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
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
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
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
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.
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
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
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
with information relating to the sources of our site traffic. Collecting this information, however,
does not allow us to personally identify you.
site, some parts of the site may not work properly for you.
Ads by Google
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
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
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 email@example.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
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:
that these policies accurately describe the practices regarding the collection of Individual
Customer Personal Data.
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
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.
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
MobiChord notifies Customers about its adherence to the EU-US Privacy Shield Principles
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.
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
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 firstname.lastname@example.org or send
regular mail to the following postal address:
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
EU customers may contact MobiChord with questions or complaints concerning this Policy at
the following email address:
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:
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.