Information Collected by Mblox
In general, Mblox will collect information from you based upon our business relationship, your use of the Site, Our services and Our products, as follows:
In order to access and view some content on the Site, you are required to register with Mblox before the content is made available to you. During the registration process, you are required to provide Us with certain contact information, including your name, address, phone number and email address. We use this information to contact you about the services We offer in relation to which you have expressed interest.
CLIENT SUPPORT PORTAL
When you contact Mblox customer support (“Customer Support”) using any Mblox client support portal (the “Client Support Portal”), We may ask you for certain information regarding your enquiry, such as your name, email address or telephone number.
What Are Cookies and How Do I Disable Them?
Cookies are files that web browsers place on a computer’s hard drive. You can disable cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Note that you may be prevented from using the Site or services effectively or at all if cookies are disabled.
Our customer support portals use session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Us to process your online data and requests. Session cookies help Us make sure you are who you say you are after you have logged in. We use persistent cookies, which only we can read and use, to identify the fact that you are an Mblox customer or prior site visitor.
The Site utilizes cookies as follows:
FORUMS AND BLOGS
If you participate in any blog or other forum offered by the Site or services, your user ID may be displayed on any content that you post and will therefore be available to the public. Therefore, if you associate your name with your user ID, your name and any related content or posts may be available to the public. You are solely responsible for all liability related to your use of any such blog or forum.
If you send Us correspondence, such as emails or letters, We may collect such information into a file specific to you.
MOBILE USER INFORMATION
We collect information about you when you submit a job application, resume, survey responses or similar information.
If you wish to subscribe to Our newsletters, We will use your name and email address to send the newsletter to you. Out of respect for your privacy, you have the option to unsubscribe from receiving some or all of the newsletters. Please see the “Opt-out” section below.
How We Use Information
We may use data We obtain as described above for purposes relating to the Site and services, including (a) providing the Site and services to you, (b) facilitating third parties to participate in the provision and improvement of the Site and services (including without limitation mobile network operators, hosting partners, and other service providers), (c) raising queries with you, and responding to issues you may raise, whether relating to our services or otherwise, (d) communications relating to surveys and other customer satisfaction-related activities, (e) progressing job applications, to perform credit checks and, (f) verification of personal or business data and payment details and other checks before offering our services to customers.
We will send you service-related announcements when it is necessary to do so. For instance, if Our service is temporarily suspended for maintenance, We might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
We will also communicate with you in response to your customer service enquiries, to provide the services you request, and to manage your account.
Disclosures and Sharing of Information
As a matter of policy, We do not sell or rent any of your information to third parties for any advertising or marketing purposes. However, the following describes some of the ways that We may disclose your information in the normal course of providing Our services.
LEGAL REQUESTS & COMPLIANCE WITH LAWS
Mblox processes Personal Data on behalf of its clients (“Customers”), that has been collected by or on behalf of those Customers including Personal Data received from the European Union. “Personal Data” or “Personal Data” means information relating to an identified or identifiable person. Mblox complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member countries and Switzerland. Mblox has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
To learn more about the Safe Harbor program, and to view Mblox’s certification, please visit http://www.export.gov/safeharbor/. Under the Safe Harbor Frameworks and in relation to Customers’ processing activities on Our platform, Mblox primarily acts as a Data Processor and each applicable Customer acts as a Data Controller. For the purposes of the Safe Harbor Frameworks and this Privacy Statement: a “Data Processor” is an entity that processes Personal Data on behalf of a Data Controller; a “Data Controller” is an entity that determines the purposes for which Personal Data are processed. To “process” Personal Data means to carry out an operation or set of operations on such Personal Data, such as collecting, recording, storing, disclosing, or organizing it. The “Data Subject” means the person to whom a certain set of Personal Data relate; for example, the person who responds to a survey.
Please be advised that in response to the European Court of Justice’s October 2015 decision invalidating the Safe Harbor Framework between the European Commission and the U.S. Department of Commerce, We are making available the European Commission’s controller-to-processor standard contractual clauses, commonly referred to as “model clauses” (in the form adopted by decision 2010/87/EU of 5 February 2010 and with Appendices 1 & 2).
This has the objective of ensuring that Customers may continue to validate transfers of Personal Data under European data protection laws. Any Customer of Mblox Inc. or Mblox Limited who undertakes processing activities on the Mblox platform (in respect of Personal Data which is governed by the European data protection laws), should contact firstname.lastname@example.org for more details.
DISCLOSURE OF INFORMATION TO MBLOX AFFILIATES
Because Mblox is a global company, We may share your information with other Mblox affiliates and business units in other parts of the world in order to provide you with Our services. Your Personal Data may be transferred by Us from your home country to Mblox employees in Mblox offices around the world, who may communicate with you regarding your enquiry. Please understand that We limit access to your Personal Data to only those Mblox employees who We believe need access in order to provide services to you or to otherwise perform their duties.
As Data Processor, Mblox will only process Personal Data pursuant to the instructions of the applicable Customer (for example where We act as a Data Processor in relation to the processing activities of Customers on Our platform). Mblox may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such Personal Data by the applicable Customer (including but not limited to the provision of services). Mblox will not be responsible for determining the authenticity of any purported Data Subject’s request to access his or her Personal Data. In the absence of express instructions to do so from the applicable Customer, Mblox will not provide a purported Data Subject with access to his or her Personal Data unless it is demonstrated to Mblox’s satisfaction that the applicable Data Controller has refused such access.
From time to time, Mblox provides messaging services to health care providers, and serves as a “Business Associate” (as that term is defined pursuant to HIPAA Regulations) to such providers in relation to the handling of protected health information (“PHI”) that is made a part of Our services.
Mblox may de-identify or depersonalize data into anonymized and aggregate data that it derives from Customers (“Anonymous Data”). Anonymous Data means data that includes no Personal Data or unique identifiers that could later be used to refer to the Personal Data to which the data was once associated. Mblox uses only Anonymous Data in performing analyses, and may disclose Anonymous Data to its Customers who have requested such analyses and to third parties where We are contractually entitled to do so.
This Site is Not for Use by Children
Protecting the privacy of children is important to Mblox. For that reason, the Site is structured specifically to not attract anyone under 13, nor do We collect or maintain Personal Data on the Site from those who Mblox actually knows are under 13. If Mblox learns or is notified that it has collected information from users under the age of 13, Mblox will immediately delete such Personal Data.
We provide you the opportunity to ‘opt-out’ of having your Personal Data used for certain purposes, when We ask for this information. For example, if you register with Us but no longer wish to receive Our newsletters and/or related communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing Us at privacy@Mblox.com.
We take appropriate technical and organizational measures to guard against unauthorized or unlawful processing of your Personal Data and against accidental loss or destruction of, or damage to, your Personal Data. Mblox uses industry-standard security measures to protect the integrity and confidentiality of any Personal Data it owns or processes on behalf of Customers, including, in appropriate circumstances, the use of firewalls, restricted access, and encrypted transmissions. Mblox limits access to Personal Data to those persons in Mblox’s organization who have a business need to process such Personal Data. However, no company, including Mblox, can fully eliminate the security risks associated with such Personal Data. Due to factors beyond Mblox’s control, Mblox cannot ensure that Personal Data will not be disclosed to third parties. For example, Mblox may become legally obligated to disclose such data, or, despite precautions, third parties may circumvent security measures to intercept or access such data.
Update Information / Revoke Choices / Suggestions / Contact Information
ATTN: PRIVACY OFFICER
1100 Abernathy Road
500 Northpark Towncenter, Ste 1200
Atlanta, GA 30328
ATTN: PRIVACY OFFICER
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9-12 Long Lane
Mblox has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Mblox, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
Revised February 17, 2016