At Mobiwise LLC, your privacy is a top priority. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly. We do not compromise with your privacy.
We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security and others to make sure that no decision is taken without respect for your privacy. We strive to be transparent in the way we process your data.
We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information. 1. INTRODUCTION
We, Mobiwise.LLC, are the data controller responsible for your information when you use our services & products.
It goes without saying, we can't help you have an awesome user experience without some information about you, such as your email address and password in some of our services. We also collect information generated as you use our services, as well as information from third parties, e.g. when you access our services through your Facebook account. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it. Information you give us
You choose to give us certain information when using our services. This includes:
● When you create an account in some of our services, you provide us with your login credentials, such as email address, name and password.
● To use certain features in our services, you may allow us to access your camera or the microphone. Depending on your device, Apple and Android system will ask for your permission before allowing us to access these features.
● Features that allow you to share content about your use of our services with your connections or through your social network. We may also collect your information when you use our app such as when you post or share material, upload data, request further services or make selections using our app, if such functionality is available in the app.
● From time to time, we may request your opinions, suggestions, or modification and improvement ideas ("Feedback") through surveys, or other similar requests. Any responses you provide are voluntary, however you agree that any Feedback you provide shall be owned Mobiwise and may be used by Mobiwise in our sole discretion. Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, including:
● Social Media
● Other Partners
• We may receive information about you from our partners, for instance where our ads are published on a partner's website or platform (in which case they may pass along details on a campaign's success).
• If you purchase a subscription in our apps, neither Google nor Apple provide us with any personal information of the subscription purchaser (like name, email or payment information). Only anonymized data gets passed to Mobiwise. Information collected when you use our services
When you use our services, we collect information about which features you've used, how you've used them and the devices you use to access our services. See below for more details:
● Usage Information
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, time spent in the app, features you've been using, advertising that you click on). We may collect such data only if you give us a consent to do so.
We collect Usage Data with the help of the following third-party services: (1) APPSFLYER
: We also analyse the manner in which our app is used via an analysis tool provided by AppsFlyer Inc. (111 New Montgomery Street, San Francisco, California 94105). A variety of user session and interaction data is gathered and collated. We need this information to improve content, to make our services more user-friendly and to optimise app use for you. Session and interaction data is only ever used anonymously. For further information about data processing at AppsFlyer, please see their data protection statement here: https://www.appsflyer.com/privacy-policy/. Should you wish to opt-out and prevent your data from being used, please follow this link to do so: https://www.appsflyer.com/optout
. (2) AMPLITUDE:
Amplitude is an analysis service of Amplitude Inc (631 Howard Street, Suite 300, San Francisco, CA 94105, U.S.A.). This tool collects technical information, such as the type of your device (e.g., iPhone 6), the operating system used (e.g., iOS 10.3), or the name of your provider. In other words, Amplitude helps us understand how you use our Services. For more information on the privacy practices of Amplitude, please visit the Amplitude Privacy & Terms web page: https://amplitude.com/privacy
● Device information
We collect information from and about the device(s) you use to access our services, including:
● geolocation data (in some of our apps), which is any information which indicates the geographical position of your device and which may include the time the location was recorded, and may include precise (e.g., GPS-level) location data. Some apps may collect this data when the app is not open or actively in use. This may help us or third parties to customize information, content, or offers to you, for instance.
● information on your wireless and mobile network connection, like your service provider and signal strength.
● hardware and software information such as IP address, device type, app crashes, app version, advertising IDs (such as Google's Advertising ID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device's settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address). 4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
If you wish to opt out of interest-based tracking through your mobile device, you can do so through your device "settings", as follows (but please note that the below is for informational purposes only and Apple, Google, or other device platforms may change the manner in which their "opt out" settings work at any time): Please note that if you opt out through these settings, you will continue to receive advertising after you opt-out, but it may not be tailored to your interests. For instance, that advertising may be based on your real-time or "contextual" application usage or general location inferred from IP address.
Opting Out on iOS Devices Such as iPhones, iPads or iPods
If you have an Apple device, you can opt out of interest-based advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to 'ON'. On an iPhone 6 for example, you can do this by clicking on Settings -> General -> Privacy -> Advertising and toggling "Limit Ad Tracking" to 'ON'. Our systems are designed to respect your choice and not use your personal information to provide interest-based advertising when this setting is ON.
Opting Out on Android Devices
If you have an Android device and would like to opt out of interest-based advertising, you may do this as follows:
● Open the Settings app on your device
● Go to "Google"
● Select Ads
● Opt out of interest-based ads 5. HOW WE USE INFORMATION
The main reason we use your information is to deliver and improve our services. Additionally, we may use your information to help keep you safe and to communicate with you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples. To administer your account and provide our services to you
● Deliver our services to you and ensure their optimal functionality and operation.
● Identify, establish and manage your account and our relationship with you.
● Provide you with customer support and respond to your requests.
● Should you provide us with this information, we may use your email address, name, country and language for customized marketing purposes.
● When we collect your precise geolocation data (subject to your consent) (which may be via the device's cellular, Wi-Fi, Global Positioning System (GPS) networks and/or Bluetooth information), we do so to provide you with our location-related products and services, for example to provide you with forecast and weather alerts for your location, and also to facilitate, measure, or otherwise support advertising by third parties (through our apps or third parties' apps) that may be related to your location over time.
● If you have registered with an app using your social media account details, we may use the information we receive from your social media provider to identify which of your friends are also using our services so that you can connect with them in our app. In some services, to ensure a consistent experience across your devices
● Link the various apps and devices you use, so that you can enjoy a consistent experience of our services on all of them. This will allow us to form a single view of your use of our services, so you can easily access your content on multiple devices. For this purpose and better user experience generally, we may use and combine your personal information which we collect across different services used by you. To improve our services and develop new ones
● Develop new features and services (for example, we may decide to build a new feature further to requests or feedback received from users).
. For further information on how Google's Firebase analytics tool uses data, please see the site "How Google uses data when you use our partners' sites or apps", (located at www.google.com/policies/privacy/partners/
● Conduct research and analysis of your behaviour about your use of, or interest in, our products, services, or content to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users' behaviour). This software may record information such as how often you use the services, what happens within the services, aggregated usage, performance data, app errors and debugging information, and where the apps were downloaded from.
To communicate with you
● Communicate with you by postal mail, telephone and/or mobile devices (including through in-application advertising) about products or services that may be of interest to you either from us, our parent or subsidiary companies or other third parties. If you do not wish to receive in-application advertising, in some cases you can upgrade to the paid version of the app.
● When you share your information with us via a social network provider like Facebook, we use this to show information on your social network profile (subject to your privacy setting and preferences for such social network) and to allow you to share information about our services with your connections or on your social network profile.
● With your consent (where needed), to send you email marketing in order to provide you with information about services that you may find of interest. You can opt-out of receiving direct marketing communications from us by following the unsubscribe instructions included in our marketing communications. We also send you non-marketing emails or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, service availability or modification of key features or functions. To serve you relevant offers and ads
● Develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. When you are on our services, third-party ad partners may provide you with advertising based upon your interests. These companies may use technologies to collect data about users, including precise device location data, to help them tailor relevant ads and measure ads' effectiveness. These companies may collect this data through SDKs or from users who view or interact with their advertisements. For the purposes of European law, most of these ad partners are independent controllers of your information, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the services. It also means that if you are a Facebook app user for example – you provided consent to Facebook in your Facebook app to allow them to show you personalized ads inside of our services.
● Verify your eligibility and deliver prizes in connection with contests and sweepstakes and in order to conduct polls and surveys; To prevent, detect and fight fraud or other illegal or unauthorized activities
● Perform data analysis to better understand and design countermeasures against these activities
● Retain data related to fraudulent activities to prevent against recurrences To ensure legal compliance
● Comply with legal requirements
● Assist law enforcement
● Enforce or exercise our rights, for example our EULA
We normally collect or use information from you or others only where we have your consent to do so
, where we need the information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Note that we may process your personal data not only on the basis of your consent or at your request, but also when the processing is necessary:
● for the compliance with our legal obligations;
● to protect your vital interests or vital interests of another natural person;
● for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
In all cases, we will notify you about applied legal basis for processing and other relevant details, before we start processing your personal data on the specific legal basis. However, we will not, if we are forbidden to do so in accordance with our obligations under any applicable legislation.
If Mobiwise decides to change the purposes of processing specified above, we will inform you on such changes prior to the use of your personal data within the newly set purposes. The notification on such changes will be sent to you via email or WhatsApp and you will have to provide your consent for the amended purposes (unless additional purpose of processing is compatible with those listed above).
Please note that in no case we sell your data or make any decision based solely on automated processing that may produce legal effects or similarly significant effects. 6. HOW WE SHARE YOUR INFORMATION
Since our goal is to provide the best services we can to you, the main sharing of users' information is with service providers and partners who assist us in operating the services, in some cases, legal authorities. Read on for more details about how your information is shared with others. With our service providers and partners
● We follow a strict vetting process prior to engaging any service provider or working with any partner. We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, marketing, advertising and security operations. These service providers may have limited access to your information, which is needed to perform their functions, but are not permitted to share or use such information for any other purposes. For example, we use your non-personal information (meaning information that, by itself, does not identify who you are such as device information) for targeted online marketing through tools like Facebook Custom Audience to contact interested parties.
● In addition, we may share aggregated information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other legitimate business purposes. Please note that such aggregated information will not include any information which allows third parties to identity you.
● For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control. You consent to the transfer of your personally identifiable information and non - personally identifiable information by Mobiwise to that third party, provided that all use of your information by that third party remains subject to the terms of this Policy.
● When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; or (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others.
● To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties and/or to comply with applicable law; (iii) to enforce our agreements or policies with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
● With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. 7. HOW WE PROTECT YOUR INFORMATION
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. We process your data using computers and/or other IT enabled tools. Mobiwise takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also guide and train our personnel to process your data securely according to our internal data protection policies. We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures. We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately at firstname.lastname@example.org 8. INFORMATION RELATING TO CHILDREN
Our services are intended for general audiences over the age of 13 years old (or over the age of 16 if you are resident in the EEA). We do not knowingly collect information from children under the age of 13 years old, or 16 years old in the EEA. If you are not over 13 years old (or 16 years old in the EEA) then DO NOT DOWNLOAD OR USE THE SERVICES. If you believe that we may have personal information from or about a child under the age of 13 years old (or over the age of 16 if you are resident in the EEA), please contact us at email@example.com and we will promptly delete that personal information. 9. YOUR RIGHTS
We want you to be in control of your information and be aware of your privacy rights, so here are a few key points to remember: You have a right to access to your personal data processed by Mobiwise and right to data portability
. This means that you can ask Mobiwise what personal data of yours is processed. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from Mobiwise your personal data in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on your consent or on contract and the processing is carried out by automated means. You have a right to request from Mobiwise to rectify your personal data.
This means you can require all the inaccurate personal data concerning you being corrected. You can also complete the personal data if you feel there is a need to do so. You have a right to request Mobiwise to erase personal data.
You can request Mobiwise to erase personal data if its processing is no longer necessary to achieve purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases, Mobiwise will erase it unless otherwise required by legislation. You have a right to restrict the processing of your personal data by Mobiwise.
In some cases, prescribed by law you will be able to restrict the processing of your personal data, for example, if you contest the accuracy of your personal data being processed or in case Mobiwise is not interested in processing of your personal data any longer, but you want Mobiwise to do this on different reasons, for example, to bring some claim for somebody and, instead of the erasure of information, its processing will be just restricted. You have a right to withdraw your consent.
You can withdraw your consent for the collection and processing of your personal data by Mobiwise at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal. After we at Mobiwise receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law. You have a right to object to processing of your personal data by Mobiwise.
Any requests to exercise your rights can be directed to Mobiwise at firstname.lastname@example.org
or through the contact details provided below. These requests are free of charge.
Mobiwise will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if Mobiwise is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. Mobiwise will inform you of any such extension within one month of receipt of the request, together with the reasons of such delay.
If you have doubts as to our reply or reaction, or absence of such, you have the right to lodge a complaint with a supervisory authority that is empowered to process such complaints in your country. 10. BREACH NOTIFICATIONS
If any personal data of yours would be under the breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as data subject. We would also do our best to minimize any such risks. 11. CROSS-BORDER DATA TRANSFERS
Sharing of information sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. The United States, European Economic Area ("EEA") Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live.
The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of the EEA. We use these Model Clauses or other suitable safeguards (such as EU-US Privacy Shield to send personal information to some of our third party service providers in the United States, where they are certified to receive such information under the Privacy Shield Program
) to permit data transfers from the EEA to other countries. 12. HOW LONG WE STORE YOUR INFORMATION
We retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active or as needed to provide the services to you. We will also retain and use your information to the extent necessary:
● to comply with applicable law;
● to evidence our compliance with applicable law;
● if there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
● if the information must be kept for our legitimate business interests, such as enforcing our terms or fraud prevention. For example, information may need to be kept to prevent a user who was banned for security incidents from opening a new account.
Because we're always looking for new and innovative ways to help you enjoy our services, this policy may change over time. We will notify you of any material changes so that you have time to review the changes. 14. DATA PROTECTION OFFICER
For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached by contacting email@example.com 14. HOW TO CONTACT US