Mobilewalla complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”), as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Economic Area, the United Kingdom and Switzerland to the United States. Mobilewalla has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https:// www.privacyshield.gov. Additionally, we may protect information through other legally valid methods, including international data transfer agreements.
This Policy applies to all of Mobilewalla’s operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates certified under the Privacy Shield and any additional subsidiary, affiliate, or branch of Mobilewalla that we may subsequently form. We have put in place mechanisms to verify ongoing compliance with Privacy Shield Principles and this Policy. Any employee who violates these privacy principles will be subject to disciplinary procedures.
When interacting with the Property or providing the Business Services, Mobilewalla may receive the following:
Mobilewalla uses business data to:
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
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:
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.
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.
Privacy Shield. With respect to onward transfers to agents under Privacy Shield, Privacy Shield requires that Mobilewalla remain liable should its agents process personal information in a manner inconsistent with the Privacy Shield Principles.
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.
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.
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:
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.
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. 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
Notifications. We or our Clients may occasionally send you
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
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
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
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:
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
In compliance with the Privacy Shield Principles, Mobilewalla commits to resolve complaints about our collection or use of your personal information. Individuals from the EEA, Switzerland and the United Kingdom with inquiries or complaints regarding our Privacy Shield policy should first contact Mobilewalla at email@example.com.
Mobilewalla has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit the JAMS complaint link at https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact your national data protection authority.
You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Mobilewalla’s compliance with the Privacy Shield.
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.
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 applicable privacy laws and regulations and/or its Client contracts, Mobilewalla will implement data onward transfer instruments, such as the Controller to Controller/Processor Standard Contractual Clauses, the Privacy Shield Framework and a statement of compliance with the Privacy Shield Principles.
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.
If you have any questions, comments, or concerns, please send correspondence to Mobilewalla