Last Modified: January 17, 2019
1. Information We Collect
When You Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you register for a demonstration of our products, we request that you provide Personal Information about yourself, and we collect Navigational Information.
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.
Personal Information also includes Navigational Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Navigation Information" section below.
When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Mobials for the operation of and to provide general statistics regarding use of the Mobials Website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.
Information About Children
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at firstname.lastname@example.org, so that we may delete the information.
2. How We Use Information We Collect
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
- improve your browsing experience by personalizing or improving the Websites;
- send information or Mobials content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
- promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
- provide other companies with statistical information about our users — but this information will not be used to identify any individual user;
- meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
We use the information collected through our Services by our customers for the following purposes:
- to provide the Subscription Service (which may include the detection, prevention and resolution of security and technical issues);
- to respond to customer support requests; and
- otherwise to fulfill the obligations under the Mobials Customer Terms of Service.
Legal Basis for Processing Personal Information (EEA visitors only)
If you are a visitor/customer located in the European Economic Area ("EEA"), Mobials Inc. is the data controller of your personal information. Mobials' Data Protection Officer can be contacted at email@example.com.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal 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. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Mobials.
Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial, unless the customer testimonial or comments was already in the public domain.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Services or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in "To Unsubscribe from Our Communications" below.
If you provide information to our customers as part of their use of the Services, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Services, then we will provide customer with access to all information stored for the customer by the Services, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Services.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Mobials account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
3. How We Share Information We Collect
We employ other companies and people to provide services to visitors to our Websites, our customers, and users of the Services and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
In addition, we may share data with trusted partners to help us, for example, perform statistical analysis. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Mobials on the Websites and the Services. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
4. Cookies and Similar Technologies
Navigational Information Collected by Our Customers
Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on the Services. Mobials does not control our customers' use of these tools, nor do we control the information they collect or how they use it.
Third Party Tracking Technologies
5. How to Access and Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- you can request access, correction, updates or deletion of your personal information.
- you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- if we have collected and process 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 information conducted in reliance on lawful processing grounds other than consent.
- you have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)
To exercise any of these rights, please contact us at firstname.lastname@example.org or by mail to Mobials Inc., 192 Dundas Street, Suite 300, London, Ontario, Canada, N6A 1G7, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the unsubscribe link located on the bottom of our emails, updating your communication preferences, or by sending us email us at email@example.com or postal mail to Mobials Inc., 192 Dundas Street, Suite 300, London, Ontario, Canada, N6A 1G7, Attention: Privacy. Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.
To Unsubscribe from Our Customer Communications
Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customer marketing communications by clicking on the "unsubscribe" link located on the bottom of their emails, or by contacting them directly.
Chief Financial Officer
192 Dundas Street, Suite 300
London, Ontario, Canada
Last Modified: January 17, 2019
What are cookies?
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page. For example, if you personalize pages on our Websites, or register for a demonstration, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.
Cookies set by the website owner (in this case, Mobials) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.
We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites. For example, Mobials keeps track of the Websites and pages you visit within Mobials, in order to determine what portion of the Mobials Website is the most popular or most used. This data is used to deliver customized content and promotions within the Mobials Website to visitors whose behavior indicates that they are interested in a particular subject area. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below.
What types of cookies do we use and how do we use them?
The specific types of first and third party cookies served through our Websites and the purposes they perform. These cookies include:
- Essential website cookies: These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features.
- Analytics and customisation cookies: These cookies collect information that is used either in aggregate form to help us understand how our Websites are being used or how effective our marketing campaigns are, or to help us customise our Websites for you.
How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided below.
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. You may opt out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.
Essential website cookies: Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them. You can block or delete them by changing your browser settings however, as described above.
Do you serve targeted advertising?
Third parties may serve cookies on your computer or mobile device to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.
Where can I get further information?
Recruiting Privacy Notice
Last Modified: January 17, 2019
Introduction and scope of privacy notice
This Recruitment Privacy Notice explains the type of information we process, why we are processing it and how that processing may affect you.
What do we mean by "personal data" and "processing"?
"Personal data" is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.
"Processing" means doing anything with personal data. For example, it includes collecting it, holding it, disclosing it or deleting it.
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by EU privacy law to be "sensitive personal data".
Your personal data
We process your personal data for the purposes of fulfilling our recruitment practices. Some of the personal data that we process about you comes from you. For example, you tell us your contact details, like your first and last name, email address, and phone number. Other personal data about you is generated from references and third party companies such as recruitment agencies, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google. Your personal data will be seen internally by managers, administrators and HR. We may also share your data with external law firms for assessment of employment permits and visa options.
During the recruitment process, we try not to collect or process any “Sensitive Personal Information” unless authorized by law or where necessary to comply with applicable laws. Sensitive Personal Information includes the following: information that reveals your racial or ethnic origin, religious, political, or philosophical beliefs, or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health, sex life, or sexual orientation.
How long do we keep your personal data?
If you are successful in your application your data will be kept on your personnel/employee file. We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so. When we have no ongoing legitimate business need to process your personal data, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your personal data and isolate it from any further processing until deletion is possible. Generally this means your personal information will be kept for the duration of the application process plus a reasonable period of time after confirmation that your application was unsuccessful. We will delete this information from the servers at an earlier date if you so request, as described below.
Legal grounds for processing personal data
What are the grounds for processing?
Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts more than one ground applies. Three of those grounds can be summarised as Legal Obligation, Legitimate Interests, and Consent. We outline what those terms mean below:
- Ground for processing: Processing necessary to comply with our legal obligations
- Explanation: Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination, or complying with immigration laws and regulations.
- Ground for processing: Processing necessary for our or a third party's legitimate interests.
- Explanation: We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data. Your data will not be processed on this basis if our or a third party's interests are overridden by your own interests, rights and freedoms.
- Grounds for processing: Processing based on your consent.
Processing sensitive personal data
If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one of the grounds for processing sensitive personal data applies, including (for example) that the processing is for equality and diversity purposes to the extent permitted by law.
Further information on the data we process and our purposes
Examples of the data and the grounds on which we process data are explained below. This is not an exhaustive list of examples.
Recruitment for jobs at Mobials
- Examples of personal data that may be processed: Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or, insofar as required or permitted by local law, background checks and any information connected with your right to work. If relevant, and insofar as permitted or required by local law, we may also process information concerning your health, any disability and in connection with any adjustments to working arrangements.
- Grounds for processing: legal obligation; legitimate interests
Contacting you or others on your behalf
- Examples of personal data that may be processed: Your address, email address, and phone number.
- Grounds for processing: Legitimate interests
Monitoring of diversity and equal opportunities
- Examples of personal data that may be processed: Insofar as permitted and/or required by local law information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age.
- Grounds for processing: Legitimate interests
Submitting your information to process visa applications
- Grounds for processing: Legal obligation or performance of a contract.
Who gets to see your data?
Your personal data may be disclosed to managers, HR and administrators for employment, administrative and management purposes as mentioned in this document. We may also share your data with external law firms for assessment of employment matters, permits, and visa options. We may also disclose this to other members of our group.
Access to your personal data and other rights
- We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.
You have a legal right to make a "subject access request". If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including a description and copy of the personal data and an explanation of why we are processing it. If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
- As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted.
- You may also have the right to be given your data in a machine readable format for transmitting to another data controller though this right is unlikely to be relevant to you the context of our recruitment processes.
- We are unlikely to rely on consent as a ground for processing. However, if we do, you may withdraw consent at any time — though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.
- To exercise any of these data subject rights, please contact us by emailing firstname.lastname@example.org.
You have the right to complain to a data protection authority about our collection and use of your personal information.
You may also raise complaints with the statutory regulator in your jurisdiction.
Please contact us by emailing email@example.com.