Privacy Policy

Version: 2.00
Effective Date: 12/12/2025
Last Reviewed: 19/01/2026

1. Introduction

This Privacy Policy explains how IMEI Ltd trading as Mobicode (“Mobicode”, “we”, “us”, “our”) collects, uses, shares, and protects personal data when you interact with our websites, software, platforms, and services.

This Privacy Policy is designed to meet the requirements of the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and applicable United States data protection and privacy laws. It is written primarily for business-to-business (“B2B”) users.

This Privacy Policy applies alongside our Terms and Conditions and does not form part of the contract governing use of our services.

2. Who We Are

IMEI Ltd trading as Mobicode is the organisation responsible for your personal data.

Company details:
IMEI Ltd
Halsgrove House
Lower Moor Way
Tiverton Business Park
Tiverton
Devon
EX16 6SS
United Kingdom

Company Number: 08681621

Email: info@mobicode.co.uk
Telephone: +44 (0)203 150 2529

For the purposes of UK GDPR and EU GDPR, IMEI Ltd acts as a Data Controller in respect of personal data processed through our websites and services. Where we process personal data on behalf of our business customers, we may act as a Data Processor.

3. Scope of This Privacy Policy

This Privacy Policy applies to personal data collected through:

• www.mobicode.co.uk
• mobi-server.com
• Mobicode software applications and platforms, including MobiONE, MobiCHECK, MobiWIPE, Recycle-IT, and Repair Centre Plus (RCP)
• Account registration, billing, support, and customer communications
• Sales, onboarding, and service-related interactions

This Privacy Policy does not apply to third-party websites or services that may be linked from our platforms.

4. How We Collect Personal Data

We collect personal data in the following ways:

• when you provide information directly to us, such as during account registration, onboarding, or support requests
• when you use our websites, platforms, or software
• through cookies and similar technologies
• through communications with us by email, phone, or other channels
• from third-party organisations that lawfully share data with us in connection with fraud prevention, compliance, or service delivery

We only collect personal data that is relevant and necessary for our business purposes.

We use cookies and similar technologies to collect certain information automatically when you visit our websites. Further details about the cookies we use, their purpose, and how you can manage your preferences are set out in our Cookie Policy.

5. Categories of Personal Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data:

• Identity and contact data (name, business address, email address, telephone number)
• Account and authentication data (username, password, role-based access information)
• Billing and transaction data (payment references, invoices, subscription details)
• Device and technical data (IMEI numbers, serial numbers, device identifiers submitted for processing)
• Usage data (log files, access times, feature usage, diagnostics and erasure reports)
• Communications data (support tickets, emails, call records)
• Marketing preferences (where applicable)

We do not intentionally collect special category data.

6. How We Use Personal Data

We use personal data for the following purposes:

• to create and manage customer accounts
• to provide diagnostics, data lookup, secure data erasure, recycling, and repair services
• to process payments and manage subscriptions
• to deliver customer support and respond to enquiries
• to monitor usage, performance, and system security
• to comply with legal, regulatory, and contractual obligations
• to prevent fraud, misuse, and unlawful activity
• to send service-related and transactional communications
• to send marketing communications where you have opted in

Under UK and EU data protection law, we rely on one or more of the following lawful bases: performance of a contract, legal obligation, legitimate interests, and consent (where required).

7. Marketing Communications

We may send marketing communications about our products and services where you have opted in to receive them or where permitted under applicable law.

You can opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting us directly. Transactional and service-related communications are not affected by marketing preferences.

8. How We Share Personal Data

We may share personal data on a need-to-know basis with:

• service providers who support our platforms, infrastructure, payment processing, and customer support
• professional advisers such as legal, financial, and compliance advisers
• law enforcement, regulatory authorities, insurers, mobile network operators, and fraud-prevention partners where required or permitted by law
• third parties in connection with a merger, acquisition, or sale of all or part of our business

We do not sell, rent, or trade personal data.

9. International Data Transfers

Personal data may be transferred to and processed in countries outside the United Kingdom or European Union, including the United States, where our service providers or partners are located.

Where required, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) or UK International Data Transfer Agreements (IDTAs), to protect personal data transferred internationally.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, accounting, and fraud-prevention requirements.

Retention periods vary depending on the type of data and the purpose for which it is processed.

11. How We Protect Personal Data

We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or disclosure.

These measures include access controls, encryption, secure infrastructure, and monitoring. However, no system can be guaranteed to be completely secure.

12. Your Data Protection Rights

Depending on your location and applicable law, you may have the right to:

• request access to personal data we hold about you
• request correction or updating of inaccurate data
• request deletion of personal data
• object to or restrict certain processing activities
• withdraw consent where processing is based on consent

Requests can be made by contacting us using the details below. We may need to verify your identity before responding.

13. Data Received from Third Parties

We may receive personal data from third-party organisations that use our services or that provide fraud-prevention, compliance, or verification services.

These organisations operate under their own privacy policies, and we encourage you to review them where applicable.

14. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be published on our website and will take effect from the date of publication.

Further information about our use of cookies and similar technologies is available in our Cookie Policy.

15. How to Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at:

Email: info@mobicode.co.uk

Post:
IMEI Ltd
Halsgrove House
Lower Moor Way
Tiverton Business Park
Tiverton
Devon
EX16 6SS
United Kingdom