Mobilewalla Website Privacy Policy

Effective: December 23, 2019


This Mobilewalla Website privacy policy (“Policy”) explains our privacy practices for processing personal information on Mobilewalla’s website (“Site”) and via Mobilewalla’s corporate operations (“Website Services”). It does not include any information or practices governed by the Mobilewalla Services Privacy Policy. Please take the time to read the full policies.

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. .

1. The Mobilewalla Site and Website Services – www.mobilewalla.com

The Mobilewalla Site is a corporate website designed to provide information and content about Mobilewalla and its Website Services. You may visit our Site without registering.

When visiting the Site, Mobilewalla may capture information that you voluntarily provide, and information that is automatically collected by your device. Our Site is not directed to children under 16 years of age, and we do not knowingly collect personal information on such users. 

2. The Personal Information that You Provide to Mobilewalla Voluntarily

When you contact Mobilewalla, by filling out a form on the Site, subscribing for email updates, requesting a trial of our services, participating in a survey or contacting our customer support team or when Mobilewalla contacts you regarding any of the above, we may receive and process any personal information that you provide such as your name and job title, your company’s name and type, phone number, country, and email address.

If you submit personal information in a comment on a blog post or on any applicable social media websites, the personal information that you submit can be read, collected or used by others and could be used to send you unsolicited messages or otherwise contact you. Mobilewalla is not responsible for the personal information that you choose to submit in these blogs or social media websites. This information is considered “public” and not subject to this Policy.

Mobilewalla may use the information you provide via the Site for its business’ purposes, such as responding to your inquiries or support requests, for marketing, recruiting and hiring, and to contact you in the course of providing you with any of the Website Services and/or the Mobilewalla newsletter or blog. Mobilewalla retains the information collected via the Site for so long as you use the Website Services or until you choose to unsubscribe from the Mobilewalla mailing list, or until Mobilewalla deletes your personal information pursuant to a written request from you (subject to certain exceptions prescribed by law).

3. The Personal Information that Mobilewalla Collects Automatically

We may collect certain information automatically through our Site and Website Services, such as cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, unique identifiers, browser type and language, hardware type, operating system, IP address, location, Internet service provider, and other actions taken through the use of the Website Services such as preferences. Mobilewalla may also collect information about your activity on the Site and Website Services (e.g., the duration of sessions, pages or content viewed, pages visited before and after using the Site or Website Services, and the date and time visited).  

4. The Site and Website Services May Include Third Party’s Services

The Mobilewalla Site may include links to third-party social media websites, such as Facebook, Twitter, and LinkedIn, as well as associated social media features and scripts, such as the Facebook “like” button and widgets. These features and scripts may collect your IP address, which page you are visiting on the Site, and may set a cookie to enable the feature to function properly. Your interactions with these social media features and widgets, as well as your interactions with the social media websites themselves, are governed by the privacy policies of the applicable social media websites. Third party’s services, such as marketing automation tools like Hubspot and Salesforce, are also incorporated in the Site and are governed by their privacy policies. We encourage you to read these privacy policies before using the Site.

5. What Does Mobilewalla Do With Personal Information?

We process personal information about individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested.

We may use information about you to:

  • Provide the Site and Website Services,
  • Manage individual information and accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of our Website Services;
  • Answer requests for customer or technical support; and
  • Allow you to register for events.

For Administrative Purposes.

We may use personal information about you to:

  • Measure interest and engagement in our Site and Website Services;
  • Develop new products and Website Services;
  • Ensure internal quality control and identify and repair any errors or bugs;
  • Verify individual identity;
  • Communicate with you about your account, activities on our Site and Website Services and policy changes;
  • Contact you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
  • Carry out activities which you otherwise consent to;
  • Process payment for products or Website Services purchased;
  • Process applications and transactions;
  • Prevent potentially prohibited or illegal activities; and
  • Enforce our terms.

Information We Process on Behalf of Our Business Customers. Our business customers may choose to use our Business Services to process certain data of their own, which may contain personal information. The data that we process through our Business Services is processed by us on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our customers and the Business Services Privacy Policy, not this Policy. 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 business customers 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 business customers to address any concerns you may have, in accordance with the terms of our contract with them.

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 Site and Website 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 Site and Website 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. 

Marketing Our Products and Services. We may use personal information to provide you with materials about 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 Site and Website Services to you and our sponsors;
  • To enable and optimize the Site and Website Services’ tools and features and to audit current interactions;
  • To study and analyze the functionality of the Site and Website Services, customers’ and users' activities;
  • To maintain, improve and develop the Site and Website 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.

De-identified and Aggregated Information Use. We may use personal information and other information about you 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 you access our Site and Website Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site and Website Services. 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 that is designed to prevent anyone from identifying you.

Other Uses. Mobilewalla will use information you provide to enforce Mobilewalla’s terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, to detect and prevent malicious, deceptive, fraudulent, or illegal activity, to prevent and prosecute any misappropriation, infringements, identity thefts and any other misuse of the Website Services, and to take any action in any legal dispute and proceeding. 

6. Sharing Personal Information with Others

Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (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 Site and Website 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.

Business Partners. We may share personal information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Mobilewalla may also provide personal information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. 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.

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.

Marketing – Interest-Based Advertising and Third Party Marketing. Through our Site and Website Services, we may allow third party advertising partners to set tracking tools and Technologies to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site and Website Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or 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 on the Site or Website Services. 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.

Share or Transfer Personal Information 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. You will be notified via email or a notice on the Site of any change in ownership or uses of this information, if applicable.

Share Personal Information in any other circumstances where Mobilewalla receives your consent.

7. Cookies, Social Media, Analytics & Advertising

We, as well as third parties that provide content, advertising, or other functionality on our Site and Website Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Site and Website Services. 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 our Site, Website Services, 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 Site and Website 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 the Site and Website Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Social Media Integration: Our Site includes 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 our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics. We may also use Google Analytics to collect information regarding visitor behavior and visitor demographics on our Site and Website Services. 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. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Site, Website Services, applications, and tools. This includes Technologies that allow you access to our Site, Website Services, applications, and tools 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. We may use cookies, web beacons, or other similar technologies to assess the performance of our Site, Website Services, applications, and tools, including as part of our analytic practices to help us understand how our visitors use our Site and Website Services, interact with our messaging, or view an item or link in order to improve our Site, Website Services, applications or tools;
  • Functionality Related. We may use cookies, web beacons, or other similar Technologies that allow us to offer you enhanced functionality when accessing or using our Site, Website Services, applications, or tools. This may include identifying you when you sign into our Site or Website Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance our Site and Website Services;
  • Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Site and Website Services or on third party sites. 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 we employ on our Site, Website Services, applications, or tools, 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. 

8. Your Choices

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 subject to certain exceptions as described to your and/or allowed by law.

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 Website Services you have requested. We may also send you certain non-promotional communications regarding us and our Website Services, and you will not be able to opt out of those communications (e.g., communications regarding the Website Services or updates to our terms or this 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 may occasionally send you push notifications or contact you through our Website Services, the Site, 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 receiving these types of communications by changing the settings on your mobile device.

Human Resources Data. We will use personal information we collect for Human Resources activities only for employment-related purposes as more fully described above. If we intend to use this personal information for any other purpose, we will notify the individual and provide an opportunity to exercise their rights under applicable law.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

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 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.

9. Human Resources Data

Mobilewalla collects personal information from current, prospective, and former employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.

We process Human Resources Data for a variety of business purposes including:

  • Workflow management, including assigning, managing and administering projects;
  • Human Resources administration and communication;
  • Payroll and the provision of benefits;
  • Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, monitoring overtime and compliance with labor laws, and company recognition programs;
  • Job grading activities;
  • Performance and employee development management;
  • Organizational development and succession planning;
  • Benefits and personnel administration;
  • Absence management;
  • Helpdesk and IT support services;
  • Regulatory compliance;
  • Internal and/or external or governmental compliance investigations;
  • Internal or external audits;
  • Litigation evaluation, prosecution, and defense;
  • Diversity and inclusion initiatives;
  • Restructuring and relocation;
  • Emergency contacts and services;
  • Employee safety;
  • Compliance with statutory requirements;
  • Processing of employee expenses and travel charges; and
  • Acquisitions, divestitures, and integrations.

10. Your Rights in Personal Information and Recourse Mechanism

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 by Mobilewalla;
  • withdraw your consent where you have consented to Mobilewalla’s processing;
  • request additional rights under California law (see below), 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. 

In compliance with the Privacy Shield Principles, Mobilewalla commits to resolve complaints about our collection or use of your personal information. Individuals from the European Economic Area, the United Kingdom and Switzerland with inquiries or complaints regarding our Privacy Shield policy should first contact Mobilewalla at privacy@mobilewalla.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 the 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.

11. Your California Privacy Rights

This section of the privacy policy applies solely to visitors, users and other who reside in the State of California.

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 to 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 email Mobilewalla at: privacy@mobilewalla.com .

Personal Information We Collect & Share Under the CCPA

We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice.

We collect personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household as described below. Personal information does not include: publicly available information from government records; de-identified or aggregated consumer information; or information excluded from the CCPA.

Your Rights and Choices

To exercise your privacy rights under the CCPA, please submit a verifiable consumer request to us by filling out this form, writing to us or emailing us. Please note that only you, or a person who you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

We will not discriminate against you for exercising any of your CCPA rights.

You may also opt out of the sharing or “sale” of Personal Information by clicking the “Do Not Sell My Info” link  consistent with applicable law. While there are many positive aspects of the CCPA, California’s definition of “sale” includes transfers that ordinarily may not be thought of as a “sale” in the traditional sense of the word such as serving you an ad about our services after you leave our Site (see interest based ads above).

The table lists the categories of personal information we have collected from California consumers and disclosed for a business purpose or as part of a sale within the last twelve (12) months.

CCPA Categories of Personal Information Collected:

For a business purpose

As part of a “sale”

Identifiers.  A unique personal identifier, online identifier, or IP address.

Yes

Yes

Personal information categories described in the California Customer Records statute such as a name, address, or telephone number.

Yes

No

Internet or other electronic network activity information.  Browsing history, search history, and information regarding a consumer's interaction with a website or advertisement.

Yes

Yes

Inferences drawn from other personal information.  Inferences drawn from the information identified above to create a profile reflecting a person's preferences

Yes

Yes

 

Categories of Sources, Business Purposes and Third Parties

We obtain personal information from the categories of sources described above including you and your devices, our Site and Website Services, and third parties such as advertising partners and ISPs. We may use or disclose the personal information we collect with the categories of third parties for the business purposes described above.

12. Data Retention

Mobilewalla stores and retains your personal information for as long as you use the Site and/or as necessary to fulfill the purposes for which it was collected, provide our Site and Website 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. 

13. Transfer of Data Outside Your Territory

You agree that Mobilewalla may store and process information in various locations throughout the globe, including the United States and other sites operated and maintained by cloud based service providers in order to provide the Website Services.

To the extent necessary under applicable privacy laws and regulations, Mobilewalla will implement data onward transfer instruments, such as the Controller to Processor Standard Contractual Clauses, the Privacy Shield Framework and a statement of compliance with the Privacy Shield Principles.

14. Information Security

Mobilewalla is committed to safeguarding the confidentiality of your personal information. Mobilewalla and its hosting services make reasonable efforts to secure your 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 Site or Website Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

15. Changes to this Policy

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

16. Contact Mobilewalla

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

Last Updated: December 19, 2019