We provide economic infrastructure for the internet. Businesses of all sizes use our software and services to accept payments and manage their businesses online. Mobile Credits cares about the security and privacy of the personal data that is entrusted to us.
“Personal Data” means any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP address).
“Services” means the products and services that Mobile Credits indicates are covered by this Policy, which may include Mobile Credits-provided devices and apps. Our “Business Services” are Services provided by Mobile Credits to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. Our “End User Services” are those Services which Mobile Credits directs to individuals (rather than entities) so that those individuals do business directly with Mobile Credits. “Sites” means Mobile Credits.com and the other websites that Mobile Credits indicates are covered by this Policy. Collectively, we refer to Sites, Business Services and End User Services as “Services”.
Depending on the context, “you” means End Customer, End User, Representative or Visitor:
- When you directly use an End User Service (such as when you sign up for Link, or make a payment to Mobile Credits Climate in your personal capacity), for your personal use, we refer to you as an “End User.”
- When you do business with, or otherwise transact with, a Business User (typically a merchant using Mobile Credits Checkout, e.g. when you buy a pair of shoes from a merchant that uses Mobile Credits for payment processing) but are not directly doing business with Mobile Credits, we refer to you as an “End Customer.”
- When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for a merchant who is a Business User), we refer to you as a “Representative.”
- When you visit a Site without being logged into a Mobile Credits account or otherwise communicate with Mobile Credits, we refer to you as a “Visitor.” (e.g. you send Mobile Credits a message asking for more information because you are considering being a user of our products).
Depending on the activity, Mobile Credits acts as a “data controller” or “data processor” and for more information about this and on the Mobile Credits entity that is responsible under this Policy, see below.
- 1. Personal data that we collect and how we use and share it
- 2. More ways we collect, use and share personal data
- 3. Legal bases for processing data
- 4. Your rights and choices
- 5. Security and retention
- 6. International data transfers
- 7. Updates and notifications
- 8. Jurisdiction-specific provisions
- 9. Contact us
3. Legal bases for processing data
For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data.
a. Contractual and Pre-Contractual Business Relationships. We process Personal Data for the purpose of entering into business relationships with prospective Business Users and End Users and to perform the respective contractual obligations that we have with these Users. Activities include:
- Creation and management of Mobile Credits accounts and Mobile Credits account credentials, including the evaluation of applications to commence or expand the use of our Services;
- Creation and management of Mobile Credits Checkout accounts;
- Accounting, auditing, and billing activities; and
- Processing of payments, including fraud detection and prevention, optimizing valid transactions, communications regarding such payments, and related customer service.
b. Legal Compliance. We process Personal Data to verify the identity of our Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as “Anti-Money Laundering (“AML”) and Know-Your-Customer (“KYC”)” obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.
c. Legitimate Business Interests. Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes for which we have a legitimate interest in processing your data:
- Detect, monitor and prevent fraud and unauthorized payment transactions;
- Mitigate financial loss, claims, liabilities or other harm to End Customers, End Users, Business Users and Mobile Credits;
- Determine eligibility for and offer new Mobile Credits products and services;
- Respond to enquiries, send Service notices and provide customer support;
- Promote, analyze, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services;
- Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
- Analyze and advertise our Services;
- Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
- Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business.
- Enable network and information security throughout Mobile Credits and our Services; and
- Share Personal Data among our affiliates.
d. Consent. We may rely on consent to collect and process Personal Data as it relates to how we communicate with you and for the provision of our Services like Link, Atlas and Identity. When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.
4. Your rights and choices
You may have choices regarding our collection, use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us
If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, our Business Users may still send you messages and direct us to send you messages on their behalf.
b. Your data protection rights
Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
- The right to request confirmation of whether Mobile Credits processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
- The right to request that Mobile Credits rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
- The right to request that Mobile Credits erase your Personal Data in certain circumstances provided by law;
- The right to request that Mobile Credits restrict the use of your Personal Data in certain circumstances, such as while Mobile Credits considers another request that you have submitted (including a request that Mobile Credits make an update to your Personal Data);
- The right to request that we export your Personal Data that we hold to another company, where technically feasible;
- Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or
- Where we process your information based on our legitimate interests, you may also have the right to object to the processing of your Personal Data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
c. Process for exercising your data protection rights
To exercise your data protection rights please also see the Mobile Credits Privacy Center or contact us as described below.
5. Security and retention
We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
To help us protect personal data, we encourage you to use a strong password and never share your password with anyone or use the same password with other sites or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your account has been compromised), please contact us immediately.
We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your Mobile Credits account or complete a transaction with a Business User, we retain your Personal Data in order to comply with our legal and regulatory obligations. We may also retain it to allow for fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
6. International data transfers
We are a global business. Personal Data may be stored and processed in any country where we do business, where our service providers do business or if you use an international payment method or financial partner service, the countries in which that payment method or financial partner operates. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from Officials (such as law enforcement or security authorities).
If you are located in the European Economic Area (“EEA”), the “United Kingdom (“UK”)” or Switzerland, please see Mobile Credits Privacy Center for more information. Where applicable law requires a data transfer mechanism, we use one or more of the following: EU Standard Contractual Clauses with a data recipient outside the EEA, Switzerland or the UK, verification that the recipient has implemented Binding Corporate Rules, or other legal methods available to us under applicable law. For transfers to third countries we have entered into Standard Contractual Clauses, approved by the European Commission, to ensure an adequate level of protection for the transfer of your Personal Data to those entities outside the EEA. You can obtain a copy of the relevant Standard Contractual Clauses.
While Mobile Credits Inc. remains self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, it is not currently relying on these frameworks for the transfer of personal data to the U.S. For more information, please see Mobile Credits Privacy Center.
7. Updates and notifications
We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Services.
We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Business User, by contacting you through your Mobile Credits Dashboard, email address and/or the physical address listed in your Mobile Credits account.
If applicable law requires that we provide notice in a specified manner prior to making any changes to this Policy applicable to you, we will provide such required notice.
8. Jurisdiction-specific provisions
- Australia. If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Policy, you may wish to contact the Office of the Australian Information Commissioner.
- EEA and UK. To exercise your rights, you may contact our payment provider DPO. If you are a resident of the EEA or we have identified Mobile Credits Payments Europe Limited as your data controller, and believe we process your information within the scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Irish Data Protection Commission. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. Where Personal Data is used for regulated financial activities in Europe, Mobile Credits Payments Europe Limited and Mobile Credits local regulated entities (defined as those who are licensed, authorized or registered by a Local Regulatory Authority) are considered joint controllers.
- Indonesia. As used in this Policy, “applicable law” includes Law No. 11 of 2008 as amended by Law No. 19 of 2016 on Electronic Information and Transactions, Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions, and Minister of Communication and Informatics Regulation No. 20 of 2016 on Personal Data Protection in Electronic Systems and “Personal Data” includes “personal data” as defined under such laws.
- Malaysia. If you have any questions or complaints about this Policy, please contact our DPO.
- Thailand. Thailand residents may have additional rights under applicable laws. If we process your Personal Data due to a legal obligation or contractual right, and you do not provide us with personal Information, we may not be able to lawfully provide you services.
- United States – California. If you are a consumer located in California, we process your personal information in accordance with the California Consumer Privacy Act (“CCPA”). You have a right to receive notice of our practices at or before collection of personal information. This section provides additional details about the personal information we collect and use for purposes of CCPA.
- Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:
- Exercising the right to know: you may request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about categories of their personal information collected, sold, or disclosed; purposes for which this personal information was collected or sold; categories of sources of personal information; and categories of third parties with whom we disclosed this personal information.
- Exercising the right to delete: you may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
- Exercising the right to opt-out from a sale: We do not sell Personal Data as defined by the CCPA and have not done so in the past 12 months.
- Non-discrimination: The CCPA provides that you may not be discriminated against for exercising these rights.
- To submit a request to exercise any of the rights described above, please contact us using the methods described in the Contact Us section below. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
- Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.
- An authorized agent may submit a request on your behalf by contacting us using the methods described in the Contact Us section below. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.
9. Contact us