PRIVACY POLICY OF Mobiem

This policy describes how Mobiem sp. z o.o. (Mobiem) collects, processes personal data of the users of websites and mobile applications of Mobiem.

The policy does not apply to websites and services that refer to other policies or privacy statements.

This privacy policy may be subject to change in the future. Every time we make changes, we will publish a new version of the privacy policy on this page.

Privacy protection

1. Mobiem guarantees the users the right to choose information regarding their access to information.
2. Mobiem fully respects the right to privacy and the protection of users' personal data.
3. Mobiem allows the use of its services and applications anonymously; however, in order to get full access to content and services offered through the services and applications, it is advisable to register by filling out the available registration forms.
4. Any transfer of information to third parties is carried out if required by applicable law, and in the following cases:
   1. after obtaining Users' consent, in order to perform the data processing activities to which the consent relates,
   2. in an aggregated form that does not allow direct identification, characterizing the population of Mobiem applications and services to current and potential business partners.

Protection of personal data

1. Where can you find the most important information related to the processing of personal data?

   In addition to the services terms and conditions, information about us as Administrator, Data Protection Officer and other required by law is published on the following website: www.prywatnosc.mobiem.pl

2. What data are we processing in connection with the provision of services?

   It is the so-called Internet data that may include, depending on the service, the following information: visited applications, information about the terminal device, including its localisation, time of visit and activity of users in the mobile applications managed by Mobiem, attributes of marketing campaigns.

3. How long do we keep your data?

   We do not store your data for longer than it is necessary to achieve the purposes for which it was collected, unless applicable law requires us to keep it longer. We generally remove or anonymise Internet data after 90 days. Data contained in cookies are stored for the period indicated below in the chapter on cookies and similar technologies.

4. Do we share your data?

   Mobiem is paying particular attention to the protection of your users' data. It is possible thanks to organizational and technical activities as well as unique know-how. Based on the applicable provisions on the protection of personal data, we may share your information with the following entities, including those outside the European Union or the European Economic Area:

   Third parties: to the extent permitted by applicable law, we may share your information with trusted third parties for purposes related to the provision of our services, e.g. IT service providers, agents, marketing agencies, telecommunications entrepreneurs with whom Mobiem has entered into cooperation and network sharing agreements. To the extent permitted by applicable law, we may also share your information with business information offices and institutions dealing in debt recovery, including companies dealing with debt collection and trade in receivables and their proxies.

   In such cases, we require third parties to maintain the confidentiality and security of information and use them only to provide us with a given service or product.

   Our suppliers are based mainly in Poland and other countries of the European Economic Area (EEA), e.g. in Ireland. Some of our suppliers, e.g. Google or Facebook, are located outside the EEA. As for the transfer of your data outside the EEA, Mobiem makes sure that the suppliers can guarantee a high level of personal data protection. These guarantees result in particular from the obligation to use standard contractual clauses adopted by the Commission (EU) or participation in the “Privacy Shield” program established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of protection provided by by the EU-US Privacy Shield. You have the right to request us to provide copies of standard contractual clauses by sending a request to us.

By providing services as part of its activities, Mobiem grants access or discloses personal data to various entities

As a rule, they are our subcontractors, to whom we determine to what extent they can perform operations on personal data on our behalf. This applies to, among others:

• Entities providing IT maintenance or IT development services
• Entities providing specialized services for us (e.g. research, statistics, targeting)



It is worth remembering that:

• the data to which subcontractors have access is often a fragment of information that we have about the user, thus, it rarely happens that our subcontractor has as much information about the user as we as the Personal Data Administrator.
• the category of data recipients also includes entities to whom we do not transfer data, but who may potentially have access to them by performing services for us.

In any case, the contract we conclude with a subcontractor obliges the subcontractor to keep confidential and perform only necessary operations on the user's personal data.

We also provide data (not all but selected) to entities such as electronic payment operators in connection with your request for electronic payment.

In the remaining scope, data may be made available to state authorities and institutions on the basis of a strictly legal basis, which we verify and examine every time.

5. The legal basis for the processing of your personal data is:
   • conclusion and performance of a contract for access to the resources of mobile application or website;
   • consent: for example for saving and reading cookies in accordance with the provisions of the cookie policy (indicated below)
   • Implementation of a legally justified of Mobiem. Internet data and information saved in cookie files or other similar technologies are processed in order to detect and prevent abuse in the telecommunications network as well as for analytical purposes and matching of the displayed online advertisement. We combine your data with information about other users for the purposes of preparing analyses and reports, thanks to which we can optimize our services. Such information allows us, for example, to better match the functionality of services offered to users' needs, plan our network capacity, make decisions regarding the development of our offer of provided services and constantly improve service processes.


6. DATA SUBJECT’S RIGHTS

   In accordance with the provisions of the General Regulation on Personal Data Protection (Regulation of the European Parliament and of the Council (EU) 2016/679 of 27.04.2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/CE (OJ EU L 119, p. 1) you are entitled to:

   1. the right to express and withdraw consents, including to read or register cookies,
   2. the right to:
      • objection to the processing of your data for direct marketing purposes:
      • objection
      • reasoned objection to the processing of your personal data within the legitimate interests of Mobiem, for reasons related to your particular situation:
   3. the right to access your data, including obtaining a copy of the data to be processed, also in electronic form:
   4. the right to rectify (correct) your personal data if your data in our possession is inaccurate or incomplete:
   5. the right to delete your data if your data is no longer necessary for the purpose for which it was collected, and Mobiem has no grounds for its processing, e.g. based on your consent or legal obligation:
   6. the right to transfer data provided to us by you in a machine-readable format, e.g. if you want to share it with another service provider:
   7. the right to limit the processing of your data in the following cases (when applying, please indicate one of the following):
      • if you have concerns about the accuracy of your data:
      • if you think that we should not process your data, but at the same time you do not want us to remove it:
      • if we do not need such personal data anymore, but you need them in connection with the pursuit of claims:
      • If you object to the processing of your data, it is our responsibility to check whether we should process it further.
   8. the right to lodge a complaint to the supervisory authority.
7. You can exercise your rights by submitting an appropriate instruction to the following email address: iodo@mobiem.pl. Applications can also be submitted via traditional mail.
8. In order to fulfil your request, we are required to verify your identity so that your data does not go to an unauthorized person.
9. Mobiem, within one month of receiving the instruction, shall provide you with information about the actions taken in connection with your request. If necessary, the deadline for your request can be extended by further two months days to the complex nature of the request or the number of requests.
10. If your request turns out to be unreasonable or excessive, in particular due to its usual nature, Mobiem may request a reasonable fee for the implementation of another application or refuse to take action in connection with the request.

Cookies Policy

Cookies Policy for websites and applications of the company Mobiem sp. z o.o.

This document sets out the rules for the use of information provided by the user when using the websites and mobile applications of Mobiem sp. z o.o. with its registered office in Warsaw, al. Stanów Zjednoczonych 61, 04-028 Warsaw, registered at the National Court Register kept by the District Court for the Capital City of Warsaw, 12th Commercial Division of the National Court Register, under KRS (National Court Register) number 0001054636, NIP (Tax Identification Number): 5242743960, hereinafter referred to as Mobiem. Please read this document carefully, including the solutions presented below for managing your information and to determine user preferences in the above field. Further information regarding the processing of personal data by Mobiem can be found here.

Mobiem is guaranteeing the users of the websites and mobile applications of Mobiem the right to choose to share information that concerns them. Mobiem informs that it uses cookie technology (i.e. text files, so-called cookies) and other similar technologies on its websites and in its applications to record information on how the user uses the websites and applications of Mobiem.

“Cookies” – what are they?

Cookies are tiny portions of information saved by the user's browser used to browse the Internet. Everyone uses cookies - why? It is simple - thanks to cookie files, websites remember your preferences - such as setting of the city for weather forecast or recently viewed auctions. We do NOT use cookies in order to collect personal data that directly identify you, such as your name, address, email address or telephone number. Cookies have NO influence on the user's software or hardware. And one more important thing - cookies of Mobiem can be read only by Mobiem.

How do cookies and other similar technologies match our websites and applications to the user's needs?

The information stored in cookies helps in adjusting the content of the website to the expectations of users. For example, analytical cookies are used to analyse the range of our services and the behaviour of users, in particular their preferences and level of satisfaction, which in turn allows us to constantly improve our online services.

Cookies used for authentication, enable the use of services after authorization and the provision of a number of facilities, such as easy login, form filling, remembering website settings selected by the user.

On our websites and applications, we also use the successor of cookie technology, i.e. Local Storage (LS). This technology is similar to the principle of operation for cookies. It is a separate part of the browser's memory, which allows storing locally data by Internet applications, but without a few defects of its predecessor. First of all, it is safer, because only the website that introduced them has access to the data stored in it. Secondly, large amounts of data can be stored, without affecting site performance, as they are not sent by the browser each time you reference the server. In contrast to the cookies technology, the space limit is much larger (at least 5 MB) when only 4 KB can be stored in the cookie. This gives much more freedom and the possibility to customize the site to the expectations of users.

The data in LS is permanently stored by the browser and is not deleted when the browser is closed. They also do not have a specific validity period.

The purposes for which we use LS technology are the same as for cookies, but thanks to the smaller constraints, we can do it much better, faster and more efficiently.

Why and how do we use cookies and other similar technologies?

Mobiem uses cookies and other similar technologies on its websites and in applications for the following purposes:

• Authentication – to identify logged-in users to display them the appropriate information that suits their interests.
• Security – support of mechanisms preventing abuse of websites, including data leakage, ensuring confidentiality of information processed for the user.
• Preferences, functions and services – obtaining information on the user's language and communication preferences. They are also helpful when filling out forms on the site. Nevertheless, through the so-called social plugins, they provide the users with functions, important information and content consistent with their individual needs.
• Adjusting the content of websites and applications – recognize the users' device and display the content of websites or applications tailored to their individual needs.
• Performance, analysis and research – acquiring knowledge, checking how well our websites work, understanding and continuous improvement of products, functions and services. The above occurs, inter alia, at a time when users enter the Mobiem’s webistes from other websites, applications or devices while working on a computer or other device.
• Advertising - marketing aimed at showing the user the ads that interest him, on the sites of Mobiem, as well as outside them. We may also use cookies to find out if the users who have seen the advertisement on the websites or applications of Mobiem have in fact visited the advertiser's website. The advertisement displayed by Mobiem can be matched to the user's interests determined on the basis of information provided by the user while using the websites.

The average period of storage of this information by us for the above purposes is up to 60 days from their collection. Some information, for example about preferences in a given service or authorization data, may be stored for longer if the user does not clean the browser's cookies or the application cache.

The use of cookies and other similar technologies by other entities

Mobiem allows other entities to use cookie technology and other similar technologies on websites and applications of Mobiem.

• Plugins of social networks:
  1. Facebook – on the websites of Mobiem, there are buttons Like and Recommend / Share related to Facebook. For this purpose, a code referring to Facebook is placed in the relevant sections and pages. By using the Like button or by recommending the image or sections of the page, the user logs in to Facebook, where the Facebook’s privacy policy applies. You can read these rules here: http://pl-pl.facebook.com/help/cookies
  2. Youtube – on the websites of Mobiem, there are video materials (using the so-called embedding mechanism) made available on YouTube. For this purpose, a code referring to YouTube is placed in the relevant sections and pages. YouTube keeps track of video clips, and this tracking follows the privacy policies that are available http://www.google.com/intl/en/policies/privacy/
  3. Twitter – on the websites of Mobiem, there are buttons to add tweets on Twitter that are related to Twitter. For this purpose, a code referring to Twitter is placed in the relevant sections and pages. By adding the tweets on Twitter, the user logs in to Twitter, where the Twitter’s privacy policy applies. You can read these rules here: https://twitter.com/privacy
• Advertising and marketing goals of partners of Mobiem – our partners may use cookies or other similar technologies to determine whether a particular advertisement was displayed by them or on their order, what the results were, and to collect information on how Users respond to the displayed ads. Our partners may also, if the user agrees, match the ads displayed to the user's interests determined on the basis of information provided to our partners by the user while using the websites (also outside the services of Mobiem) or the application. If the user has given the consent referred to in the preceding sentence, this information may also be made available for further marketing purposes to other entities displaying or ordering the advertisement on the Internet. For these purposes, we can also work with partners to show the user an advertisement on the websites or applications of Mobiem or outside of them, after visiting the website or application by the user. Cookie files and technologies such as web navigation signals, pixels and anonymous ad network tags allow us to display ads to our users more effectively, as well as to gather collected audits, surveys and reports required by advertisers. Note: Since network ads and signals must be transmitted to the browser directly from the ad network servers, these networks can display, edit or enter their own cookies as if the user visited the website from their website.

SmartPush Technology

Furthermore, in order to inform our users about important events and new elements in our services, Mobiem uses the SmartPush Technology.

SmartPush is a technology that gives you the possibility of unilateral communication in real time and is supported by the application installed in your mobile phone. In order not to receive information, you need to change your phone's settings.

Additional information from our partners

• Research and analysis of services

  Cookies related to Internet network research come from Gemius S.A. and Google Inc.

  Using the Google Analytics and Gemius software, the website, based on the relevant agreements with the above-mentioned entities, places counting codes on the user's computer enabling the collection of user data.

  At any time, the user may object to the collection of data by the Google Analitycs or Gemius software by changing the settings of the web browser. Information on how to do this can be found at: http://nt.interia.pl/internet/news-jak-zablokowac-google-analytics-w-naszej-przegladarce,nId,2583876

  Mobiem also informs that, together with other major Internet service providers in Poland, it participates in the Polish Internet Research, and the principles of conducting the Internet network research are available on the following websites:

  1. http://pbi.org.pl/badania/jak-to-dziala and
  2. http://www.gemius.pl/pl/polityka_prywatnosci

  Each of the Internet users may object to the participation in the above-mentioned research by:

  • accepting special cookies with a resignation clause (http://optout.hit.gemius.pl/removeEN.php)
  • configuring the browser so that it deletes cookies when it is closed
  • configuring the browser so that it does not accept cookies and does not accept LocalStorage technology.

  The additional information are available at: http://www.gemius.pl/cookie-policy.html

Defining the conditions for the use of cookies or other similar technologies

Most browsers allow users to control cookies in their privacy settings.

If the users do not want to receive cookies, they may change the browser settings. We underline that disabling the cookies necessary for Authentication, Security, maintaining User Preferences, will make it difficult to use the websites of Mobiem and, in extreme cases, may prevent the use of these websites.

In order to clear data from mobile applications, depending on the system that is installed on the mobile device:

For Android:

1. Go to Settings
2. Go to Application
3. Search for the given application
4. Choose Memory
5. Select the option “Clear data”

For iOS:

The iOS system does not allow you to clear application data. The only solution is to remove and reinstall the application. You can do it in two ways:

1. Going to Settings, then to General and to Memory. There, you should search for the given application, enter its settings and check the “Delete application” option.
2. Hold your finger on the icon of the application until “X” appears in the upper left corner of the application. Clicking on “X” deletes the application along with the data.

Instructions for managing cookies

Desktop Platform

In order to manage cookies settings, select from the list below the web browser you use and follow the instructions:

• Internet Explorer
• Chrome
• Safari
• Firefox
• Opera

Mobile devices:

• Chrome
• Safari
• Windows Phone
• Blackberry

Flash cookies

The Adobe website provides information on how to remove and disable Flash Player cookies on specific domains: http://www.adobe.com/products/flashplayer/security.

Please note that limiting the use of Flash player cookies will probably affect the operation of Flash-based applications, and disabling Flash Player cookies on www.Mobiem.pl will prevent the playback of most content.

Partners

Below, you will find a list of our technology partners who, through the use of cookies or other similar technologies, collect information about the user's behaviour on websites or applications of Mobiem and process them for marketing purposes, including displaying an advertisement tailored to the user's preferences or sharing this information with other entities displaying or ordering an advertisement on the Internet. The rules of our partners' use of cookies or other similar technologies, as well as the opt-out mechanisms (withdrawal of consent), can be read in their privacy policies (cookies) located on websites to which links are in the table’s right column.

List of partners