Privacy Policy

Mobile Data Management Limited (“we”, “us”, “our”) is committed to protecting the privacy of the users (“you”, “your”, the “user”) of our Mobile Data Management apps (our “Services”). Mobile Data Management Limited is a company registered in Scotland (company number: SC653060) and our registered address is 7 Palmerston Place, Edinburgh, EH12 5AH.

This Privacy Policy is used to inform you of our collection, use, and disclosure of the personal information that you disclose to us during your use of our Service.

If you choose to use our Service, then you agree to the collection and use of your personal information as described in this Privacy Policy. Please read the following carefully to understand how we will treat your personal information.

The terms used in this Privacy Policy have the same meanings as in our Consumer Terms and Conditions and Business Terms and Conditions (as applicable) unless otherwise defined in this Privacy Policy.

1. Personal information collection and use Personal information means information that identifies (or which could, with other information that we hold or are likely to hold, identify) a living individual. This includes any information provided to us in relation to your use of our Service.

We may require you to provide us with certain personal information, including but not limited to:

1.1 Information you give us:

In order to use our Service, we will ask you to provide us with:

• Company Name and contact details

• Email addresses of other individuals who should receive emails from thesystem (alert emails when data alarms are triggered).

In providing this information to us, you agree that you have obtained the consent of each other individual, and have brought their attention to this Privacy Policy.

If you are acting on behalf of an organisation providing us with personal information about its employees, you must ensure that you have (where appropriate) obtained their consent, and brought their attention to this Privacy Policy, before you share any employee personal information with us.

For owners of devices which are added to the Service by the organisation:

• Mobile phone number

• First and last name

1.2 Information we collect about you:

When the devices send up data to the Service we store:

• Current country (i.e. your geographical location)

• Amount of data the device is reporting as used and received

• For Android devices, data usage is broken down on a ‘per app’ basis (we will collect information about how much data you use on specific apps)

• Roaming status of the device

Log Data

Whenever you use our Service, in case of an error in the Mobile Data Management app or Service, we collect data and information (through third party products) on your phone called “Log Data”.

This Log Data may include information such as your device’s Internet Protocol (“IP”) address, device name, operating system version, configuration of the app when utilising our Service, the time and date of your use of the Service, and other statistics.

Cookies

Cookies are files with small amount of data that are commonly used as an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your device’s internal memory. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.

You have the option to either accept or refuse cookies, and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

More information about our use of cookies is available in our Cookie Policy.2. Why do we hold your personal information?

We collect and hold your personal information so that we can provide our Service to you, to make improvements to our Service and for analytics purposes. Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide the Service to you. Without using the personal information described in this Privacy Policy, we would not be able to do so.

3. Using your personal information in accordance with the data protection laws

Data protection laws require that we meet certain conditions before we are allowed to use your personal information in the manner described in this Privacy Policy. We take our responsibilities under data protection laws very seriously, including meeting these conditions. To use your personal data, we will rely on the following conditions:

• Providing our Service to you: We will process your personal information to the extent that this is necessary for the performance of our obligations under our Business Terms and Conditions;

• Legitimate Interests: We will also process your personal information where this processing is in our “legitimate interests”. It is in our legitimate interests to collect your personal information as it provides us with the information that we need to provide the Service to you more effectively. When relying on this condition, we are required to carry out a balancing test of our interests in using your personal information (for example, in order to improve our Service), against the interests you have as a citizen and the rights you have under data protection laws (for example, to not have your data sold to third party marketing companies without your knowledge, or store your personal data in insecure or unstable countries or regions). The outcome of this balancing test will determine whether we can use your personal information in the ways described in this privacy policy. We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.

4. Disclosure to third party service providers

We may disclose your personal information to third–party service providers for the following reasons:

• To facilitate our Service;

• To provide the Service on our behalf; or

• To assist us in analysing how our Service is used.

These third–party service providers are obligated not to disclose or use your personal information for any other purposes.

5. How long we keep your information for

The personal information that we collect will be retained by us for a period of three (3) months after we stop providing our Service to you.

6. Security and where we store your personal data

We value your trust in providing us your personal information, thus we take all steps reasonably necessary to protect it. But please remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable. Although we do our best to protect your personal information, we cannot guarantee its absolute security. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The service is currently only being offered in the United Kingdom and information that we collect from you will be stored and processed in the United Kingdom.

7. Links to Other Sites

This Service may contain links to other sites. If you click on a third–party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third–party sites or services.

8. Children’s privacy

Our Mobile Data Management Service is intended for business use and is not intended to be provided to anyone under the age of 16.9. Changes to this Privacy Policy We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

10. How do we use cookies?

Our Site may place and access certain Cookies on your computer or device. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products AND/OR services . We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. All Cookies used by and on our Site are used in accordance with current Law and our Cookie Policy Before Cookies are placed on your computer or device, you will be shown a dialogue box requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.

11. Your rights and how to contact us

You have a number of rights under data protection laws in relation to the way we process your personal information. These are set out below. You may contact us directly by emailing support@mobiledatamanagement.co.uk to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request. If you have any questions or suggestions about our Privacy Policy, please do not hesitate to contact us by emailing support@mobiledatamanagement.co.uk.

Right 1.  A right to access personal information held by us about you.

Right 2.  A right to require us to rectify any inaccurate personal information held by us about you.

Right 3.  A right to require us to erase personal information held by us about you. This right will only apply where (for example): we no longer need to use the personal information to achieve the purpose we collected it for; or where you withdraw your consent (if we are using your personal data based on your consent); or where you object to the way we process your data (in line with Right 6 below).

Right 4.  A right to restrict our processing of personal information held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal information held by us; or where you would have the right to require us to erase the personal information but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.

Right 5.  A right to receive personal information, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal information to another organisation, at your request.

Right 6.  A right to object to our processing of your personal information (including for the purposes of sending marketing materials to you).

Right 7.  A right to withdraw your consent, where we are relying on it to use your personal data. If you have any concerns regarding our processing of your personal information, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner’s Office. Their address is:

First Contact Team, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.