GDPR Privacy Notice

This Business Services Privacy Notice (“Policy“) provides information about how Mobilewalla, Inc., (“Mobilewalla”, “we”, “us”) processes Personal Data within the scope of the Business Services that we provide to our clients and partners.

The European Union has established a privacy and security framework called the General Data Protection Regulation – (EU) 2016/679 (“GDPR”).  It imposes a number of obligations on data controllers and data processors and affords data subjects a number of important rights, including access, deletion and rectification of their data.  This document is intended to provide transparency regarding Mobilewalla operations in the United States as required under Articles 13 and 14 of the GDPR when we process “personal data” from the EU/EEA.  This Business Services Privacy Policy addresses compliance regarding GDPR and applicable national data protection laws.

Mobilewalla acts as both a “Data Controller” and, in some limited cases, “Data Processor” under the GDPR.  Mobilewalla acts as a data controller with respect to personal data about its employees in the EU/EEA (i.e., human resource data), personal data it collects from its clients and prospective clients (i.e., its own customer relationship management data), and personal data about EU/EEA citizens it licenses from others.

In limited cases where Mobilewalla acts as a data processor under GDPR to the extent it processes personal data about EU/EEA citizens on behalf of its clients; our clients are considered data controllers and Mobilewalla processes the personal data according to contract and written instructions from the data controller.

This privacy notice focuses on the personal data that Mobilewalla collects and processes that is used for insight, recognition, and contact purposes.

Terms such as “Controller“, “Processor“, “Data Subject“, “Personal Data“, “Processing” (and “Process“) and “Special Categories of Personal Data” shall therefore have the meanings given in the EU General Data Protection Regulation.

Mobilewalla participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies.   Mobilewalla’s identification number within the framework is #581.

If you reside in the U.S., please visit our Business Services Privacy Notice or the state specific notice section.

1. Who We Are – Controller/Processor Information

The name of our company is Mobilewalla, Inc. a company incorporated under the laws of the State of Delaware, United States of America.   Our principal place of business is 5170 Peachtree Road, Bldg 100, STE 100, Chamblee, Georgia 30338 USA. Individuals wishing to contact us about data protection issues may reach us the following ways:

Consumer Advocate
Mobilewalla
2472 Jett Ferry Road, STE 400-214
Dunwoody, GA 30338 USA

Or by emailing us at privacy@mobilewalla.com

Our data protection officer is Mr. J. Clark, who may be reached at our principal place of business or by emailing privacy@mobilewalla.com

You may opt-out using this form. 

2. What we do

Mobilewalla provides Business Services that facilitate the creation and execution of targeting, measuring, and analyzing digital and location-based advertising campaigns, powering the machine learning models of our clients. This helps companies to make their marketing campaigns more relevant, reducing the number of ads you see that aren’t beneficial or of interest to you and validating their effectiveness. An opt-out from targeting would not reduce the number of ads, it just makes the ads you receive less relevant.

In a nutshell:

• Mobilewalla does not collect Personal Data from users directly for providing its products and services through our platforms. Mobilewalla’s platform processes the Personal Data provided by third-party data partners which have chosen to do business with Mobilewalla.
• Data partners provide Mobilewalla a license to use their data as a Data Controller. This means that Mobilewalla decides on the purposes and means for processing the Personal Data.
• The Business Services allow advertisers to use and manage data to improve their effectiveness and analyze their online and offline advertising campaigns. This helps them to provide you with more relevant advertising, e.g. based on your interests and affinities.
• This data uses pseudonymous advertising identifiers associated with your mobile device rather than names, e-mail addresses or phone numbers.
• For some products such as location visitation measurement, audience insights and some audience targeting cases, Mobilewalla also processes Personal Data on the behalf of a client as a Data Processor. In those cases, the client is the Controller of the Personal Data.

For information about Personal Data collected on our website please visit our Website Privacy Policy.

3. Sources of Personal Data

• Partners that collect and provide Mobilewalla with data, including Personal Data, to be used in our Business Services. 
• Clients that upload their data to our Business Services for their use.

We require our clients and partners to satisfy all transparency disclosure and consent requirements before processing their data.

4. What Personal Data do we collect and for which purposes?

Information collected from users by third parties that we process through the Business Services as mapped to the Purposes specified in the IAB Europe Transparency and Consent Framework Policies:

Types of Personal Data	Purposes / Use Cases
Mobile Advertising ID (MAID) and Cookie Information	1. Storage and/or access of information Cookies, device identifiers, or other information can be stored or accessed on consumers’ devices for all following purposes.
Mobile Advertising ID Location Data (lat, long) Date and time of accessing client's and/or partner's digital properties or location Cookie Information Audience Segments	2. Selection of basic ads Ads can be shown to consumers based on the content they’re viewing, the app they’re using, their approximate location, or their device type (“Contextual Targeting”). Combination of data obtained offline with data available in the moment, about the user, to select an ad ("Local Contextual / Proximity Targeting") Using precise geolocation data to select and deliver an ad in the moment, without storing it ("Precise Local Contextual / Proximity Targeting", “Digital Out-Of-Home Targeting”)
	3. Creation of a personalized ads profile A profile can be built about consumers and their interests to show them personalized ads that are relevant to them. Associating data obtained offline with an online user to create or edit a user profile for use in advertising (“Offline Data Onboarding”) Storing a user identifier, obtained by actively scanning device characteristics, in a profile for use in advertising ("Cross-device Segmentation") Creating a personalized ads profile, by processing precise geolocation previously stored or made available in the moment ("Place Visit Creation")
	4. Selection of personalized ads Personalized ads can be shown to consumers based on a profile about them. ("Audience Targeting") Selecting a personalized ad, based on a personalized ads profile, by matching and combining data obtained offline with the data stored in an online profile ("Offline Data Targeting") Selecting a personalized ad, based on a personalized ads profile, by linking different devices ("Cross-device Targeting") Selecting an ad based on precise geolocation previously stored ("Place Visit Targeting") These profiles influence the decision as to which ads/content are displayed to the consumer. However, this decision is not solely based on these profiles.
	5. Creating a personalized content profile A profile can be built about consumers and their interests to show them personalized content that is relevant to them. Associating offline data with an online user to create or edit a user profile for use in content personalization ("Offline Data Onboarding") Linking different devices and storing that data point in a profile for use in content personalization ("Cross-device Segmentation") Storing precise geolocation data in a profile for use in content personalization ("Place Visit Creation")
	7. Measuring ad performance The performance and effectiveness of ads that consumers see or interact with can be measured, this includes digital and offline ads such as Out-Of-Home advertising. Measuring ad performance by matching and combining data obtained offline with the data obtained online ("Offline Data Measurement") Measuring ad performance by linking different devices ("Cross-Device Measurement") Measuring ad performance by processing precise geolocation previously stored or made available in the moment ("Footfall Measurement")
	9. Applying market research to generate audience insights Market research can be used to learn more about the audiences who visit sites, apps or locations and view ads or are exposed to offline ads such as (Digital) Out-Of-Home posters. Matching offline obtained data (e.g. panel data) to online obtained data ("Offline Data Insights") Apply market research to generate audience insights by linking different devices ("Cross-Device Insights") Use precise geolocation data to apply market research data in order to generate audience and location insights ("Footfall Insights", "Out-Of-Home Planning")
	10. Developing and improving products Consumers' data can be used to improve existing systems and software, and to develop new products. Developing and improving products by matching and combining data obtained offline with the data obtained online Developing and improving products by linking different devices Developing and improving products by processing precise geolocation previously stored or made available in the moment

5. Who do we share your information with?

We disclose your information to the following categories of recipients:

• To our affiliate and third-party services providers who provide data processing services to us and support us in providing our products and services, or who otherwise process Personal Data for purposes that are described in this Privacy Policy or notified to you when we collect your personal information,
• To our Clients and Partners including digital marketers, advertising agencies, publishers, demand side platforms, data management platforms or supply-side platforms which are listed in our Partner List.
• To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person,
• To a potential buyer (and its agents and advisors) in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.

6. Your rights as a Data Subject

As a company doing business in the EU/EEA, we guarantee your GDPR rights to:

•   Access - You can obtain information about the Personal Data that we have about you.

•   Rectification - You can ask us to correct the Personal Data that we have about you that is incorrect, inaccurate, or incomplete.

•   Data Portability -You can request your information in a format that is machine-readable.

•   Object Processing -You can object the processing of your personal data for marketing purposes.

•   Restrict Processing -You can request the restriction of the processing activities.

•   Erasure - You can request your data to be erased.

If you wish to exercise any of these rights, you can do so at any time by opting out using this form or by email to privacy@mobilewalla.com. 

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

To opt-out from our marketing communications please refer to our Website Privacy Policy.

You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

If you are a reside in the U.S., please refer to our Business Services Privacy Notice or the state specific notices as appropriate.

7. How long do we keep your information?

The data we hold is non-sensitive personal data and not subject to any sector specific data retention requirements. We retain data for as long as it is useful in our products, either as an actual variable or to derive other variables.

Personal data that is not used for any purpose is deleted.  If a data subject under GDPR objects to us processing their data, we will remove it from our data products, and then from our environment in accordance with our data deletion cycle, unless we have a valid justification to hold on to it, such as to resolve disputes or comply with our legal obligations. We also retain personal data which is necessary to keep on a suppression file (e.g. opt-out database) so if we obtain someone’s data again, we will know not to use it.

Personal Data will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Policy or as otherwise required by applicable law (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). 

8. International Data Transfer

Where business needs exist, Mobilewalla may 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

9. Legal basis for processing (EU/EEA Data Subjects only)

If you are a Data Subject from the European Economic Area (EU/EEA), our legal basis for collecting and processing the information described above will depend on the information concerned and the specific context in which we collect and process it. 

Mobilewalla uses and shares personal data based on its legitimate commercial interests, and those of its clients and partner businesses, for direct marketing, fraud prevention, information security, and organizational purposes, in accordance with Article 6(1)(f) of the GDPR. We take great care to handle all personal data in accordance with data protection law and to ensure that it is never used in ways that unduly prejudice individuals’ interests. Users of our data are prohibited by contractual restrictions from using our data in a way which discriminates unfairly against individuals or produces legal or similar effects. You have the right to object to this processing if you wish and if you wish to do so please inform us by using one of the contact channels in the preceding section. 

We collect and process information from you only:

• where we have your consent (Art. 6 para 1 lit. a) GDPR) obtained by our data providers
• where we need the information to provide our contractual obligation to you (Art. 6 para 1 lit. b) GDPR) or
• where we have a legitimate interest to do so (Article 6 para 1 lit. f) GDPR)

10. Opt-Out Options

Via Your Device Settings

Data is only processed in order to show you the most relevant advertising content and to provide statistical analytics products and services. If you’re opposed to this, always read the terms and conditions and privacy notices when installing new apps. Many websites and mobile applications provide opt-out options, and you have the option to limit ad tracking on your smartphone.

If you wish that your location, be private, you can turn the geo-location feature off within the location settings of your device. In addition to this, you can disable ad tracking on your device so that Mobilewalla will no longer include device information in its audience segments or analytics products and services.

The following instructions explain how to turn off ad tracking for Apple and Android devices:

iOS:

• Choose Settings > Privacy & Security > Tracking
• Turn off “Allow Apps to Request to Track” or make your choice per app below

Android:

• Choose Settings > Google > Ads
• Check Opt out of Ads Personalization
• Toggle it off, then tap on “Reset advertising ID”

Via Advertising ID (Mobile Advertising ID-MAID)

To specifically opt-out from our services without changing your device settings, you can use the opt out form, or by email to privacy@mobilewalla.com, to submit your Advertising ID to our platform. To find out your Advertising ID, use the following instructions:

• iOS users have to download an app (e.g. The Identifiers) and copy the “Advertising Identifier”
• Android users choose Google Settings > Ads and copy the “advertising ID”

Effective Date: May 18, 2018, last updated, November 1, 2023.