Privacy Notice

Simply Depo Platform

Last updated: 2023.01.15

Intro

Simply Depo Inc. (“Simply Depo” or “we”) welcomes you. We provide you with the Simply Depo web-based platform for wholesalers & distributors available following the link https://simply-depo-staging.web.app/login (”Platform”).

The Privacy Notice (“Privacy Notice”) describes how your personal data is collected, stored, and used and what happens when you use the Platform.

Content

About us

Data subjects

Personal data

Roles in the processing
Sources of data
Lawful basis for processing
Brands’ data
Customers’ data
Representatives’ data
Data received from third parties

Data sharing with third parties

Details

Data protection

Data subjects rights

United States residents
Do not sell my personal information
Do-not-track requests

Privacy Notice updating

About us

Name	Simply Depo Inc.
File Number	6017876
Address	1751 Stillwell Avenue, Brooklyn, NY 11223
Email	privacy@simplydepo.com – for any privacy issue

Data subjects

We process personal data of the representatives of who use the functionality of our Platform, as well as their customers and representatives.

Data subjects	Description
Brand	User, who registers on our Platform on the behalf of company either through the request to the representatives of SimplyDepo or through the Website.
Customer	Contact person of the customer of the Brand, whose data provided by the Brand.
Representative	Representative of the Brand, whose data provided by the Brand.
Please note! We do not knowingly process the personal data of data subjects under age 18. If you are such a data subject or you are the legal representative of such a data subject, please, contact us.

Personal data

Roles in the processing

Simply Depo is the controller of the Brands’ data.

Simply Depo is the processor of the Customers’ and Representatives’ data, acting on behalf of the Brands, which are the controller of the Customers’ and Representatives’ data.

Sources of data

We receive data when you interact with our Platform and use its functionality, depending on your actions and chosen settings of the Platform.

We process the personal data of the Customers and Representatives provided by the Brands based on the Data Processing Agreement, which is part of the Terms of Service.

We may also (although we do not necessarily do so) receive data from third parties. It depends on your settings and the features you use.

Lawful basis for processing

To process data subjects’ personal data, we rely on the following lawful basis:

performance of the contract — for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract with Brands;
legitimate interest — for the processing necessary for the development of our services and reasonable for Brands;
consent — for additional processing for specific purposes.

Brands’ data

Source of data	Description	Reasons for processing	Lawful basis
Onboarding communications.	Name of the company.	To provide with the Platform functions.	Performance of the contract.
Onboarding communications.	Business email.	To provide an access to the Platform functions.	Performance of the contract.
Settings.	Business phone.	To contact you in case of necessity.	Performance of the contract.
	FED Tax ID (EIN).	To comply with applicable legislation.	Legal obligation.
	Industry.	To provide you with the functions of the Platform.	Performance of the contract.
	Primary Time Zone.	________________
	Website.	________________
	Logo.	To provide you with the functions of the Platform.	Performance of the contract.
	Locations.	To provide you with the functions of the Platform.	Performance of the contract.
	Carrier info.	To provide you with the functions of the Platform.	Performance of the contract.
Payment settings.	Credit card info.	To charge you for the use of the Platform.	Performance of the contract.
Payment settings.	Bank account info.	To provide you with the payouts.	Performance of the contract.
Stripe.	Last 4 numbers of the credit card.	To verify your payment.	Performance of the contract.
Simpy Depo.	Invoices.	To provide you with the info about the payment to make.	Performance of the contract.
Simpy Depo.	Invoices.	To store the invoices in the Platform.	Legal obligation.
Conversations page.	Text of the messages to the Representatives.	To provide you with the functions of the Platform.	Performance of the contract.
Data storage
Data that is processed based on the legal obligation.		Stored during the use of the Platform and 3 years after the deletion of the account.
Data that is processed based on the performance of the contract.

Customers’ data

Source of data	Description of the data	Reasons for processing	Legal basis
Provided by the Brand.	Business name.	To provide you with the functions of the Platform.	Performance of the contract.
	ID.
	Group.
	FED Tax ID (EIN).
	Billing address.
	Shipping address.
	Business phone.
	Business email.
	Payment terms.
	Percent discount.
	Territory.
	Website.
	Tags.
	Assigned representatives.
	Full name of the customer contact.
	Phone number of the customer contact.
	Email address of the customer contact.
	Type of customer contact.
Data storage
Data that is processed based on the performance of the contract.		Stored during the use of the Platform.

Representatives’ data

Source of data	Description of the data	Reasons for processing	Lawful basis
Provided by the Brand.	Photo.	To provide you with the functions of the Platform.	Performance of the contract.
	Full name.
	ID.
	Role.
	Phone number.
	Email.
	Status.
Data storage
Data that is processed based on the performance of the contract.		Stored during the use of the Platform.

Data received from third parties

We may receive some personal data from third parties.

The amount of data collected, the purposes, and the legal basis for processing is determined by the respective privacy documents of these parties:

Third parties	Description
Google Analytics	We use these tools for statistics and analytics.
Facebook	We use Facebook for authorization functionality in the Platform.
HubSpot CRM	We use HubSpot CRM to analyze how our users interact with the application.
Other services	We may use various tools and services for marketing and other purposes. To get a detailed list of the tools, contact us.

Data sharing with third parties

We use personal data on the basis of the performance of the contract to provide services.

We share data subjects’ data with the service providers and contractors in the scope we need to provide services and technical and customer support, who, for example, help us:

operate, develop, and improve the features and functionality of our Platform;
provide you with their services;
complete your’ payment transactions;
fulfill your support requests;
communicate with you as described elsewhere in this Privacy Notice.

Also, we can share data subjects’ data on the following grounds: consent, compliance with the law, and legitimate interest.

Details

We share your data on the following grounds:

Performance of a contract. We may transfer your data to our contractors for contractual purposes.

Consent. We may transfer your personal data based on your explicit consent.

Compliance with the law. We may disclose your personal data to third parties to the extent that it is necessary:

to comply with a government request, court order, or applicable law;
to prevent unlawful use of our Website or policies;
to protect against claims of third parties;
to help prevent or investigate fraud.

Transfer to third parties. We may transfer your personal data to third parties based on a data processing agreement, subject to applying technical and organizational measures to protect your personal data. We may share data with certain companies, consultants and contractors hired to provide certain services on our behalf.

Please note! We will ask for your consent if data transfer is not part of the contract.

Data protection

We apply a variety of security measures appropriate to the risks.

Organizational measures
Staff training	Internal policies and instructions
Non-disclosure agreements (NDA)

Physical measures
Video-monitoring

Technical measures
Two-factor authentication	Encryption technologies

Data subjects rights

The Customers and Representatives shall exercise their privacy rights through the communication with the corresponding Brand.

Brands, as the data subjects, have the following rights:

United States residents

To use them, please contact us.

Please note! Depending on the state and legislative requirements, we have from 30 to 60 days to exercise your request, with the right to postpone it for 30 days more.

If your complaint was not satisfied, you can file a complaint with the Federal Trade Commission.

Right	Description	Area
Right to access.	You can request an explanation of the processing of your personal data.	California; Virginia; Ohio; Colorado; Nevada; Massachusetts;	Minnesota; New York; North Carolina; Pennsylvania; Delaware; Utah.
Right to rectification.	You can change the data if it is inaccurate or incomplete.	California; Virginia; Colorado; Nevada; Delaware;	Massachusetts; Minnesota; New York; North Carolina.
Right to deletion.	You can send us a request to delete your personal data from our systems. We will remove your data within 48 hours from our systems and all backups will be deleted in 7 days.	California; Virginia; Ohio; Colorado; Massachusetts;	Minnesota; New York; North Carolina; Pennsylvania; Utah.
Right to restriction.	You may partially or completely prohibit us from processing your personal data.	California; Massachusetts;	New York.
Right to portability.	You can request all the data you provided to us and request to transfer data to another controller.	California; Virginia; Ohio; Colorado; Massachusetts;	Utah; Minnesota; New York; North Carolina.
Right to Opt-Out.	The right to prohibit the sharing or selling of your data.	California; Virginia; Ohio; Colorado; Nevada; Massachusetts; Minnesota;	New York; North Carolina; Pennsylvania; Delaware; Colorado; Utah.
Right Against Automated Decision Making.	You have the right not to be subject to a decision based solely on automated means if the decision produces legal effects concerning you or significantly affects you in a similar way.	California; Massachusett; Virginia; Colorado;	Minnesota; New York; North Carolina.
Right to lodge a complaint.	If your request was not satisfied, you can file a complaint to the regulatory body.	By default.
Note: Some states do not have their own privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us.

Do not sell my personal information

California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by CCPA.

Simply Depo does not sell your personal information to anyone nor use your data as a business model.

However, we support the CCPA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that we will not sell your data in the future, please contact us: at privacy@simplydepo.com.

Do-not-track requests

California residents visiting our Website may request that we do not automatically gather and track information about their online browsing movements across the Internet.

Such requests are typically made through web browser settings that control signals or other mechanisms that allow consumers to exercise choice regarding collecting personal data about an individual consumer’s online activities over time and across third-party websites or online services.

We currently do not have the ability to honor these requests. We may modify this Privacy Notice as our abilities change.

Privacy Notice updating

The Privacy Notice and the relationships falling under its effect are regulated by the laws of the New York state.

Existing laws and requirements for processing personal data are subject to change. In this case, we will publish a new version of the Privacy Notice.

If significant material changes are made to our Platform that may affect your privacy and confidentiality, we will notify you by displaying information in the Platform and ask for your consent if necessary.