The Mobilewalla Business Services Privacy Policy

Effective: October 3, 2018


1. The Services

This Mobilewalla Business Services privacy policy (“Privacy Policy”) explains our privacy practices for processing our clients’ business data via our business services. Mobilewalla’s clients are advertisers, advertising agencies, publishers and other users (“Clients”). The Privacy Policy 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 service (“Property”). Mobilewalla helps its Clients deliver relevant marketing and advertising campaigns, provide insights, manage and monitor the success of campaigns, identify and reduce fraud, and provide consumers with advertisements that are more likely to be interesting and applicable to them (“Business Services”).

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.

2. Business Data We Receive

Mobilewalla collects business data in order to provide the Business Services and for other specific purposes as described in this Privacy Policy. Business data may be considered personal data in some jurisdictions, including the European Union. Our Business Services are not directed to children under 16 years of age, and we do not knowingly collect information on such users.

When interacting with the Property or providing the Business Services, 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, 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.

3. What Do We Do with Business Data?

Mobilewalla uses business 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,
  • measure the Business Services’ activity for pricing, efficacy, accuracy and other purposes,
  • maintain, improve and develop the Business Services,
  • 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,
  • 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, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Business Services, and to take any action in any legal dispute and proceeding.

4. Sharing Information with Others

We may share information for the following purposes with:

Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (sub-processors) to whom we entrust personal information include service providers for: IT and related services; the provision of information and services you have requested; payment processing; customer service activities; and the provision of the Business Services. We have executed appropriate contracts with our service providers that prohibit them from using or sharing personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. A list of our sub-processors is available upon request.

Clients and Third Parties. Our Clients and their partners may allow third party advertising vendors and us to set tracking tools and Technologies to collect information regarding individuals’ activities and devices (e.g., IP address, mobile identifiers, page(s) visited, location, time of day, etc.). That information may also be combined and shared with other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use information (and similar information collected from other websites and Properties) for purposes of delivering targeted advertisements to individuals within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions on our Client’s websites or review the information below. Our Clients may also use information for the purposes of serving contextual and/or targeted ads; for ad reporting, performance, engagement, and measurement purposes and for fraud protection, bot detection, rating, analytics, viewability, location services, ad security and verification services.

Business Partners. Mobilewalla may also provide personal information to business partners with whom we may jointly offer products or services. In such cases, our business partner’s name will appear along with ours. Mobilewalla requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf and not to use it for any purpose other than the purpose for which we provided them. If Mobilewalla is involved in a merger, acquisition, financing due diligence, or sale of all or a portion of its assets, as part of such transaction.

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, and you may disable or delete your account by contacting us at privacy@mobilewalla.com.

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. 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 applications and/or information from advertisements for other legal purposes as described herein.

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 California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personal information relating third parties to which Mobilewalla has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. To make such a request, please contact us at: privacy@mobilewalla.com

8. Your Rights in Business Data

If we have received business data that contains personal information from our Clients, we will refer your requests to them directly. 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 erasure of personal data about you;
  • withdraw your consent where you have consented to  processing; and
  • lodge a complaint with your supervisory authority, subject to certain exceptions prescribed by law.

If you would like information about how to exercise any of these rights or if you have concerns about the way Mobilewalla processes your personal information, you are welcome to contact Mobilewalla at: privacy@mobilewalla.com. Mobilewalla will look into your enquiry and make good-faith efforts to resolve any existing or potential dispute with you.

9. 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.

10. Transfer of Data Outside Your Territory

Mobilewalla may store and process information in various locations throughout the globe, including in the United States and elsewhere in sites operated and maintained by cloud-based service providers and other service providers.

To the extent necessary under EU privacy laws and regulations and/or its Client contracts, Mobilewalla will implement data onward transfer instruments.

11. Information Security

Mobilewalla is committed to safeguarding the confidentiality of personal information it collects and its Clients’ business data. Mobilewalla and its hosting services make reasonable efforts to secure personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, Mobilewalla cannot guarantee that the Business Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. 

12. Changes to this Privacy Policy

This Privacy Policy may change from time to time. If there are any material changes to this Privacy Policy, Mobilewalla will notify account holders through the Business Services, by email or as otherwise required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Business Services after the updated Privacy Policy is posted to this website. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Business Services. 

13. Contact Us

If you have any questions, comments, or concerns, please contact Mobilewalla at: privacy@mobilewalla.com.

Last Updated: October 3, 2018