Privacy Policy - Mobibox

Mobibox Privacy Policy

Last Modified on: 29/11/2023

Data protection is of a particularly high priority for the management of MobiBox. The use of the Internet pages of MobiBox is possible without any indication of personal data. However, if a data subject wants to use specific parts of our service via our website, processing of personal data could become necessary. If processing personal data is necessary and if there is no legal basis for such processing, we will generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, and e-mail address of a data subject shall always be in line with the country-specific data protection regulations applicable to MobiBox. By means of this privacy policy, we would like to inform the public about the type, scope, and purpose of personal data we collect, use, and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.

As the controller, MobiBox has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions may be subject to security vulnerabilities, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Name and address of the data controller

The controller within the meaning of the General Data Protection Regulation and other provisions of a data protection nature is:
MobiBox Technologies – FZCO,
Dubai Digital Park – Office A5-Dtec, DSO-DDP-A5-D-FLEX-G027,
Dubai Silicon Oasis, Dubai, United Arab Emirates
E-mail: sales@MobiBox.mobi
Website: https://myMobiBox.mobi https://MobiBox.mobi

2. Collection of general data and information

The website of MobiBox collects a series of general data and information every time a data subject or automated system calls up the website. This general data and information is stored in the log files of the server. The following data may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (the so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using this general data and information, MobiBox does not draw any conclusions about the data subject. Rather, this information is needed (1) to deliver the contents of our website correctly, (2) to optimize the contents of our website and the advertising for these, (3) to ensure the long-term functionality of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. Therefore, MobiBox analyses anonymously collected data and information on one hand for statistical purposes and on the other hand for the purpose of increasing data protection and data security of our enterprise, and ultimately to ensure an optimal level of protection for personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.

3. Contact possibilities via the website

MobiBox offers various means of electronic contact via Contact and Enquiry Forms, as well as direct communication with us, which also includes e-mail. If a data subject contacts us by e-mail or by using a contact form, the personal data transmitted by the data subject will be stored automatically. Such personal data transmitted on a voluntary basis by a data subject to us will be stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

4. MobiBox Signup Account

If you register for a MobiBox Signup Account, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form for the purposes stated below. The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this storage is the provision of a contract according to Art. 6 para. 1 lit. b GDPR. Your data will remain stored for as long as the registration lasts, in particular, the storage is still necessary for the fulfillment/execution of the referral contract, for legal prosecution by us or for our other legitimate interests or we are required by law to retain your data (e.g., within the framework of tax retention periods).

5. Commercial and business services

We process data of our contractual and business partners, e.g., customers and interested parties in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g., to answer inquiries.

We process this data to fulfill our contractual obligations, to secure our rights, and for the purposes of the administrative tasks associated with this information as well as for the business organization. We only disclose data of the contractual partners to third parties within the scope of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the contractual partners (e.g., to participating telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers or tax authorities).

Unless otherwise specified the purposes of processing are Contractual performance and service, contact requests and communication, office and organizational procedures, administration, and response to requests, visit action evaluation, and interest-based and behavioral marketing. And, the Legal bases are Contractual performance and pre-contractual inquiries, Legal obligation, and our Legitimate interests.

6. Technical services

We process the data of our customers in order to enable them to select, purchase, or commission the selected services or works. The required information is identified as such in the context of the order, purchase order, or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information.

7. Administration, financial accounting, office organization, and contact management

We process data in the context of administrative tasks as well as the organization of our operations, financial accounting, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lie in the administration, financial accounting, office organization, and archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks, and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.

In this context, we disclose or transfer data to consultants, such as legal advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, event organizers, and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.

8. Social Media Functions and Widgets

Within our online offer, the functions and widgets of the social media platforms are integrated with MobiBox. When you click on or use any of those functions and widgets, your browser establishes a direct connection to the relevant social media platform. The function or widget then transmits log data to the relevant platform provider. This log data may contain your IP address, the address of the visited websites, the type and settings of the browser, the date and time of the request, and your usage of the relevant platform provider, as well as cookies. Those may also include the display of our post, the link to our profile, the possibility to interact with the posts and functions, as well as to measure users’ reach (so-called conversion measurement).

9. Routine deletion and blocking of personal data

We process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage or were provided for by applicable legislation and statutory retention periods. If the storage purpose ceases to apply or if a storage period prescribed expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

10. Rights of the data subject

a) Right to confirmation

Every data subject has the right to obtain confirmation from us as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact any employee of MobiBox.

b) Right of access

Any person concerned by the processing of personal data has to obtain at any time from MobiBox, free of charge, information about the personal data stored about him or her and a copy of that information. In addition, the European Directive and Regulation Body has granted the data subject access to the following information:

the purposes of the processing,
the categories of personal data processed,
the recipients or categories of recipients to whom personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations,
if possible, the planned duration for which personal data will be stored or, if this is not possible, the criteria for determining this duration,
the existence of the right to obtain the rectification or erasure of personal data concerning him or her, or the restriction of processing by MobiBox, or the right to object to such processing,
the existence of a right of appeal to a supervisory authority,
if personal data are not collected from the data subject: Any available information on the origin of the data, and
the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

Furthermore, the data subject shall have the right to obtain information as to whether the personal data have been transferred to a third country or an international organization. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in relation to the transfer.

If a data subject wishes to exercise this right of access, he or she may contact an employee of MobiBox at any time.

c) Right of rectification

Any person affected by the processing of personal data has the right to request the immediate rectification of any inaccurate personal data concerning him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, considering the purposes of the processing.

If a data subject wishes to exercise this right of rectification, he or she may, at any time, contact any employee of MobiBox.

d) Right to erasure (right to be forgotten)

Any person concerned by the processing of personal data has the right to obtain from us the erasure without delay of personal data concerning him or her, where one of the following grounds applies and insofar as the processing is not necessary.

personal data were collected or otherwise processed for such purposes for which they are no longer necessary.
the data subject revokes the consent on which the processing was based pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9(2)(a) GDPR and there is no other legal basis for the processing.
the data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
personal data have been processed unlawfully.
the erasure of personal data is necessary for compliance with a legal obligation to which we are subject to.
personal data have been collected in relation to information society services offered pursuant to Art. 8(1) GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to arrange for the deletion of personal data stored by MobiBox, he or she may, at any time, contact any employee of MobiBox. The employee of MobiBox will arrange for the deletion request to be complied with immediately.

If personal data has been made public by MobiBox and our company is responsible pursuant to Art. 17 Para. 1 GDPR to erase personal data, MobiBox shall implement reasonable measures, including technical measures, taking into account the available technology and the cost of implementation, in order to inform other data controllers which, process the published personal data that the data subject has requested from those other data controllers to erase all links to or copies or replications of personal data unless the processing is necessary. The employee of MobiBox will arrange the necessary in individual cases.

e) Right to restriction of processing

Any person affected by the processing of personal data has the right, -maker, to request us to restrict the processing if one of the following conditions is met:

The accuracy of personal data is contested by the data subject for a period enabling us to verify the accuracy of personal data.
The processing is unlawful, the data subject objects to the erasure of personal data and requests instead the restriction of the use of personal data.
We no longer need personal data for the purposes of the processing, but the data subject needs it for the assertion, exercise, or defense of legal claims.
The data subject has objected to the processing pursuant to Article 21(1) of the GDPR, and it is not yet clear whether the legitimate grounds override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by MobiBox, he or she may, at any time, contact any employee of MobiBox. The employee of MobiBox will arrange the restriction of the processing.

f) Right to data portability

Every person affected by the processing of personal data has the right to receive the personal data concerning him or her which has been provided by the data subject to a controller in a structured, commonly used and machine-readable format. The data subject shall also have the right to transmit such data to another controller without hindrance from us to whom the personal data have been provided, provided that the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and the processing is carried out by automated means unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in MobiBox.

Furthermore, when exercising the right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to obtain the direct transfer of personal data from one controller to another controller where technically feasible and provided that this does not adversely affect the rights and freedoms of other persons.

In order to assert the right to data portability, the data subject may at any time contact any employee of MobiBox.

g) Right of objection

Any person affected by the processing of personal data has the right-maker to object at any time, on grounds relating to his or her particular situation, to the processing of the personal data concerning him or her which is carried out on the basis of Art. 6 para. 1 lit. e and f GDPR. This also applies to profiling based on these provisions.

MobiBox shall no longer process personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the assertion, exercise, or defense of legal claims.

If MobiBox processes personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to the processing of personal data processed for such marketing. This also applies to profiling, insofar as it is related to such direct marketing. If the data subject objects to MobiBox processing for direct marketing purposes, MobiBox will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of the personal data concerning him or her which is carried out by MobiBox for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

In order to exercise the right to object, the data subject may directly contact any employee of MobiBox or another employee. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise his or her right to object by means of automated procedures using technical specifications.

h) Automated decisions in individual cases, including profiling

Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, provided that the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and MobiBox, or (2) is authorized by law. And that such law lays down appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is made with the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or (2) it is made with the data subject’s explicit consent, MobiBox shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain the data subject’s involvement on the part of MobiBox, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise the rights concerning automated decisions, he or she may, at any time, contact any employee of MobiBox.

i) Right to withdraw consent under the data protection law

Any person affected by the processing of personal data has the right to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact any employee of MobiBox.

Legal basis of processing

Art. 6 para. 1 lit. a GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 para. 1 lit. b GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in the case of inquiries about our products or services. If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 para. 1 lit. c GDPR. In rare cases, the processing of personal data might become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance details, or other vital information had to be passed on to a doctor, hospital, or other third parties. Then the processing would be based on Art. 6 I lit. d GDPR. Finally, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of MobiBox (recital 47, sentence 2 of the GDPR).

11. Legitimate interests in the processing pursued by us or a third party

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.

12. Duration for which the personal data are stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiry of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfillment of the contract or the initiation of the contract.

Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We inform you that the provision of personal data is sometimes required by law (e.g., tax regulations) or may also result from contractual regulations (e.g., information on the contractual partner). Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Before providing personal data by the data subject, the data subject must contact one of our employees. Our employee will explain to the data subject on a case-by-case basis whether the provision of the personal data is required by law or by contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.

13. Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

14. When do we disclose your Personal Data?

We may share your information with organizations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support our online offer and our services.

Typically, and unless otherwise stated in this policy, data may be shared on the basis of our contractual and pre-contractual obligations, in accordance with Art. 6 para. 1 lit. b GDPR. Equally, if you have consented to it, or where there we have a legal obligation to do so or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing, and similar services that allow us to perform our contractual obligations, administrative tasks and duties efficiently and effectively).

If we commission third parties to process data on the basis of a so-called “processing agreement”, this is done on the basis of Art. 28 GDPR.

In relation to metadata obtained about you, we may share a cookie identifier and IP data with analytic service providers to assist us in the improvement and optimization of our website which is subject to our Cookies Policy.

We may also disclose information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation, or regulatory authority asks us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our rights, property, or personal safety of our staff, the website, and its users.

15. Integration Of Services and Contents of Third Parties

We use within our online offer on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR), content or services offered by third-party providers in order to integrate their content and services.

This always requires that the third-party providers of this content are aware of your IP address since the content or service could not send to your browser without the IP address. The IP address is thus required for the display of this content, and we endeavor to use providers that only use your IP address for the delivery of the content or services. However, Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of the visit and other information about the use of our online offer, as well as be linked to such information from other sources.

16. Google reCAPTCHA

We use “Google reCAPTCHA” on our websites. The provider is Google Inc. The purpose of reCAPTCHA is to check whether the data input on our websites is made by a human being or by an automated program, and reCAPTCHA also protects our users from SPAM when using the message function. For this purpose, reCAPTCHA analyses the behavior of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g., IP address, time spent by the website visitor on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run entirely in the background. Website visitors are not informed that an analysis is taking place. We have a legitimate interest in protecting our offers from abusive automated spying and our users from SPAM.

17. Children Data

Our website is not intended for children, and we do not knowingly collect data relating to children. If you become aware that your Child has provided us with Personal Data, without parental consent, please contact us and we take the necessary steps to remove that information from our server.

18. International transfers

Your personal information is generally processed, stored and used in the global data centers of Amazon (AWS). We take steps to ensure there is an appropriate level of security, so your personal information is protected in the same way as if it was being used within the EU and the EEA.

Where we need to transfer your data outside the EU and the EEA, we will use one of the following safeguards:

The use of approved standard contractual clauses in contracts for the transfer of personal data to third countries.
Transfers to a non-EEA country with privacy laws that give the same protection as the EEA.

19. Google Analytics

We use Google Analytics, a service provided by Google Inc. This means that the data collected can in principle be transmitted to a Google server in the USA, whereby the IP addresses are anonymized by means of IP anonymization so that an allocation is not possible. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can object to the collection and processing of this data by Google Analytics by setting an opt-out cookie that prevents the future collection of your data when you visit this website: http://tools.google.com/dlpage/gaoptout?hl=en.

20. Changes

This policy and our commitment to protecting the privacy of your personal data can result in changes to this policy. Please regularly review this policy to keep up to date with any changes.

21. Queries and Complaints

Any comments or queries on this policy should be directed to us at sales@mobibox.mobi. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.