Privacy Policy
Thank you for choosing to be part of our community at OneMobile/OneLoyalty, doing business as
OneMobile/OneLoyalty (“OneMobile”, OneLoyalty”,“we”, “us”, “our”). We are committed to protecting
your personal
information and your right to privacy. If you have any questions or concerns about this privacy
notice, or our
practices with regards to your personal information, please contact us at
[email protected]
When you visit our website https://onemobile.ai/ (the “Website”), and more generally, use any of our
services
(the “Services”, which include the Website), we appreciate that you are trusting us with your
personal
information. We take your privacy very seriously. In this privacy notice, we seek to explain to you
in the
clearest way possible what information we collect, how we use it and what rights you have in
relation to it. We
hope you take some time to read through it carefully, as it is important. If there are any terms in
this privacy
notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described
above,
includes our Website), as well as, any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the
information that
we collect.
1. What Information Do We Collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to
us.
We collect personal information that you voluntarily provide to us when you register on
the Website,
express an interest in obtaining information about us or our products and Services, when
you participate
in activities on the Website (such as by posting messages in our online forums or
entering competitions,
contests or giveaways) or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions
with us and the
Website, the choices you make and the products and features you use. The personal
information we collect
may include the following:
Personal Information Provided by You. We collect names; email
addresses; phone numbers;
and other similar information.
Social Media Login Data. We may provide you with the option to register
using your social
media account details, like your Facebook, Twitter or other social media accounts. If
you choose to
register in this way, we will collect the information described in the section called
"HOW DO WE HANDLE
YOUR SOCIAL LOGINS" below.
All personal information that you provide to us must be true, complete and accurate, and
you must notify
us of any changes to such information.
Information automatically collected
In Short: Some information — such as your Internet Protocol
(IP) address and/or browser and device
characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the
Website. This information
does not reveal your specific identity (like your name or contact information) but may
include device and
usage information, such as your IP address, browser and device characteristics,
operating system, language
preferences, referring URLs, device name, country, location, information about how and
when you use our
Website and other technical information. This information is primarily needed to
maintain the security and
operation of our Website, and for our internal analytics and reporting purposes.
The information we collect includes:
– Log and Usage Data. Log and usage data is service-related,
diagnostic, usage and
performance information our servers automatically collect when you access or use our
Website and which we
record in log files. Depending on how you interact with us, this log data may include
your IP address,
device information, browser type and settings and information about your activities in
the Website (such
as the date/time stamps associated with your usage, pages and files viewed, searches and
other actions you
take such as which features you use), device event information (such as system activity,
error reports
(sometimes called 'crash dumps') and hardware settings).
– Device Data. We collect device data such as information about
your computer,
phone, tablet or other device you use to access the Website. Depending on the device
used, this device
data may include information such as your IP address (or proxy server), device and
application
identification numbers, location, browser type, hardware mode, Internet service provider
and/or mobile
carrier, operating system and system configuration information.
– Location Data. We collect location data such as information
about your device's
location, which can be either precise or imprecise. How much information we collect
depends on the type
and settings of the device you use to access the Website. For example, we may use GPS
and other
technologies to collect geolocation data that tells us your current location (based on
your IP address).
You can opt out of allowing us to collect this information either by refusing access to
the information or
by disabling the Location setting on your device. However, if you choose to opt out, you
may not be able
to use certain aspects of the Services.
2. How Do We Use Your Information?
In Short: We process your information for purposes based on
legitimate business interests, the fulfillment of our
contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of business purposes
described below.
We process your personal information for these purposes in reliance on our legitimate
business interests,
in order to enter into or perform a contract with you, with your consent, and/or for
compliance with our
legal obligations. We indicate the specific processing grounds we rely on next to each
purpose listed
below.
We use the information we collect or receive:
– To facilitate account creation and logon process. If you choose
to link your
account with us to a third-party account (such as your Google or Facebook account), we
use the information
you allowed us to collect from those third parties to facilitate account creation and
logon process for
the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR
SOCIAL LOGINS" for
further information.
– To post testimonials. We post testimonials on our Website that
may contain
personal information. Prior to posting a testimonial, we will obtain your consent to use
your name and the
content of the testimonial. If you wish to update, or delete your testimonial, please
contact us at
[email protected] and be sure to include your name, testimonial location, and
contact information.
– Request feedback. We may use your information to request
feedback and to contact
you about your use of our Website.
– To enable user-to-user communications. We may use your
information in order to
enable user-to-user communications with each user's consent.
– To manage user accounts. We may use your information for the
purposes of managing
our account and keeping it in working order.
3. Will Your Information Be Shared With Anyone?
In Short: We only share information with your consent, to
comply with laws, to provide you with services, to
protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal
basis:
– Consent: We may process your data if you have given
us specific
consent to use your personal information for a specific purpose.
– Legitimate Interests: We may process your data when
it is reasonably
necessary to achieve our legitimate business interests.
– Performance of a Contract: Where we have entered
into a contract with
you, we may process your personal information to fulfill the terms of our contract.
– Legal Obligations: We may disclose your information
where we are
legally required to do so in order to comply with applicable law, governmental requests,
a judicial
proceeding, court order, or legal process, such as in response to a court order or a
subpoena (including
in response to public authorities to meet national security or law enforcement
requirements).
– Vital Interests: We may disclose your information
where we believe it
is necessary to investigate, prevent, or take action regarding potential violations of
our policies,
suspected fraud, situations involving potential threats to the safety of any person and
illegal
activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal
information in the
following situations:
– Business Transfers. We may share or transfer your
information in
connection with, or during negotiations of, any merger, sale of company assets,
financing, or acquisition
of all or a portion of our business to another company.
– Vendors, Consultants and Other Third-Party Service
Providers. We may
share your data with third-party vendors, service providers, contractors or agents who
perform services
for us or on our behalf and require access to such information to do that work. Examples
include: payment
processing, data analysis, email delivery, hosting services, customer service and
marketing efforts. We
may allow selected third parties to use tracking technology on the Website, which will
enable them to
collect data on our behalf about how you interact with our Website over time. This
information may be used
to, among other things, analyze and track data, determine the popularity of certain
content, pages or
features, and better understand online activity. Unless described in this notice, we do
not share, sell,
rent or trade any of your information with third parties for their promotional purposes.
We have contracts
in place with our data processors, which are designed to help safeguard your personal
information. This
means that they cannot do anything with your personal information unless we have
instructed them to do it.
They will also not share your personal information with any organization apart from us.
They also commit
to protect the data they hold on our behalf and to retain it for the period we instruct.
– Other Users. When you share personal information
(for example, by
posting comments, contributions or other content to the Website) or otherwise interact
with public areas
of the Website, such personal information may be viewed by all users and may be publicly
made available
outside the Website in perpetuity. If you interact with other users of our Website and
register for our
Website through a social network (such as Facebook), your contacts on the social network
will see your
name, profile photo, and descriptions of your activity. Similarly, other users will be
able to view
descriptions of your activity, communicate with you within our Website, and view your
profile.
4. Who Will Your Information Be Shared With?
In Short: We only share information with the following
third parties.
We only share and disclose your information
with the following third parties. We have
categorized each party so that you may easily understand the purpose of our data
collection and processing
practices. If we have processed your data based on your consent and you wish to revoke
your consent,
please contact us using the contact details provided in the section below titled “HOW
CAN YOU CONTACT US
ABOUT THIS NOTICE?”.
–
Advertising, Direct Marketing, and Lead Generation: Google AdSense and
Facebook Audience
Network
– Allow Users to Connect to Their Third-Party Accounts:
Facebook account
– Cloud Computing Services:
Amazon Web Services (AWS)
– Communicate and Chat with Users:
Crisp
– Content Optimization: Google Fonts
–
Data Backup and Security: Amazon Glacier
– Retargeting
Platforms: Facebook Remarketing and Google Ads Remarketing
–
User Account Registration and Authentication:
Google OAuth 2.0 and Facebook Login
– User Commenting and Forums:
Facebook
Comments
– Web and Mobile Analytics: Google Analytics and Google
Tag Manager
– Website Performance Monitoring:
Sentry
5. How Do We Handle Your Social Logins?
In Short: If you choose to register or log in to our services
using a social media account, we may have access to
certain information about you.
Our Website offers you the ability to
register and login using your third-party social media
account details (like your Facebook or Twitter logins). Where you choose to do this, we
will receive
certain profile information about you from your social media provider. The profile
information we receive
may vary depending on the social media provider concerned, but will often include your
name, email
address, friends list, profile picture as well as other information you choose to make
public on such
social media platforms.
We will use the information we receive only for the
purposes that are
described in this privacy notice or that are otherwise made clear to you on the relevant
Website. Please
note that we do not control, and are not responsible for, other uses of your personal
information by your
third-party social media provider. We recommend that you review their privacy notice to
understand how
they collect, use and share your personal information, and how you can set your privacy
preferences on
their sites and apps.
6. How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to
fulfill the purposes outlined in this privacy
notice unless otherwise required by law.
We will only keep your
personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as
tax, accounting or other legal requirements). No purpose in this notice will require us
to keep your
personal information for longer than the period of time in which users have an account
with us.
When
we have no ongoing legitimate business need to process your personal information, we
will either delete or
anonymize such information, or, if this is not possible (for example, because your
personal information
has been stored in backup archives), then we will securely store your personal
information.
7. Do We Keep Your Information Safe?
In Short: We aim to protect your personal information
through a system of organizational and technical security
measures.
We have implemented appropriate technical and
organizational security measures designed to
protect the security of any personal information we process. However, despite our
safeguards and efforts
to secure your information, no electronic transmission over the Internet or information
storage technology
can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or
other unauthorized third parties will not be able to defeat our security, and improperly
collect, access,
steal, or modify your information. Although we will do our best to protect your personal
information,
transmission of personal information to and from our Website is at your own risk. You
should only access
the Website within a secure environment.
8. Do We Collect Information From Minors?
In Short: We do not knowingly collect data from or market to
children under 18 years of age.
We do not knowingly solicit data
from or market to children under 18 years of age. By using
the Website, you represent that you are at least 18 or that you are the parent or
guardian of such a minor
and consent to such minor dependent’s use of the Website. If we learn that personal
information from users
less than 18 years of age has been collected, we will deactivate the account and take
reasonable measures
to promptly delete such data from our records. If you become aware of any data we may
have collected from
children under age 18, please contact us at
[email protected].
9. What Are Your Privacy Rights?
In Short: We do not knowingly collect data from or market to
children under 18 years of age.In some regions, such
as the European Economic Area, you have rights that allow you greater access to and
control over your
personal information. You may review, change, or terminate your account at any
time.
In some regions (like the European Economic Area), you have
certain rights under applicable
data protection laws. These may include the right (i) to request access and obtain a
copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict the processing
of your personal
information; and (iv) if applicable, to data portability. In certain circumstances, you
may also have the
right to object to the processing of your personal information. To make such a request,
please use the
contact details provided below. We will consider and act upon any request in accordance
with applicable
data protection laws.
If we are relying on your consent to process your
personal information,
you have the right to withdraw your consent at any time. However, please note that this
will not affect
the lawfulness of the processing before its withdrawal, nor will it affect the
processing of your personal
information conducted in reliance on lawful processing grounds other than
consent.
If you are a
resident in the European Economic Area and you believe we are unlawfully processing your
personal
information, you also have the right to complain to your local data protection
supervisory authority. You
can find their contact details here: If you are a resident in the European Economic Area
and you believe
we are unlawfully processing your personal information, you also have the right to
complain to your local
data protection supervisory authority. You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If
you are a resident in Switzerland, the contact details for the data protection
authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
If
you have questions or comments about your privacy rights, you may email us at
[email protected].
Account
Information
If you would like to review or change the
information in your account or terminate your account at any time, you can contact us
using the contact
information provided.
Upon your request to terminate your account, we will
deactivate or
delete your account and information from our active databases. However, we may retain
some information in
our files to prevent fraud, troubleshoot problems, assist with any investigations,
enforce our Terms of
Use and/or comply with applicable legal requirements.
Opting out of
email marketing
You can unsubscribe from our marketing email list at
any time by clicking on the unsubscribe link
in the emails that we send or by contacting us using the details provided below. You
will then be removed
from the marketing email list — however, we may still communicate with you, for example
to send you
service-related emails that are necessary for the administration and use of your
account, to respond to
service requests, or for other non-marketing purposes. To otherwise opt-out, you may
contact us using the
contact information provided.
10. Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted and that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. Do California Residents Have Specific Privacy Rights?
In Short: Yes, if you are a resident of California, you
are granted specific rights regarding access to your
personal information.
California Civil Code Section 1798.83,
also known as the “Shine The Light” law, permits our
users who are California residents to request and obtain from us, once a year and
free of charge,
information about categories of personal information (if any) we disclosed to third
parties for direct
marketing purposes and the names and addresses of all third parties with which we
shared personal
information in the immediately preceding calendar year. If you are a California
resident and would like
to make such a request, please submit your request in writing to us using the
contact information
provided below.
If you are under 18 years of age, reside in California,
and have a registered
account with the Website, you have the right to request removal of unwanted data
that you publicly post
on the Website. To request removal of such data, please contact us using the contact
information
provided below, and include the email address associated with your account and a
statement that you
reside in California. We will make sure the data is not publicly displayed on the
Website, but please be
aware that the data may not be completely or comprehensively removed from all our
systems (e.g. backups,
etc.).
CCPA Privacy Notice
The California
Code of Regulations
defines a “resident” as:
(1) every individual who is in the State of
California for other
than a temporary or transitory purpose and
(2) every individual who is
domiciled in the
State of California who is outside the State of California for a temporary or
transitory purpose
All
other individuals are defined as “non-residents.”
If this definition of
“resident” applies to
you, we must adhere to certain rights and obligations regarding your personal
information.
What categories of personal information do we
collect?
We have collected the following categories of
personal information in the past twelve (12)
months:
Category | Examples | Collected |
A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name | YES |
B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history and financial information | YES |
C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
D. Commercial information | Transaction information, purchase history, financial details and payment information | NO |
E. Biometric information | Fingerprints and voiceprints | NO |
F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements | NO |
G. Geolocation data | Device location | NO |
H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
I. Professional or employment-related information | Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us | NO |
J. Education Information | Student records and directory information | NO |
K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO |
We may also collect other personal information outside of these categories
instances where you
interact with us in-person, online, or by phone or mail in the context
of:
– Receiving help
through our customer support channels;
– Participation in customer surveys or
contests; and
–
Facilitation in the delivery of our Services and to respond to your
inquiries.
How do we use and share your personal
information?
OneMobile collects and shares your personal
information through:
– Targeting cookies/Marketing
cookies
More information about our data collection and sharing
practices can be found in this
privacy notice.
You may contact us by email at
[email protected], or by referring to the
contact details at the bottom of this document.
If you are using an
authorized agent to exercise your right to opt-out we may deny a request if the
authorized agent does
not submit proof that they have been validly authorized to act on your
behalf.
Will your information be shared with anyone
else?
We may disclose your personal information with our
service providers pursuant to a written
contract between us and each service provider. Each service provider is a for-profit
entity that
processes the information on our behalf.
The current list of our service
providers can be
found below.
We may use your personal information for our own business
purposes, such as for
undertaking internal research for technological development and demonstration. This
is not considered to
be “selling” of your personal data.
OneMobile has disclosed the
following categories of
personal information to third parties for a business or commercial purpose in the
preceding twelve (12)
months:
– Category B. Personal information, as defined in the
California Customer Records law, such as your
name, contact information, education, employment, employment history and
financial information.
The categories of third parties to whom
we disclosed personal information for a business or
commercial purpose can be found under “WHO WILL YOUR INFORMATION BE SHARED
WITH?”.
Your rights with respect to your personal
data
Right to
request deletion of the data – Request to delete
You can ask
for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal
information, subject to
certain exceptions provided by law, such as (but not limited to) the exercise by
another consumer of his
or her right to free speech, our compliance requirements resulting from a legal
obligation or any
processing that may be required to protect against illegal
activities.
Right to be informed
– Request to know
Depending on the circumstances, you have a
right to know:
– whether we collect and
use your personal information;
– the categories of personal information that
we collect;
–
the purposes for which the collected personal information is used;
– whether
we sell your personal
information to third parties;
– the categories of personal information that we
sold or disclosed
for a business purpose;
– the categories of third parties to whom the personal
information was
sold or disclosed for a business purpose; and
– the business or commercial
purpose for collecting
or selling personal information.
In accordance with applicable law, we
are not obligated to
provide or delete consumer information that is de-identified in response to a
consumer request or to
re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise
of a Consumer’s Privacy Rights
We will not discriminate
against you if you exercise your privacy rights.
Verification process
Upon
receiving your request, we will need to verify your identity to determine you are
the
same person about whom we have the information in our system. These verification
efforts require us to
ask you to provide information so that we can match it with information you have
previously provided us.
For instance, depending on the type of request you submit, we may ask you to provide
certain information
so that we can match the information you provide with the information we already
have on file, or we may
contact you through a communication method (e.g. phone or email) that you have
previously provided to
us. We may also use other verification methods as the circumstances
dictate.
We will only use
personal information provided in your request to verify your identity or authority
to make the request.
To the extent possible, we will avoid requesting additional information from you for
the purposes of
verification. If, however, we cannot verify your identity from the information
already maintained by us,
we may request that you provide additional information for the purposes of verifying
your identity, and
for security or fraud-prevention purposes. We will delete such additionally provided
information as soon
as we finish verifying you.
Other privacy rights
– you
may object to the processing of your personal data
– you may request
correction of your personal data if it is incorrect or no longer relevant, or ask to
restrict the
processing of the data
– you can designate an authorized agent to make a
request under the
CCPA on your behalf. We may deny a request from an authorized agent that does not
submit proof that they
have been validly authorized to act on your behalf in accordance with the CCPA.
– you may
request to opt-out from future selling of your personal information to third
parties. Upon receiving a
request to opt out, we will act upon the request as soon as feasibly possible, but
no later than 15 days
from the date of the request submission.
To exercise these rights, you
can contact us by
email at [email protected]. If you have a complaint
about how we handle your data, we would like to hear from you.
12. Do We Make Updates To This Notice?
In Short: Yes, we will update this notice as necessary to stay
compliant with relevant laws.
We may update this privacy notice from
time to time. The updated version will be indicated by
an updated “Revised” date and the updated version will be effective as soon as it is
accessible. If we
make material changes to this privacy notice, we may notify you either by prominently
posting a notice of
such changes or by directly sending you a notification. We encourage you to review this
privacy notice
frequently to be informed of how we are protecting your information.
13. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may email us at [email protected] or by post
to:
We may update this privacy notice from time to time. The updated version
will be indicated by an updated “Revised” date and the updated version will be effective
as soon as it is
accessible. If we make material changes to this privacy notice, we may notify you either
by prominently
posting a notice of such changes or by directly sending you a notification. We encourage
you to review
this privacy notice frequently to be informed of how we are protecting your
information.
FireGroup JSC
22nd Floor – Flemington
Tower, 182 Le Dai Hanh Str, Ward 15,
Dist. 11, Ho Chi Minh City
Vietnam
14. How Can You Review, Update or Delete The Data We Collect From You?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.
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