Canada Privacy Notice

This policy applies to all of Mobilewalla’s information products involving Canadian data.

Mobilewalla respects the privacy of every individual about whom we process information. This privacy notice describes our product and service offerings involving Canadian data and the practices we follow to show that respect. Please visit  the Mobilewalla Privacy Center  for privacy notices that cover other aspects of Mobilewalla’s business and operations.

1. Mobilewalla’s Business

2. Personal Information Collection and Use

3. Disclosure and Sale of Personal Information

4. Your Rights and How to Contact Us About Our Data Products

5. Other Important Information

1. Mobilewalla’s Business – Mobilewalla has a broad line of data management services to help our clients efficiently manage their customer and potential customers’ information and helps them market effectively to both their existing and prospective customers. 

2. Personal Information Collection and Use - Mobilewalla collects business and consumer information, including Mobile Advertising ID (MAID), device information like device model, operating system, geolocation and other related information.  All of our data is sourced from our data partners.

Mobilewalla’s Canadian data products contain only the information required for the intended use. Mobilewalla’s data products are designed for a specific use by our clients that have a legitimate need for the product. 

Products for Marketing and Advertising Purposes: These products contain information about individuals and households in Canada and are developed from multiple sources, including: 

• Data from other information providers (sometimes called “data brokers”): 

  Examples include Mobile Advertiser ID (MAID), demographic information, information from mobile apps where consent has been provided by the consumer as well as information concerning interests associated with mobile advertising identifiers; all collected by the sources with appropriate notice regarding what information is collected, why it is being used, and with whom it is being shared.

Mobilewalla’s marketing and advertising products do not include specific details about a purchase, detailed financial information, credit information, information revealing a person’s physical or mental health condition or Social Insurance numbers.  We also do not hold sensitive personal data or personal data like name, address, phone number, email address, etc.

Collection and Use of Geo-Location Data: Mobilewalla does collect “movement data” as that term is generally understood in marketing. We do hold data like Mobile Advertising ID (MAID), latitude, and longitude plus timestamp. We do collect information related to visits to commercial locations, such as restaurants, retail stores, and car dealerships from third parties that utilize geo-location data (e.g., pseudonymous Mobile Advertising ID (MAID) plus “visits fast food restaurants”). 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.

3. Disclosure and Sale of Personal Information – Mobilewalla sells pseudonymous Mobile Advertising device ID (MAID) associated with information it has collected to our third-party clients and business partners for their business and commercial purposes.  More specifically, Mobilewalla licenses such pseudonymous information to our clients or, in some cases to marketing agencies working on behalf of our clients, to enable more relevant marketing and advertising campaigns.  

Mobilewalla does not knowingly collect identifiable information concerning anyone younger than 16.

Mobilewalla’s marketing products are used by qualified companies and non-profit organizations in their marketing, fundraising, customer service, and constituent service and outreach programs. Mobilewalla does not provide services or data to individual consumers or make our data available online. Our marketing products are used to enhance customer files. Mobilewalla’s clients use our marketing and advertising products to provide customers with better service, improved offerings, and special promotions. 

Additional Terms and Conditions: For a company to use Mobilewalla’s products and services, it is required to enter into a contract with us. The terms of these contracts further govern the use of the personal information Mobilewalla collects and maintains. 

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. 

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 contractors may reside outside of Canada. 

4. Your Rights and How to Contact Us About Our Data Products –

Mobilewalla does not hold personal or sensitive data to authenticate a consumer and therefore we will treat all requests as “deletion” requests.

Opt Out from Mobilewalla’s Canadian Marketing Products and/or Information Access Requests:   

Consumers have multiple options to submit an opt-out request and/or access to their information request as noted below: 

• Online: Mobilewalla online opt out form.

• By Email: privacy@mobilewalla.com

• In Writing: See Mobilewalla’s address below 

Questions and Complaints: Individuals with questions or who wish to file a complaint, should contact us at the address below or by emailing us at privacy@mobilewalla.com.  

Mobilewalla, Inc. 
Attention: Canada – Privacy Rights Request 
2472 Jett Ferry Rd., STE 400-214 
Dunwoody, Georgia 30338 USA 

5. Other Important Information –

Third Party Opt Outs: Mobilewalla may accept opt outs from qualified third parties authorized by a consumer/data subject to act on their behalf.

Accuracy: Mobilewalla maintains quality control procedures to ensure the information we compile, and process is as accurate and complete as possible.

Safeguards: 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 reviews 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 physical security for our facilities and limit access to certain critical areas of our business.

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.  Because we do not hold data that is considered sensitive personal data or personally identifiable data, we believe any such impact to consumers would be minimized.

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 the 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 provides.

When Mobilewalla provides data management 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 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.

Effective Date: June 30, 2023, last updated September 20, 2023