Simply Smart Social Privacy Policy

Last updated: 19th January 2017

  1. Introdution
    1. This privacy policy (the "Privacy Policy") explains our approach to any personal data that you might supply to us (or that might be collected from you) ("Information") when you use the Service. The Information shall be used in accordance with the permissions granted by you and in accordance with the Data Protection Act 1998 (the "Act").
    2. This Policy relates to your use of the Service as provided by us as set out in, and should it should be read in conjunction with, our Terms of Service.
  2. Data Controller

    SoTech Creations Ltd, on behalf of Simply Smart Social (, is the data controller of your Information for the purposes of the Act.

  3. Consent
    1. By using the Service you consent to our collection and use of your Information as described in this Privacy Policy. If we change our Privacy Policy and/or procedures, we will post those changes on the Service to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it.
    2. Your continued use of the Service after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Privacy Policy, as amended. We encourage you to bookmark this web page and review this Privacy Policy regularly.
  4. The Information we Collect
    1. The type of information we may collect includes:
      1. Your full name
      2. Your address and postcode
      3. Your contact information (such as your email address)
      4. You payment details
      5. General information about yourself (such as your interests, your experience of our services and products or other services and products and your contact preferences)
      6. Information relating to your use of our Service
    2. When you connect to, or link the Service using Twitter, Facebook or other third party services, such third parties provide us with your “basic information”, which may include your service specific ID, name, username, gender, location and age range, as well as any other information you agree to share with us.
    3. We may also collect certain Information about your mobile device, computer hardware and software, which may include the following:
      1. IP address of device(s) used
      2. Browser type
      3. Operating system and device type
      4. Approximate location (e.g. London or Tokyo)
      5. Access times and dates
      6. Referring website addresses
  5. How Do We Collect Information
    1. When you visit and use the Service you may provide us with, or we may collect, your Information in a number of ways.
    2. Information you voluntarily provide to us
      We collect and maintain Information that you voluntarily submit to us during your use of the Service. For example
      1. When you register on the Service, you may provide us with certain Information including your name, email address, username, password, address, mobile phone number, and payment details
      2. When you link the Service to other third party platforms such as Twitter you may provide us with certain Information from or about your use of that service
      3. You may provide us with Information in the course of email exchanges, customer support interactions and surveys
    3. Information we collect through your use of the Service
      As you use the Service, Information may also be passively collected by us through our use of cookies, pixels, beacons, log files and other technologies. This Information allows us to deliver more helpful information, services and tools
    4. Information we receive from other third party sources
      We may also combine online and/or offline information received from third parties with your Information
    5. The third party information referred to above is used for a variety of purposes including:
      1. To verify your age or residency
      2. To verify other Information about you (e.g., your mailing address to send you requested products or services, email address for transactional emails)
      3. To enhance the content and services we provide to you
  6. How We Use Your Information
    1. We will use your Information in the ways described below and as described at the time that the Information is collected
    2. In general, we use your Information as necessary or appropriate for our business purposes, including:
      1. To ensure that the content on the Service is presented in the most relevant and effective manner for you
      2. To enable you to use the interactive features of the Service
      3. To provide products and services that you have requested
      4. To check that you comply with these Terms of Service
      5. To develop and improve the Service
      6. To send communications and administrative emails about the Service, our products, and updates to your account
      7. To analyse, benchmark and conduct research on user data and user interactions with the Service and our products and services
      8. For our internal record keeping
      9. To contact you to answer any queries you may have
      10. To contact you or permit our group companies and/or partners to contact you for market research or marketing purposes where you have given us, our group companies and/or our partners permission to do so. For more information on how we may market products and services to you please see below
  7. Marketing
    1. Where you have provided us with the appropriate consents, or where the Act entitles us to do so, we may send you marketing materials about other products or services offered by us, and/or products or services offered by our group companies. In addition, where you have provided us with the appropriate consents, we may also pass your Information to one or more of our group companies or other selected third parties for marketing purposes
    2. If you decide you do not want to receive those marketing communications, you can unsubscribe using the following method
      1. On each marketing communication there will also be an opportunity for you to unsubscribe (usually in the footer of the email)
  8. How We Disclose Your Information to Third Parties
    1. We may share your Information with third parties as specifically approved by you or under the circumstances described below
      1. If we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Information may be disclosed to prospective sellers or buyers and/or be among the assets transferred
      2. If we or a member of our group is under a duty to disclose or share your Information to:
        1. Comply with any legal obligation
        2. Enforce our rights under our terms and conditions and/or other agreements to which we are a party
        3. Protect the rights, property, or safety of our users, or others
      3. To third party service providers to enable them to perform functions and process user data on our behalf, consistent with this Privacy Policy. These service providers act as data processors and are strictly controlled in how they may/may not use your Information and we will remain responsible for the protection of your Information
      4. With your consent
  9. Third Party Links and Services
    1. Please remember that when you use a link to go from the Service to another website or you request a service from a third party, this Privacy Policy no longer applies.
    2. Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
    3. This Privacy Policy applies solely to information collected by us through the Service and does not apply to these third party websites and third party service providers.
  10. Where We Store Your Information
    1. The Information that we collect from you may be transferred to and stored at a destination outside the European Economic Area.
    2. Your Information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
    3. By submitting Information to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Information is treated securely and in accordance with this Privacy Policy and the Act.
  11. Security of Your Information
    1. We follow appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal information to comply with the same.
    2. However, unfortunately, the transmission of information via the Internet is not completely secure. So, we cannot ensure the security of your Information transmitted by you to us via the Internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the Act. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.
  12. Our Retention of Your Personal Information
    1. We will take all reasonable steps to retain your Information only for as long as reasonably necessary. If you no longer want us to store your Information you may request for it to be removed from our records. Please see below for details of how to request removal.
  13. How To Find Out What Personal Information We Hold on You
    1. Under the Act, you have the right to request a copy of the Information that we hold about you. There may be an administration fee of £10 associated with this request and it will require two pieces of identification to prove your identity.
    2. If you would like to request a copy of the Information that we hold about you, please make a written application to Support Team / contact us using the details provided at the end of this Privacy Policy.
  14. How To Correct or Remove Information About You Held By Us
    1. You also have the right to have Information removed or for any inaccurate Information about you to be corrected.
    2. If your Information requires amending, this can be done by either:
      1. Editing your Information on your Service profile; and
      2. Contacting us using the details provided at the end of this Privacy Policy.
    3. If you require us to correct or update your information, we will endeavour to do so as swiftly as possible. However, until such Information has been correctly amended, communications may be sent using the original details until the changes have been processed.
    4. If you would like your Information to be removed from our records, this can be done by
      1. Closing your account with us. If you choose to close your account with us, we will then cease processing your Information for any new purposes, but such closure shall not affect our ability to retain and process any Information required or the performance of obligations arising from law or for the completion of any services which are in process; or
      2. Contacting us using the details provided at the end of this Privacy Policy.
    5. Please note:
      1. That the removal of Information may prevent us from supplying certain services to you;
      2. Even if you delete Information, we may retain your Information in conformance with our data retention policy; and
      3. We are not responsible for updating or removing your Information contained in the lists or databases of third parties who have been provided with Information as permitted by this Privacy Policy.
  15. How to Contact Us
    1. If you have any questions about how we collect, use and share your data, you may contact us as follows:
      1. Email Support Team;