Business Services Privacy Notice
Mobilewalla respects the privacy of each individual about whom we process information. This privacy notice describes our product and service offerings and the practices we follow. Mobilewalla’s clients include advertisers, advertising agencies, brands, publishers and other users (“Clients”). The Privacy Notice applies when our Clients provide business data to us for processing or when our Clients incorporate our Business Services as part of their website, mobile application or services (“Property”).
Mobilewalla helps its Clients deliver relevant marketing and advertising campaigns, provide insights, manage and monitor the success of campaigns, identify and reduce fraud, power analytics and business models and provide consumers with advertisements that are more likely to be interesting and applicable to them (“Business Services”).
Mobilewalla sources its data from other information providers that operate throughout the adtech ecosystem. Mobilewalla has no direct interaction with individuals who use our Clients’ Properties.
Mobilewalla’s Clients are required to provide notice to individuals and to obtain the appropriate authorizations and lawful bases for Mobilewalla’s processing as set forth in this Privacy Policy and to provide a privacy policy of their own. Mobilewalla honors the IAB Europe’s Transparency and Consent Framework.
For information about Mobilewalla’s Site and Website Services, please visit the Mobilewalla Website Privacy Policy here.
General
1. Mobilewalla’s Business Services
We provide solutions to help our business Clients manage, use, and optimize their customer data and to help them identify and reach potential new customers using analytical tools and marketing and advertising strategy services. Stated differently, we design, build, and run processes and solutions for our business Clients to help them enhance and manage their data, and we provide the information to help our Clients better understand their customers and identify potential customers who are like their best customers.
Our data helps our Clients implement marketing lifecycle improvements, new ways to connect with consumers, and mobile app and website experience optimization. When we provide data management services by processing data on behalf of our Clients, we process our Clients’ and their partners’ information according to contracts with our Clients. In that capacity, we are acting as a service provider, sometimes called a processor.
For a company to use Mobilewalla’s products and services, it is required to enter into a contract with us. The terms of those contracts govern the use of personal information Mobilewalla collects, processes, sells, shares and discloses to Clients.
In addition to disclosures of information in the ordinary course of business, we may disclose personal information as necessary to comply with a legal obligation or to respond to law enforcement or a regulator, such as in response to a subpoena.
Mobilewalla does not provide services or data to individual consumers and does not make our data available for purchase online.
2. Personal Information We Collect and Use
Mobilewalla collects data in order to provide the Business Services and for other specific purposes as described in this Privacy Policy. Mobilewalla’s Business Services contain only the information required for its intended use. Mobilewalla’s Business Services are designed for a specific use by our Clients that have a legitimate need for the service.
Some data may be considered personal data in some jurisdictions and sensitive personal data in other jurisdictions. Our Business Services are not directed to children under 16 years of age, and we do not knowingly collect information on such users. The Business Services contain information about individuals and households in the U.S. and are developed from many sources.
When interacting with the Property, providing the Business Services, or receiving data from other information providers (sometimes called “data brokers”) Mobilewalla may receive the following:
• Device Information, such as device type and model, network provider and connection type, browser type, language, operating system, cookie identifiers, mobile carrier, mobile IDs, MAC address, IMEI, unique identifiers, hardware type, device specifications, operating system, IP address, location, Internet service provider, hashed email address, and other actions taken through the use of the Business Services.
• Information about the Property, such as Property ID, app name, website, mobile website URL, app ID, and bundle ID.
• Information Provided By Clients and Other Third Parties, such as demographics, age, interests, preferences, gender, zip or postal code, advertiser ID, and Device Information.
The Mobilewalla Business Services we license to Clients do not include specific details about a purchase, detailed financial information, credit information, or information identifying or revealing a person’s past, present, or future, physical or mental health condition.
Collection and Use of Minor Data: We ask our data suppliers not to provide any data to us that is associated with anyone younger than 16. We do not knowingly collect, process, store or transfer any data to third parties that is related to anyone younger than 16.
Collection and Use of Geo-Location Data: Mobilewalla does process “movement data” that includes mobile advertising ID (MAID), latitude and longitude, IP Address, and timestamp. We do process information related to visits to commercial locations, such as restaurants, retail stores, and car dealerships (e.g., pseudonymous mobile advertising ID (MAID or device ID), latitude and longitude, timestamp and duration of visit). We do not knowingly collect information related to visits to sensitive locations such as places of worship, domestic abuse shelters, drug and alcohol treatment centers or reproductive health clinics.
Collection and Use of Deidentified Data: Mobilewalla processes deidentified information (as that term is defined in applicable US statutes) that are used to build our marketing models. Mobilewalla commits to maintain and use such information in its deidentified form and not attempt to reidentify the information.
Collection and Use of Retail Purchase Data: Mobilewalla does not collect individually identifiable information regarding retail purchases at a granular level (i.e., at a “SKU”- level). Instead, Mobilewalla may processes identifiable retail purchase information at category levels (e.g., “health & beauty products,” “clothing,” “electronics”).
Offshoring: Where permitted by law, third parties under contract to Mobilewalla may have access to the information in Mobilewalla’s marketing and advertising data products to assist in processing the data. Some of these third-party service providers or contractors may reside outside the United States.
3. What Do We Do with Business Data and Personal Data?
Mobilewalla uses business and personal data to:
• provide the Business Services,
• enable and optimize the Business Services’ tools and features,
• study and analyze the functionality of the Business Services, Clients’ and individuals' interactions with the Property and activities,
• provide support and help desk services and verify identity,
• measure the Business Services’ activity for pricing, efficacy, accuracy and other purposes,
• maintain, improve and develop the Business Services,
• ensure internal quality control and identify and repair any errors or bugs,
• pursue our legitimate interests (e.g., direct marketing (including profiling), research (including marketing research), network and information security, and fraud prevention), and/or
• carry out activities per the instructions of our Clients.
Process Data on Behalf of Our Clients. Our Clients may choose to use our Business Services to process certain data of their own, which may contain personal information. If the data that we process through our Business Services is solely processed by us on behalf of our Clients, their privacy policies and/or the contracts we have in place with them will govern how they use the data. If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Business Service to process this data. Our Clients control the personal information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our Clients to address any concerns you may have, in accordance with the terms of our contract with them.
Market Our Products and Business Services. We may use personal information to provide you with materials about our Business Services, and offers, products, and services that may be of interest, including new content or services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
• To tailor content, advertisements, and offers;
• To notify you about offers, products, and services that may be of interest to you;
• To provide the Business Services to you and our sponsors;
• To enable and optimize the Business Services’ tools and features and to audit current transaction;
• To study and analyze the functionality of the Business Services, Clients’ and individuals' activities;
• To maintain, improve and develop the Business Services;
• To pursue our legitimate interests (e.g., direct marketing (including profiling), research (including marketing research), network and information security, and fraud prevention); and/or
• Other purposes you consent to or are disclosed when you provide personal information.
Research and Development. We may use personal information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our Business Services or develop new products. We may perform research via surveys and engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Business Services, various types of communications, advertising campaigns, and/or promotional activities. If an individual participates in a survey, the information given will be used along with that of other study participants. We may use de-identified individual and aggregated data for research and analysis purposes.
De-identified and Aggregated Information Use. We may use business data, personal information and other information about individuals to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which individuals access our Business Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions. De-identified or aggregated information is not personal information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Mobilewalla and with third parties for our or their purposes in a de-identified or aggregated form.
Other Uses. Mobilewalla will use information to enforce Mobilewalla’s terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, to detect and prevent malicious, deceptive, fraudulent, or illegal activity, to prevent and prosecute any misappropriation, infringements, identity thefts and any other misuse of the Business Services, and to take any action in any legal dispute and proceeding.
4. Disclosure, Sale and Sharing of Personal Information
During the last year, Mobilewalla has sold personal information it has collected to our Clients and others, including ad tech partners, for their business and commercial purposes. More specifically, Mobilewalla licenses personal information to third parties for the purpose of enabling and improving their marketing and advertising campaigns from identifying potentially interested consumers to measuring the effectiveness of the marketing and advertising campaigns. We also license personal information for the purpose of identity resolution services (i.e., connecting related data) and marketing analytics, including the creation of predictive models through human and computerized analytics. Mobilewalla does not sell personal information to individual consumers or make information available online.
During the last year, Mobilewalla has disclosed personal information to service providers and contractors (e.g., cloud computing and storage vendors; security contractors, and consultants), for Mobilewalla’s own operational business purposes.
Mobilewalla does not knowingly sell personal information about consumers younger than 16.
Mobilewalla does not engage in profiling or automated decisioning in furtherance of “decisions that produce legal or similarly significant effects.”
Affiliates: We may share personal information with our affiliates.
Law Enforcement and Others: We may access, preserve, and disclose your personal information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; respond to your requests; protect your, our or others’ rights, property, or safety; to enforce our policies or contracts; to collect amounts owed to us; when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs and other records may be reviewed for security purposes to detect unauthorized activity, illegal activity or fraud. In such cases, personal information may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
5. Cookies, Social Media, Analytics & Advertising
For the use of cookies and other Technologies on our Site and Website Services, please see our Website Services Privacy Policy. We, as well as our Clients and third parties that provide content, advertising, or other functionality as part of the Business Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information from your devices. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with Properties, websites, applications, messaging, and tools, and to recognize you across devices.
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the websites, applications and Business Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on websites, applications, services and advertisements that collects information about users’ engagement and activities. The use of a pixel indicates, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Social Media Integration. Our Clients’ Properties and other third party sites may include social media features. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on the Property. Your interactions with these features are governed by the privacy policy of the company providing it.
Analytics. Our Clients and other third parties may also use Google Analytics to collect information regarding visitor behavior and visitor demographics. For more information, please visit www.google.com/policies/privacy/partners/ . You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Uses of such Technologies fall into the following general categories:
• Operationally Necessary. Cookies, web beacons, or other similar technologies that are necessary to the operation of the Business Services, Properties, websites, applications, and tools. This includes Technologies that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. Cookies, web beacons, or other similar technologies are used to assess the performance of Business Services, Properties, websites, applications, and tools, including as part of standard analytic and measurement practices to help understand how visitors use the Business Services, Properties, websites, and applications and interact with messaging, or view an item or link;
• Functionality Related. Cookies, web beacons, or other similar Technologies that offer enhanced functionality. This may include identifying you when you sign into a Property, website, application or Business Service or keeping track of your specified preferences, interests, or past items viewed so that we, our Clients and third parties may enhance the Business Services, Properties, websites, applications, and tools;
• Advertising or Targeting Related. First-party and third-party cookies and web beacons deliver content, including ads relevant to your interests, through our Business Services, Properties or on third party websites and applications. This includes using Technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies, you may do so by blocking, deleting, or disabling them as your browser or device permits. If you wish to delete cookies or limit the kinds of cookies that can be placed on your device you need to check out the settings in your browser, use the ‘Help’ tab or look for settings like ‘Options’ or ‘Privacy.’ From there, you may be able to delete cookies, block them or control when they can be placed.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Business Services. APIs and third party SDKs may allow third parties including advertisers and Clients to collect your personal information to provide relevant content, products and services.
6. Choice:
Mobilewalla Business Services Account. If you have a Mobilewalla account for Business Services, your personal information is processed according to the Website Services Privacy Policy.
Consent. You have the right to object to and change your preferences or opt out of certain uses and disclosures of your personal information. Where you have consented to our processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below subject to certain exceptions as described to you and/or allowed by law. Even if you opt out, we, our Clients and third parties may still collect and use information regarding your activities on the Services, Properties, websites and/or applications and/or information from advertisements for other legal purposes as described herein. Click here to see the list of Mobilewalla Clients and data providers that may process your data.
Email and Telephone Communications.
At any time, you may unsubscribe from Mobilewalla’s mailing list, by sending Mobilewalla an opt-out request to: marketingopt-out@mobilewalla.com or clicking the “unsubscribe” link in the email. Note that you will continue to receive transaction-related emails regarding products or Business Services you have requested. We may also send you certain non-promotional communications regarding us and our Business Services, and you will not be able to opt out of those communications (e.g., communications regarding the Business Services or updates to our terms or this Privacy Policy). We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by law.
Notifications. We or our Clients may occasionally send you push notifications or contact you through our Business Services, social media or third party services with notices or alerts that may be of interest to you. You may at any time opt out or stop from receiving these types of communications by changing the settings on your mobile device.
Cookies and Interest-Based Advertising. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may limit ad tracking of certain mobile ads via their device settings. You may also control interest-based advertising on apps on your mobile device in certain jurisdictions with the AppChoices app. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these and learn about targeted advertising and consumer choice and privacy at www.youronlinechoices.eu/ , www.aboutads.info/choices/ , youradchoices.ca/choices/ and www.networkadvertising.org/managing/opt_out.asp.
To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. You must separately opt out in each browser on each device. Advertisements on third party websites that contain the AdChoices link and that link to this Policy may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
7. Your Rights and How to Contact Us About Our Business Services
For a summary of your state specific rights click on the following:
California
Colorado
Connecticut
Virginia
International:
In accordance with applicable law, you may have the right to:
• Request confirmation of whether we are processing any of your personal data;
• Obtain access to or a copy of your personal data;
• Receive an electronic copy of personal information that you have provided to us or ask us to send that information to another company (the “right of data portability”);
• Restrict our uses of your personal data or object to those uses;
• Seek correction of inaccurate, untrue or incomplete personal data;
• Request deletion/erasure of personal data about you;
• Request that we do not sell or share your personal data;
• Request that we limit the use of your sensitive personal data;
• Withdraw your consent where you have consented to processing;
• Request additional rights under various state laws;
• Lodge a complaint with your regulatory authority, subject to certain exceptions prescribed by law,
Opt Out Of Mobilewalla’s Business Services
Mobilewalla offers consumers the opportunity to opt-out of our Business Services at no cost. Mobilewalla’s products include “targeted advertising” as defined by applicable US state privacy laws and as such, consumers choosing to opt out of our data products will also be opted out of targeted advertising. You can use this online form to opt out.
Separately, consumers may also want to utilize opt-out options offered by independent third party organizations such as Digital Advertising Alliance opt out program, http://www.aboutads.info/choices/ or the Network Advertising Initiative opt-out program http://optout.networkadvertising.org/.
Mobilewalla will accept opt-outs from qualified third parties on behalf of other consumers, regardless of the consumer or agent’s state of residence, provided that the third party successfully completes certain qualification procedures. Mobilewalla has adopted the qualification procedures prescribed under California law for validation of such third parties as described here.
Access and Deletion Rights. In addition to opt-outs, Mobilewalla provides consumers nationwide, regardless of their state of residence, the right to make access and deletion requests. If you would like to submit a request, you may do so by filling out an opt-out request form found here.
You can also submit your request by mail. Our mailing address is:
Mobilewalla Inc.
2472 Jett Ferry Road
STE 400-214
Attention: Consumer Rights Requests
Dunwoody, GA 30338
Appeals Process: Mobilewalla provides consumers a formal method for appealing Mobilewalla’s refusal to take action on a request for access, deletion, correction, opt-out, or any other right afforded by state privacy laws. An appeal may be submitted here privacy@mobilewalla.com.
You may also file a complaint with your state’s Attorney General.
Other Privacy Related Questions: If you have other questions about Mobilewalla’s privacy information practices or products, or your rights under applicable US state privacy laws please contact us at privacy@mobilewalla.com.
8. Other Privacy Information
Transfer of Data Outside Your Territory: Where business needs exist, Mobilewalla may process, store and transfer your personal data to entities outside the US and EU/EEA. However, your personal data will not be transferred unless a valid transfer mechanism is in place legitimizing such a transfer. In the case of transfers referred to in Article 46, 47, or the second paragraph of Article 49(1), this will typically involve EU model clauses (a.k.a standard contractual clauses) or the EU-US Privacy Shield Framework. Safeguards afforded by the EU model clauses may be accessed here EU Model Clauses. We exclusively use global, top tier cloud-based service providers.
European Union Model Contracts: As a global company, Mobilewalla complies with privacy laws of many countries. Mobilewalla has executed EU and UK approved standard contractual clauses with its EU and UK Clients and partners to ensure ongoing compliance with the international transfer principle as set out in the EU and UK’s General Data Protection Regulation.
Accuracy: Mobilewalla uses best efforts to ensure the information we compile, and process is as accurate and complete as possible. Mobilewalla responds promptly to questions from Clients and consumers about the accuracy of information.
Data Retention: Mobilewalla stores and retains business data for as long as instructed by its Clients and for its personal data as long as necessary to fulfill the purposes for which it was collected, provide our Business Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. Our Clients and other third parties may have different practices, and you should refer to their privacy policies.
Security: Mobilewalla maintains security procedures designed to keep information we own, license and process from being accessed by any unauthorized person or business. We use a variety of multi-level security systems to control access to our services and data products. All users at client locations, as well as all Mobilewalla associates, must have the appropriate access credentials and be authorized to access certain data and applications.
Mobilewalla conducts risk assessments and regular audits on our internal and external information systems to assess our ability to maintain the integrity of client and Mobilewalla data. Our enterprise security operations center maintains real-time monitoring for information system vulnerabilities and unauthorized access attempts into our internal systems. We also maintain electronic access and physical security for our facilities.
We take reasonable precautions to ensure that our security procedures are adequate for the protection of our computer systems and data, but this does not eliminate the possibility that our security will be breached. If a security breach causes Mobilewalla leadership to believe individual consumers are at actual risk for identity theft or other fraudulent activities that may cause substantial harm or inconvenience to consumers or if such breach otherwise requires public notification, Mobilewalla will post a security alert notice on our website (www.mobilewalla.com) that will provide relevant information for consumers and Mobilewalla Clients to consider to protect against fraudulent and other harmful actions that may result from the unauthorized access.
Compliance: Mobilewalla participates in industry efforts to establish fair and workable guidelines above and beyond current laws and regulations and believes such actions are an effective way to protect privacy in the marketplace. We also support legislation and regulatory efforts to introduce fair and workable guidelines that protect privacy of consumers.
We actively work to ensure that such guidelines are consistent with, and complement established self-regulatory measures and that they enable the consumer to continue receiving the benefits that appropriate information use provide.
When Mobilewalla provides Business Services to our Clients, we process their information in strict accordance with the terms and conditions of the contract. Mobilewalla works closely with our Clients to ensure the processing we perform is in accordance with all the laws governing those activities.
Awareness: Mobilewalla is committed to privacy education. We provide education to our associates about the issues, guidelines and laws surrounding individual consumer privacy issues, corresponding responsibilities, responsible data collection and use and Mobilewalla’s privacy policies and practices.
Privacy Policy Changes: From time to time Mobilewalla may update and revise our privacy policy based on changes in our business environment and changes to applicable law. We urge consumers and Clients to periodically visit our website to understand any changes that may have occurred.
Our privacy policy contains an “effective date” reflecting when the last changes occurred.
Effective Date: June 30, 2023, updated January 19, 2024.
