PRIVACY POLICY

Last Updated 24-05-2018

This privacy policy statement (“Privacy Policy”) describes how Mob Opinions Limited ("MOBOPINIONS", “we,” “us,” or “our,” including our affiliates and subsidiaries) collect that information about you our Survey Respondent and Business contacts, how that information may be used, and with whom it may be shared.

Please read this Privacy Policy carefully because it governs your use of our websites http://www.mobopinons.com or http://www.quizxt.com or http://VSreward.com (the “WebSite”) and any mobile device applications (“Apps”), displaying our surveys and offers. The Website, and Apps are collectively called the “Services.” Participating in our surveys, or using other products or services we provide (collectively, “Services”), you are accepting this Privacy Policy. If you do not agree with this Privacy Policy, then you must not access or use the Services. Our Services may be offered through or in connection with third party mobile applications or third party mobile websites. When you participate in the Services you are leaving the third party mobile application or website through which you accessed the Services.

HOW & WHAT INFORMATION WE COLLECT

All Information collected is relevant for the purpose for which it is to be used and, to the extent necessary, we take reasonable steps to ensure that data is reliable for intended use, accurate, complete, and current.

How we collect information

Information submitted or provided by you:

  • Through or in connection with our corporate website(s), including, without limitation, www.mobopinions.com;

  • Through or in connection with business meetings with actual or potential customers or clients;

  • Through or in connection with promotions, meetings, events, and/or trade or industry shows or conferences sponsored by, hosted by, or attended by MOBOPINIONS and/or our employees, representatives, and/or agents; 

  • Through telephone calls, email communications, instant messages, SMS and/or other forms of communication with you;

  • Through inquiries, from requests for bids or quotes from MOBOPINIONS, and from orders for MOBOPINIONS services.  

What personal information we collect from you:

  • Personally identifiable information (“PII”) includes, without limitation, first and last names, email address, telephone number(s) (e.g., home, mobile, and business numbers), and residential address. Demographic information such as household income, age, education, and gender. Contact Information such as your email address, or mobile number may be collected using a Double Opt In Process;

  • Business contact information, of your employer or the company you represent including, without limitation, company name, job title, and department;

  • Preferences & Opinion Information you provide such as product or content interests, or communication or marketing preferences;

  • Usage activity about how you interact with us such as surveys you complete;

  • Health or Medical Information such as prescription information you provided;

Information collected automatically: When you use the Services

We automatically collect and store information about your mobile device and your online activities (“Metadata”), which we transfer and store in accordance with the provisions contained in this Privacy Policy. Metadata may include:

  • Device Information. Technical information about your device (e.g., type of device, operating system, IP address, etc.);

  • Geographic Location. We use your IP address or Phone Geo Location to derive your device's approximate geographic location;

  • Time, Length and Extent of Usage. When you use the Services, how long you use a Service for (e.g., how long it takes you to answer a survey question) and which Services feature(s) and/or function(s) you use;

  • Mobile Device Advertising ID: We collect mobile device identifiers, such as Apple’s Identifier for Advertising ID (IDFA) or Google’s Android Advertising ID (AAID), to help us identify you within a mobile application and match you with appropriate survey opportunities;

  • Referring Source Information including URLs, and Mobile applications IDs;

  • Cookies: We may use cookies to keep track of some types of information while you are using the Services. Cookies are small files that store certain data on a device or computer which allow us to perform analytics, such as counting the number of users of the Services and distinguishing repeat users from new or unique users. Cookies help provide additional functionality to the Services and help us analyze usage of the Services more accurately, such as user preferences or trends.

Information collected from third parties

MOBOPINIONS may collect information, including, without limitation, PII and business contact information, from third parties, including, without limitation, information service bureaus, data brokers, social media platforms, and/or industry conference or event organizers or sponsors. We may use the information collected from such third parties for various purposes, including, without limitation, sending you emails or other communications as described herein. In the event you receive such communications you will have the opportunity to opt-out of receiving communications from us. 

HOW WE USE YOUR INFORMATION

We obtain your prior opt-in consent at the time of collection for the processing of (i) personal information for marketing purposes and (ii) personal information deemed sensitive pursuant to applicable law. Pursuant to the terms of this Privacy Policy, we may use the information we collect from you for the following purposes:

  • To process, analyze, and develop survey data for use with the Services and our third party customers;

  • To improve upon the surveys and delivery of our surveys through the Services;

  • To prevent fraud and other illegal activities;

  • To monitor and analyze trends, usage, and activities;

  • To communicate with you about the Services; 

  • To provide, maintain, and improve the Services and our overall business.

Sharing your information:

We will share your information with third parties only in the ways that are described in this privacy statement.

We may provide your personal information to companies that provide services to help us with our business activities. These third parties are authorized to use your personal information only as necessary to provide these services to us. These include website hosting, data analysis, customer service, email delivery, and other services.

We may disclose your personal information:

  • with our clients which include survey creators, researchers, survey routers, advertisers, app developers and others;

  • with unaffiliated third parties for their own internal purposes, including marketing purposes. If you wish to opt-out of having your information shared with these Third Parties, please contact privacy@mobopinions.com;

  • as required by law, such as to comply with a subpoena, or similar legal process;

  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

  • if MOB OPINIONS Limited is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. 

PRIVACY OF CHILDREN

We do not knowingly solicit data from or market to children under the age of 13 (14 in South Korea, Austria, Bulgaria, Cyprus, Italy, 15 in Czech Republic, Greece, Slovenia, and 16 in France, Lithuania, Hungary, Germany, Croatia, Slovakia, Romania, Malta, Luxembourg, and Netherlands). If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact privacy@MOBOPINIONS.com. We will take immediate steps to delete the information, within a reasonable time.

ACCESSING & DELETING YOUR INFORMATION

You can opt-out and instruct us not to send you marketing communications by e-mail by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us at. Under the Privacy Shield & EU GDPR provisions, it is your right to access, correct, or delete your personal data. If you wish to do so, please contact privacy@mobopinions.com.

You may also withdraw any consent you previously provided to us, or object at any time on legitimate grounds to the processing of your personal information by contacting us at privacy@MOBOPINIONS.com. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal information will mean that you cannot take advantage of certain products, services, surveys or promotions we may offer.

SECURITY

The security of your personal information is important to us. When you provide sensitive information to us, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

If you have any questions about security on our Web site, you can contact us at privacy@MOBOPINIONS.com .

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at privacy@MOBOPINIONS.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

LOCATION & TRANSFER OF DATA

Information, including, without limitation, PII and business contact information, is primarily stored on servers and systems located in the United States, which servers are licensed, owned, and/or maintained by or on behalf of MOBOPINIONS. We may transfer the information we collect about you to countries other than the country in which the information was originally collected. Please be advised, however, that such countries may not have the same data protection laws as the country in which you initially provided the information. We will protect your information as described in this Privacy Policy when we transfer such information to other countries. By using the Services, you consent to the collection, transfer, use, storage and disclosure of your information as described in this Privacy Policy, including to the export of your information outside of your country of residence.

MOBOPINIONS complies with the European Union and United States – Swiss Safe Harbor Frameworks as set forth by the United States Department of Commerce regarding the collection, use and retention of information from European Union member countries and Switzerland. We adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement.

The EU GDPR Highlighted Addendum

The EU General Data Protection Regulation (“GDPR”), effective May 25, 2018 in the EEA countries and Switzerland, requires MOBOPINIONS and the publishers and researchers using our services to provide data subjects with information about the processing of personal data. (“Personal data”, as used in the GDPR, means information relating to an identified or identifiable natural person, including name, address, cookie identifiers, mobile device identifiers, and more; “data subject” here means the person involved; and “processing” of data includes collection, storage, and use.)  

This section provides representations and information in compliance with our GDPR obligations, for the benefit of our users located in the EEA countries and Switzerland only. 

MOBOPINIONS: IS A DATA CONTROLLER & A DATA PROCESSOR

EU data protection law makes a distinction between organisations that process personal data for their own purposes (known as “data controllers”) and organisations that process personal data on behalf of other organisations (known as “data processors”).  If you have a question or complaint about how your personal data is handled, we encourage you to direct your inquiry to the relevant data controller, since data controllers have primary responsibility for your personal data.

MOBOPINIONS may act as either a data controller or a data processor in handling your personal data, depending on the precise circumstances. For instance, for personal data that we use internally to create our data-related services, such as survey/ad targeting, and for personal data that we collect about our publisher and customers for use in marketing to them, we are a data controller. But when we handle personal data strictly on behalf of our customers to provide our services to them (for example, if they provide us with a list of device identifiers to use for targeting or suppression), we are a data processor.

LEGAL GROUNDS FOR PROCESSING YOUR DATA

The GDPR requires us to identify the legal ground we’re relying on to process personal data about you.  Our legal grounds for processing your personal data as described in this Privacy Policy will typically be because: 

• You provided your consent. To store and access information on your device, we rely on your consent.  For this you will opt in the first time you select to answer a survey, mobile ad identifiers and cookies are then used, to fulfill our obligations under the ePrivacy Directive. We rely on mobile app developers and oblige them contractually to pass on only legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to consent and its withdrawal.  

• The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing personal data to provide our and our commercial partners’ services. A legitimate interest we rely on, for instance, is the tailoring of offers and opportunities to obtain survey rewards to users of mobile applications and services, which is beneficial to users and offers them a value exchange and goes beyond the original collection of mobile ad identifiers and also includes providing analysis of and reporting about ad campaigns. We also rely on legitimate interest when we use personal data to maintain the security of our services, including fraud detection and identifying and fixing bugs. 

• Contractual Relationships. Sometimes, we process personal data as necessary under a contractual relationship we have, such as our customer records and contact information.

• Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.

PERSONAL DATA RETENTION

As a general matter, we retain your personal data for as long as necessary to provide our services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.     

EXERCISING YOUR RIGHTS AS A DATA SUBJECT

As a data subject covered by the GDPR, you have certain rights about the personal data that data controllers hold about you, including right of access, right to request correction, right to be forgotten (i.e., deletion), and right to object to processing (including profiling for online ad targeting).  

RIGHT TO ACCESS

If you are a consumer and wish to exercise your right to access personal data we process as a data controller, you may do so by requesting access through the e-mail address gdpr-access@MOBOPINIONS.com and following the instructions we provide you to authenticate your request and obtain access. We will assess requests to exercise data access rights on a case-by-case basis, factoring in the difficulty of verifying whether a mobile device identifier, and the data we have linked to it, truly and solely belongs to the person making the request, as well as the potential risk of harm through disclosure of personal data to the wrong individual. Because improper disclosure would likely harm the privacy rights and freedoms of the person involved, we may limit the personal data we make available. We only grant requests where we are the data controller, as explained further, below. Where we act as a processor for one of our advertisers or publishers, we will refer your request to that company.

RIGHT TO CORRECT

If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below. 

RIGHT TO OBJECT TO PROCESSING OR TO WITHDRAW CONSENT

You may withdraw consent for processing where we rely on consent. If you do so, we will cease processing your personal data for such purposes within 30 days, to request this you can email us at gdpr-optout@MOBOPINIONS.com. 

RIGHT TO ERASURE

You also have the right to request erasure of personal data that we hold as a controller. The above opt-out process satisfies this right, because when a user opts-out by submitting a request to gdpr-optout@MOBOPINIONS.com, we stop using your personal data to provide our services to you; the data is permanently rendered disconnected to your device and will be automatically deleted from our production system. We may retain copies of some personal data for our own internal and necessary purposes, such as auditing, accounting and billing, legal, bug-detection, backups, and (if applicable) to ensure that you receive and that we are able to track the rewards you have received.   

RIGHT TO LODGE COMPLAINTS

You have the right to lodge a complaint with a supervisory authority.  However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have. 

Notice to California Users

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. We do not sell or share your personal information (as that term is defined under California law) with third parties for use for their own marketing purposes.

OTHER INFORMATION

Third Party Links, Websites, and Services

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage, nor does it apply to your relationship with the third party web sites, applications, services, and surveys (including those of any Third Party MR Company) that may be linked to, facilitated through or provided via our Services. For example, our Services may be made available to you through third party mobile applications (including mobile games). If you use a third party application, website, or service or participate in a third party survey, then such third party's privacy policy will govern the use, storage and disclosure of your information in connection with such site, application, service, or survey. We are not responsible for the privacy practices of such third party sites, applications, services, and surveys nor any data or information you may share with such third parties. We encourage you to read the privacy policies applicable to each and every third party site, application, service, and survey prior to your access, use, or participation.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT DETAILS

You can contact us about this Privacy Statement by writing or email us at the address below:

MOBOPINIONS Limited
18 Shirehall Gardens
London, NW4 2QS
United Kingdom

Email: privacy@mobopinions.com.