PRIVACY POLICY

 

Last updated August 11, 2020

 

Thank you for choosing to be part of our community at Lulu Systems, Inc., (“Mobilo Card”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected].

 

This Privacy Policy applies to all information collected through our website (at https://www.mobilocard.com) (the “Site“), and any related services, applications, software, content, marketing, events, hardware, and technologies offered through or in connection with the Site (the “Services“).

 

When you visit the Site or use our Services, you trust us with your personal information. We take your privacy very seriously. In this Privacy Policy, 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 Policy that you do not consent to, please discontinue use of our Site and Services. By accessing or using the Site or the Services, you acknowledge that you have read and understood this Privacy Policy.

 

 

 

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.   

 

TABLE OF CONTENTS

 

  1. WHAT INFORMATION DO WE COLLECT?

 

  1. HOW DO WE USE YOUR INFORMATION?

 

  1. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

 

  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

 

  1. DO WE COLLECT INFORMATION FROM MINORS?

 

  1. WHAT ARE YOUR PRIVACY RIGHTS?

 

  1. CONTROLS FOR DO-NOT-TRACK FEATURES

 

  1. DO RESIDENTS OF CERTAIN US STATES HAVE SPECIFIC PRIVACY RIGHTS?

 

  1. DO WE MAKE UPDATES TO THIS POLICY?

 

  1. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

 

  1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us

 

In Short: We collect personal information that you provide to us such as name, address, contact information, and other information you voluntarily provide us .

We collect personal information that you voluntarily provide to us (i) when you sign up for the Site or Services, (ii) when you express an interest in obtaining information about us or our products and services, (iii) automatically as you use the Site or Services, or (iv) otherwise when contacting us.

The personal information that we collect depends on the context of your interactions with us and the Site or Services, the choices you make and the products and features you use. The personal information we collect can include the following (“Your Data”):

  • Profile Data. We collect names current office address, phone number(s), email addresses, title, company name, business email, business phone number, social media handles, and other similar data.
  • Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. We do not store your payment data; we merely enable the processing of that data via our payment gateway providers. All payment data is stored by the applicable payment providers detailed in our Terms of Use.
  • Contributions. We collect your contributions, trademarks, trade dress, logos, designs, slogans, text, writings, reviews, survey responses, video, audio, photographs, graphics, comments, suggestions, and other material that you voluntarily provide to us.

Your Data that you provide to us must be true, complete and accurate, and you should notify us of any changes to YourData.

 

Information collected through our Site

In Short:  We may collect information regarding Your Data when you use our Site or Services.

If you use our Site or Services, we, our service providers, and our third party partners may automatically log or collect information about you, your computer, or mobile device, and your activity over time on the Site or Services including:

    • Device Data. We, or our service providers, collect information about your device such as unique device identifier, media access control address, network information, hardware model, browser type, screen resolution, IP address, as well as usage and traffic data and information about how the device interacts with the Site or Services.
    • Usage Data. We collect usage information such as the date and time of your access, visit or use of the Site, pages or screens viewed, how long you spent on a page or screen, navigation paths between pages or screens, searches you conduct, on our Site and information about your activity on a page or screen.
    • Location Data. Through our service providers, we use your IP address and other information to approximate your location when accessing the Site or Services.

  1. HOW DO WE USE YOUR INFORMATION?

In Short:  We process Your Data 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 Your Data for a variety of business purposes described below. We process Your Data for these purposes in reliance on our legitimate business interests, in order to, among other things, provide the Site’s functionality, fulfill your requests, engage in analysis related to improving the quality of the Site, personalize your experience, enter into or perform a contract with you, track usage of the Site and Services, deliver targeted advertising, market the Site and Services, provide customer support, send you electronic communications, request feedback, allow for disaster recovery, enhance the security of the Site and Services, 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. 
  • To send you marketing and promotional communications. We and/or our third party marketing partners may use Your Data for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
  • To send administrative information to you. We may use Your Data to send you product, service and new feature information and/or information about changes to our Terms of Use, conditions, and policies.
  • Fulfill and manage your orders. We may use Your Data to fulfill and manage your orders, payments, returns, and exchanges made through the Site.
  • Deliver targeted advertising to you. We may use your information to develop online advertising to keep you aware of what we’re up to and help you see and find our products. You may see Mobilo Card banners or ads when you are on other websites and apps. We manage this using a range of advertising technologies, including cookies, pixel tags, and web beacons..
  • Request Feedback. We may use your information to request feedback and to contact you about your use of our Site or Services.
  • To protect our Services. We may use Your Data as part of our efforts to keep our Site and Services  safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our policies.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.
  • To deliver services to the user. We may use Your Data to provide you with the requested service.
  • To respond to user inquiries/offer support to users.  We may use Your Data to respond to your inquiries and solve any potential issues you might have with the use of our Site or Services.
  • For other Business Purposes. We may use Your Data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Site and Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

We may combine information we collect from or about you for any of the purposes set out above (depending on the types of information we receive).

 

  1. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share Your Data with your consent, to comply with laws, to provide you with access to the Site and Services, to protect your rights, or to fulfill business obligations.   

We may share Your Data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use Your Data for a specific purpose.
  • Legitimate Interests: We may share Your Data when it is reasonably necessary to achieve our legitimate business interests or we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of Mobilo Card, our customers, or others for the purposes of, including but not limited to, fraud protection and risk reduction.
  • Performance of a Contract: Where we have entered into a contract with you, we may process Your Data with a third-party vendor to fulfill the terms of our contract.
  • Legal Obligations: We may disclose Your Data 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 Data where we believe it is necessary to investigate, prevent, enforce or take action regarding potential violations of our Terms of Use or terms of sale and other agreements, including for billing and collection purposes, 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 or share Your Data in the following situations:

  • 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, such as Stripe and Paypal, 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 Site or Services, which will enable them to collect data about how you interact with the Site or Services over time. Your Data may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, rent or trade any of Your Data with third parties for their promotional purposes.
  • Business Transfers. We may share or transfer Your Data 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.
  • Third-Party Advertisers. We may use third-party advertising companies, such as Adroll and Google, to help you see and find our products. You may see Mobilo Card banners or ads when you are on other websites and apps.. These companies may use information about your visits to the Site and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
  • Business Partners. We may share Your Data with our business partners to offer you certain products, services or promotions.

      

  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store Your Data.

Cookie Policy

This section (“Cookie Policy”) applies to all information collected through the Site, including the technologies we and third parties with whom we partner, use for automatic data collection. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store Your Data. This Cookie Policy explains the different types of cookies used on the Site and how you can control them. We may change this Cookie Policy at any time.

A browser cookie is a small piece of data that is stored on your device to help websites and mobile apps remember things about you. Other technologies, including Web storage and identifiers associated with your device, may be used for similar purposes. We use cookies, including third-party cookies, for a number of reasons, like protecting your data and account, helping us see which features are most popular, counting visitors to a page, improving our users’ experience, keeping our Site and services secure, providing targeted advertising, and to provide you with a better experience.

 

The cookies we use generally fall into one of the following categories:

CATEGORIES OF COOKIES

WHY WE USE THESE COOKIES

Necessary

To run the Site and to identify and prevent security risks.

Preferences

To remember your settings and preferences, and to improve your experience on the Site.

Performance

To collect information about how you use the Site, and monitor and improve the Site’s performance.

Marketing

To deliver advertisements, to make them more relevant and meaningful to consumers, and to track the efficiency of our advertising campaigns on other sites or mobile apps.

 

Where applicable, we provide you with the opportunity to opt out of the use of Cookies. You may refuse to accept browser cookies by activating the appropriate setting on your device. However, doing so may affect the Site’s functionality.5. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep Your Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

 

We will only keep Your Data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us to keep Your Data 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 Data, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store Your Data and isolate it from any further processing until deletion is possible.

 

By submitting Your Data to us, or to a third-party via the Site or Services, you acknowledge that you will be voluntarily transferring Your Data to the United States, a jurisdiction which may not provide the same privacy framework as other regions. We take steps to ensure that the data we collect under this Privacy Policy is stored and processed in accordance with this Privacy Policy regardless of where the data is located.

 

  1. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

 

The Services are not intended for children under 13 years of age. We do not knowingly solicit data from or market to children under 18 years of age. 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 have collected from children under age 18, please contact us at: [email protected].

 

  1. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short:  You may review, change, or terminate your account at any time.

 

If you are a resident of a country in the European Economic Area (“EEA”) or Switzerland (“European Resident”), you have the right to access Your Data, and the right to request that we correct, update, or delete your personal information. You can object to the processing of Your Data and your personal information, ask us to restrict processing of Your Data and your personal information, and request portability of Your Data and your personal information. Similarly, if we have collected and processed Your Data or your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect processing of Your Data or your personal information conducted in reliance on lawful processing grounds other than consent. The Site generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. If you have any questions or comments about the processing of your personal information, you may contact us at: [email protected]

 

For European Residents, please note that the personal information we obtain from or about you may be transferred, processed, and stored outside of the EEA or Switzerland for the purposes described in this Privacy Policy, including in the United States of America. We take the privacy of our users seriously and therefore take steps to safeguard your information, including ensuring an adequate level of data protection in accordance with E.U. standards in effect as of the date of this Privacy Policy. These steps include use of the European Commission’s Standard Contractual Clauses for transfers of personal information by third party service providers and partners and further details can be provided upon request.

 

If you are a resident of the EEA 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

 

Account Information

 

If you would at any time like to review or change the information in your account or terminate your account, you can:

  •    Log into your account settings and update your user account.  
  •    Contact us using the contact information provided.  

Upon your request to terminate your account, we will deactivate or delete Your Data and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with 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 will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you maycontact us at: [email protected].

 

  1. 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 you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. 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 that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

 

  1. DO RESIDENTS OF CERTAIN US STATES HAVE SPECIFIC PRIVACY RIGHTS?

 

In Short:  Yes, if you are a resident of California or Nevada, you are granted specific rights regarding access to Your Data.

 

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights regarding Mobilo Card’s collection, use, and sharing of their personal information. This Privacy Policy applies to “Consumers” as defined by the CCPA. In the event of a conflict between any of our policies, statements, or notices, including but not limited to this Privacy Policy, this section will prevail as to California Consumers and their rights under the CCPA. For purposes of this section only, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you, as defined under the CCPA. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you. Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered consumers for purposes of this notice or the rights described herein.

 

Mobilo Card does not sell your Personal Information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. We may disclose your Personal Information for the following purposes, which are not a sale: (i) if you direct us to share your Personal Information, (ii) to comply with your requests under the CCPA, (iii) disclosures as part of a merger or asset sale, and (iv) as otherwise required or permitted by applicable law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your Personal Information.

 

We collect various categories of Personal Information when you use the Site, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information. A more detailed description of the information we collect and how we use it is provided above. 

 

Under the CCPA, you have the following rights:

  • Right to Know. You have the right to access and request that we inform you of the Personal Information we collect, use, or disclose to third parties;
  • Right to Obtain a Copy. You have the right to make or obtain a transportable copy of your Personal Information that we have collected in the period that is 12 months prior to the request date and are maintaining.
  • Right to Request Deletion. You have the right to request that we delete your Personal Information that we have collected from you and are maintaining. Please be advised, however, that exceptions under the CCPA may allow us to retain and use certain Personal Information notwithstanding your deletion request; and
  • Right to Non-Discrimination. We will not discriminate against you in a manner prohibited by the CCPA for exercising any of your CCPA rights.

Please note that to protect your information and the integrity of our Site and Services, we will need to verify your identity before processing your request. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.

 

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 Site, you have the right to request removal of unwanted data that you publicly post on the Site. 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 Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

 

Additionally, Nevada law (SB §220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. Mobilo Card does not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.

 

All requests for information or changes to your preferences must be directed to: [email protected]. Such requests must include the reference “Request for California Privacy Information” or “Request for Nevada Privacy Information” in the subject line and in the body of the message, and must include the email address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.

 

  1. DO WE MAKE UPDATES TO THIS POLICY?

 

In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

 

We may update this Privacy Policy from time to time. All changes are effective immediately when we post them and we will use reasonable efforts to alert you about any changes by updating the “Last updated” date of this Privacy Policy. It is your responsibility to review this Privacy Policy frequently to be informed of how we are protecting your information.  You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted. We may, in our sole discretion, translate this Privacy Policy into other languages for your convenience, nevertheless, the English version governs your relationship with Mobilo Card and any inconsistencies among the different versions will be resolved in favor of the English version.

 

  1. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at [email protected] or by post to:

 

Lulu Systems, Inc.

    

1178 Broadway 

2nd Floor #1021 

New York, NY 10001    

United States