Privacy Policy

Our website and applications are published and operated by the company Mobilu Sarl.

• Address 9 Rue de Bitbourg, L-1273 – Luxembourg
• Telephone +352 661 189 253
• email info@mobilu.eu
• Registered capital x,xxx.xx €
• Registration number xxx xxx xxx – RCS Caen B
• Publication manager David Iachetta
• Hosted by OVH France, 2 Rue Kellermann, 59100 Roubaix – +339 72 10 10 07

Copyright ©

This website complies with copyright. All copyright and other rights reserved in relation to the protected works reproduced on and communicated via this website. Unless authorised, any use of the said works other than for private individual reproduction and consultation is strictly prohibited.

Reproduction in paper form

With the exception of the graphics, the reproduction of the pages of this website in paper form is authorised subject to compliance with the following three conditions:

• That they are circulated free of charge;
• That the integrity of the reproduced documents is respected;
• That any reproduction explicitly mentions the mobilu.eu website as the source and mentions that reproduction rights are reserved and strictly limited.

Reproduction on electronic media

The reproduction of all or part of this website on an electronic medium is authorised on condition that the source is clearly and legibly mentioned (mobilu.eu) along with the wording “All rights reserved”. The information used should only be used for personal, association or professional purposes. Any use for commercial or advertising purposes is prohibited.

Linking to mobilu.eu:

mobilu.eu authorises the creation of hypertext links pointing to its content on condition that:

• The “deep linking” method is not used, i.e., pages from the mobilu.eu website must not be embedded in the pages of another website, but instead must be accessed by opening a window;
• The source is mentioned, which should point to the content by means of a hypertext link;
• The information is only used for personal, association or professional purposes;

Any use for commercial or advertising purposes without Mobilu’s prior consent is strictly prohibited.

Caution! This authorisation does not apply to websites displaying information of a controversial, pornographic, or xenophobic nature or which, more widely, may be considered offensive.

Entry into force on 18 March 2019

Our website and applications collect certain Personal Data from our Visitors and Users. To protect your personal data, Mobilu has ensured that it is fully compliant with the European general data protection regulation (GDPR) which means that you can be sure that the collected data is processed in a responsible and secure manner.

Personal Data (privacy)

The information gathered via our website and applications undergoes computerised processing for the purpose of managing your requests for information concerning our products and to enable us to contact you.

The data recipients are Mobilu and its partners.

Pursuant to the Informatique et Libertés law of 6 January 1978, modified, (the French data protection act) and regulation number 2016/679 otherwise known as the General Data Protection Regulation (GDPR), you have a right to access, rectify or delete information concerning you and a right to data portability. You may exercise your rights and obtain details of the information concerning you by e-mailing gdpr@mobilu.eu. You also have a right to oppose the processing of the data concerning you on legitimate grounds.

Types of Data collected

The following are included among the types of Personal Data that our website and applications collect directly or via third parties: Cookies and Usage Data. Other personal data collected may be described in other parts of this privacy policy or may be the subject of dedicated contextual explanations associated with the Data collection operation.

The Personal Data may be supplied freely by the User or collected automatically when he uses this Application.

Unless mentioned otherwise, the use of Cookies or any other traceability solution by our website and applications, or by the owners of services proposed by third parties used by our website and applications, is intended to identify the User and to record his preferences for the sole purpose of providing the service requested by the latter.

Our website and applications may be unable to supply services if certain Personal Data is not supplied.

The User assumes liability for the Personal data of third parties obtained, published or shared via our website and applications, and confirms that he has obtained the said third parties’ consent to supply this Data to the Owner.

If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and others as part of the application process. We’ll save your data for two years.

What is a cookie?

A “cookie” is a small file generally comprised of letters and numbers sent by the web server to the cookie file of the browser or browsers used by you to surf the Internet.

Types of cookie

Mobilu.eu uses different kinds of cookies:

Session cookies

These cookies enable the website to operate in an optimal manner. You may choose to delete them from your browser although this risks impairing your user experience when surfing on our website.

Audience measurement and analysis cookies

To improve your user experience and to adapt the website to visitors’ requirements, we use tracking cookies, including those from Google Analytics. These cookies measure the number of visits, the number of pages viewed, the users’ activity on the website and their return frequency.

These cookies also determine the town or city from which you are connecting. This data is anonymous and cannot be used to identify the user.

Social networking cookies

The social network sharing plug-ins use cookies which make it possible to track surfers’ browsing history and to propose advertising to users of these networks linked to their interests.

 

Which cookies are used on mobilu.eu?

Data-processing mode and location

Processing methods

The Data Manager processes the Users’ Data in an appropriate manner and takes all necessary security measures to prevent all unauthorised access to, divulgence of, modification of or destruction of the data. The Data Processing is performed with the aid of computers and IT resources and pursuant to procedures and organisational methods closely linked to the stated end purposes. In addition to that reserved for the Data Controller, in certain cases access may be granted to certain categories of persons handling website-related operations (administration, sales, marketing, legal department, systems admin) or external stakeholders (such as third-party suppliers of technical services, messaging services, hosting suppliers, IT companies, and communication agencies) designated where applicable as Data Processors by the Owner. The updated list of these stakeholders can be requested any time from the Data Controller, by e-mailing the address gdpr@mobilu.eu.

Processing site

The Data is processed at the Data Controller’s registered office and any other location at which the parties responsible for processing are located. Please contact the Data Manager for further information.

Data retention periods

The Data is stored for the time required to supply the service requested by the User, or as stated in the objectives described in this document. The maximum retention period for the data collected via the audience measurement and analysis tools will be 13 months in compliance with the General Data Protection Regulation, unless the user has explicitly renewed his consent during this period.

The User may always request its suspension or deletion by contacting the Data Manager.

Use of the Data collected

Data concerning the User is collected to enable the Owner to supply its services.

Further information concerning Data processing and collection

Legal proceedings

The User’s Personal Data may be used for legal purposes by the Data Manager before the courts or in any proceedings leading to legal action resulting from the inappropriate use of this Application or of the related services.

The User is aware that the public authorities may require the Data Manager to divulge the Personal Data.

Further information concerning the User’s Personal Data

In addition to the information contained in this privacy policy, our website and applications may provide the User with further details and contextual information concerning specific services or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance purposes, our applications and any other third-party service may collect files which record interactions with applications (system logs) or use other Personal Data to this end, such as the IP address.

Information not included in this privacy policy

Further information concerning the collection or processing of Personal Data may be requested from the Data Manager at any time. Please see the contact details shown at the beginning of this document.

The User’s rights

At all times, the User has the right to know if his Personal Data is being stored and may contact the Data Manager to learn more about its content and origin, to check its accuracy or to request that it be added to, cancelled, updated or rectified. He may also request that it be converted into an anonymous format or that any data obtained in violation of the law be blocked, or oppose its processing on any legitimate grounds. The right to data portability enables him to recover the collected data in a machine-readable format for personal use or for transfer to a third-party organisation. Requests to this effect should be sent to the Data Manager at the address shown above.

Our website and applications do not process “Do Not Track” requests. Please refer to the privacy policies of the third-party services to determine whether or not they comply with the “Do Not Track” option.

Modifications to this privacy policy

The Data Manager reserves the right to modify this privacy policy at any time, by informing the User of this on this page. We recommend that you consult this page often by referring to the date of the last modification displayed at the bottom of the page. If a User opposes any modification made to this policy he must stop using our applications and request that the Data Manager delete his Personal Data. Unless stated otherwise, the privacy policy applicable at the time will apply to all Personal Data in the Data Manager’s possession concerning the User.

Information concerning this privacy policy

The Data Manager has responsibility for this privacy policy.

Definitions and legal references

Personal Data (or Data)

Any information concerning a natural or artificial person, an institution or an association which is or which could be identified, even directly, with reference to any other information including a personal identification number.

Usage data

The information collected automatically by our website and applications (or by third party services used on our website or applications), which may include the IP addresses or domain names of the computers used by the User using our website and applications, URI addresses (Uniform Resource Identifier), the time of the request, the method used to submit the request to the server, the size of the file received in reply, the numeric code indicating the status of the reply from the server (favourable result, error, etc.), the country of origin, the characteristics of the browser and operating system used by the User, various details concerning visit times (for example the time spent on each page on our website and applications) and details concerning the navigation path through our website and applications with special reference to the sequence the pages visited and other parameters concerning the User’s operating system or IT environment.

The person using our website and applications, who must be the Data Subject or be authorised by the latter, to whom the Personal Data refers.

The Data Subject

The natural or artificial person to whom the Personal Data refers.

Department with responsibility for data processing (or Data Controller)

A natural or artificial person, public authority or any other entity, association or organisation authorised by the Data Manager to process the Personal Data in compliance with this privacy policy.

Data Manager (or Owner)

The natural or artificial person, public authority or any other entity, association or organisation authorised, even jointly with another Data Manager, to take decisions concerning the Personal Data processing objectives and methods, including security measures relating to the operation and use of this Application. Unless stated otherwise, the Data Manager is the Owner of our website and applications.

Legal information

Information for European Users: this privacy policy has been prepared in application of the obligations stated in article 10 of European directive number 95/46/EC and in compliance with the provisions of directive 2002/58/EC, as revised by directive 2009/136/EC concerning cookies and the General Data Protection Regulation (GDPR). This privacy policy applies exclusively to our website and applications.

As a Trusted Service Provider, the security and confidentiality of the data we collect have always been at the heart of our concerns. Mobilu has therefore ensured that it complies with GDPR across all its activities and guarantees the confidentiality of documents and information processed and hosted on our servers and those of our subcontractors.

Our key principles

• Mobilu does not under any circumstances sell your data to third parties.
• We only collect the data necessary for the performance of our services.
• We keep your data for the time necessary to meet our contractual and regulatory obligations and then we delete or anonymise them.
• All data is encrypted.

What data are we talking about?

Mobilu collects, processes and stores confidential data of its customers and third-party signatories such as first and last name, email address, telephone number and IP address. This processing is carried out within the framework of the digital processes service agreement binding Mobilu to its customers. Mobilu retains this data for the entire duration of the agreement.

The data in the audit trail, created during each signature procedure, is retained by the third-party archiver for a period of 10 years from its creation without the expiry or termination of the agreement being able to call into question this retention period.

Details of the data collected, processed and stored by Mobilu are set out in Mobilu’s Privacy Policy.

Who is the controller?

When our customers use our Services, we collect and process certain information on their behalf. Our customers are therefore controllers of the data in accordance with Article 4 of GDPR. Mobilu, as a service provider, then acts as a processor. As such, we undertake to assist our customers in ensuring the compliance of their processing.

How does Mobilu protect your data?

We have technical and organisational measures in place for the security and protection of your data.

For more details, please contact our security officer: julien.bastin@mobilu.eu

What are our commitments?

Mobilu has put in place a series of measures to ensure compliance with GDPR.

• We have a multidisciplinary team with experienced members of the Legal, Technical and Quality teams who ensure Mobilu’s compliance.
• We train our employees and raise their awareness of cybersecurity and data protection.
• We apply the principle of data protection by design when developing new services or improving our existing services.
• We guarantee the exercise of your rights in accordance with the law.
• We guarantee the traceability and control of our processing operations by keeping a record of processing activities.
• We have a procedure for notifying personal data breaches.

Does Mobilu use subcontractors?

Yes. We keep up to date a comprehensive list of all our subcontractors and have ensured that all those who might process personal data undertake to comply with existing legal frameworks. We can provide you with this list upon request.

Are there Cookies?

Yes. Like most sites, we use cookies to facilitate the use of our site, improve its performance and security, converse with you, analyse your visit and better understand your needs in order to support you. We have ensured that the cookies we use comply with privacy rules.

For more details, please refer to our Privacy Policy.

How to access, amend or delete your data or make a complaint?

If you are a Mobilu customer

From your customer space you have the option to amend and update your personal information. For more details, contact us at info@mobilu.eu.

You may also exercise your right of access, rights to rectification, erasure and data portability, and rights to object and restrict processing, in accordance with the regulations in force. To do so, you can send your request by e-mail to the following address: info@mobilu.eu.

If you feel that we have not respected your rights, you may refer the matter to the Supervisory Authority in the country in which you reside.

If you are an external user (not a Mobilu customer)

Mobilu is authorised to process the personal data necessary on behalf of its customers to provide the services to which they have subscribed.

In this case, Mobilu acts as the processor of this data, so we are not authorised to manage your requests regarding rights of access, rights to rectification, erasure and data portability, and rights to object and restrict processing. Therefore, you should directly contact the organisation that uses Mobilu’s services as part of your electronic processes.

Of course, Mobilu is committed to working with its customers to respond to the requests submitted.