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Privacy policy

1. Scope of this privacy policy

1.1 “We”, “us”, “our” or “Mobito” meaning Mobito Technology SRL, with registered seat at Chaussee de Boitsfort 48, 1050 Brussels, Belgium, and VAT number 0747.793.289.

1.2 Mobito acts as a controller for:

(i) The personal data Mobito gathers of you through the use of its website (https://www.mobito.io/) (“Website”); and

(ii) The personal data Mobito collects about you in relation to our services, such as when you are making use of the platform (as a data provider or as a data customer) provided by Mobito r (“Services”). 

1.3 Since your privacy is our priority, we’ve developed this privacy policy setting out how we collect, disclose, transfer and use (“Process”) the personal data that you share with us, and how we‘ll be respecting your rights in accordance with the objectives and obligations arising from the General Data Protection Regulation (“GDPR”), i.e. Regulation (EU) 2016/679 of 27 April 2016 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC and the Belgian law of 30 July 2018 on the protection of natural persons with regard to the processing of their personal data. 

1.4 This privacy policy can be amended from time to time if our Services require us to do so. Since we are constantly looking to improve our Service, it is possible that new applications will be available trough the use of our Services and we will collect, or want to use your personal data, in a different way. If significant changes are made in this privacy policy we will let you know and, where required, we’ll ask for your consent.  

1.5 If you have any questions, concerns or complaints regarding this privacy policy or about how we are processing your personal or you wish to submit a request to exercise your rights as set out in article 8, you can contact us via privacy@mobito.io.

2. Purposes of the processing

2.1 Personal data is defined as: “all information about an identified or identifiable natural person (“the Data Subject”)”. A natural person is regarded as identifiable if he or she can be identified directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more elements characterising the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.”

2.2 Mobito will use and collect your personal data in the execution of its Services for the purposes as listed hereunder:

(i) to register you as a user of our Services, and for all communication relating to the Services;

(ii) to send you alerts to platform actions linked with you;

(iii) to contact you in case of a (technical or business) issue (troubleshooting);

(iv) to send you marketing material related to the Services you use;

(v) to create marketing campaigns;

(vi) to offer you support and guidance on how to use our Services;

(vii) to enable relevant user functionalities (i.e. team management);

(viii) to personalize and improve our Services;

(ix) to invoice our Services or pay you for data consumed by the data customer;

(x) to better understand your needs (“user feedback”);

(xi) where we have a legal right or duty to use or disclose your personal data (for example in relation to an investigation by a public authority or in a legal dispute) so that we are able to enforce or exercise any rights that are available to us based on the applicable law;

(xii) to fulfil our obligations as set out by the applicable law.

2.3 Mobito will use and collect your personal data that is gathered through your use of its Website for the following purposes:

(i) to support the Website and to enhance your user experience, which includes ensuring the security, availability, performance, capacity and health of the Website;  

(ii) to contact you in case you applied for a job function and to follow up on applications for current or future job functions. 

(iii) in the event you use the contact form on our Website, we will use your personal data in order to reply to your query, via e-mail; 

(iv) for user communication in general;

(v) in the event you would like to receive marketing material, to provide with such marketing material;

(vi) to provide you with customer support and guidance on how to use the platform we provide you through our Website.

(vii) to reach out with offers and updates we consider to be relevant to you.

3. Categories of personal data being collected

3.1 Mobito collects the following personal data about you in the event you make use of our Services: 

(i) identification data, such as your e-mail address, telephone number (including mobile number), first name, last name, business role, company name and organization sector/domain;

(ii) financial information, such as purchase location, bank account number, e-mail address of contact person (if needed), billing address;

(iii) your user activity;

(iv) your communication and marketing preferences;

(v) your correspondence and communications with Mobito.

3.2 Mobito collects the following personal data that you share with us via the use of the Website: 

(i) Your contact data (such as e-mail address, first name, last name, company name) that is provided by you via the form “Contact” on our Website. We also collect the personal data you provide to us via the therefore designated blank field on the Website or when you send us an e-mail. Please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions or credit card/account numbers.

(ii) In addition to contact data, any data included in a resumé or motivation letter you sent in the event you apply for a job function, including relevant experience, education and hobbies.

(iii) Your usage data, such as IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of the visit, page views or information about timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our Website. In the event the usage data is completely anonymised (and can therefore not be traced back to you as an individual) this will not be considered personal data for the purpose of this privacy policy. This is personal data that is automatically collected through your use of our Website. 

4. The legal basis for the processing of the personal data

4.1 To register you as a user of our Services and to invoice our Services or to pay you for data consumed by the data customer, the legal basis for the processing of your personal data by Mobito is the necessity for the performance of the contract you’ve concluded with us. We need your contact details, name and agreed and signed contracts, but also your bank account numbers.

4.2 The legal basis for the processing of the other personal data we collect about you in the event you make use of our Services and our Website is our legitimate interest, namely to provide you with a useable Website and to communicate with you. 

4.3 In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to potential clients and prospects and to promote and advertise our Services to potential clients and prospects. In the event you are an existing client , and the direct marketing communication relates to the Services you receive, the legal basis for the processing is our legitimate interest. 

4.4 You have the right to opt-out of receiving any such promotional communications at any time, by making use of the simple “unsubscribe” link in emails or by contacting Mobito as set out in article 1 of this privacy policy.

4.5 In the event the legal basis for the processing is consent, you have the right to withdraw your consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn. This will however not affect the lawfulness of any processing done prior to the withdrawal of your consent. 

4.6 In the event the legal basis for the processing is our legitimate interest you will have the right to object to such processing, as set out in article 9 of this privacy policy. 

5. Sharing your personal data with third parties

5.1 In order to make our Website available to you, and to provide you with our Services, we share your personal data with service providers, such as IT service providers, service providers for the hosting of our Website, associates and marketing service providers. Our service providers may only use and process certain personal data in relation to their services and only in accordance with the purposes as mentioned in this privacy policy. At the end of our collaboration with such service providers, they will delete all of your personal data.

5.2 We may share your personal data with governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are legally required to do so:

(i) to comply with our legal obligations;

(ii) to exercise our legal rights (for example in court cases);

(iii) for the prevention, detection, investigation of crime or prosecution of offenders; 

(iv) for the protection of our employees, associates and clients.

5.3 As such, we do not disclose your personal data to our social media partners. We do, however, make use of the social media plugin of LinkedIn and Crunchbase to direct you to our resp. LinkedIn-page or Crunchbase-page and to allow you to interact with our content. In the event you click on the link, resp. LinkedIn and Crunchbase may collect personal data about you. For the avoidance of doubt, we are not responsible for the use of your personal data by LinkedIn or Crunchbase. In such case, LinkedIn or Crunchbase will act as the controller of your personal data.

6. International transfers

6.1 To deliver our Website and our Services to you, it is sometimes necessary for us to share your personal data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under GDPR.
If this happens, we will ensure that the transfer will be compliant with GDPR and all personal data will be secure. 

7. Retention of your personal data

7.1 We will not retain your personal data for longer than necessary for the purposes as set out in this privacy policy. This means the following:

(a) In the event the legal basis for the processing of your personal data is for the execution of a contract, then your personal data will be kept for as long as we have a contractual relationship with you and thereafter for the following purposes and according to the following duration: (i) accounting purposes for the period legally required to comply with our tax, fiscal and accounting obligations, (ii) other legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.

(b) In the event you have applied for a job with us through the Website, we will retain the information you submit for a period of two (2) years if we did not hire you in order to contact you if a comparable position opens us. 

(c) For usage data collected through the Website, a retention period of (2) years applies.

7.2 In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. This will however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.

8. Your rights as a data subject

8.1 This article lists your rights under the GDPR. We have tried to summarize them for you in a clear and legible way. 

8.2 To exercise any of your rights, please send us a written request in accordance with article 1 of this privacy policy including proof of your identity (e.g. by referencing your data customer or data provider identifier). We will respond to your request without undue delay, but in any event within one month of receipt of the request. The period mentioned can be extended by two further months where necessary, taking into account the complexity and number of request we’re receiving. We shall in any event inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. In the event we will not take action on your request, we shall inform you thereof without undue delay and at the latest within one month of receipt of your request including the reasons for not taking action.  

RIGHT OF INSPECTION AND TO ACCESS

You have the right to confirmation as to whether or not we process your personal data. In the event we do so, you have the right to access your personal data and to check how your personal data is being used by Mobito. You may obtain a free copy of your available personal data at any time by simply making a request to this effect, providing that this does not adversely affect the rights and freedoms of others.

RIGHT TO CORRECTION

If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed. 

RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”) 

In the following circumstances, you have the right to have your personal data erased:

(i) The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;

(ii) You withdraw your consent, and no other lawful ground exists;

(iii) The processing is for direct marketing purposes;

(iv) The personal data have been unlawfully processed; or,

(v) Erasure is necessary for compliance with EU law or Belgian law.

There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary for (i) exercising the right of freedom of expression and information; (ii) compliance with a legal obligation; or, (iii) the establishment, exercise or defense of legal claims. 

RIGHT TO RESTRICT PROCESSING

You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:

(i) You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);

(ii) The processing is unlawful, and you request restriction (as opposed to exercising the right to erasure);

(iii) We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,

(iv) You have objected to processing, pending the verification of that objection. 

In addition to our right to store your personal data, we may still otherwise process it but only: 

(i) with your consent; 

(ii) for the establishment, exercise or defense of legal claims; 

(iii) for the protection of the rights of another natural or legal person; or, 

(iv) for reasons of important public interest. 

RIGHT TO OBJECT

You may oppose the processing of your personal data at any time if your objection is based on serious and legitimate reasons, and only to the extent that the legal basis for the processing is that the processing is necessary for (i)the performance of a task carried out in the public interest or in the exercise of any official authority vested in us, or (ii)the purpose of the legitimate interest pursued by us or by a third party.

If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. 

If you wish to oppose the use of your personal data for direct marketing purposes (which is only possible if we are processing your personal data on the legal ground “legitimate interest”), you do not have to give any reasons for this. We will cease to process your personal data for this purpose.

RIGHT TO WITHDRAW CONSENT

If the processing of your personal data is based on consent you have given, you may withdraw this consent at any time.

RIGHT TO DATA PORTABILITY

You may ask us to transfer your personal data in a structured, commonly used and machine-readable form to another controller. For the avoidance of doubt, you only have this right to the extent that the legal basis for the processing is that the processing is based on your consent or that the processing is carried out by automated means.

THE RIGHT TO COMPLAINT TO A SUPERVISORY AUTHORITY

If you believe that your rights as a data subject are being infringed by us you have the right to make a complaint to the supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Belgium, you can submit a complaint to  the Data Protection Authority (the Data Protection Authority, Drukpersstraat 35, 1000 Brussels, email: contact@apd-gba.be, tel. +32 (0)2 274 48 00, fax +32 (0)2 274 48 35), without prejudice to any other possibility of initiating a judicial review or seeking a judicial remedy.

9. Cookies

9.1 Technical information about cookies​

A cookie is an information file which is placed on the web browser of a computer or mobile device by the server of the website that the visitor is consulting. The cookie contains a code that can be read by the server that placed it on the visitor’s web browser. Cookies ensure that visitors of the Website have the best possible experience. This means, for example, enabling the visitor to navigate more quickly and easily between the different parts of the Website and adjusting the content of the Website to the visitor’s personal preferences, such as their preferred language. ​

9.2 The website being visited does not have access to other information files located on the visitor’s computer or mobile device.

9.3 The cookie can be found in a separate folder for the web browser on the hard disk of the visitor’s computer or mobile device and consists of the following components:

(i) the name of the server that placed the cookie file on the computer;​

(ii) an expiry date;

(iii) a unique numerical code.

9.4 The relevant legislation makes a distinction between different types of cookies. First of all, you have strictly necessary cookies on the one hand and other cookies on the other hand.

 

The strictly necessary cookies are necessary for the proper functioning of the Website, e.g. for the security of our Website and the accessibility of our Website. By virtue of the applicable legislation, we are not required to ask your consent to use such cookies.

 

A further distinction on the basis of category can be made according to the specific purpose of the cookie. For each of the following categories of cookies, we will ask your consent.

 

What are 'performance’ cookies? 'Performance' cookies monitor how the visitor uses the Website. This enables the website administrator to adjust and optimize the content and ease of use of the Website. For example, performance cookies enable daily tracking of how many different people have visited the different pages and which language version of the Website is the most popular.

 

What are ‘functional’ cookies? Functional cookies are cookies that remember your preferences when you use the Website, e.g. chosen language.

 

Cookies can be further classified according to duration and the origin of the cookie:

 

What are 'session' cookies and 'permanent' cookies and what is the difference between these two? The task of the session cookie is to recognize the web browser during the visit to the Website, while the task of the permanent cookie is to recognize the web browser with a view to repeat visits to the Website. Session cookies expire at the end of a browser session, and permanent cookies can be stored longer.

 

What are ‘first-party’ cookies? First-party cookies are cookies that are set by the Website itself.

 

What are 'third-party' cookies? Third-party cookies are cookies that are set by other websites. This happens when our Website incorporates elements from other websites, e.g. social media plug-ins. 

9.5 Cookies will not always contain personal data, but may contain information that may lead to your identification, in which case such cookie shall be treated as personal data. In such case, our privacy policy will apply to the extent that a cookie can be considered personal data. 

 

HOW CAN YOU MANAGE OR BLOCK THE COOKIES?

9.6 You can at all times control the management of the cookies or block the cookies yourself. You can adjust the settings of your web browser according to your personal preferences. You can delete cookies which have already been installed at any time and refuse new cookies by adjusting their browser settings.

9.7 For more details about controlling and/or deleting cookies, you can visit http://aboutcookies.org/how-to-delete-cookies/. Or you can visit the page corresponding to your browser for more information: 

(A) https://support.google.com/chrome/answer/95647?hl=en (Chrome);​

(B) https://support.apple.com/kb/PH21411 (Safari);

(C) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(D) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(E) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(F) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

9.8 Which types of cookies do we use

Our company is hosted on the Wix.com platform. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. 

Please take a look below to see which cookies are placed on WIX websites:

Cookie Name
Purpose
Duration
Cookie Type
XSRF-TOKEN
Used for security reasons
Session
Essential
hs
Used for security reasons
Session
Essential
svSession
Used in connection with user login
2 years
Essential
SSR-caching
Used to indicate the system from which the site was rendered
1 minute
Essential
_wixCIDX
Used for system monitoring/debugging
3 months
Essential
_wix_browser_sess
Used for system monitoring/debugging
Session
Essential
consent-policy
Used for cookie banner parameters
12 months
Essential
smSession
Used to identify logged in site members
Session
Essential
TS*
Used for security and anti-fraud reasons
Session
Essential
bSession
Used for system effectiveness measurement
30 minutes
Essential
fedops.logger.sessionId
Used for stability/effectiveness measurement
12 months
Essential
wixLanguage
Used on multilingual websites to save user language preference
12 months
Functional

Please note that we reserve the right to modify this privacy policy at any time, so please review it frequently. At any time you can check which cookies are used by our website using Google Chrome's built-in cookie view. While in incognito mode, click the Secure icon         next to the URL bar and then select Cookies.