MOBILion Systems, Inc. Privacy Notice
Last updated on September 25, 2023
This Privacy Notice describes the information collection, use, retention and sharing practices of MOBILion Systems, Inc. (“MOBILion”, “we”, “us”, “our”) when you interact with us through our website at www.mobilionsystems.com (the “Website”), in-person at an event, or through other digital products or services on which this Privacy Notice is posted (collectively, the “Services”).
OUR ROLE IN DATA PROCESSING
The entity responsible for the collection and use (processing) of your personal information is MOBILion Systems, Inc., which, for the purpose of the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“DPA”), is the data controller. You can contact MOBILion by email at firstname.lastname@example.org, by telephone at (+1) 484-246-6060, or by sending a letter to 4 Hillman Drive, Suite 130, Chadds Ford, PA 19317.
The Services are controlled and operated by us from the United States of America (“U.S.”) and we collect data from you directly from the U.S. Please be aware that in accordance with U.S. laws, in certain circumstances which may be different than those in your country of residence, U.S. courts, law enforcement agencies, regulatory agencies, or security authorities may be entitled to access your personal data.
PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG
We collect personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you, when you engage with the Services. As used in this Privacy Notice, “personal information” includes “Personal Data”, as defined under the GDPR and DPA. We will retain your information for as long as necessary for the purpose of the processing, unless we receive a request to delete this information and no exception to your right to deletion applies.
We collect personal information from a variety of sources and in a variety of ways, including when you:
- Contact us via telephone or email. When you contact us via telephone or email, we collect, from you, your personal identifiers (name, email address, and telephone number) and any information you choose to include in your message. We use this information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you have with the Services. To the extent the EU or UK data protection laws apply, the legal basis for this processing is that it is necessary for the performance of the service requested by you.
- Purchase a product or service. When you make a purchase, we collect from you your personal identifiers (name, business email address, business telephone number, country/region, and physical address), employment information (employer name), financial information (bank account and routing number), and any additional information you choose to include in your correspondence with us as part of the purchase, contract negotiation, and/or customer service process. We use this information to process your purchase, to facilitate payment to MOBILion, to send you a receipt or invoice of your purchase, and provide customer service to you, including set-up and installation, processing and investigating complaints. To the extent the EU or UK data protection laws apply, the legal basis for this processing is that it is necessary for the performance of our contract with you.
- Engage us to provide professional services, training, or certification. When you engage with us to provide professional services, training, or certification, we will collect your identifiers (name, business email address, business telephone number, country/region, and physical address), employment information (employer name). We process this information to perform the professional services and set up and provide the training or certification for you and/or your company. To the extent the EU or UK data protection laws apply, the legal basis for this processing is that it is necessary for the performance of our contract with you.
- Participate in a MOBILion sponsored event or interact with us at an event. When you interact with us at an event, we will collect your identifiers (name, business email address, business telephone number) and employment information (employer name) in order to correspond with you in the future about our products and services and answer your correspondence. This information will be shared with our service provider/processor, Integrate, to assist us with managing leads. To the extent EU or UK data protection laws apply, the legal basis for this processing is your consent.
- Sign up for our marketing communications. When you sign up (i.e., opt in) to receive our email marketing communications, we collect, from you, your personal identifiers (name and email address). We use this information to send you product and services updates, news, and event opportunities. To the extent the EU or UK data protection laws apply, the legal basis for this processing is your consent to receive our email marketing communications. You can revoke your consent at any time with effect moving forward by clicking “unsubscribe” at the bottom of each email we send or by emailing us at email@example.com. Our emails include a tracking pixel that tracks whether you open the email and whether you click banners in the email and your subsequent clicks and usage of our Website. We use this information to send you additional email communications which may be of interest to you, based on your interaction with our emails and/or Website. To the extent the EU or UK data protection laws apply, the legal basis for this processing is your consent. You can revoke your consent at any time by emailing us at firstname.lastname@example.org.
Facebook, Twitter, LinkedIn, and Instagram (the “Social Networks”) process personal information in the USA where the laws may be less protective than in your country of residence. For example, in accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal data.
- Fan Pages. When interacting with our Fan Pages, we collect, from you, your personal identifiers (first and last name) and visual information (photograph (i.e., profile picture)), as well as any information that you provide when interacting with our Fan Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. To the extent the EU or UK data protection laws apply, the legal basis for the processing is our legitimate interest in advertising our products via our Fan Pages and communicating with users, customers, and interested parties. Because our Fan Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit.The content posted on our Fan Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to us at email@example.com.
- Community Management. We collect, from you, your contact, including "likes", shares, messages and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts. We use this information to create advertisements that match our Fan Page and to disseminate them via the Social Network based on demographic data. To the extent the EU and UK data protection laws apply, the legal basis for analyzing your content and creating advertisements is our legitimate interest in organizing, facilitating, and optimizing communication with our users and the general public. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email at firstname.lastname@example.org.
- Surveys. When you participate in a survey on our Fan Pages, we collect, from you, your personal identifiers (email address), your internet or other electronic network activity information (device and browser data, IP address, location information based on the IP address), log data (IP address to determine whether a respondent has previously participated in a survey), and metadata (usage patterns)). We use this information to analyze and process the results of our surveys for market research purposes. To the extent the EU or UK data protection laws apply, the legal basis for the processing is our legitimate interest in the creation of appealing opinion and market research surveys to obtain helpful insights into customer satisfaction and any existing need for optimization of products and internal processes.
- Contests or Sweepstakes. When you participate in a contest or sweepstakes on our Fan Pages, we collect, from you, your personal identifiers (name, email address, telephone number, and physical address (if provided)), and your visual identifiers (photograph (i.e., profile picture)). We use this information to manage your entry, communicate with you about your entry, and to run the sweepstakes or contest. We also use this information to create unique offers to enhance your customer experience. To the extent the EU or UK data protection laws apply, the legal basis for the processing is that it is necessary for the performance of a contract. If you do not provide this information, it would not be possible for you to participate in the sweepstakes or contest. If it is necessary to send non-cash prizes, we will forward your information to a shipping service provider.
- Events and Photos. When you register for an event on our Fan Pages, we collect, from you, your personal identifiers (first and name, email address, telephone number, physical address, and any other information you provide). We use this information to create and manage the event (e.g., to create the guest list, accreditation and admission control, room and personnel planning, planning the catering) as well as to send you your invitation and notifications about the event. We also use this information for prevention of fraud and defense against legal claims. To the extent the EU or UK data protection laws apply, the legal basis for processing your information to facilitate your attendance is the necessity for the performance of a contract with you. If you do not provide this information, you would not be able to participate in the event. The legal basis for the other uses is our legitimate interest in fraud prevention. At events for which you have registered, photos and video recordings may be made (possibly by a photographer commissioned by us), in which you may also be shown. If you are the central subject of a recording, the photographer will ask you before the recording/taking the photo whether you agree and consent. We use the photos for our public relations and marketing on our various media/digital media outlets. To the extent the EU or UK data protection laws apply, the legal basis for processing your photos where you are the subject is your consent. You can revoke your consent with effect going forward by email@example.com. The legal basis for taking and publishing photos where you are in the background is our legitimate interest in public relations. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email at firstname.lastname@example.org.
- Page Insights. When you visit our Social Network Page, the Social Network records your IP address and other information about your usage behavior on our Social Network Fan Page. The Social Network collects, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Social Network app through your mobile device (e.g., smartphone or tablet). Social Network uses this information to provide us with statistical evaluations of the use of our Social Network Fan Page. We receive this information directly from Social Network, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Social Network fan pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, "Likes” and reactions; comments and shared content; and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Social Network Fan Page. We do not collect or process any other personal information in connection with Social Network “Page Insights” function.
To the extent the EU and UK data protection laws apply, we are joint controllers with the Social Network for this processing. For the purpose of the EU and UK data protection laws, the legal basis for this processing is our legitimate interest in statistical evaluation of users on our Social Network Fan Page for the improvement and adjustment of our advertising measures based on the information collected. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email at email@example.com.
- Information Processed Solely by Social Networks. We do not know how the Social Networks use personal information for its own purposes, how long the personal information is stored on the Social Network or whether the Social Network data is passed on to third parties. If you are currently logged in to a Social Network as a user, the Social Network automatically collects, through trackers on your device, your Social Network ID or a link between the Social Network ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Social Network app through your mobile device (e.g., smartphone or tablet). This enables the Social Network to understand that you have visited our Social Network Fan Page along with other Social network pages that you have clicked on, whether you clicked on Social Network buttons integrated into websites that partner with the Social Network, and other online interactions that report user data to the Social Network. Based on this data, content or advertising tailored to you can be offered. You can find more information about the personal information collected by Social Networks, how it is used and how long it is stored by visiting the Social Network’s privacy policies, linked above.
- Interact with the Services. In addition to the personal information you provide directly to us, we also collect information from you automatically as you use our Services via cookies, pixels, and similar tracking technologies. To the extent the EU and UK data protection laws apply, the legal basis for this processing is your consent. You may withdraw your consent at any time with effect moving forward by managing your Cookie Preferences by clicking “Cookie Preferences” under the “General” header in the footer of our website. To the extent the EU or UK data protection laws apply, the legal basis for the placement and access of strictly necessary cookies is the performance of a contract. These cookies are necessary to provide the Website to you.
We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information (determined through your IP address) when you interact with the Services. We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse; and (vi) provide targeted advertising. To revoke your consent to our use of non-essential cookies, please visit managing your Cookie Preferences by clicking “Cookie Preferences” under the “General” header in the footer of our website.
Particular third-party cookies to note on our Website include the following:
- Google Tag Manager. Google Tag Manager is a tag management system to manage tags used for tracking and analytics on websites. Tags are small code elements that, among other things, are used to manage traffic and visitor behavior and to test and optimize websites. We utilize Google Tag Manager to manage and organize all third-party tags on our Website and to control when those tags are triggered. You can view more information about Google Tag Manager’s privacy practices here.
- Hotjar. We use Hotjar to better understand user experience and to improve the Website. Hotjar allows us to better understand users’ experience (e.g., how much time you spend on which pages, which links you choose to click, what users do and don’t like, etc.) and this enables us to build, maintain, and improve our Website. You can opt-out of Hotjar here.
- Microsoft Clarity. We will use Clarity to collect information to analyze your use of the Website and create heatmaps of your use of the Website to improve our Website and analyze efficiency of online advertisements. We will collect a recording of your session on the Website, scroll behavior, click behavior, custom events, page navigation flow, browser type, country, device ID, device type, operating system, and session code errors. In order to collect this information, Clarify may set cookies on your browser, or read cookies that are already there. You can view Microsoft’s Privacy Statement for more information about its data collection practices. To opt-out of the use of your data for interest-based advertising from Microsoft, please visit Microsoft’s opt-out page. To access and clear some of your data, please visit Microsoft’s privacy dashboard.
Aggregate data. We aggregate the data we collect for benchmarking purposes, marketing purposes, and for internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data, unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.
MOBILion will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.
We may need to use and retain your personal information for longer than the periods indicated above for purposes of:
- Compliance with our legal obligations. For example, retaining your records for the purpose of accounting, dispute resolution, and compliance with labor, tax, and financial regulations.
- Meeting our safety and security commitments. Such as keeping our properties secure and preventing fraud.
- Exercising or defending legal claims. We also may need to retain information for longer than the terms in order to meet with legal process or enforceable governmental request.
HOW WE SHARE YOUR PERSONAL INFORMATION
A. General Sharing
MOBILion shares personal information in the following instances:
- In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
- For legal purposes. We share personal information where we are legally required to do so, such as in response to court orders, subpoenas, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations. To the extent EU or UK data protection law applies, our legal basis is compliance with the law or our legitimate interest in complying with Non-EU data protection law to which we are subject.
- With service providers. We share personal information with service providers that assist us in providing the Services. These service providers assist us with the following: IT support, email marketing service providers, event lead management provider, HR applicant processing service provider, digital marketing providers, customer relationship management providers, and payment processors.
- With Business Partners. With your consent, we share personal information with business partners under a co-marketing agreement. The information shared will be used by our business partners to market our business partners’ products and services to your business organization.
- With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time with effect going forward by emailing us at mobilionsystems.com.
YOUR INFORMATION CHOICES
You have the following choices with respect to your personal information:
- Correct or view your information. You may email us at firstname.lastname@example.org to correct or view certain personal information of yours in our possession.
- Opt out of Google Analytics. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser, which can be accessed here.
- Opt Out of Other Cookies. To set your cookie preferences, please visit Cookie Preferences by clicking “Cookie Preferences” under the “General” header in the footer of our website. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s Website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your device. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.
- Association of National Advertisers opt-out registration: https://dmachoice.thedma.org/
- Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
- European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu
- Opt out of email tracking. You can disable this tracking by blocking automatic loading of images in your email.
- Opt out of marketing communications. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send or by emailing us at email@example.com. Please note that we will continue to send you notifications necessary to the Services, your purchases, or any assistance you request.
RIGHTS OF INDIVIDUALS IN THE EUROPEAN UNION AND UNITED KINGDOM
Individuals in the EU and UK are entitled certain rights to their personal data under applicable law. To the extent these laws apply to our processing of your personal data, you are entitled to the following rights:
- Right to access: For any of the processing described above, you have the right to ask us for copies of your personal data. This right has some exemptions, which means you may not always receive all the personal data we process. Applicable exemptions may include the management information exemption (data that we process for management forecasting or management planning about a business or other activity), confidential references (references given or received about an individual), or certain instances of ongoing or prior negotiations with the requestor, among others.
- Right to rectification: For any of the processing described above, you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to restrict processing: For any of the processing described above, if you believe that your personal data is inaccurate, that our processing is unlawful, or that we do not need your personal data for a specific purpose, you have the right to request that we restrict the processing of this personal data. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing (per your right to object below), you may also request us to restrict processing of your personal data while we make our assessment.
- Right to object to processing: When you interact with us directly or indirectly through the Social Networks, you have the right to object to processing of your personal data, which is based on our legitimate interest, by referencing your personal circumstances.
- Right to data portability: You have the right to ask that we transfer the personal data you gave us from one organization to another or give it to you. However, this right only applies when: (i) you have provided your personal data to us; (ii) the legal basis for the processing is your consent or for the performance of a contract; and (iii) the processing is carried out by automated means.
To exercise these rights, please contact us at firstname.lastname@example.org.
Right to lodge a complaint: You have the right to lodge a complaint with the relevant Supervisory Authority.
RIGHTS OF NEVADA RESIDENTS
If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at email@example.com. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.
DO NOT TRACK
We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We implement and maintain reasonable security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.
The Services are not intended for individuals under the age of eighteen (18) years. If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below.
CHANGES TO THIS PRIVACY NOTICE
We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.
If you have any questions or concerns regarding this Privacy Notice, please contact us by email at firstname.lastname@example.org, by telephone at (+1) 484-246-6060, or by sending a letter to 4 Hillman Drive, Suite 130, Chadds Ford, PA 19317.