Last updated: 17th December 2012
Mobiroo is responsible for maintaining and protecting the Personal Information under our control. Accountability for this function within our organization is held by Mobiroo’s Privacy Officer (who can be contacted at the address below). We will, to our best efforts, protect all personal data (including Usernames, Password, Credit Card details etc.)
- Information Collected and Its Purpose
Mobiroo will identify to an individual the purposes for which Personal Information is collected at or before the time the information is collected. We will only collect, use and disclose Personal Information from our customers and employees for the following business reasons:
(a) to provide you with our goods and services;
(b) to determine which of our products and related services meet the needs of individual customers;
(c) to develop, enhance, market or provide products and services;
(d) to provide enhancement and/or updates for products already accessed by customers and the customer is an active customer;
(e) to manage and continually develop our businesses and operations, including personnel and employment matters;
(f) to investigate and detect potentially fraudulent transactions; and
(g) to meet legal and regulatory requirements.
Mobiroo collects and uses Personal Information for providing promotions and offers from us and our business partners only after receiving express permission to do so. We will advise you in advance if Personal Information is to be collected or used for our business partners; such collection and use will be by and for such business partners and subject to their privacy policies, and you should consult such privacy policies prior to consenting to such collection or use. We may also sell, transfer and disclose your Personal Information as part of a business divestiture, sale, merger, reorganization, or acquisition of all or a part of our business.
If we want to use Personal Information for a purpose other than what was identified at the time the Personal Information was collected, then we will obtain the prior consent of the individual to that additional use.
Personal Information collected may include your email address, name and responses to survey questions. Information such as survey responses will not be directly associated with you and will only be provided to our business partners on an anonymized basis. We may use your email address to send you your credentials or other account information for future reference. We may also use this to notify you of future software updates for apps that you download as they become available.
We may passively collect your mobile device information, such as PIN, IMEI number, device model, carrier network as well as information about your bandwidth usage of apps downloaded from the Website or Software Application, such as the date and time of each usage, time spent using an app, clicks on advertisements, statistics, etc. This information will only be used to generate aggregate usage statistics. PIN, IMEI number and device information will be used to register each device as an active device. Unless otherwise indicated to you in advance, such information will only be used for support-related requests and will not be shared with any third parties, except for certain developers or distributors who will be contractually obligated to limit its use to authenticating or supporting their app, as otherwise required by law, or pursuant to a separate agreement or notification between you and the developer or distributor.
Mobiroo also routinely collects anonymous, non-Personal Information through our Web servers. This is information that is not associated with or traced back to a specific individual. Gathered electronically, this information includes the type of Web browser used, the level of encryption a browser supports and the Internet Protocol address. This information may be used for research and analytical purposes, to examine how the Web site is being used and to determine how it can be improved.
Mobiroo does not store any Payment Information such as PayPal usernames and Credit Card numbers. All payment data is collected and stored by third party payment provider and processors (such as PayPal). Third party payment processors may provide us with limited information associated with you in order for you to continue to make additional purchases using the information the payment processor has stored.
- Limiting Use, Disclosure and Retention
We will only collect the amount and type of Personal Information which is necessary for our identified purposes or as required by law, and we will only collect Personal Information by fair and lawful means.
Access to Personal Information is limited to Mobiroo employees and suppliers who require access for business purposes.
From time to time, we transfer Personal Information for administrative or processing purposes to related companies or third party suppliers, or to assist us in communicating with individuals (such as for surveys and mail distribution, or for technical support). These related companies or suppliers may be in another jurisdiction. We may also disclose or transfer Personal Information to third parties retained to assist in the administration and investigation of a claim reported to us. In these cases, we use contractual or other safeguards to ensure protection of Personal Information. Our suppliers are contractually obligated to keep the information confidential, to use the information only for the purpose requested by Mobiroo and to destroy the information when it is no longer required. As a result of the use of related companies and suppliers, your Personal Information may be securely used, stored or accessed in the USA or other countries and may be subject to the laws of those countries. For example, Personal Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries.
When Personal Information is no longer required to fulfill the purpose for which it was collected, it will be destroyed, erased, or made anonymous, provided there are no legal requirements for its continued retention.
Mobiroo does not automatically share your activity with any third party or other integrated services when you connect Mobiroo to them. This may alter in future releases of Mobiroo and you agree that such information may be recognized and/or published on your accounts with any third-party or other integrated services.
We will use reasonable commercial efforts to ensure that Personal Information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used, including information that is transferred to related companies and suppliers for administrative and processing purposes.
- Safeguarding Personal Information
Personal Information, whatever its form, will be protected by commercially reasonable security safeguards appropriate to the sensitivity of the information to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
Mobiroo employees will be made aware of the importance of maintaining the confidentiality of Personal Information, and we will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to it.
We will safeguard Personal Information by physical measures (for example, locked filing cabinets and restricted access to offices), organizational measures (for example, by continued employee training and limiting access on a “need-to-know” basis), and technological measures (for example, by the use of passwords and encryption).
- Access to Personal Information
Individuals may request a copy of their Personal Information held at Mobiroo by submitting a written request to the Chief Privacy Officer at the address below. If you feel the information we have about you is inaccurate, you may request that it be reviewed and, if inaccurate, changed, by contacting the Chief Privacy Officer. An individual’s written request for access to Personal Information will be answered within a reasonable time and at a reasonable cost. Acceptable proof of identification is required before proceeding with the request.
If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, we will amend the Personal Information. If a challenge is not resolved to the satisfaction of the individual, we will document the substance of the unresolved challenge. The amended information or the existence of the unresolved challenge, as the case may be, may be transmitted to third parties having access to the information in question.
Requests for access to the Personal Information we hold about an individual may be refused if permitted or required by law. In such a case, the reasons for denying access will be provided to the individual upon request. Exceptions may include: information that contains references to other individuals or contains confidential commercial information which cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.
- Your preferences
Using the settings area of Mobiroo you are able to edit your preferences. Not all personal information may be kept private including usernames. Please choose an appropriate username and other identifying attributes such as profile pictures. You can log on at any time to edit these preferences. To edit the preferences of any third-party services you must visit your account setting on that service.
The Mobiroo service may contain advertisements or other promotional material from third party services or websites. Mobiroo will not be responsible for the third party’s content or practises.
Applicable to US customers: If you are under 13 years of age do not use the Mobiroo Service without adult’s supervision or approval. Please do not enter any of your personal information. If we later discover that you are under 13 and you have personally signed up, your information will be removed and deleted.
- Challenging Compliance
All written complaints will be investigated. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices. A complainant shall be informed of the outcome of the investigation regarding his or her complaint.
We encourage the use of our internal information and resolution process to resolve a complaint. However, an individual may also seek advice from the Office of the Privacy Commissioner of Canada at 1.800.282.1376 or firstname.lastname@example.org and, if appropriate, file a written complaint with that office.