California Consumer Privacy Rights

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively the “CCPA” or the “Act”) defines privacy rights for California consumers and imposes corresponding obligations on businesses subject to the Act as described below.

The following is intended to explain a consumer’s rights and the obligations Mobilewalla has under CPRA. Note: Mobilewalla employees in California should refer to the Privacy Notice in their Employee Handbook.

Right to Know/Request for Access to Personal Information

As a consumer under the CCPA, you have the right to request that Mobilewalla disclose what personal information we collect, use, disclose, and sell or share about you. We call this your “right to know.”

To take advantage of your right to know, you can submit a request by filling out a request on our opt out form found here.

You can also submit your request by mail. Our mailing address is:

Mobilewalla, Inc.
Attention: Consumer Rights Requests
2472 Jett Ferry Road, STE 400-214
Dunwoody, GA 30338

To respond to your right to know request, the CCPA permits Mobilewalla to verify your identity. Mobilewalla does not have the personal or personal sensitive data in our data corpus to authenticate your request, therefore we treat all such requests as a “delete” request.    You will need to provide us with the mobile advertising ID (MAID) assigned by Google or Apple for us to search our database for your information. This link may be helpful in finding your MAID. You must provide your MAID for us to act on your request.

Types of Personal Information Mobilewalla Collects

Right to Know about Personal Information Collected, Disclosed, Sold, or Shared

Business and Commercial Purposes for which Personal Information is Collected:  We collect personal information for our own business purposes, including internal research, internal operations, auditing, detecting security incidents, improving our services, quality control, and legal compliance.  We also collect personal information for commercial purposes. Mobilewalla licenses the categories of personal information described below from the third-party sources categorized below in developing Mobilewalla’s marketing and advertising products as previously described. Mobilewalla licenses such data products to categories of third parties as described in the table below.

Categories of Personal Information Collected

  • Personal identifiers (e.g., (e.g., IP address, mobile advertising identification number (MAID)), or similar identifiers)
  • Personal Characteristics (e.g., characteristics of protected classifications under California and federal law like gender)
  • Personal Property or Buying Activity/Interest (e.g., commercial or transaction information)
  • Internet Activity (interest based on mobile apps, web site type, source URL)
  • Geo Location
  • Inferences (e.g., inferences drawn to create a profile about a consumer reflecting the consumer’s preferences)
 

Categories of Sources from Which Personal Information Was Collected

Public Record and Publicly Available Information

  •      Not Applicable

Information from Other Data Brokers

  • Demographic Marketing Information
 

Categories of Third Parties with Which Personal Information May be Sold or Shared

  • Agriculture, Forestry and Fishing (for example, farm cooperatives)
  • Automotive (for example, car manufacturers and dealerships)
  • Business Services/Agency (for example, data brokers)
  • Communications (for example, wireless carriers)
  • Construction (for example, real estate development companies)
  • Consumer Packaged Goods (for example, companies that sell personal and household products)
  • Education (e.g., colleges and universities)
  • Energy and Utilities (for example, electric and gas companies)
  • Entertainment (for example, movie and television studios and streaming services)
  • Financial Services (for example, banks and investment companies)
  • Healthcare (for example, hospitals)Insurance (for example, insurance carriers)
  • Manufacturing (for example, consumer product manufacturers)
  • Media and Publishing (for example, magazines, retail catalogs)
  • Non-Profit (for example, charitable organizations)
  • Real Estate (for example, real estate brokerage companies)
  • Retail (for example, department stores, hardware stores)
  • Services-Non Professional (for example, consulting firms)
  • Services-Professional (for example, advertising agencies and financial planners)
  • Sports (for example, professional sports teams)
  • Technology (for example, software and hardware providers, social media platforms)
  • Transportation (for example, railway companies, airlines, rental car companies)
  • Travel and Tourism (for example, cruise lines, hotels, online travel services)
 

Categories of Service Providers and Contractors with Whom Personal Information May be Disclosed for a Business Purpose

Cloud computing and storage vendors; security contractors; consultants, analysis providers, marketing analytics platforms; programmatic advertising marketplaces/platforms; ; measurement platforms; onboarding partners; ad tech partners (e.g., Adsquare, The Trade Desk)  

 

Mobilewalla does not collect data directly from consumers for use in our data products. Please also note that Mobilewalla does not collect biometric information from consumers who are not Mobilewalla employees. Lastly, Mobilewalla does not collect sensory information such as voice, visual, thermal, olfactory, or similar sensory information.

Disclosure and Sale of Personal Information

During the last year, Mobilewalla has sold personal information it has collected to our clients (i.e., “third parties” under CCPA), for their business and commercial purposes. More specifically, Mobilewalla licenses personal information to our clients 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 campaign and informing their predictive modeling and marketing analytics. We also license personal information for resolution services (i.e., connecting related data records) and marketing 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 for the purpose of marketing or advertising directly to the minor.

Mobilewalla does not engage in profiling in furtherance of “decisions that produce legal or similarly significant effects.”

Right to Correct and Delete Personal Information

Pursuant to the CCPA, California consumers have a right to request correction or deletion of personal information about them that Mobilewalla has collected or maintained. As permitted by CCPA regulations, Mobilewalla will treat correction requests as a request to delete.

To take advantage of your right to delete, you may submit a request via our online opt out form, which is found here.

You can also submit your request by mail at the following address:.  Our mailing address is:

Mobilewalla, Inc.
Attention: Consumer Rights Requests
2472 Jett Ferry Road, STE 400-214
Dunwoody, GA 30338

To respond to your right to delete request, the CCPA permits Mobilewalla to verify your identity. Mobilewalla does not have the personal or personal sensitive data in our data corpus to authenticate your request, therefore we treat all such requests as a “delete” request.   You will need to provide the mobile advertising ID (MAID) assigned by Google or Apple for us to search our database. This link may be helpful in finding your MAID. You must provide your MAID for us to act on your request.

Even assuming a verifiable request, Mobilewalla will retain certain personal information in our systems as necessary to comply with a legal obligation (including ensuring the deletion request is honored and record-keeping obligations), detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for the activity. In such cases, Mobilewalla will retain only the minimum amount of information that does not qualify for a statutory or regulatory exception, and only use the remaining data for the purposes provided by the statutory or regulatory exception.

Right to Opt Out

Consumers have a right to opt out from Mobilewalla selling their personal information for marketing purposes.

To take advantage of your right to opt out, you may submit a request here.

You can also submit your request by mail. Our mailing address is:

Mobilewalla, Inc.
Attention: Consumer Rights Requests
2472 Jett Ferry Road, STE 400-214
Dunwoody, GA 30338

Right to Limit Use of Sensitive Personal Information

Mobilewalla may use Sensitive Personal Information as a part of its marketing and advertising products.

Pursuant to the CCPA, California consumers have a right to request a business limit use of “sensitive personal information” about them that Mobilewalla has collected or maintained. “Sensitive personal information” includes (1) (A) A consumer’s social security, driver’s license, state identification card, or passport number; (B) A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) A consumer’s precise geolocation (1850 ft radius); (D) A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (F) A consumer’s genetic data. (2) (A) The processing of biometric information for the purpose of uniquely identifying a consumer; (B) Personal information collected and analyzed concerning a consumer’s health; and (C) Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. Only (1) (C) is applicable to Mobilewalla based on the data in our database. Mobilewalla will treat a request to limit our use of sensitive personal information as a request to delete.

To take advantage of your right to limit Mobilewalla’s use of sensitive personal information which we will treat as a request to delete, you may submit a request via our online opt out form, which is found here.

You can also submit your request by mail. Our mailing address is:

Mobilewalla, Inc.
Attention: Consumer Rights Requests
2472 Jett Ferry Road, STE 400-214
Dunwoody, GA 30338

Right to Non-Discrimination

The CCPA protects California consumers who exercise their rights from discrimination.  Mobilewalla will not discriminate against consumers who request access to personal information about them, request deletion, or request that Mobilewalla opt them out of future sales.

Right to use Authorized Agents to Exercise Rights

The CCPA allows California consumers to use authorized agents to submit requests to Mobilewalla on their behalf. In addition, Mobilewalla has expanded these rights to allow consumers to use authorized agents regardless of their State of residence. Mobilewalla requires that the authorized agent verify that they have authorization from the consumer to act on the consumer’s behalf. In the case of an authorized agent’s request for access to personal information, the resulting report will be delivered to the consumer directly.

How to Contact Us for More Information

If you have questions regarding your rights under CCPA or Mobilewalla’s data collection, use and disclosure practices, you may contact us as provided below.

Reach us by email at CCPACompliance@mobilewalla.com or by mail:

Mobilewalla, Inc.
Attention: Consumer Rights Requests
2472 Jett Ferry Road, STE 400-214
Dunwoody, GA 30338

Information for California Consumers

You may contact the California Attorney General (https://www.oag.ca.gov), or the California Privacy Protection Agency (https://www.cppa.ca.gov), for more information.

Statistical Information

The CCPA requires certain businesses to compile and disclose information by July 1 of each year regarding their compliance with the CCPA for the previous twelve-month period. As Mobilewalla does not have a means to verify the identity of a submitter all requests are treated as deletions and opt-outs.

CCPA Reporting Requirements 

Metrics for Interim Reporting Period January 1, 2023 to December 31, 2023

Requests Received

1615

 Requests  Fulfilled 

1578

Requests Abandoned* 

37

Average Days to Respond ** 

2

*The volume of abandons is due to the consumer failing to provide their MAID (initially or after a follow up request).

**This number reflects the number of days until it is processed. We typically respond and start honoring the request within one (1) business day.

Mobilewalla honors opt-out, data deletion, do not track (DNT), do not sell, and consent withdrawals directly from individuals through the above means.  We also honor other similar user requests received from our data partners, industry groups and the Digital Advertising Alliance (DAA) through both Ad Choices and their CCPA Opt Out Tool API.

Effective December 16, 2019,  updated February 29, 2024.