Last Revised: June 7th, 2014

SimplexCC Ltd. (“SimplexCC”, “Company” “we” or “us”) respect the privacy of the users of our platform (the “Platform”) and/or our website or (the “Site”), and are committed to protect the personal information that users share with us in connection with the use of our Platform and/or Site (collectively – the “Service”).

This Privacy Policy (the “Privacy Policy”) is intended to describe our practices regarding the information we may collect from you (the “User” or “you”) when you use the Service (or any part thereof), the manners in which we may use such information, and the options and rights available to you.

Capitalised terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at (the “TOU”), which this Privacy Policy is incorporated thereto by reference.




Please note: you are not obligated by law to provide us with any Personal Information. You hereby acknowledge and agree that you are providing us with Personal Information at your own free will, for the purposes described in Section ‎‎4 below, and that we may retain such Personal Information in accordance with this Privacy Policy and any applicable laws and regulations.


2. Which information we may collect on our Users?

We may collect two types of data and information from our Users:

a. The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Service and/or the Exchange carrying the Service, as applicable (“Non-personal Information”). We are not aware of the identity of the User from which the Non-personal Information was collected.

b. Non-personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Service, the period of time the User visited the Service and related time stamps, etc

c. Non-personal Information shall be gathered by us in order to perform preliminary examinations of the Exchange’s users before enabling such users to use the Service.


d. The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual, or may be of private or sensitive nature (“Personal Information”).

Personal Information which is being gathered may consist of the following:

  • The User’s IP address, which is automatically provided by the User and used mainly for enhancing the User’s experience and for geolocation, personalisation and security purposes, as further detailed below.
  • In the event that following the preliminary examinations of Non-personal Information as noted above, such user is determined as qualified to use the Service (as shall be determined in our sole discretion), then after clicking the Service button the User will be requested to fill out the registration form available on the Service, and such User will be required to provide certain information such as his/her contact details, e-mail address and password for the Service, the User’s credit card details, billing information and official proof of identity and address and any additional required information in order to render the Service. In addition by clicking on the Service button, you hereby agree that the Exchange shall transfer Personal Information needed for rendering the Service and that we may reuse such information provided by the Exchange or provided by you as described above in this section.
  • The User’s publicly-available social network information, provided that the User has an existing third-party social network account (namely, a Facebook, Twitter, LinkedIn or Google+ account) (“SN Account”) registered under the same name and/or e-mail provided by User when registering to the Service.
  • In the event a User registers to the Service or otherwise grants us with certain access permissions to his/her SN Account, the third-party social network(s) operating such SN Account(s) may provide us with certain information about the User, as is stored in and/or made available by the User through his/her SN Account and in accordance with the permissions granted to us by the User. For example, such information may consist, as applicable and/or made available by the User, of the User’s name, public profile picture URL address, SN Account User ID, e-mail address, date of birth, gender, occupation or work information, education and other information which the User made public.
  • The User’s credit rating and other information available through publicly available credit card black lists and official limited bank account lists.
  • Any Personal Information provided voluntarily by the User via its use of the Service, such as the User’s e-mail address in order to be contacted (and any additional information related to such contacts), transaction details provided through use of the Service, and/or other actions performed by the User in connection with the Service.

For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.


3. How Do We Collect Information on Our Users?

We use the following methods of collection:

a. We collect Non-personal Information through your use of the Service and/or the Exchange carrying the Service. In other words, when you are using the Service, including when you browse the Exchange website(s) carrying the Service, we may be aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below.

b. We receive Non-personal Information from the Exchange carrying the Service. For example, when you return to an Exchange website(s) carrying the Service, such Exchange may provide us with non-identifying usage information regarding your previous visits to its website(s).

c. We collect Non-personal and Personal Information through publicly available sources. For example, we may collect certain information about you through your publicly available SN Account(s) information, publicly available credit card black lists and official limited bank account lists, and other online public information.

d. We obtain Personal Information from third-party services and from the Exchange carrying the Service. For example, we may use third-party services to receive and enhance User information.

e. We collect Personal Information which you provide us voluntarily. For example, we collect Personal Information required to use the Service when you register and open an Account by completing the registration form and/or contact us directly.

We store the Personal Information either independently or through the help of our authorised third-party service providers as detailed below.

4. What are the Purposes of the Collection of Information?

We collect Non-personal and Personal Information in order to provide and operate the Service, including for risk analysis, billing, statistical and research purposes; to enable us to further develop, customise and improve the Service based on Users’ common preferences and uses; to create and provide our business partners and affiliates with aggregated statistical data and other aggregated and/or inferred Non-personal Information; to enable us to provide our Users with a better user experience, with more relevant Content, features and functionalities, and with technical assistance and support; and in order to abide by any applicable law.


5. Sharing Information with Third Parties

SimplexCC will not share any Personal Information it collects with any third party. Notwithstanding the foregoing, we may disclose Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s support requests; (e) to respond to claims that any content available on the Service violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of SimplexCC, any of its Users, or the general public; (h) when SimplexCC is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) to collect, hold and/or manage your Personal Information through SimplexCC’s authorised third party service providers (for example, Amazon Web Services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) to enable payment and processing of transactions through your credit card operator and certain online payment methods; (k) pursuant to your explicit approval prior to the disclosure; or (l) to cooperate with third parties for the purpose of enhancing the Service User’s experience.

For avoidance of doubt, SimplexCC may transfer and disclose to third parties or otherwise use Non-personal Information at its own discretion.


6. Deletion of Personal Information

If for any reason you wish to delete your Personal Information stored with us and identifying to you, please send us an e-mail, and we will make reasonable efforts to delete any such Personal Information pursuant to any applicable privacy laws. Note that unless you instruct us otherwise we may retain your Personal Information for a period of five (5) years or a longer period as required to provide you with the Service and/or as legally required.


7. Minors

To use the Service, you must be over the age of eighteen (18). SimplexCC does not knowingly collect Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Service. In the event that it comes to our knowledge that a person under the age of eighteen (18) is using the Service, we will prohibit and block such User from accessing the Service and will make all efforts to promptly delete any Personal Information stored with us with regard to such User.


8. Cookies & Local Storage

When you access or use the Service, we may use industry-wide technologies such as “cookies” or similar technologies, which stores certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. The cookies used by the Service are created per session, do not include any information about you other than your session key (removed as your session ends (usually after 24 hours)) and the ability to login again quickly (automatically removed usually after two years, unless manually removed on an earlier occasion). It is easy to prohibit the Local Storage. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited. OTHER THAN THE STANDARD COOKIES MENTIONED ABOVE, PLEASE NOTICE THAT WE MAY ALSO MAKE USE OF E-TAGS WHICH WILL ENABLE US TO IDENTIFY USER BEHAVIOURS. SUCH E-TAGS CAN ONLY BE REMOVED BY US AFTER RECEIVING A REQUEST FROM YOU IN WRITING IN THE MATTER.

We may also use certain third-party cookies. These are a different kind of cookies, stored on your computer by third parties, rather than by us. This kind of cookie is read-only (and not altered by the Site) each time you visit the Service, and also when you visit certain websites or applications that use similar cookies. Third-party cookies usually store only a Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc.

9.       Direct Marketing

You hereby agree that we may use your contact details for the purpose of informing you regarding products and services (offered by SimplexCC and/or by third parties) which may interest you, and to send to you advertisements and other marketing material, transmitted to the e-mail address you have provided.

You may withdraw your consent via sending a written notice to SimplexCC by email to the following address: or on the same manner as the advertising was transmitted to you (e.g. via phone text message). It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable in connection thereof.

10.    Security

We take a great care in implementing and maintaining the security of the Service, and our Users’ Personal Information. The Personal Information is hosted on Amazon Web Services, which provides advanced security features. SimplexCC employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. However, we do not and cannot guarantee that unauthorised access will never occur.

11.    Third Party Software/Service

While using the Site and/or Service we may be using third party software and/or service, in order to collect and/or process the information detailed herein. Such software includes without limitation, Google Analytics, which privacy policy is available at and Amazon Web Services, which privacy policy is available at

12.    Third Party Websites

While using the Service you may encounter links to third party websites and/or services. Please be advised that such third party websites and/or services are independent from SimplexCC, and may use cookies and other web-tracking technologies to collect non-personal and/or personal information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties.

13.    Changes to the Privacy Policy

SimplexCC reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Service and/or we will send you an e-mail regarding such changes to the e-mail address that is registered with your Account. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

14.    Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at, and we will make an effort to reply within a reasonable timeframe.