Mobio Global Ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients, customers, business partners and business contacts and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Mobio Global Ltd.
Limited company registered in England under company number 12596183.
Registered address: 2nd Floor 2 Woodberry Grove, North Finchley, London, United Kingdom, N12 0DR.
VAT number: 373002532.
Data Protection Officer: Sergey Konovalov.
Email address: firstname.lastname@example.org.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact ususing the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table.
|Data Collected||How We Collect the Data|
|name and surname||Forms on site mobiogroup.com, CRM Hubspot|
|Forms on site mobiogroup.com, CRM Hubspot|
|telephone number||Forms on site mobiogroup.com, CRM Hubspot|
|postal code||CRM Hubspot|
|Designated Market Area (DMA) or geographic areas||CRM Hubspot|
|ip address (is a unique address that identifies a device on the internet or a local network)||Appsflyer or Tracemetrics|
|advertising_id (user-resettable device ID, AKA GAID, a parameter of the user’s device)||Appsflyer or Tracemetrics|
|idfa (is a random device identifier assigned by Apple to a user’s device)||Appsflyer or Tracemetrics|
|android_id||Appsflyer or Tracemetrics|
|customer_user_id (is a unique user_id or account inside the advertiser’s app)||Appsflyer or Tracemetrics|
|Imei (is a permanent device id)||Appsflyer or Tracemetrics|
|user_agent (is an identification of advertiser’s app which includes special info about the version of operational system, application, and language of the app)||Appsflyer or Tracemetrics|
|Idfv (a unique Vendor ID provided by iOS)||Appsflyer or Tracemetrics|
6. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
|What We Do||What Data We Use||Our Lawful Basis|
|direct marketing/service provision||Name/Surname, e-mail, telephone number, region, country code, state, city, postal code||study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy/performance of services|
|improving marketing campaigns, analyzing marketing data of clients||DMA, ip address, advertising_id, idfa, android_id, customer_user_id, Imei, user_agent, Idfv||study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy/performance of services|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message with information, news, and offers on ourservices. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long We Keep It|
|Name and Surname||As long as a person remains client, period depends on the actuality of a contract, potential negotiations, operational activity which is needed to communicate and provide services.|
|As long as a person remains client, period depends on the actuality of a contract, potential negotiations, operational activity which is needed to communicate and provide services.|
|Telephone number||As long as a person remains client, period depends on the actuality of a contract, potential negotiations, operational activity which is needed to communicate and provide services.|
|Designated Market Area (DMA) or geographic areas||1 year|
|ip address (is a unique address that identifies a device on the internet or a local network)||1 year|
|advertising_id (user-resettable device ID, AKA GAID, a parameter of the user’s device)||1 year|
|idfa (is a random device identifier assigned by Apple to a user’s device)||1 year|
|customer_user_id (is a unique user_id or account inside the advertiser’s app)||1 year|
|Imei (is a permanent device id)||1 year|
|user_agent (is an identification of advertiser’s app which includes special info about the version of operational system, application, and language of the app)||1 year|
|Idfv (a unique Vendor ID provided by iOS)||1 year|
8. How and Where Do You Store or Transfer My Personal Data?
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you where we are legally required to do so.
9. Do You Share My Personal Data?
The personal data of our clients, customers, business partners and business contacts may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, IPO or sale of all or a portion of our assets.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 10 business days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details
Email address: email@example.com.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on https://mobiogroup.com/. This Privacy Notice was last updated on 01 January 2023.