Privacy Policy

Version: 1.00 Revision Date: 29/12/2022

This policy informs you about the type of personal data that is collected and received through our websites or applications and about how we use, share, retain and protect such personal data.

Who are we?

We are IMEI Ltd of Halsgrove House, Lower Moor Way, Tiverton Business Park, Tiverton EX16 6SS. Registered in England and Wales with Company Number 08681621. We are the controller responsible for the processing of personal data that we have received in accordance with the General Data Protection Regulation 2018

How do we obtain personal data?

We collect and receive personal data through the following sources:

Data Sources:

These are the website, applications and social media profiles where we may obtain data, and include:

Websites:

• www.mobicode.co.uk
• www.mobi-server.com

Applications:

• MobiCHECK (SmartPhone Application)
• MobiOne (PC & SmartPhone Application)
• MobiWIPE (PC-Based Secure Data Erasure Application)

Social Media Profiles for:

• Mobicode Ltd
• PhoneWipe
• MobiWIPE
• CheckTestWipe
• MobiCHECK

Personal data means any information relating to an identified or identifiable natural person.

We collect personal data that you voluntarily provide to us for your use of our Data Sources, we also collect certain personal data by using cookies, including similar technologies such as local storage when you visit the website.

Cookies are bits of text that are placed on your computer’s hard drive or mobile device when you visit certain websites. Cookies hold information that may be accessible by the party that places the cookie, which is either the website itself (first part cookie) or a third party (third party cookies). You do have control over cookies and can refuse the use of cookies by selecting the appropriate setting on your browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable or delete existing cookies. Please note, however, that by not accepting or deleting the use of cookies, you may not be able to use our websites or applications.

On the websites, we use cookies for the following purposes:

1. To gather website statistical data to analyse how our users use the website, such as which pages are visited, how long pages were visited, and the paths taken by visitors to our website as they move from page to page. These cookies are placed by the domain you have visited
2. To provide authentication (i.e. to keep you logged in between sessions). The information collected using local storage is stored on your browser and persists after your browser is closed.

For the purpose listed under 1, we use Google Analytics. Google Analytics is a web analytics service provided by Google, Inc., which uses cookies to help. The information generated by the cookie about your use of our website (such as your IP address, the URL visited, the date and time the page was viewed) will be transmitted and stored by Google on servers in the United States or any other country in which Google maintains facilities.

If you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter, or giving us a ‘+1’ via Google Plus, those social networks will record that you have done so and may set a cookie for this purpose.

In some cases, where a page on our website includes content from a social network, such as a Twitter feed, or Facebook comments box, those services may set a cookie even where you do not click a button.  As is the case for all cookies, we cannot access those set by social networks, just as those social networks cannot access cookies we set ourselves.

The types of personal data we may obtain

We may collect and receive the following personal data from you:

1. Name and contact details (such as name, address, email, username and phone numbers)
2. Account details (such as username and password)
3. Payment information (such as bank account, PayPal information)
4. Information to help us provide any requested service (such as IMEI or Serial of devices)
5. Information on your use of our websites and applications
6. Personal data included in content or comments uploaded or posted by you to our Data Sources and our help desk
7. Personal data of individuals you wish to share your uploaded content with (such as name and email address)
8. Traffic data (such as your Internet usage and IP address)

We may collect other types of personal data if required under applicable law or if necessary for the purposes listed below. We will then inform you and ensure that there is a valid legitimate basis for doing so.

How we may use personal data

We may use the personal data we collect and receive for the following purposes:

1. To create an account for your use of the Data Sources
2. To complete contracts of service requested by you in our websites or applications
3. To analyse how the websites or applications are used, such as which pages are visited, how long pages were visited, and the paths taken by visitors to our website as they move from page to page, account activity and statistics
4. To verify compliance with applicable legal requirements and our policies
5. To contact you, such as by sending transactional emails related to activity on your account
6. To contact you, such as sending promotional emails expressly for our products and services where you have opted in to receive communications of this type.

How we may share personal data

We may share the personal data we collect and receive on a need to know basis with the following third parties:

1. Service providers
2. Public Authorities such as Law Enforcement and Competent Third Parties such as Insurance Companies, Mobile Operators, ID Verification Partners for the prevention of Crime and Fraud and if required by law or to protect the rights, property and safety of ourselves or others.

We may also transfer your personal data if we sell or transfer all or a portion of our business or assets on a need to know basis. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with applicable law and this Privacy Statement.

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

Data transfers outside the EEA

We may transfer the personal data we obtain to Law Enforcement in countries outside the European Economic Area (EEA) for the prevention of Crime and Fraud. The laws in those countries may not offer an adequate level of data protection.

When we transfer your personal data outside the EEA, we will protect your personal data as described in this Privacy Statement and in accordance with applicable law, such as by entering into the European Commission’s Standard Contractual Clauses for the transfer of personal data to a processor located outside of the European Union.

Receiving data from third party organisations

We may receive data on you from Organisations that utilise our Data Sources to provide solutions directly to you, and also for the prevention of Crime and Fraud. These Organisations have their own privacy policies and we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these Organisations.

How do we protect personal data?

We maintain appropriate technical and organizational security safeguards designed to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, due the inherent open nature of the Internet, we cannot guarantee that communications between you and us or the personal information stored is secure. We will notify you of any data breach that is likely to have unfavourable consequences for your privacy in accordance with applicable law.

How long do we hold personal data for?

We retain personal data for as long as necessary to fulfil the purposes for which we collect or receive the personal data, except if required otherwise by applicable law or the prevention of Crime and Fraud.

Your Rights

You have the following rights in relation to your personal data:

1. The right to obtain, at reasonable intervals and free of charge, information on whether or not your personal data are being processed and to receive the personal data that is being processed in an intelligible form;
2. The right to have your personal data rectified, blocked or deleted if your personal data are incorrect, incomplete, inaccurate, irrelevant, outdated or processed unlawfully.
3. The right to object on legitimate grounds to the processing of your personal data.
4. To exercise these rights, please contact us using our contact details set out below. We may request you to provide a copy of your ID card or otherwise evidence your identity. We will respond to your request within the applicable statutory term.

Privacy Policy Updates

We may update this Privacy Policy from time to time. We will notify you of any significant changes to this Privacy Policy on the website or through other appropriate communication channels. All changes shall be effective from the date of publication, unless otherwise provided in the notification.

How to Contact Us

If you have any comments or inquiries about the information in this Privacy Statement, if you would like us to update your personal data, or to exercise your rights, please contact us by emailing info@mobicode.co.uk or write to us at IMEI Ltd of Halsgrove House, Lower Moor Way, Tiverton Business Park, Tiverton EX16 6SS.