EU-U.S. and Swiss – U.S. Privacy Shield
MOBI participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework. MOBI is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S Department of Commerce’s Privacy Shield List.
MOBI is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. MOBI complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, MOBI is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, MOBI may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that MOBI has not addressed satisfactorily, please contact MOBI’s U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Website & Service Provider Collection/Use
MOBI collects the following kinds of personal information from MOBI’s Clients:
- Contact Information such as name, phone number and e-mail address
- Unique Identifiers such as user name and password
- Credit Card Information
Collection of Third Party PI
MOBI collects the following personal information from you about your contacts:
- First and last name
- Email address
- Mailing address
- Phone number
MOBI uses this information to:
- Fulfill your order
- Send you an order confirmation
- Send you requested product or service information
- Respond to customer service requests
- Administer your account
- Send you a newsletter
- Send you marketing communications
MOBI collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. MOBI works with its Clients to help them provide notice to their customers concerning, the purpose for which personal information is collected. MOBI’s Clients may have their employee information stored in a third-party HR System (such as Workday). MOBI will connect to the Client’s third-party HR Processor to obtain the data necessary to support the services MOBI has been contracted to provide, only after prior authorization from the Client.
Service Provider, Sub-Processors/Onward Transfer
MOBI may transfer personal information to companies that help MOBI provide MOBI’s service. MOBI uses sub-processors in instances where MOBI collects billing information to process payments, and to provide you with customer support outside of normal business hours. Transfers to these third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with MOBI’s Clients. MOBI uses other third parties such as an email service provider to send out emails on MOBI’s behalf and a customer support provider. When you sign up for MOBI’s services, MOBI will share your personal information only as necessary for the third party to provide that service.
Client’s Access and Choice
Upon request MOBI will provide you with information about whether we hold any of your personal information. If your personal information changes, you may access, correct, update, amend, delete or remove it by contacting your HR Department, or by updating your daily HR Feed that is delivered to MOBI. Alternatively, if you use an HR Processor (Workday, for example), you are required to make your changes within their system so that they propagate appropriately into the MOBI Portal. If you no longer desire MOBI’s service, you are encouraged to refer to the terms for Service Termination in the MOBI MSA (Master Service Agreement), and by reaching out to your assigned Service Delivery Manager. To request this information please contact email@example.com. MOBI will respond to your request within a reasonable timeframe.
Access to Data Controlled by MOBI’s Clients
MOBI acknowledges that you have the right to access your personal information. MOBI has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to MOBI’s Client (the data controller). If the Client requests MOBI to remove the data, MOBI will respond to the request within a reasonable timeframe.
MOBI will retain your personal data (MOBI’s Client) and the personal data MOBI processes on behalf of MOBI’s Clients for as long as needed to provide services to you (MOBI’s Client) and to MOBI’s Client. MOBI will retain and use this personal information as necessary to comply with MOBI’s legal obligations, resolve disputes, and enforce MOBI’s agreements.
The security of your personal information and MOBI’s clients’ information is important to MOBI. When you enter sensitive information (such as login credentials and billing information) MOBI encrypts the transmission of that information using secure transmission layer security (TLS). MOBI follows industry and technology standards to protect the personal information submitted to MOBI, both during transmission and once MOBI receives it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, MOBI cannot guarantee its absolute security. If you have any questions about security on MOBI’s Web site, please contact firstname.lastname@example.org.
MOBI reserves the right to disclose your personally identifiable information as required by law and when MOBI believes that disclosure is necessary to protect MOBI’s rights and/or to comply with a judicial proceeding, court order, or legal process served on MOBI’s Web site. In the event MOBI goes through a business transition, such as a merger, acquisition by another company, or sale all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via prominent notice on MOBI’s Web site for 30 days of any such change in ownership or control of your personal information.
Cookies & Tracking Technologies
MOBI and its marketing partners (Pardot), affiliates, or analytics (Google Analytics, HotJar), or customer service providers (8×8), use technologies such as cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about MOBI’s user base as a whole. MOBI may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
As is true of most Web sites, MOBI gathers certain information automatically and stores it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. MOBI uses this information, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about MOBI’s user base as a whole.
If you wish to subscribe to MOBI’s newsletter, MOBI will use your name and email address to send the newsletter to you. If you no longer wish to receive MOBI’s newsletter you may follow the unsubscribe instructions contained in each of the email communications, you receive.
Social Media Features and Widgets
MOBI may update this privacy statement to reflect changes to MOBI’s information practices. If MOBI makes any material changes, MOBI will notify you by e-mail (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. MOBI encourages you to periodically review this page for the latest information on MOBI’s privacy practices.
MOBI Wireless Management, LLC
6100 W. 96th Street Suite 200
Indianapolis, IN 46278
Attn: Privacy Department