Privacy Policy / GDPR

Mobilise Group Ltd

 

 

Mobile Group Ltd t (“we”, “us”, or “our”) operates this website http://www.mobile-group.com  (“our site”) and is committed to protecting and respecting your privacy and complying with applicable data protection and privacy laws.

 

This privacy policy (“Policy”) (together with our Terms and Conditions of Sale and Terms of Website Use) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

 

Please read the following to enable you to understand our views and practices regarding your personal data and how we will treat it.

 

This Policy applies to personal data collected in connection with our products offered by or from other interactions with us where a link or other reference of incorporation to this Policy is made, for example, in connection with mobile phone accessories, offered by us typically in electronic form, as well as other services such as customer care and warranty services or promotions and campaigns.

 

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[Certain products and services collect and use personal data in accordance with their own privacy policies. Such policies prevail over this Policy to the extent of any conflict.]

 

Mobilise Group Ltd  is the controller and responsible for your personal data.

 

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

 

Contact details

 

Full name of legal entity: Mobilise Group Ltd

Postal address:

Mobilise Group, The Charter Building, Charter Place, Uxbridge, UB8 1JG

Email address: Ajay Ahluwalia is our DPO – Email address ajay@mobilise-group.com

 

Information we may collect from you and how we collect your data

We may collect and process the following data about you:

 

  • Information that you provide by filling in forms on our site. This includes information provided when you register to use our site, subscribe to buying our products, enter into a sales promotion/voucher or a campaign, report a problem with our site or otherwise contact us.

 

  • If you contact us, we may keep a record of that correspondence.

 

  • We may also ask you to complete surveys or provide feedback this we use for research purposes only, although you do not have to respond to them.

 

  • Details of transactions you carry out through our site and of the fulfilment of your orders.

 

  • Below are examples of the categories of data collected:

 

  • Technical Information: You may visit and browse our site without telling us who you are. However, certain technical information is normally collected as a standard part of your use (such as your IP-address, access times, the website you linked from, pages you visit, the links you use, the ad banners and other content you viewed, information about your devices and other technical information your browser provides us with or as may be otherwise collected in connection with certain products.

 

When you use our website or contact us, certain additional information, such as your mobile telephone, subscription number, may be transmitted to us as a standard part of that communication.

 

Please also see the section “Use of Cookies and Web Beacons” below.

 

Information you provide us with: When you register and make a purchase, enter a sales promotion or otherwise contact us, we may ask you to provide us with information, this to used to authenticate users and to validate your actions or to provide you with the products you have requested or to contact you.

 

We may collect demographic information: For example, your age, gender, postal code and language preferences. We may also collect other information you provide, such as your consent, preferences and feedback, information relating to our products and other such information you provide us with. Please note that certain non-identifiable information collected from you may become

personally identifiable when you provide us with your personal data.  If you are buying a present and sending in the recipient, then we will be collecting their name and address.

 

Your transactions with us: We collect or ask for information relating to your purchase and/or use of our products and your other communications with us. Such information may include, for example, details of the queries or requests you have made, the products paid for  (including delivery details), financial details (including payments made, credit card details, billing address, credit checks and other such financial information), details of agreements between you and us, records of

contacts and communications, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance within applicable law, record your communication with our customer care or with other such contact points. Certain services may involve the use of your location data. However, use of your location data for such services is subject to your consent.

 

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data).

 

Our products are not intended for children and we do not knowingly collect data relating to children.

 

Uses made of the information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

 

  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or those of a third party,  i.e. PayPal or Epos payment systems – you will have to read through their Privacy Policy and your interests and fundamental rights do not override those interests.
  •  Where we need to comply with a legal or regulatory obligation.
  • Where you have given consent to the processing of your personal data for one or more specific purposes.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us via our nominated DPO – contact information:  ajay@mobilise-group.com

 

Under this Policy the following terms are defined as below.

 

Lawful basis:

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities

by contacting us using the contact details provided.

 

“Performance of Contract” means processing your data where it is necessary for the performance of our products to which you have requested to buy or more information.

 

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

“Consent” means where you have given consent through a statement or a clear affirmative action to the processing of your personal data for one or more specific purposes.

 

Purpose/Activity Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer and fulfil your order including but not limited to:

  • Network activations (where applicable)
  • Identity verification
  • Storage of data with logistics partners to aide with customer service queries.
  • Performance of a contract with you – To process and deliver your order including:
  • Manage payments, fees and charges
  • Collect and recover money owed to us
  • To ensure the functionality and security of our products and to identify you and to prevent and investigate fraud and other misuses

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us via email to our DPO – ajay@mobilise-group.com

 

Under this Policy the following terms are defined as below.

 

Lawful basis:

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us emailing our nominated DPO – ajay@mobilise-group.com

 

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

“Consent” means where you have given consent through a statement or a clear affirmative action to the processing of your personal data for one or more specific purposes.

 

Purpose/Activity Lawful basis for processing including basis of legitimate interest

To register you as a new customer and fulfil your order including but not limited to:

  • Network activations and credit searching (where applicable)
  • Identity verification
  • Storage of data with logistics partners to aide with customer service queries.

 

Performance of a contract with you to process and deliver your order including:

  • Manage payments, fees and charges
  • Collect and recover money owed to us
  • To ensure the functionality and security of our products, to identify you and to prevent and investigate fraud and other misuses
  • Necessary for our legitimate interests (to recover debts due to us, to carry out fraud prevention checks, to provide secure services to you)

 

To manage our relationship with you which will include?

 

  • Notifying you about important changes to our terms or privacy policy
  • Asking you to leave a review or take a survey or provide service feedback
  • via third parties
  • Corresponding with you to provide service updates.
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products)

 

To enable you to partake in a prize draw or competition.

  • Consent
  • If you have purchased products from us and you have not opted out of receiving our marketing literature.

 

To send to you information via newsletters and marketing information about offers on our products that we feel would be of interest to you, including but not limited to information about sales and products.

 

  • Consent
  • If you have purchased products from us and you have not opted out of receiving our  marketing literature.

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation
  • To personalise our offering deliver relevant website content and information, products we feel may interest you, and measure or understand the effectiveness of the information we provide to you via the use of cookies
  • Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy)
  • To use data analytics to improve our website, products, marketing, customer relationships and experiences
  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

Marketing and promotional offers from us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing). We may therefore contact you from time to time in relation to products which may be of interest to you or provide you with information through newsletters and collect information from you via surveys, feedback and competitions.

 

You will receive marketing communications from us if you have provided us with consent or you have requested information from us or purchased products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

Some of our products may be used to promote products and services of other companies. We do not disclose information about identifiable individuals to our advertisers or any other company, for marketing purposes without your prior consent.

 

Third party marketing

  • We will get your consent before we share your personal data with any company outside our group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible

with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

If you fail to provide personal data

Where we need to collect personal data by law, and you fail to provide that data when requested, we

may not be able supply the product.  In this case, we may have to cancel a product you have purchased from us but we will notify you if this is the case at the time.

 

Disclosure of your information

 

  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Mobilise Group Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes (unless we have collected consent from you on their behalf) and only permit them

to process your personal data for specified purposes and in accordance with our instructions.

 

IP addresses

We may collect information about your computer, including where available your Internet protocol (IP) address, operating system and

browser type, for system administration. This is statistical data about our users’

browsing actions and patterns and does not identify any individual.

 

Data Quality

 

We take steps to keep the personal data we possess accurate and up-to-date and to delete out of date or otherwise incorrect or unnecessary personal data.

 

As certain products may allow you to manage your profile, we encourage you to access your personal data from time to time to ensure that it is correct and up-to-date. Please remember that it is your responsibility to provide us with correct details as well as to update the personal data you have provided us with in case of any changes.

 

Security

 

While there are always risks associated with providing personal data, whether in person, by phone, via the internet or otherwise, and no technology is completely safe or “tamper” or “hacker” proof, we take appropriate technical and organisational information security measures to

prevent and minimise such risks.

 

Such measures include, where appropriate, the use of firewalls, secure server facilities, encryption, implementing proper access rights management systems and processes, careful selection of processors and other technically and commercially reasonable measures to provide

appropriate protection for your personal data against unauthorised use or disclosure.

 

Where appropriate, we may also take back-up copies and use other such means to prevent accidental damage or destruction to your personal data.

 

If a particular part of our site supports online transactions, all information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using an industry standard security measure, such as Paypal to protect the confidentiality and security of online transactions.

 

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

In addition, we limit access to your personal data to those employees and other third parties who have a business need to know.

 

They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data Retention

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

Your rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

 

You have the right to:

 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

 

Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

If you wish to exercise any of the rights set out above, please contact us using the contact details provided for our DPO.

 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products to you. We will advise you if this is the case at the time you withdraw your consent.

 

Fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to

receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please

contact us in the first instance.

 

 

Changes to our privacy policy

We may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice.

 

Any changes we may make to this Policy in the future will be posted on this page. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.

 

 

Signed:   Qayes Nori

Managing Director

 

June 2019