to train our AI module is subject to your consent.
Data set: Depending on the App you are using, we may collect images or access your device's camera as part of our Services. In order to access your camera, you will need to grant us permission through your device settings. Please note that, in most cases, Image and Camera Data collected through our Services are not expected to include any human image at all and therefore would not ordinarily be considered Personal Data. Nevertheless, we may still treat such recordings as Personal Data where we can reasonably associate them with you or your account, or where doing so helps us apply a consistent level of privacy and security protection. The manner in which image and camera data is collected and processed may vary depending on the specific App you are using, as described below: Simply Guitar: We may capture up to 10 images of your fingers while you play, which are sent to our servers for the purpose of training our machine learning models. On your device, we perform analysis of how you hold the guitar. We may also share certain images with third-party AI services (such as Google Gemini) to generate visual descriptions that assist us in training our models. These images are retained on our servers until the relevant model training is completed. Simply Draw: You may share your artwork through your device's native sharing functionality. Please note that sharing is facilitated through your device's operating system API, and we do not have visibility into the identity of the recipient. Recipients may add comments to shared artwork, which will then appear to you within the App.
Purpose and operations: We process Image and Camera Data for the purpose of performing our contract with you and providing you with the core functionality of our Services. Where image data is used for service improvement, such processing is subject to our legitimate interest. In case we will use the data to train our AI model we will first obtain your consent. Accessing your device's camera is subject to your consent as provided through your device settings.
Lawful basis: The Image and Camera Data is processed to perform our contract with you. Model training is subject to your consent. Accessing your device's camera is subject to your consent as provided through your device settings.
Data set: When you purchase a Subscription through our App and offered Services, all payment are in-app payments and are subject to the applicable App Store terms and privacy policy. Google Terms of Service Google Privacy Policy App Store Terms of Use App Store Privacy Policy when you purchase a Subscription through our website, we will use Stripe or Paypal as a third party payment processor to process information related to the transaction any transactions that are processed by Stripe or Paypal will be governed by its privacy policy, which we recommend that you review.
Purpose and operations: We use payment processors; the registration and payment information are solely processed by the applicable app store provider. We do not store nor process any Personal Data when you process the payment. We receive an order number which is connected to a user ID which was generated when installing the app (non identifiable).
Lawful basis: The Payment Information is processed to perform our contract with you to provide you our Services.
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above.
Certain features of our Services may use computer vision and other artificial intelligence ("AI") technologies, that enables to interpret and analyze visual information such as images and videos. For example, some features (i) access your device camera to provide on-device, real-time guidance, and (ii) use AI to generate or tailor certain content (such as encouragement messages) based on your activity and performance within the Services. When you use such real time features, note that personal information included in the videos or images is processed on your device and shall not be uploaded to our servers. We may extract non-personal information, and use it for internal services improvement purposes, however personal information will not be processed for machine learning or AI training purposes unless we obtain your prior consent.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
Automatically, We process this information based on your consent provided through the organic in-app permissions in order to execute our contract with you and provide you with our services.
When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.
Provided from third-parties.
We may use cookies, tracking pixels (also known as clear GIFs and web beacons), third party software development kits (SDKs) as detailed in the table below, and other technologies in order to maintain, provide, and improve our website, Apps and Services. We use Cookies for various purposes:
Strictly Necessary Cookies: these cookies are necessary for our website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the website will not work.
Functional Cookies: these cookies enable the website to provide enhanced functionality and personalization (e.g., remembers your preferences so you don’t have to re-set them each time you visit). They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Performance and Analytics Cookies: these cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the website. If you do not allow these cookies we will not know when you have visited our website, and will not be able to monitor its performance.
Marketing and Targeting Cookies: these cookies allow us to know whether or not you’ve seen an ad or a type of ad, how you interacted with such an ad, and how long it has been since you’ve seen it. We also use cookies to help us with targeted advertising. We may partner with ad networks and other ad serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your use of our website and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.
The third-party cookies we currently use and purpose of use are listed in our Cookie List, which you may further use to opt-out of cookies or change your preferences at any time. The specific SDK we currently use, the purpose of the SDK, their privacy policy and opt-out controls are set forth in the table below:
Names: Firebase; Mixpanel; Snowflake
Purpose: Authentication, Analytics & Crash data
Privacy policies:
Names: Meta; TikTok; Google; Microsoft
Purpose: Marketing and Advertisements
Privacy policies:
Names: Google Generative AI (Gemini); OpenAI; Apple
Purpose: AI based features
Privacy policies:
Names: Intercom; Braze
Purpose: Support and system notification
Privacy policies:
Names: Stripe; PayPal; Apple Pay; Google Pay
Purpose: payment
Privacy policies:
Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and are responsible for their practices.
We do not share any personal identifiable information or data with third parties, except as described below:
We may share Personal Information with service providers and third parties for our operational purposes to enable the provisions of our services and with other service providers who provide crucial functions as database management, maintenance, marketing, data processing and analytics customer support platforms, hosting service providers, payment processors, analytics partners, AI technology providers, third party account providers, security and/or social media service. These third parties have access to your data only to carry out these tasks on our behalf and are contractually obligated to keep all personal data they process strictly confidential.
Marketing. We engage with marketing partners and share personal information to market and promote our Services, including for targeted ads. These may include social media partners or other marketing services operators, including by way of placing their cookies or other tracking technologies on our website. These marketing partners may combine your personal information with other data they collect independently from you through other websites you visit online
Third Parties, Authorities, Security Providers, Governmental Agencies, or Authorized Third Parties. For protecting rights and safety of our Services and Apps, we may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of users or individuals, or any members of the general public. This will include legal and law enforcement purposes, meaning, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our services.
Subsidiaries and Affiliated Companies . We may share Personal Data, internally within our group or in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
Your request and consent. Where you request to share your personal information with others we may do so in order to comply with your request. If we ever want to use or share your information for something that isn’t already covered in this policy we will share your information per your request. For other purposes we have not disclosed under this policy, unless required under applicable we will ask for your permission first.
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
The principal rights that may apply to your Personal Data (subject to your jurisdiction and additional conditions) may include:
You have the right to be provided with information regarding our Personal Data collection and privacy practices, as we detail under this Privacy Policy. You may also have the right, at our option, to receive a list of the specific third parties to which we have disclosed either your Personal Data or any Personal Data. This Privacy Policy also details our Personal Data handling practices.
You have the right to confirm whether we collect Personal Data about you and to know which Personal Data we specifically hold about you, as well as receive a copy of such or access it. If you wish to receive a copy of the Personal Data, please contact our DPO: dpo@hellosimply.com
You have the right to correct inaccuracies in your Personal Data in the event you found it incorrect, outdated, etc. (or otherwise request its deletion), taking into account the nature and purposes of each processing activity. If you wish to exercise this right, please contact our DPO: dpo@hellosimply.com
You have the right to request the deletion of certain Personal Data we process, if specific conditions are satisfied, for example, if you think we no longer need to use it for the purpose we collected it; in the event that the collection was based on your consent; where we have used it unlawfully, or; where we are subject to a legal obligation to delete your Personal Data. Deletion request will be subject to our rights and obligations under applicable law (for example, our legitimate interests to maintain record keeping, completing transactions, providing a service that you have requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, detecting security incidents, protecting against illegal activity; debugging; exercising right provided for by law, etc.). If you wish to exercise this right, please contact our DPO: dpo@hellosimply.com You are not required to create an account with us to submit a deletion request.
You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please contact our DPO: dpo@hellosimply.com
Where we process Personal Data based on your consent, you have the right to withdraw such consent at any time. For example - you have the right to withdraw consent from receiving any marketing communication from us or otherwise opt-out, by unsubscribing through the message received. You have the right to opt-out or otherwise withdraw consent from processing of Personal Data through our use of cookies, by changing your preferences through the cookie setting tool available on our website. You have the right to withdraw our access to certain data collected from device permissions from the App’s Privacy Settings. If and to the extent applicable, you have the right to opt out of the “sale” or “share” of your Personal Data, which includes opting-out of our practice of using cookies for the purposes of targeted advertising, analytic, etc., by clicking on the “Do Not Sell or Share My Personal Information” link on our website or communicating your opt out through opt-out preference signals, like Global Privacy Control (learn more here). In any event, please keep in mind that opt-out tools are limited to the browser or device you use because they work off your browser ID and device ID and, accordingly, you will need to opt-out on each browser and device you use. Your browser may save some information in its cookies and cache to maintain your privacy preferences. Clearing these may remove opt-out preferences, requiring you to opt-out again. We do not profile you in a manner that has a significant effect on you or other individuals, therefore we do not provide an opt-out option from such use of Personal Data.
You have the right to object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest. If you wish to exercise this right, please contact our DPO: dpo@hellosimply.com
You have the right to ask us to restrict or limit the purpose for which we process your Personal Data, where certain conditions are satisfied (for example, where you contest the accuracy of the Personal Data, for a period enabling us to verify its accuracy). If you wish to exercise this right, please contact our DPO: dpo@hellosimply.com
If you believe that our processing of your Personal Data infringes the UK GDPR, you have the right to submit a complaint to us under section 164A of the Data Protection Act 2018. You may do so by contact our DPO: dpo@hellosimply.com. Upon receipt of your complaint, we will acknowledge it within 30 days and, without undue delay, take appropriate steps to investigate and respond, including notifying you of the outcome. You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) under section 165 of the Data Protection Act 2018, as further described below.
If we decline to take action on your request, we will inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Within the timeframe set under applicable law as of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority. Where the GDPR applies, you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK.
For additional information on your rights and how to exercise your rights, please contact our DPO: dpo@hellosimply.com.
Further, certain rights can be exercised from the App: you may correct, revise and delete information using the App settings at any time, any consent provided may be easily withdrawn (for example, permission to access the camera or audio, through the App Privacy Settings), and you may opt-out from certain features and tracking, therefore we recommend you use the technical solutions we have provided you with to exercise your rights.
In general, unless a different retention period is described above, we retain the Personal Data we collect for as long as it is necessary for the purposes set forth above, where permitted by law or regulation, or until you request deletion of your information, where applicable.
Other circumstances in which we may retain your Personal Data for longer periods of time, where permitted by law or regulation, include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) to maintain an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data.
Please note that, except as required by applicable law or our specific agreements with you, we are not obligated to retain your Personal Data for any particular period, and we may securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at dpo@hellosimply.com.
Our data servers, on which we host and store information, are located globally, including in the US and EU. Our headquarters are based in Israel, where we may access information stored on local servers, cloud-hosting servers, or other systems and platforms we use. If we need to transfer your Personal Data outside your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection, as required under applicable law. Furthermore, when Personal Data collected within the European Economic Area ("EEA"), the United Kingdom, or Switzerland is transferred outside such jurisdiction to a country that has not received an adequacy decision from the European Commission or the ICO, we will take the necessary steps to ensure that sufficient safeguards are provided during the transfer of such Personal Data, in accordance with the EU, UK, or Swiss Standard Contractual Clauses or, as applicable, the EU/UK-US Data Privacy Framework. Accordingly, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections that regulators have pre-approved to help ensure your Personal Data is protected.
We maintain technical and organizational measures to protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your information and we are committed to ensuring that all your collected data is secure.
We strive to maintain the reliability, accuracy, and completeness of personal information that we collect and to protect the privacy and security of our users. We keep your personal information only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We limit access to personal information about you to employees, contractors, and service provider who we believe reasonably need to be exposed to the personal information. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
If you suspect your login information has been compromised, you should notify us immediately at dpo@hellosimply.com and change your password.
From time to time, we review our security mechanisms. However, please be aware that despite the efforts and resources we are investing, no security measures are perfect or impenetrable. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
This section is for parents and guardians that adds a user which is considered as a “child” to its account. We take children’s privacy seriously. Below, we explain how we protect your child’s information when they use our Services.
How your child’s account works. Children do not create their own accounts on Simply. You as the parent or legal guardian are always the account holder. You can add your child as a user (a “Child User”) through your account settings by providing basic profile information, such as a first name or nickname and age or age range.
How we get your permission. We do not knowingly collect personal information from or about your child without your consent. Because you are the account holder, the combination of creating your account, completing a paid subscription, and then choosing to add a Child User to your profile serves as our way of obtaining your verifiable parental consent.
What information we collect about your child. We collect the profile information from you when adding a Child User (such as your child’s first name or nickname and age). When your child uses the Services, we also collect some of the data types described in Section 2 of this Privacy Policy and is needed to make the App and the Services available. We do not directly use your child’s personal information for marketing purposes. We may process the device ID as part of behavioral or targeted advertising.
Your rights as a parent. Because you are the account holder, you have direct control over your child’s data. You can manage your Child User’s information at any time through your account settings, or by contacting us at info@hellosimply.com (see also Section 1 for our full contact details).
How long we keep your child’s information. We keep your child’s personal information only for as long as we need it to provide the Services. We will delete information associated with a Child User profile when it is no longer needed, when you request deletion or remove the profile from your account.
Questions about your child’s data? If you believe your child has given us personal information without your consent, or if you have any questions about how we handle children’s data, please contact us at info@hellosimply.com We will look into it promptly and delete any information that was collected without proper consent.
Residents of certain U.S. states (depending on the applicable state law, acting in an individual or household context and not in a commercial or employment context or as a representative of business), including California, Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws and be entitled to additional disclosures.
“Personal Data” under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)
“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; personal information collected from a known child; Precise geolocation data.
We are required to provide you with a clear and accessible privacy notice that includes the categories of personal information processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of personal information shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.
Categories of Personal Data & Categories of third parties with whom Personal Data is shared:
Under the paragraph “Collection of Personal Information” of this Privacy Policy, we describe our collection and processing of personal information, the categories of personal information that are collecting and processing, and the purposes for which personal information is processed, stored or used.
Additionally, under the paragraph “When and With Whom Information is Shared” of this Privacy Policy, we detail and disclose the categories of third parties we share personal information with for business purposes. We will not collect additional categories of personal information or use the personal information we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent.
“Sale” of Personal Data:
Under US privacy laws, the term “sale” refers to disclosing or making available Personal Data to a third party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” Personal Data as most people would commonly understand that term, i.e., we do not disclose your Personal Data in direct exchange for money or some other form of payment. However, subject to the definition of the term “sale” under such US privacy laws, our practice of sharing the categories of Personal Data detailed above, when we use cookies or other third-party advertising services, is considered as “selling” Personal Data. The categories of Personal Data shared for this purpose include: Online Identifiers such as IP and Cookie ID; Internet and electronic network activity information (Device and Usage Data – such as your engagement with our Services); geolocation data (such as country level extracted from IP). You have the right to opt out of such “sale” at any time by changing your preference using the cookies preferences tool available on our Site or through the App.
Consumer Rights:
Residents of certain U.S. states, including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:
Access - the right to confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.
Delete - the right to delete their personal information provided to or obtained by us.
Correct - the right to correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of the personal information.
Opt-Out – the right to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for profiling in furtherance of making decisions that produce legal or similarly significant effects. However, as noted above, we do not engage in profiling in furtherance of legal or similarly significant decisions.
Appeal – the right to appeal if we decline to take action in response to your exercise of a privacy right.
Non-Discrimination – the right to not be discriminated against for exercising your privacy rights.
The paragraph “Controlling Your Privacy Rights” provides additional information regarding your principal rights.
Exercising Your Privacy Rights:
You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at: dpo@hellosimply.com
When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.
Authorized agents may initiate a request on behalf of another individual by contacting us at dpo@hellosimply.com; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
If we decline to take action on your request, we shall so inform you without undue delay, within the timeframe set out under applicable law. Our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction.
We may update and amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be accessible from our websites and Apps. The updated date of the Policy will be reflected in the “Last Modified” heading. In case of a material change, or if required by law, we will provide notice reflecting these changes and any such material amendments to our privacy practices described under this Policy will become effective within the period noted in such notice. Unless otherwise notified, any changes will become effective when we publish the modified Policy. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices.
We require that you read this Privacy Policy and encourage you to contact us for any questions at dpo@hellosimply.com, or by mail to:
Simply Ltd.
22 Isserles St., Tel Aviv-Jaffa
Israel