Privacy Policy

MobiChord, Inc. (“MobiChord’) is committed to protecting your online privacy. We feel it is

important for you to know how we handle the information we receive from you via the Internet.

You can visit http://www.mobichord.com (“our Website”) without revealing any personal

information.

We may provide third parties with aggregate statistics about our visitors, traffic patterns and

related site information. These data reflect site-usage patterns gathered during visits to our

website each month, but they do not contain behavioral or identifying information about any

individual member unless that member has given us permission to share that information.

This Policy also applies to the processing of Personal Data that MobiChord obtains from its

Customers in the European Union and Switzerland in order to establish and maintain an

adequate level of Personal Data privacy protection.

MobiChord complies with the EU-US Privacy Shield Principles as set forth by the US

Department of Commerce regarding the collection, use, and retention of personal information

from Customers in the European Union member countries. MobiChord has certified that it

adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer,

security, data integrity and purpose limitation, access, recourse, enforcement and liability. If

there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy

Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy

Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

The Federal Trade Commission (FTC) has jurisdiction over MobiChord’s compliance with the

Privacy Shield.

All MobiChord employees who handle Personal Data from Europe and Switzerland comply with

the Principles stated in this Policy.

 

Aggregate information, IP addresses, newsletters

We use general traffic, site usage and length-of- stay information in reports to advertisers and

firms with which we have a business relationship. This sort of information is shared only in

aggregate and does not personally identify individuals.

We collect and log the Internet Protocol address (IP) of all visitors of our Website. We collect it

so that we can properly administer our system and gather aggregate information about how our

site is being used. This aggregate information may be shared with advertisers, sponsors and

other businesses. To maintain your anonymity, we do not associate IP addresses with records

containing personal information. We will use IP address information, however, to personally

identify you in order to enforce our legal rights or when required to do so by law enforcement

authorities.

We require you to provide an email address to subscribe to a newsletter. If you subscribe, we

may also use this email address to send you communications about other products and

services. We may also share this email address with our third party email management vendor

for purposes of delivering the newsletter to you; however, we do not share your email address

with groups outside of MobiChord for any marketing purposes. You can sign up for a free email

newsletter. You can unsubscribe from this newsletter at any time.

 

Use of cookies

Our sponsors and advertisers and their ad servers may use cookies when you view pages on

our site. They use those cookies to collect non-personal information as a way of measuring the

effectiveness of their advertising, or to provide advertisements about goods and services that

may be of interest to you or to avoid running the same ads to you over time. We do not control

these third parties’ use of cookies or how they manage the non-personal information they gather

through them. However, our sponsors and advertisers have agreed that they will not collect any

personally identifiable information from our site visitors while they are on our Website. If you

click on an advertisement on our Website and visit a site maintained by one of our sponsors or

advertisers, please be aware that we are not responsible for the privacy practices of that site.

You should read the privacy policies of each site you visit to determine what information that site

may be collecting about you.

Some of our advertisers may participate in the Facebook/Nielson program, which helps

advertisers improve their measurement of advertising effectiveness. If you are a Facebook user

and access a page on our site containing an ad from a participating advertiser, Facebook

receives a random numeric code identifying the ad that was served to you. The ad is only

identified to Facebook by the numeric code. Facebook does not receive information which

identifies the product or the advertiser. Facebook, in turn, discloses only aggregate, de-

identified information to Nielson and the advertiser, not any personally identifiable information

from your Facebook profile. You can learn more about this program and find out how to opt out

here:

https://www.facebook.com/help/?faq=211774365532736#What-is- the-Nielsen- partnership-with-

Facebook-and- how-does- it-affect- me.

“Cookies” are small pieces of information that some websites store on your computer’s hard

drive when you visit them. Like many other websites, our Website uses cookies to provide us

with information relating to the sources of our site traffic. Collecting this information, however,

does not allow us to personally identify you.

Our site requires that both cookies and JavaScript be enabled. If you reject cookies from our

site, some parts of the site may not work properly for you.

 

Ads by Google

Note that Google, as a third party vendor, uses cookies to serve ads on our site. Google’s use

of the DART cookie enables it to serve ads to our site users based on their visit to our site and

other sites on the Internet. No personally identifiable information is collected as part of Google’s

process. Users may opt out of the use of this DART cookie by visiting Google’s privacy

document.

If you would like more information about these practices and to know your choices about not

having this information used by these companies, visit the Network Advertising Initiative. Some

ad servers allow you to opt out of anonymous data collection through the use of cookies. To do

so, you must opt out of such data collection with each individual site. You can opt out of cookies

for several ad servers by visiting the Network Advertising Initiative gateway opt-out site. At that

site you can also review the privacy policies of those ad servers.

 

Responsibilities and management

MobiChord has designated its corporate security officer to oversee its information security

program, including its compliance with the EU-US Privacy Shield Principles. Any material

changes to this program will be reviewed and approved as necessary. Any questions, concerns,

or comments regarding this Policy may be directed to privacy@mobichord.com

MobiChord will maintain, monitor, test, and upgrade information security policies, practices, and

systems to assist in protecting the Personal Data that it collects. MobiChord stuff is trained to

effectively implement provisions this Policy.

From time to time we may employ other companies and/or third parties (“agents”) to perform

tasks on our behalf and with whom we may need to share, and may need to internationally

transfer, the personal data to provide our services; for example, ServiceNow, Inc., Amazon Web

Services, Inc. and others. MobiChord is liable under the EU-U.S. Privacy Shield Principles for its

agents to process transferred Personal Information in a manner consistent with the Principles.

Renewal and verification

MobiChord will renew its EU-US Privacy Shield certification annually, unless it subsequently

determines that it no longer needs such certification or if it employs a different adequacy

mechanism.

Prior to the re-certification MobiChord will conduct an in-house verification to ensure that its

attestations and assertions with regard to its treatment of Customer Personal Data are accurate

and that the company has appropriately implemented these practices. Specifically, as part of the

verification process, MobiChord will undertake the following:

1. Review this Privacy Shield policy and its publicly posted website privacy policy to ensure

that these policies accurately describe the practices regarding the collection of Individual

Customer Personal Data.

2. Ensure that the publicly posted privacy policy informs Individuals of MobiChord's

commitment towards compliance with EU-US Privacy Shield Principles.

3. Confirm that Customers are made aware of the process for addressing complaints and

any independent dispute resolution process (MobiChord may do so through its publicly

posted website, customer contract, or both).

4. Review its processes and procedures for training it’s stuff about MobiChord's

participation in the EU-US Privacy Shield program and the appropriate handling of

Individual’s Personal Data.

MobiChord prepares an internal verification statement on self-assessment, that is singed by

authorized corporate officer on an annual basis.

 

Collection and use of personal data

MobiChord provides Telecommunication Expense Management solutions to Customers.

MobiChord collects personal data from Customers to analyze contractual, usage, service and

expense information in order to fulfill contractual obligations, information requests or from other

ways of communication.

The Personal Data that we collect may vary based on the Customer’s interaction with the

service may provide or the request to provide it and with our website. As a general matter,

MobiChord collects several types of personal data from its Customers, such as contractual data

(e.g. terms), invoice data (including usage data / expense data for phone lines), Customer’s HR

originated data etc.

In MobiChord’s capacity as a service provider, we may receive, store, and/or process personal

data. In such cases, we are acting as a data processor and will process the personal

information on behalf of and under the direction of our Customers and/or related third parties.

MobiChord uses Personal Data that it collects directly from its Customers or from affiliated third

parties the following purposes, without limitation:

1. providing services requested by customers, complying with its contractual obligations;

2. storing, analyzing and processing data, including personal data;

3. as requested by the Customer;

4. for other business-related purposes permitted or required under applicable local laws

and regulations.

 

Disclosures and onward transfers

Except as otherwise provided herein, MobiChord discloses personal data only to third parties

who reasonably need to know such data only for the scope of the initial transaction and not for

other purposes. Such recipients must agree to abide by confidentiality obligations.

MobiChord may provide personal data to third parties that act as agents, consultants and

contractors to perform tasks on behalf of and under our instructions. Such third parties must

agree to use such personal data only for the purposes for which they have been engaged by

MobiChord and they must either:

1. comply with the EU-US Privacy Shield Principles or another mechanism permitted by the

applicable EU data protection law(s) for international transfers and processing of

personal data or

2. agree to provide adequate protection for the personal data that is no less protective than

those set out in this Policy;

MobiChord also may disclose personal data for other purposes or to other Third Parties when a

Data Subject has consented to or requested such disclosure. Please be aware that MobiChord

may be required to disclose an individual's personal information in response to a lawful request

by public authorities, including to meet national security or law enforcement requirements.

MobiChord is liable for appropriate onward transfers of personal data to third parties.

Our Website may contain links to websites operated by third parties. MobiChord has no control

over the privacy policies and practices of such third party sites, and if you have any concerns,

you are urged to review the terms of those sites for more information about the policies

applicable to those sites.

 

Sensitive Data

MobiChord does not collect Sensitive personal data from its Customers.

 

Data integrity and Security

MobiChord uses reasonable efforts to maintain the accuracy and integrity of personal data and

to update it as appropriate. MobiChord has implemented physical and technical security

measures to protect personal data from loss, misuse, and unauthorized access, disclosure,

alteration, or destruction. MobiChord also implements access restrictions, limiting the scope of

employees who have access to personal data.

Furthermore, MobiChord uses secure encryption technology to protect certain categories of

personal data.

 

Notification

MobiChord notifies Customers about its adherence to the EU-US Privacy Shield Principles

through its publicly posted website privacy policy, available at:mobichord.com/privacy-policy/

and take Customer approval and adherence to the current policy when they provide their

information to us in the transactional process.

 

Right to access, change or delete personal data

1. Right to Access. Customer’s present and former employees have the right to know what

personal data about them is included in the databases and to ensure that such Personal

Data is accurate and relevant for the purposes for which MobiChord collected it.

Individuals may review their own Personal Data stored in the databases and correct,

erase, or block any data that is incorrect, as permitted by applicable law and MobiChord

policies. Upon reasonable request and as required by EU-US Privacy Shield Principles,

MobiChord allows Customer’s present and former employees access to their Personal

Data, in order to correct or amend such data where inaccurate. To request erasure of

Personal Data, individuals should submit a written request to MobiChord office.

2. Requests for Personal Data. MobiChord will track each of the following and will provide

notice to the appropriate parties under law and contract when either of the following

circumstances arise: (a) legally binding request for disclosure of the personal data by a

law enforcement authority unless prohibited by law or regulation; or (b) requests

received from the data subject. If MobiChord receives a request for access to his/her

personal data from a person, then, unless otherwise required under law or by contract

with Customer, MobiChord will refer such data subject to that person.

3. Satisfying Requests for Access, Modifications, and Corrections. MobiChord will

endeavor to respond in a timely manner to all reasonable written requests to view,

modify, or inactivate personal data.

MobiChord personnel may access and use personal data only if they are authorized to do so

and only for the purpose for which they are authorized, e. g. under contractual obligations and

direct Customer’s instructions.

 

Children’s privacy

Our website is intended for adults age 18 and older. It is not intended for or designed to attract

people under the age of 18. We do not collect personally identifiable information from any

person we actually know to be under the age of 18.

 

E-mail communications and related services

Our Website provides you with the opportunity to receive communications from us or third

parties.

Email communication that you send to us via the email links on our site may be shared with a

customer service representative, employee or agent that is most able to address your inquiry.

We make every effort to respond in a timely fashion once communications are received. Once

we have responded to your communication, it is discarded or archived, depending on the nature

of the inquiry.

The email functionality on our site does not provide a completely secure and confidential means

of communication. It’s possible that your e-mail communication may be accessed or viewed by

another Internet user while in transit to us. If you wish to keep your communication private, do

not use our email.

You may decide at some point that you no longer wish to receive communications from our site.

To stop receiving communications, send an email message to info@mobichord.com or send

regular mail to the following postal address:

MobiChord, Inc

7440 Creek Road

Sandy, Utah 84093

United States of America

 

Changes to this Policy

This Policy may be amended from time to time, consistent with EU-US Privacy Shield Principles

and applicable data protection and privacy laws and principles. We will make employees

available of changes to this Policy either by posting to our intranet, through email, or other

means. We will notify Customers if we make changes that materially affect the way we handle

Personal Data previously collected, and we will allow them to choose whether their Personal

Data may be used in any materially different manner.

 

Question or complaints

If you have a complaint or problem, or if you believe your privacy rights have been violated, you

may email us by clicking the “Contact us” link at the bottom of any page. Please indicate the

following reason for contacting us: I want to provide feedback about your site. Our Customer

Service department will forward your complaint to the appropriate department for response or

resolution.

EU customers may contact MobiChord with questions or complaints concerning this Policy at

the following email address:

privacy@mobichord.com

 

Enforcement and dispute resolution

In compliance with the EU-US Privacy Shield Principles, MobiChord commits to resolve

complaints about your privacy and our collection or use of your personal information. EU

individuals with questions or concerns about the use of their Personal Data should contact us at:

privacy@mobichord.com

If a Customer’s present or former employee’s question or concern cannot be satisfied through this

process in timely manner, MobiChord has further committed to refer unresolved privacy

complaints under EU-US Privacy Shield to an independent dispute resolution mechanism, such

as EU Data Protection Authorities.

MobiChord commits to cooperate with EU data protection authorities (DPAs) and comply with

the advice given by such authorities with regard to human resources data transferred from the

EU in the context of the employment relationship.

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