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<form class="search-form" action="/es-es/search/">
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PRIVACY POLICY

(Last updated: Aug 4th, 2023)

 

of MobiSystems, Inc.

4501 Mission Bay Drive, Suite 3A

San Diego, CA 92109

(the "Data Controller", "us", "we", or "our")

 

The Data Controller operates
the mobisystems.com, officesuite.com, pdfextra.com and mobidrive.com websites,
the OfficeSuite/ Pro/ Trial, MobiDrive, File Commander, PDF Extra, Oxford
Dictionary of English and Talk & Translate multi-platform applications, as well
as a number of mobile dictionaries and reference sources (the "Service").


Our Service does not address anyone under the age of eighteen ("Child"). In some
countries, we may impose higher age limits as required by the applicable law. We
do not knowingly collect Personal Data of and from Children. If you are a holder
of parental responsibility (a parent or a guardian) and you become aware that
your Child has provided us with Personal Data without your consent or
authorization, please contact us. Once we become aware of that, we will delete
them.


This Privacy Policy aims to acquaint you with the main moments related to the
processing of your personal data. The Data Controller reserves the right to
update it, and its current version will be at your disposal at any time on the
Service as listed above.



I. DEFINITIONS


1. Cookies: means small pieces of data stored on the user’s device. 


2. Data Controller: means a person who (either alone or jointly or in common
with other persons) determines the purposes for which and the way any personal
data are, or are to be, processed.   


3. Data Processor or Service Providers: means a natural or legal person, public
authority, agency, or other body (other than an employee of the Data Controller)
who processes the data on behalf of the Data Controller.  


4. Personal Data: means any information relating to an identified or
identifiable natural person (the "Data Subject") via an identifier such as a
name, an identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental, economic,
cultural, or social identity of that natural person.  


5. Processing: means any operation or set of operations which is performed on
Personal Data or on sets of Personal Data, whether by automated means, such as
collection, recording, organization, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction.  


6. Recipient: means a natural or legal person, public authority, agency, or
another body, to which the personal data are disclosed, whether a third party or
not.  


7. Usage Data: means the data collected automatically either generated using the
Service or from the Service infrastructure itself.   


8. User: means the individual visiting and using our Service. The User
corresponds to the Data Subject. 



II. PRINCIPLES


2.1 The main principles on which the Data Controller bases the processing of
personal data are: (i) legality; (ii) good faith and transparency; (iii)
minimizing data and limiting the purposes and retention period; (iv) accuracy;
(v) integrity and confidentiality; (vi) accountability.


2.1.1 In order for the Processing to be lawful, the Data Controller processes
your Personal Data based on legitimate grounds, when necessary, in the context
of a contract or with an expressed intention to conclude such.


2.1.2 The principle of good faith and transparency requires the Data Controller
to ensure that all information and communication related to the Processing of
your Personal Data is easily accessible and understandable, using clear and
unambiguous wording. This principle applies to the information that you as a
Data Subject receive about the identity of the Data Controller and the purposes
of the Processing, as well as to the additional information guaranteeing
conscientious and transparent Processing.


2.1.3 Compliance with the third principle, namely to minimize data and limit the
purposes and period of storage by the Data Controller, is ensured by collecting
only those data that are absolutely necessary for the purposes and activities of
the Data Controller and its compliance with the legal requirements, as they are
processed only for specific, explicitly stated and legitimate purposes, and are
not processed in a way incompatible with these purposes, and are stored for a
period not longer than necessary or provided by the law.


2.1.4 The principle of accuracy requires that all Personal Data processed by the
Data Controller be accurate and kept up to date, and for this purpose the Data
Controller relies on you as a Data Subject, on your correctness and assistance.
If it proves impossible to correct inaccurate Personal Data provided by you, the
Data Controller shall delete them in a timely manner, considering the purposes
for which they are processed.


2.1.5 In accordance with the principle of integrity and confidentiality, the
Data Controller processes your Personal Data in a way that ensures an
appropriate level of security, including protection against unauthorized or
unlawful processing and against accidental loss, destruction, or damage,
applying appropriate technical or organizational measures.


2.1.6 The principle of accountability comes to ensure before you that everything
the Data Controller does regarding your Personal Data is subject to control and
the Data Controller is responsible for it.


2.2 The Data Controller ensures that all persons involved in the Personal Data
processed by it are familiar with the basic principles set out here, this
Policy, as well as the applicable legal requirements regarding the protection of
your Personal Data.



III. TYPES OF PERSONAL DATA COLLECTED


3.1 While using our Service, we may ask you to provide us with certain Personal
Data. The categories of Personal Data may include, but are not limited to:

 * First name and surname
 * Country and country code
 * Email address
 * Phone number (if applicable)
 * Habitual residence (if applicable)
 * Google, Facebook, Huawei, Microsoft and/ or Apple credentials and profile
   pictures (if applicable)
 * Billing and payment data - credit or debit card number, bank account
   information (if applicable) and information about payments
 * Cookies and Usage Data - device type, device ID and/ or IP address,crash logs
   data, diagnostics data, music files data and other information as clarified
   below (if applicable)
 * Communications and content, including audio, video, text (typed, inked,
   dictated, or otherwise), in a message, email, or chat (if applicable).


3.2 The Data Controller receives your Personal Data in the following ways: (i)
personally from you, when you visit and start using the Service; (ii) from other
sources like Google, Facebook, Apple, etc. but only as supplementary information
to that, already provided voluntarily by you; and (iii) through so-called
Cookies and other unique identifiers.


3.3 Integration with third party services (Google, Facebook, Huawei, Microsoft,
Apple, Stripe, and more) may require exchange of information, such as username,
open ID, single-sign-on tokens, and any other data required for implementation
of said integration. Integration is optional for social media, and necessary for
payments. Any data received from third party service is covered by this Privacy
Policy.


3.4 Please note that when you provide your credit or debit card number on the
Service, this Personal Data is automatically redirected for Processing to our
Service Providers of Payments as enumerated in item 9.4 below. We do not process
this Personal Data ourselves. We process only a derivative information about
your payments (amount paid, date of payment, return, if any, transaction
history, etc.).


3.5 Where required by law, we store the data and information we collect from you
when you are unauthenticated (not signed in) separately from any Account
Personal Data that directly identifies you, such as your name, email address, or
other. If we link other data and information relating to you with your Personal
Data, we will treat that linked data as Personal Data. Please note that, if you
use the unauthenticated version of our Service, you may contact us with a
request concerning your rights as Data Subject, but in this case, we may not be
able to identify you. If such a situation occurs, please go to your Service
settings and explore your options.


3.6 In addition, some of our Service have optional features which, if used by
you, require us to collect additional information to provide such features. You
will be notified of such collection, as appropriate. If you choose not to
provide the information needed to use a feature, you will not be able to use the
respective feature. For example, you cannot open files from your device if you
don't grant file access permission to the respective application. Another
example is the camera access - we ask for permission to access your device’s
camera. If you grant permission, you may be able to take pictures or video
within the app experience. Permissions can be managed through your Account
settings.



IV. GROUNDS FOR PROCESSING


4.1 Once provided, your Personal Data will be processed by us (our authorized
employees/ representatives/ Data Processors) on the following grounds: (i) the
Processing is necessary for the performance of a contract to which you as Data
Subject are party or in order to take steps at your request prior to entering
into any such contract; (ii) the Processing is necessary for compliance with a
legal obligation to which we as Data Controller are subject; and (iii) the
Processing is necessary for the purposes of the legitimate interests pursued by
us as Data Controller or by a third party, except where such interests are
overridden by your interests or fundamental rights and freedoms as Data Subject
which require protection of Personal Data, in particular where you are a Child.


4.2 When you have consented to your Personal Data being processed by the Data
Controller for direct marketing and remarketing purposes, you have the right to
object/ opt out to this at any time in one of the ways described below. Upon
receipt of your objection/ opt out, we shall cease the Processing of your Data
for these purposes.



V. PURPOSES OF PROCESSING


5.1 The Data Controller processes/ uses your Personal Data and Usage Data for
the following purposes:


5.1.1 for provision and maintenance of the Service, its modifications, changes,
updates, or enhancements, including but not limited to, provision of interactive
features associated with the Service; for Service-related announcements; to
detect, prevent and address technical and security issues; for monitoring of the
Service usage; for transfer of your Personal Data to our Service Providers/ Data
Processors; for measuring effectiveness and analysis; for processing of
subscriptions and collection of fees; for execution of distance End-User License
Agreements (whether paid or as a free trial); for returns and reimbursements;
for management of your account; for measures to protect the Service against
fraud, IP rights infringements, cyberattacks and other attempts to harm the
rights, property, piracy or safety of the Data Controller and/ or our employees,
Users, Children, or the public


5.1.2 for direct marketing and remarketing, including but not limited to,
tracking preferences and interests, sending you information about our Services
and/ or special offers, participation in promotions, raffles and competitions,
filling in and submitting questionnaires and quizzes, conducting surveys, market
research, etc.


5.1.3 for customer support, assistance, and solving problems; for investigating
and responding to any comments or complaints


5.1.4 for the observance of legal obligations by the Data Controller, including
arising from the applicable tax and accounting legislation


5.1.5 for the protection of the legitimate rights and interests of the Data
Controller and third parties, in full balance with your interests, fundamental
rights and freedoms


5.1.6 for the transfer of your Personal Data to competent authorities; for
handling various other risks, as well as any other purposes compatible with the
above.


5.2 The Processing of Personal Data for purposes other than those for which they
were originally collected is also permitted when the Processing is compatible
with the purposes for which they were originally collected. Processing for
archiving purposes in the public interest, for scientific or historical research
purposes, or for statistical purposes should be considered as compatible lawful
processing operations.



VI. RETENTION PERIOD


6.1 The Data Controller will retain your Personal Data only for as long as is
necessary for the purposes set out in this Privacy Policy. We will retain and
use your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply with
applicable laws), resolve disputes, and enforce our legal agreements and
policies.


6.2 The Processing of your Personal Data will continue as follows: (i) in cases
where you have filled in and submitted incorrect, incomplete or inaccurate data,
and there is no way to be corrected or updated by the Data Controller, they will
be deleted within one (1) month as of their receipt; (ii) in the case of consent
given for direct marketing, until the Data Controller has received your
objection/ opt-out to the processing of Personal Data for this purpose; (iii) in
cases where the Processing is based on a signed contract - until the final
settlement of the legal relationship between you and the Data Controller and
five (5) years thereafter, except in cases of legal or enforcement proceedings,
tax inspections and/ or audits, as well as when the protection of the legitimate
interests of the Data Controller or third parties requires a longer period. All
these terms will be valid only on condition that laws or by-laws do not provide
for longer or shorter ones. Usage Data is generally retained for short periods,
except when this data is used to strengthen the security or to improve the
functionalities of our Service, or we are legally obligated to retain this data
for longer time periods.


6.3 Please note that the data and information stored under your account in
MobiDrive or in your email inbox shall not be considered as part of the Personal
Data/ Information we receive and process hereunder. Therefore, there may be
other reasons why these data must be deleted or will be deleted by us, for
example, if you exceed limits on how much data and information you are allowed
to store therein. For more information, please refer to our Terms of Use.


6.4 The Data Controller makes regular checks on the Personal Data processed and
stored, and based on the rules contained herein, proceeds with their deletion,
destruction, or anonymization for statistical or research purposes. Regarding
Personal Data, for the storage of which special laws provide for longer periods,
the Data Controller shall take technical and organizational measures for their
archiving so that they are not subject to further Processing and cannot be
amended.



VII. TRANSFER OF PERSONAL DATA. RECIPIENTS


7.1 Your Personal Data may be transferred to and processed on computers located
outside of your state, province, country, or other governmental jurisdiction
where the data protection laws may differ from those of your jurisdiction. Also,
the privacy protections and rights of authorities to access your information may
not be equivalent to those in your country. If you are located outside United
States and choose to use the Service, please note that your Personal Data are
received and processed in the United States. Your Personal Data are stored and
kept safe in Google Cloud Platform. More information thereof you can find on the
following link: https://cloud.google.com/security/infrastructure.


7.2 We will only transfer your Personal Data when appropriate safeguards are put
in place to ensure that they receive adequate protection. Depending on the case,
we transfer or may give access to some of your Personal Data to the following
categories of Recipients: (i) companies from the group to which the Data
Controller belongs; (ii) Service Providers - partners and contractors like
courier service providers, payment/ banking service providers, marketing service
providers, including digital advertising agencies and market research service
providers, IT and hosting service providers, fraud monitoring and prevention
service providers, and other companies with which the Data Controller develops
joint programs; (iii) public government bodies and organizations, where this is
necessary in order to protect the legitimate interests of the Data Controller or
third parties, or where it is provided for as a legal obligation.


7.3 The Data Controller may entrust the processing of your Personal Data on its
behalf only to Data Processors who provide sufficient guarantees that they will
apply appropriate technical and organizational measures in such a way that the
Processing complies with legal requirements, this Privacy Policy, and ensures
the adequate protection of your interests, fundamental rights, and freedoms. We
always use HTTPS protocol while transferring your Personal and/ or Usage Data.


7.4 If the Data Controller merges with or is acquired by another company, sells
a Service, or business unit, or if all or a substantial portion of our assets
are acquired by another company, your Personal Data will likely be disclosed to
our advisers and any prospective purchaser's advisers and will be one of the
assets that is transferred to the new owner.



VIII. DISCLOSURE FOR LAW ENFORCEMENT


Under certain circumstances, we may be obliged to disclose your Personal Data by
law or in response to valid requests by public authorities (e.g., a court or a
government authority). Therefore, we may disclose your Personal Data in the good
faith belief that such action is necessary to:

 * comply with a legal obligation, a subpoena, a court or administrative order
   or another official act of a competent public or government authority
 * protect and defend the rights or property of the Data Controller
 * prevent or investigate possible wrongdoing in connection with the Service
 * protect the personal safety of our employees, Users, Children, or the public
 * respond to an emergency involving the danger of death or serious bodily harm
 * protect ourselves against legal liability.



IX. COOKIES. USAGE DATA. SERVICE PROVIDERS. OTHERS


9.1 Cookies. We use cookies and similar tracking technologies to track the
activity on our Service and hold certain information. Cookies are files with
small amount of data which may include an anonymous unique identifier. Cookies
are sent to your browser from a website and stored on your device. Tracking
technologies also used are beacons, tags, and scripts to collect and track
information and to analyze the performance of and improve our Service. You can
instruct your browser to refuse all cookies or to indicate when a cookie is
being sent. However, if you do not accept cookies, you may not be able to use
some portions of our Service. Examples of Cookies we use:

 * Necessary Cookies: we use Necessary Cookies to operate our Service. They help
   make the Service usable by enabling basic functions and access to secure
   areas. The Service cannot function properly without these cookies.
 * Preference Cookies: we use Preference Cookies to remember your preferences
   and various settings. They enable the Service to remember information that
   changes the way it behaves or looks like your preferred language or the
   region that you are in.
 * Statistic Cookies: we use Statistic Cookies to help us understand how you
   interact with the Service by collecting and reporting information
   anonymously.
 * Security Cookies: we use Security Cookies for security purposes.
 * Advertising Cookies: we use Advertising Cookies to serve you with
   advertisements that may be relevant to you and your interests.


Via our cookie banner the Data Controller collects and stores your prior,
explicit, and affirmative consent before using cookies and trackers, or any
other technology that stores Personal Data on your terminal equipment (hardware
and software) and before allowing third-party interference into your electronic
communications. You can control the use of cookies at the individual browser
level. If you reject cookies, you may still use our Service, but your ability to
use some of its features or areas may be limited.


9.2 Usage Data. We may also collect Usage Data that your browser sends whenever
you visit our Service or when you access the Service by or through a computer or
a mobile device. This Usage Data may include information such as your computer's
Internet Protocol address (e.g., IP address), browser type, browser version,
search terms, entered into a search engine which led you to our Service, types
of apps and websites of your interest, the pages of our Service that you visit,
the time and date of your visit, the time spent on those pages, unique device
identifiers, and other logs and diagnostic data. When you access the Service by
or through a mobile device, this Usage Data may include information such as the
type of mobile device you use, your mobile device unique ID, the IP address of
your mobile device, your mobile operating system, the type of mobile Internet
browser you use, and other logs and diagnostic data.


9.3 We may employ third party companies and individuals to facilitate our
Service ("Service Providers"), to provide the Service on our behalf, to perform
Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform the tasks
assigned on our behalf and are obligated not to disclose or use them for any
other purposes whatsoever.


9.3.1 Service Providers of Analytics Data: 


a) Google Analytics and Firebase are web and application analytics services
offered by Google that track and report website and applications traffic and
information about your device. This information is automatically uploaded to the
Google servers and used to provide better services to the Users. Google uses the
data collected to track and monitor the use of our Service. This data is shared
with other Google services. Google may use the collected data to contextualize
and personalize the ads of its own advertising network. For more information on
the privacy practices of Google, please visit the Google Privacy Terms web page:
https://policies.google.com/privacy


b) Flurry Analytics service (for iOS products only) is provided by Yahoo!
Inc. You can opt-out from Flurry Analytics service to prevent Flurry Analytics
from using and sharing your information by visiting the Flurry's Opt-out
page: https://developer.yahoo.com/flurry/end-user-opt-out. For more information
on the privacy practices and policies of Yahoo!, please visit their Privacy
Policy page: https://developer.yahoo.com/flurry/end-user-opt-out.


c) Hotjar (used for websites Services only) is a technology service that helps
us better understand our Users` experience and this enables us to build and
maintain our Service with User feedback. For further details, please see
Hotjar’s privacy policy by clicking on this link:
https://www.hotjar.com/legal/policies/privacy/. You can opt-out HotJar services
by following this link https://www.hotjar.com/policies/do-not-track/.


d) We use Adjust in our Android and iOS apps when conducting our marketing
campaigns. Adjust may gather some analytics or statistical consumer data on our
behalf to help us better understand how Users use our apps, and how our
marketing campaigns are performing. For in-depth information about Adjust,
see https://www.adjust.com/terms/privacy-policy/. To opt out of tracking by
Adjust follow this link https://www.adjust.com/forget-device/.


e) We use AppsFlyer in our Android and iOS apps to gather basic statistical
information and user data. This data helps us track the progress of our
marketing campaigns and allows us to better understand how Users use our apps.
For more information on the data gathered by AppsFlyer,
see https://www.appsflyer.com/legal/privacy-policy/. To opt out of tracking by
AppsFlyer follow this link https://www.appsflyer.com/legal/opt-out/.


f) We use AdMost in our Android, iOS and Windows apps when conducting our
marketing campaigns. AdMost may gather some analytics or statistical consumer
data and information on our behalf to help us better understand how Users use
our apps, and how our marketing campaigns are performing. For in-depth
information about AdMost, see https://resources.admost.com/privacy-policy/.


g) We use Microsoft Clarity on our website, which is a GDPR compliant user
behavior analytics tool. It helps us understand how users are interacting with
your website through features such as session replays and heatmaps. For further
details, please see Microsoft Hotjar’s privacy policy at
https://privacy.microsoft.com/en-us/privacystatement


9.3.2 Service Providers of Advertising Data:


a) AdMob by Google is provided by Google Inc. You can opt-out from AdMob by
Google service by following the instructions described by
Google: https://support.google.com/ads/answer/2662922?hl=en. For more
information on how Google uses the collected information, please visit the "How
Google uses data when you use our partners' sites or app"
page: http://www.google.com/policies/privacy/partners/ or visit the Privacy
Policy of Google: http://www.google.com/policies/privacy/.


b) Meta Audience Network is used in our Android and iOS apps when conducting our
marketing campaigns. They have developed a targeting technology which allows
advertisements to reach a specific audience. While posting an ad, an advertiser
is provided a set of characteristics that will define his target market. For
in-depth information about Meta Audience Network, please see
https://www.facebook.com/audiencenetwork/.


c) Google Ads remarketing service is provided by Google Inc. You can opt-out of
Google Analytics for Display Advertising and customize the Google Display
Network ads by visiting the Google Ads Settings
page: http://www.google.com/settings/ads. Google also recommends installing the
Google Analytics Opt-out Browser Add-on
- https://tools.google.com/dlpage/gaoptout - for your web browser. Google
Analytics Opt-out Browser Add-on provides visitors with the ability to prevent
their data from being collected and used by Google Analytics. For more
information on the privacy practices of Google, please visit the Google Privacy
Terms web page: http://www.google.com/intl/en/policies/privacy/.


d) A4G - is an advertising service provider. It manages mobile ad sources in our
Android and iOS app by providing full suite of video, rich media, interstitial &
native ad formats. For more information on the privacy practices of A4G, please
visit: https://a4g.com/privacy.


e) CJ is an affiliate marketing company. Their services help us meet consumer
needs by providing up-to-date offers. Please visit their Services Privacy Policy
at https://www.cj.com/legal/privacy-policy-services if you want to learn more
about the personal data they collect and use about consumers when providing
affiliate marketing services.


f) Trustpilot is a a digital platform that hosts reviews to help consumers shop
with confidence and deliver rich insights to help businesses improve the
experiences they offer. Please visit their Privacy Policy at
https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms.


9.4 Service Providers of Payments. Our Service is provided not only for free but
also against monetary consideration. In the latter case, we use payment/ banking
service providers who adhere to the standards set by PCI-DSS as managed by the
PCI Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the
secure handling of payment information.  Once collected by us, your credit or
debit card number  is provided directly to our third-party payment service
providers whose use of your Personal Data is governed by their Privacy Policies.
They are as follows:


 1. a) Microsoft Store at https://www.microsoft.com/en-us/store/apps/windows

 2. b) Huawei App Gallery at https://appgallery.huawei.com/

 3. c) Apple Store In-App Payments at https://www.apple.com/legal/privacy/en-ww/

 4. d) Google Play In-App Payments at https://www.google.com/policies/privacy/

 5. e) Stripe at https://stripe.com/us/privacy

 6. f) PayPal at https://www.paypal.com/webapps/mpp/ua/privacy-full

9.5 Others:


a) Behavioral Remarketing used by us to advertise on third party websites to you
after you visited our Service. We and our third-party vendors use cookies to
inform, optimize and serve ads based on your past visits to our Service. You can
prevent the Service Providers engaged in behavioral advertising, which collect
data about your online browsing activities and use it to show you targeted ads
by submitting opt-outs. Opting-out will only prevent targeted ads, so you may
continue to see generic (non-targeted) ads. You may opt out to behaviorally
targeted ads anytime by deleting your browser's cookies.


b) "Do Not Track" Signals. We do not support Do Not Track ("DNT"). DNT is a
preference you can set in your web browser to inform websites that you do not
want to be tracked. You can enable or disable it by visiting the Preferences or
Settings page of your web browser.


c) Conversion Tracking. We use Facebook Pixel for conversion tracking, which is
the measurement of media performance with reference to campaign key performance
indicators (KPIs). For more information, please visit this link:
https://www.facebook.com/business/learn/facebook-ads-pixel.


d) Sentry.io is used in our Windows apps for error and performance monitoring to
help us diagnose, fix, and optimize our applications. For more information,
please visit this link: https://sentry.io/privacy/.


e) mconverter.eu is used in our apps and websites as a provider of file
conversion related services. For more information on their privacy, please visit
this link: https://mconverter.eu/#privacy.


f) Zamzar is used in our apps and websites as another provider of file
conversion services. For more information on their privacy, please visit this
link: https://developers.zamzar.com/privacy.


g) ABBYY is used in our apps and websites as an automated cloud OCR service that
transforms documents into structured, actionable, process-ready content. For
more information on their privacy, please visit this link:
https://www.abbyy.com/privacy/.



X. LINKS TO OTHER WEBSITES


Our Service may contain links to other websites that are not operated by us. If
you click on a third-party`s link, you will be directed to that third party's
website. We strongly advise you to review the Privacy Policy of every site you
visit. We have no control over and assume no responsibility for the content,
privacy policies or practices of any third-party websites or services.



XI. ACCOUNT


11.1 Some of our Services may require that you create an account with us
("Account"). When you create a personal Account, you will be asked to provide
certain Personal Data and we will assign a unique ID number to identify your
Account and the associated information. Thus, you become an Account Holder.
Signing into your Account enables personalization, consistent experiences across
products and devices, permits you to use cloud data storage, allows you to make
payments using payment methods stored in your Account, and enables other
features such as chats, file sharing and others. We may use the Personal Data
provided therein for the purposes as enumerated in item 5.1 above, including but
not limited to contact you via email messages regarding your Account and
maintenance related issues, newsletters, as well as marketing or promotional
information that may be of your interest. You may object/ opt out of receiving
any or all these marketing communications from us by following the unsubscribe
link or instructions provided in any email we send or by contacting us using the
details provided herein.


11.2 Once created, the use of your Account is at your own risk. Please do not
buy, sell, transfer, rent, and/ or lease your Account and/ or password to
anyone. We will not take any responsibility for the use of your Account by
others that is caused by your actions or negligent password keeping.


11.3 Please keep your Personal Data accurate and up to date. Whenever made
possible, you can also update your Personal Data directly within your Account
settings. If you are unable to do this by yourself, please contact us to make
the necessary changes.


11.4 You can also close your Account. When you close your Account, we begin
deleting certain Personal Data and Information that we no longer have a business
reason to retain. However, we typically retain Personal Data related to our
contracts and business transactions for five years after your last interaction
with us or upon the contract expiration. Please be advised that in this case you
will lose your Account`s preferences, synchronized settings on different devices
and any data stored in MobiDrive and Chats. We cannot restore any of these once
your Account is closed. For more information on this topic please check our
Terms of Use.



XII. SECURITY OF DATA


12.1 The Data Controller undertakes to apply appropriate technical and
organizational measures to ensure an appropriate level of security of your
Personal Data. In assessing the appropriate level of security, account shall be
taken of the risks associated with the Processing, and in particular the risks
of accidental or unlawful destruction, loss, alteration, unauthorized
disclosure, or access.


12.2 With regard to automated processing, the Data Controller is applying
measures aiming at:


12.2.1 control over access to equipment - to deny unauthorized persons access to
the equipment used for Personal Data Processing


12.2.2 control of data carriers - to prevent reading, copying, modification or
removal of data carriers by unauthorized persons


12.2.3 control over storage - to prevent the entry of Personal Data by
unauthorized persons, as well as the performance of checks, modification, or
deletion of stored Personal Data by unauthorized persons


12.2.4 consumer control - to prevent the use of automated processing systems by
unauthorized persons through the use of data transmission equipment


12.2.5 control over access to data - to ensure that persons who are allowed to
use an automated processing system have access only to the Personal Data covered
by their access authorization


12.2.6 control over communication - to ensure the possibility of verification
and establishment of which persons have been or may be transferred Personal
Data, or which persons have access to Personal Data through data transmission
equipment


12.2.7 control over data entry - to ensure the possibility for subsequent
verification and establishment of what Personal Data have been entered into the
automated processing systems, as well as when and by whom they were entered


12.2.8 control over the transfer - to prevent the reading, copying, modification
or deletion of Personal Data by unauthorized persons during the transfer of
Personal Data or during the transfer of data carriers


12.2.9 recovery - to ensure the possibility of recovery of the installed systems
in case of failure of the functions of the systems


12.2.10 reliability - to ensure the implementation of the functions of the
system and the reporting of defects in the functions


12.2.11 integrity - to ensure that the stored personal data is not damaged due
to improper functioning of the system.


12.3 Through measures under the previous point, the Data Controller is aiming to
ensure the protection of Personal Data at the design stage, considering the
achievements of technical progress, implementation costs and the nature, scope,
context, and objectives of Personal Data Processing, as well as risks to the
rights and freedoms of individuals.


12.4 We follow generally accepted standards to protect the Personal Data
submitted to us during Processing including HTTPS. However, no method of
transmission over the Internet, or method of electronic storage, is 100% secure.
Therefore, we do not guarantee the Personal Data absolute security.



XIII. YOUR RIGHTS AS DATA SUBJECT. GENERAL STANDARDS


The Data Controller respects your privacy no matter where your habitual
residence is. We hereby provide you with the right to request access,
correction, completion, update, and/ or erasure of your Personal Data. We will
aim to address all you request, complaints and/ or worries within reasonable
time as of their receipt by being compliant with our high standards for Personal
Data protection and the applicable legislation.



XIV. YOUR RIGHTS AS DATA SUBJECT IN CASE YOU HAVE HABITUAL RESIDENCE IN EU. GDPR
COMPLIANCE


14.1 Although the main establishment of the Data Controller is in California
(USA), this Privacy Policy takes under consideration and is made to comply with
the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27
April 2016 on the protection of natural persons regarding the processing of
personal data and on the free movement of such data ("GDPR"). In addition, we
have implemented processes in place to support Users having habitual residence
in EU to receive information how their Personal Data is processed and how to
exercise their rights, which are as follows:


14.1.1 Right of access: you have the right to obtain from the Data Controller
confirmation as to whether or not Personal Data concerning you are being
processed, and, where that is the case, access to the Personal Data and the
following information: (a) the purposes of the Processing; (b) the categories of
Personal Data concerned; (c) the Recipients or categories of Recipient to whom
the Personal Data have been or will be disclosed, in particular Recipients in
third countries or international organizations; (d) where possible, the
envisaged period for which the Personal Data will be stored, or, if not
possible, the criteria used to determine that period; (e) the existence of the
right to request from the Data Controller rectification or erasure of Personal
Data or restriction of Processing of Personal Data concerning you or to object
to such Processing when it is marketing purposes; (f) the right to lodge a
complaint with a supervisory authority; (g) where the Personal Data are not
collected from you, any available information as to their source; (h) the
existence of automated decision-making, including profiling or at least in those
cases, meaningful information about the logic involved, as well as the
significance and the envisaged consequences of such Processing for you and (i)
other processing-relevant information.


14.1.2 Right to rectification: you shall have the right to obtain from the Data
Controller without undue delay the rectification of inaccurate Personal Data
concerning you - right to have incomplete Personal Data completed, including by
means of providing a supplementary statement.


14.1.3 Right to erasure ("to be forgotten"): you have the right to request the
Data Controller to delete without undue delay the Personal Data that concern
you, when they are no longer needed for the purposes for which they were
collected and/ or processed; when you withdraw your consent, on which their
processing is based and there is no other legal basis for it; when you object to
their Processing for the purposes of direct marketing and there are no
legitimate grounds for processing to take precedence; when your Personal Data is
processed in violation of the principles outlined above; when it must be deleted
in order to comply with a legal obligation for the Data Controller or the
Personal Data have been collected in relation to the offer of information
society services. This right shall not apply to the extent that Processing is
necessary: (a) for exercising the right of freedom of expression and
information; (b) for compliance with a legal obligation to which the Data
Controller is subject or for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the Data Controller;
(c) for reasons of public interest in the area of public health; (d) for
archiving purposes in the public interest, scientific or historical research
purposes or statistical purposes in so far as the right is likely to render
impossible or seriously impair the achievement of the objectives of that
Processing; or (e) for the establishment, exercise or defense of legal claims.


14.1.4 Right to restriction of Processing: the Data Controller restricts the
processing of Personal Data without deleting them when: (i) the accuracy of the
Personal Data is disputed by you as a Data Subject and this cannot be verified,
or (ii) Personal Data must be kept for evidentiary purposes.


14.1.5 Right to data portability: you have the right to receive the Personal
Data concerning you, in a structured, commonly used, and machine-readable format
and have the right to transmit those data to another controller without
hindrance from the Data Controller to which the Personal Data have been
provided, when the Processing is based on a contractual obligation and is
performed in an automated manner. This right of yours cannot adversely affect
the rights and freedoms of others.


14.1.6 Right of objection: If you have consented to the Processing of your
Personal Data for the purposes of direct marketing, you have the right to object
to this Processing at any time, including when it involves profiling. In any
such case, the Processing of your Personal Data for the purposes of direct
marketing is suspended.


14.1.7 In addition you have the right not to be the subject of a decision based
solely on automated processing, including profiling, which has legal
consequences for you and affects you significantly. In case you exercise this
right, the Data Controller is obliged to apply appropriate measures to protect
your rights, freedoms, and legitimate interests, ensuring human intervention and
giving you the right to express your point of view and challenge its decision.


14.2 As a Data Subject, you may exercise the rights above by submitting a
written application to the Data Controller. The application can be submitted by
mail (at the address of the Data Controller or by e-mail). The application must
contain: (i) name, surname, habitual residence, IP address (if applicable); (ii)
a description of the request; (iii) a preferred form of obtaining information in
the exercise of rights; (iv) signature, date of filing of the application. When
the Data Controller has reasonable concerns, it may request additional
information needed to verify your identity. The Data Controller satisfies your
requests completely free of charge within (1) month of receipt. The period may
be extended by two (2) months when this is necessary due to the complexity or
number of requests. Where requests from a Data Subject are manifestly
unreasonable or excessive, in particular because of their recurrence, the Data
Controller may: (i) charge a fee commensurate with the administrative costs of
providing the information or correspondence, or of acting on the request, or
(ii) refuse to act on the request. Each time the Data Controller refuses to
accept an application submitted by you for the exercise of the rights above, you
will receive a written refusal, as well as the reasons for it. In these and
other cases, the Data Controller will also inform you of your right to appeal or
seek a court redress.


14.3 A register that contains information on submissions, considerations, and
responses to all Data Subjects` requests will be kept by the Data Controller.


14.4 In case of the Personal Data breach, and provided that, it is likely to
result in a high risk to your rights and freedoms, we will notify you thereof
without undue delay and describe in clear and plain language the nature of the
Personal Data breach, the likely consequences of it and the measures taken or
proposed to be taken by us to address it, including, where appropriate, measures
to mitigate its possible adverse effects. In some cases the communication shall
not be required, especially when: (i) we have implemented appropriate technical
and organizational protection measures, and those measures were applied to the
Personal Data affected by the Personal Data breach, such as encryption; (ii) we
have taken subsequent measures which ensure that the high risk to your rights
and freedoms is no longer likely to materialize; (iii) it would involve
disproportionate effort, in which case, you will be informed in an equally
effective manner like via a public communication or other.


14.5 In case of a violation of your rights under GDPR you have the right to
refer to the competent supervisory authority at your habitual place of residence
within six (6) months as of the violation discovery, but not later than two (2)
years from its occurrence. You have an additional opportunity to file a claim
against us before the competent court. In this proceeding you can seek
compensation for the damages suffered by you as a result of illegal Processing
of your Personal Data.



XV. YOUR RIGHTS AS DATA SUBJECT IN CASE YOU ARE A CALIFORNIA RESIDENT. CCPA
COMPLIANCE


15.1 WE DO NOT SELL OR RENT ANY COLLECTED PERSONAL DATA AND INFORMATION WITH ANY
THIRD PARTY. However, while providing you with the Service, we may share some
personal information about you with third parties with which the Data Controller
develops joint programs or uses as Service Providers. Such information sharing
may be considered a “sale” under the California Consumer Privacy Act of 2018, as
amended ("CCPA").


15.2 The CCPA defines Personal Information as information that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular consumer or
household, inter alia, (i) identifying information, such as real name, postal
address, unique personal identifier, IP address, email address, account name,
social security number, passport number, driver’s license number, or other
similar identifiers; (ii) commercial information, including records of personal
property, products, or services purchased; purchases considered; or other
purchasing histories; (iii) browsing history, search history, and information
regarding a consumer’s interaction with a website or advertisement; (iv)
geolocation data; (v) education information; (vi) inferences drawn from this
information, such as personal characteristics, predispositions, intelligence,
aptitude, etc. Therefore, if you are a California resident and a User of our
Service, please be advised of the additional rights for California consumers,
which are summarized below.


15.2.1 Right of access: you have the right to request (and receive) disclosure
from us regarding: (i) specific pieces of Personal Information collected about
you; (ii) categories of Personal Information collected; (iii) categories of the
sources from which the information was collected; (iv) categories of Personal
Information that we share or disclosed for a business purpose; (v) categories of
third parties with whom the Personal Information was shared or disclosed; and
(vi) the business or commercial purpose for collecting or sharing Personal
Information. This disclosure is limited to information collected, sold, or
disclosed in the past 12 months and does not cover sensitive information like
consumer's social security number, driver's license number, account password or
financial account numbers. In addition, we are not required to search for
Personal Information if we: (i) do not maintain the Personal Information in a
searchable or reasonably accessible format; (ii) maintain the Personal
Information solely for legal or compliance purposes; (iii) do not sell the
Personal Information and do not use it for any commercial purpose; and (iv)
describe to you the categories of records that may contain Personal Information
that we did not search because it meets the three conditions stated above.


15.2.2 Right to request deletion: you also have a right to request your Personal
Information to be deleted. In this case, we will: (i) permanently and completely
erase your Personal Information on existing systems and direct our partners and/
or Service Providers to do so, provided that, no exceptions are in place, or
de-identifying the information or otherwise modifying it to make it unreadable
or undecipherable through any means, and notify you that your Personal
Information have been backed up or archived and will be deleted when those
systems are next accessed. Neither we, nor our Service Providers are required to
comply with your deletion request, if the Personal Information is necessary to:
(i) complete a transaction for which the Personal Information was collected,
provide a good or service requested by you, or otherwise perform a contract
between us and you; (ii) detect security incidents, protect against malicious,
deceptive, fraudulent, or illegal activity (or prosecute those responsible);
(iii) debug to identify and repair errors that impair existing intended
functionality; (iv) exercise or ensure the right of another to exercise free
speech or another legal right; (v) comply with a legal obligation; or (vi)
otherwise use the information internally in a lawful manner compatible with the
context in which you have provided it.


15.2.3 Right to opt-out of the sale of personal information. CCPA Regulations
require us to treat your user-enabled global privacy controls, such as a browser
plug-in or privacy setting, device setting, or other mechanism, that communicate
or signal your choice to opt-out of the sale of your Personal Information as
valid opt-out requests. We must comply with it as soon as feasibly possible, but
at least within 15 days from receiving the request. Please be advised that in
practice the following scenarios involving transfers of Personal Information
between entities are potentially excluded from the scope of a "sale": (i) the
linking, at the consumer's request, of one online account to another; (ii)
sharing a particular device identifier with vendors to give effect to a
consumer's opt-out request; (iii) standard relationships with third party
vendors or service providers who process data, provided appropriate contractual
restrictions are in place; or transfers of data on a merger, acquisition or
insolvency event.


15.2.4 Right to opt-out of receiving electronic communications from us. If you
no longer want to receive marketing-related emails from us, you may opt-out via
the unsubscribe link included in such emails. We will try to comply with your
request(s) as soon as reasonably practicable. Please note that if you opt-out of
receiving marketing-related emails from us, we may still send you other messages
in connection with providing our Service.


15.3 Upon verifying your identity, we will notify you that your request has been
received and is being processed. We will respond within 45 days after
verification to any of your access requests and deletion requests. The 45-day
response time can be extended but only with appropriate notice and explanation.
The Data Controller maintains records of your requests.


15.4 To meet CCPA requirements under item 15.2.3, provide links to the relevant
opt out methods of our Service Providers as per item 9.3 above.


15.5 Non-discrimination: the CCPA provides that you may not be discriminated
against for exercising the above rights. You can also designate an authorized
agent to exercise these rights on your behalf. We may require that you provide
the authorized agent with written permission to act on your behalf and that the
authorized agent verify their identity directly with us.


15.6 In addition to the above, we comply with the requirements of the Privacy
Rights for California Minors in the Digital World Act ("the Eraser Law") as far
as it is applicable to our Service. This law provides additional protections to
individuals under the age of 18 in California, including a right to be
forgotten, which enable minors to remove their own posts (but not republications
of their posts or posts about them by others). The Eraser Law also prohibits
companies who operate websites or online services directed at minors from using
the minor's personal information to market or advertise certain enumerated
products and services deemed potentially harmful for them.


15.7 Data Breach Notification under Cal. Civ. Code §§1798.29, 1798.82 and
1798.84. We will notify you in due time of any unauthorized acquisition of
unencrypted computerized data that contains your Personal Information. This is
in addition to any other specific notification obligations for data breaches
contained in other statutes.



XVI. AMENDMENTS AND SUPPLEMENTS


We may update this Privacy Policy from time to time. The updated version of this
Privacy Policy will be posted on the Service. Please review it periodically
because any and all amendments and/ or supplements will become effective when
posted.


Please do not hesitate to contact our Data Protection Officer (DPO) Mr. Stoyan
Gogov at privacy@mobisystems.com in case you need assistance or clarification,
want to exercise your legal rights, or file a complaint.

(Last updated: March 15th, 2023)


of MobiSystems, Inc.

4501 Mission Bay Drive, Suite 3A

San Diego, CA 92109

(the "Data Controller", "us", "we", or "our")

 

The Data Controller operates
the mobisystems.com, officesuite.com, pdfextra.com and mobidrive.com websites,
the OfficeSuite/ Pro/ Trial, MobiDrive, File Commander, PDF Extra, Oxford
Dictionary of English and Talk & Translate mobile applications for Android and
iOS, the OfficeSuite, MobiDrive and PDF Extra software for Windows Desktop, as
well as a number of mobile dictionaries and reference sources (the "Service").


Our Service does not address anyone under the age of eighteen ("Child"). In some
countries, we may impose higher age limits as required by the applicable law. We
do not knowingly collect Personal Data of and from Children. If you are a holder
of parental responsibility (a parent or a guardian) and you become aware that
your Child has provided us with Personal Data without your consent or
authorization, please contact us. Once we become aware of that, we will delete
them.


This Privacy Policy aims to acquaint you with the main moments related to the
processing of your personal data. The Data Controller reserves the right to
update it, and its current version will be at your disposal at any time on the
Service as listed above.



I. DEFINITIONS


1. Cookies: means small pieces of data stored on the user’s device. 


2. Data Controller: means a person who (either alone or jointly or in common
with other persons) determines the purposes for which and the way any personal
data are, or are to be, processed.   


3. Data Processor or Service Providers: means a natural or legal person, public
authority, agency, or other body (other than an employee of the Data Controller)
who processes the data on behalf of the Data Controller.  


4. Personal Data: means any information relating to an identified or
identifiable natural person (the "Data Subject") via an identifier such as a
name, an identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental, economic,
cultural, or social identity of that natural person.  


5. Processing: means any operation or set of operations which is performed on
Personal Data or on sets of Personal Data, whether by automated means, such as
collection, recording, organization, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction.  


6. Recipient: means a natural or legal person, public authority, agency, or
another body, to which the personal data are disclosed, whether a third party or
not.  


7. Usage Data: means the data collected automatically either generated using the
Service or from the Service infrastructure itself.   


8. User: means the individual visiting and using our Service. The User
corresponds to the Data Subject. 



II. PRINCIPLES


2.1 The main principles on which the Data Controller bases the processing of
personal data are: (i) legality; (ii) good faith and transparency; (iii)
minimizing data and limiting the purposes and retention period; (iv) accuracy;
(v) integrity and confidentiality; (vi) accountability.


2.1.1 In order for the Processing to be lawful, the Data Controller processes
your Personal Data based on legitimate grounds, when necessary, in the context
of a contract or with an expressed intention to conclude such.


2.1.2 The principle of good faith and transparency requires the Data Controller
to ensure that all information and communication related to the Processing of
your Personal Data is easily accessible and understandable, using clear and
unambiguous wording. This principle applies to the information that you as a
Data Subject receive about the identity of the Data Controller and the purposes
of the Processing, as well as to the additional information guaranteeing
conscientious and transparent Processing.


2.1.3 Compliance with the third principle, namely to minimize data and limit the
purposes and period of storage by the Data Controller, is ensured by collecting
only those data that are absolutely necessary for the purposes and activities of
the Data Controller and its compliance with the legal requirements, as they are
processed only for specific, explicitly stated and legitimate purposes, and are
not processed in a way incompatible with these purposes, and are stored for a
period not longer than necessary or provided by the law.


2.1.4 The principle of accuracy requires that all Personal Data processed by the
Data Controller be accurate and kept up to date, and for this purpose the Data
Controller relies on you as a Data Subject, on your correctness and assistance.
If it proves impossible to correct inaccurate Personal Data provided by you, the
Data Controller shall delete them in a timely manner, considering the purposes
for which they are processed.


2.1.5 In accordance with the principle of integrity and confidentiality, the
Data Controller processes your Personal Data in a way that ensures an
appropriate level of security, including protection against unauthorized or
unlawful processing and against accidental loss, destruction, or damage,
applying appropriate technical or organizational measures.


2.1.6 The principle of accountability comes to ensure before you that everything
the Data Controller does regarding your Personal Data is subject to control and
the Data Controller is responsible for it.


2.2 The Data Controller ensures that all persons involved in the Personal Data
processed by it are familiar with the basic principles set out here, this
Policy, as well as the applicable legal requirements regarding the protection of
your Personal Data.



III. TYPES OF PERSONAL DATA COLLECTED


3.1 While using our Service, we may ask you to provide us with certain Personal
Data. The categories of Personal Data may include, but are not limited to:

 * First name and surname
 * Country and country code
 * Email address
 * Habitual residence (if applicable)
 * Google, Facebook, Huawei, Microsoft and/ or Apple credentials and profile
   pictures (if applicable)
 * Billing and payment data - credit or debit card number, bank account
   information (if applicable) and information about payments
 * Cookies and Usage Data - device type, device ID and/ or IP address, and other
   information as clarified below (if applicable)
 * Communications and content, including audio, video, text (typed, inked,
   dictated, or otherwise), in a message, email, or chat (if applicable).


3.2 The Data Controller receives your Personal Data in the following ways: (i)
personally from you, when you visit and start using the Service; (ii) from other
sources like Google, Facebook, Apple, etc. but only as supplementary information
to that, already provided voluntarily by you; and (iii) through so-called
Cookies and other unique identifiers.


3.3 Integration with third party services (Google, Facebook, Huawei, Microsoft,
Apple, Stripe, and more) may require exchange of information, such as username,
open ID, single-sign-on tokens, and any other data required for implementation
of said integration. Integration is optional for social media, and necessary for
payments. Any data received from third party service is covered by this Privacy
Policy.


3.4 Please note that when you provide your credit or debit card number on the
Service, this Personal Data is automatically redirected for Processing to our
Service Providers of Payments as enumerated in item 9.4 below. We do not process
this Personal Data ourselves. We process only a derivative information about
your payments (amount paid, date of payment, return, if any, transaction
history, etc.).


3.5 Where required by law, we store the data and information we collect from you
when you are unauthenticated (not signed in) separately from any Account
Personal Data that directly identifies you, such as your name, email address, or
other. If we link other data and information relating to you with your Personal
Data, we will treat that linked data as Personal Data. Please note that, if you
use the unauthenticated version of our Service, you may contact us with a
request concerning your rights as Data Subject, but in this case, we may not be
able to identify you. If such a situation occurs, please go to your Service
settings and explore your options.


3.6 In addition, some of our Service have optional features which, if used by
you, require us to collect additional information to provide such features. You
will be notified of such collection, as appropriate. If you choose not to
provide the information needed to use a feature, you will not be able to use the
respective feature. For example, you cannot open files from your device if you
don't grant file access permission to the respective application. Another
example is the camera access - we ask for permission to access your device’s
camera. If you grant permission, you may be able to take pictures or video
within the app experience. Permissions can be managed through your Account
settings.



IV. GROUNDS FOR PROCESSING


4.1 Once provided, your Personal Data will be processed by us (our authorized
employees/ representatives/ Data Processors) on the following grounds: (i) the
Processing is necessary for the performance of a contract to which you as Data
Subject are party or in order to take steps at your request prior to entering
into any such contract; (ii) the Processing is necessary for compliance with a
legal obligation to which we as Data Controller are subject; and (iii) the
Processing is necessary for the purposes of the legitimate interests pursued by
us as Data Controller or by a third party, except where such interests are
overridden by your interests or fundamental rights and freedoms as Data Subject
which require protection of Personal Data, in particular where you are a Child.


4.2 When you have consented to your Personal Data being processed by the Data
Controller for direct marketing and remarketing purposes, you have the right to
object/ opt out to this at any time in one of the ways described below. Upon
receipt of your objection/ opt out, we shall cease the Processing of your Data
for these purposes.



V. PURPOSES OF PROCESSING


5.1 The Data Controller processes/ uses your Personal Data and Usage Data for
the following purposes:


5.1.1 for provision and maintenance of the Service, its modifications, changes,
updates, or enhancements, including but not limited to, provision of interactive
features associated with the Service; for Service-related announcements; to
detect, prevent and address technical and security issues; for monitoring of the
Service usage; for transfer of your Personal Data to our Service Providers/ Data
Processors; for measuring effectiveness and analysis; for processing of
subscriptions and collection of fees; for execution of distance End-User License
Agreements (whether paid or as a free trial); for returns and reimbursements;
for management of your account; for measures to protect the Service against
fraud, IP rights infringements, cyberattacks and other attempts to harm the
rights, property, piracy or safety of the Data Controller and/ or our employees,
Users, Children, or the public


5.1.2 for direct marketing and remarketing, including but not limited to,
tracking preferences and interests, sending you information about our Services
and/ or special offers, participation in promotions, raffles and competitions,
filling in and submitting questionnaires and quizzes, conducting surveys, market
research, etc.


5.1.3 for customer support, assistance, and solving problems; for investigating
and responding to any comments or complaints


5.1.4 for the observance of legal obligations by the Data Controller, including
arising from the applicable tax and accounting legislation


5.1.5 for the protection of the legitimate rights and interests of the Data
Controller and third parties, in full balance with your interests, fundamental
rights and freedoms


5.1.6 for the transfer of your Personal Data to competent authorities; for
handling various other risks, as well as any other purposes compatible with the
above.


5.2 The Processing of Personal Data for purposes other than those for which they
were originally collected is also permitted when the Processing is compatible
with the purposes for which they were originally collected. Processing for
archiving purposes in the public interest, for scientific or historical research
purposes, or for statistical purposes should be considered as compatible lawful
processing operations.



VI. RETENTION PERIOD


6.1 The Data Controller will retain your Personal Data only for as long as is
necessary for the purposes set out in this Privacy Policy. We will retain and
use your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply with
applicable laws), resolve disputes, and enforce our legal agreements and
policies.


6.2 The Processing of your Personal Data will continue as follows: (i) in cases
where you have filled in and submitted incorrect, incomplete or inaccurate data,
and there is no way to be corrected or updated by the Data Controller, they will
be deleted within one (1) month as of their receipt; (ii) in the case of consent
given for direct marketing, until the Data Controller has received your
objection/ opt-out to the processing of Personal Data for this purpose; (iii) in
cases where the Processing is based on a signed contract - until the final
settlement of the legal relationship between you and the Data Controller and
five (5) years thereafter, except in cases of legal or enforcement proceedings,
tax inspections and/ or audits, as well as when the protection of the legitimate
interests of the Data Controller or third parties requires a longer period. All
these terms will be valid only on condition that laws or by-laws do not provide
for longer or shorter ones. Usage Data is generally retained for short periods,
except when this data is used to strengthen the security or to improve the
functionalities of our Service, or we are legally obligated to retain this data
for longer time periods.


6.3 Please note that the data and information stored under your account in
MobiDrive or in your email inbox shall not be considered as part of the Personal
Data/ Information we receive and process hereunder. Therefore, there may be
other reasons why these data must be deleted or will be deleted by us, for
example, if you exceed limits on how much data and information you are allowed
to store therein. For more information, please refer to our Terms of Use.


6.4 The Data Controller makes regular checks on the Personal Data processed and
stored, and based on the rules contained herein, proceeds with their deletion,
destruction, or anonymization for statistical or research purposes. Regarding
Personal Data, for the storage of which special laws provide for longer periods,
the Data Controller shall take technical and organizational measures for their
archiving so that they are not subject to further Processing and cannot be
amended.



VII. TRANSFER OF PERSONAL DATA. RECIPIENTS


7.1 Your Personal Data may be transferred to and processed on computers located
outside of your state, province, country, or other governmental jurisdiction
where the data protection laws may differ from those of your jurisdiction. Also,
the privacy protections and rights of authorities to access your information may
not be equivalent to those in your country. If you are located outside United
States and choose to use the Service, please note that your Personal Data are
received and processed in the United States. Your Personal Data are stored and
kept safe in Google Cloud Platform. More information thereof you can find on the
following link: https://cloud.google.com/security/infrastructure.


7.2 We will only transfer your Personal Data when appropriate safeguards are put
in place to ensure that they receive adequate protection. Depending on the case,
we transfer or may give access to some of your Personal Data to the following
categories of Recipients: (i) companies from the group to which the Data
Controller belongs; (ii) Service Providers - partners and contractors like
courier service providers, payment/ banking service providers, marketing service
providers, including digital advertising agencies and market research service
providers, IT and hosting service providers, fraud monitoring and prevention
service providers, and other companies with which the Data Controller develops
joint programs; (iii) public government bodies and organizations, where this is
necessary in order to protect the legitimate interests of the Data Controller or
third parties, or where it is provided for as a legal obligation.


7.3 The Data Controller may entrust the processing of your Personal Data on its
behalf only to Data Processors who provide sufficient guarantees that they will
apply appropriate technical and organizational measures in such a way that the
Processing complies with legal requirements, this Privacy Policy, and ensures
the adequate protection of your interests, fundamental rights, and freedoms. We
always use HTTPS protocol while transferring your Personal and/ or Usage Data.


7.4 If the Data Controller merges with or is acquired by another company, sells
a Service, or business unit, or if all or a substantial portion of our assets
are acquired by another company, your Personal Data will likely be disclosed to
our advisers and any prospective purchaser's advisers and will be one of the
assets that is transferred to the new owner.



VIII. DISCLOSURE FOR LAW ENFORCEMENT


Under certain circumstances, we may be obliged to disclose your Personal Data by
law or in response to valid requests by public authorities (e.g., a court or a
government authority). Therefore, we may disclose your Personal Data in the good
faith belief that such action is necessary to:

 * comply with a legal obligation, a subpoena, a court or administrative order
   or another official act of a competent public or government authority
 * protect and defend the rights or property of the Data Controller
 * prevent or investigate possible wrongdoing in connection with the Service
 * protect the personal safety of our employees, Users, Children, or the public
 * respond to an emergency involving the danger of death or serious bodily harm
 * protect ourselves against legal liability.



IX. COOKIES. USAGE DATA. SERVICE PROVIDERS. OTHERS


9.1 Cookies. We use cookies and similar tracking technologies to track the
activity on our Service and hold certain information. Cookies are files with
small amount of data which may include an anonymous unique identifier. Cookies
are sent to your browser from a website and stored on your device. Tracking
technologies also used are beacons, tags, and scripts to collect and track
information and to analyze the performance of and improve our Service. You can
instruct your browser to refuse all cookies or to indicate when a cookie is
being sent. However, if you do not accept cookies, you may not be able to use
some portions of our Service. Examples of Cookies we use:

 * Necessary Cookies: we use Necessary Cookies to operate our Service. They help
   make the Service usable by enabling basic functions and access to secure
   areas. The Service cannot function properly without these cookies.
 * Preference Cookies: we use Preference Cookies to remember your preferences
   and various settings. They enable the Service to remember information that
   changes the way it behaves or looks like your preferred language or the
   region that you are in.
 * Statistic Cookies: we use Statistic Cookies to help us understand how you
   interact with the Service by collecting and reporting information
   anonymously.
 * Security Cookies: we use Security Cookies for security purposes.
 * Advertising Cookies: we use Advertising Cookies to serve you with
   advertisements that may be relevant to you and your interests.


Via our cookie banner the Data Controller collects and stores your prior,
explicit, and affirmative consent before using cookies and trackers, or any
other technology that stores Personal Data on your terminal equipment (hardware
and software) and before allowing third-party interference into your electronic
communications. You can control the use of cookies at the individual browser
level. If you reject cookies, you may still use our Service, but your ability to
use some of its features or areas may be limited.


9.2 Usage Data. We may also collect Usage Data that your browser sends whenever
you visit our Service or when you access the Service by or through a computer or
a mobile device. This Usage Data may include information such as your computer's
Internet Protocol address (e.g., IP address), browser type, browser version,
search terms, entered into a search engine which led you to our Service, types
of apps and websites of your interest, the pages of our Service that you visit,
the time and date of your visit, the time spent on those pages, unique device
identifiers, and other diagnostic data. When you access the Service by or
through a mobile device, this Usage Data may include information such as the
type of mobile device you use, your mobile device unique ID, the IP address of
your mobile device, your mobile operating system, the type of mobile Internet
browser you use, and other diagnostic data.


9.3 We may employ third party companies and individuals to facilitate our
Service ("Service Providers"), to provide the Service on our behalf, to perform
Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform the tasks
assigned on our behalf and are obligated not to disclose or use them for any
other purposes whatsoever.


9.3.1 Service Providers of Analytics Data: 


a) Google Analytics and Firebase are web and application analytics services
offered by Google that track and report website and applications traffic and
information about your device. This information is automatically uploaded to the
Google servers and used to provide better services to the Users. Google uses the
data collected to track and monitor the use of our Service. This data is shared
with other Google services. Google may use the collected data to contextualize
and personalize the ads of its own advertising network. For more information on
the privacy practices of Google, please visit the Google Privacy Terms web page:
https://policies.google.com/privacy


b) Flurry Analytics service (for iOS products only) is provided by Yahoo!
Inc. You can opt-out from Flurry Analytics service to prevent Flurry Analytics
from using and sharing your information by visiting the Flurry's Opt-out
page: https://developer.yahoo.com/flurry/end-user-opt-out. For more information
on the privacy practices and policies of Yahoo!, please visit their Privacy
Policy page: https://developer.yahoo.com/flurry/end-user-opt-out.


c) Hotjar (used for websites Services only) is a technology service that helps
us better understand our Users` experience and this enables us to build and
maintain our Service with User feedback. For further details, please see
Hotjar’s privacy policy by clicking on this link:
https://www.hotjar.com/legal/policies/privacy/. You can opt-out HotJar services
by following this link https://www.hotjar.com/policies/do-not-track/.


d) We use Adjust in our Android and iOS apps when conducting our marketing
campaigns. Adjust may gather some analytics or statistical consumer data on our
behalf to help us better understand how Users use our apps, and how our
marketing campaigns are performing. For in-depth information about Adjust,
see https://www.adjust.com/terms/privacy-policy/. To opt out of tracking by
Adjust follow this link https://www.adjust.com/forget-device/.


e) We use AppsFlyer in our Android and iOS apps to gather basic statistical
information and user data. This data helps us track the progress of our
marketing campaigns and allows us to better understand how Users use our apps.
For more information on the data gathered by AppsFlyer,
see https://www.appsflyer.com/legal/privacy-policy/. To opt out of tracking by
AppsFlyer follow this link https://www.appsflyer.com/legal/opt-out/.


f) We use AdMost in our Android, iOS and Windows apps when conducting our
marketing campaigns. AdMost may gather some analytics or statistical consumer
data and information on our behalf to help us better understand how Users use
our apps, and how our marketing campaigns are performing. For in-depth
information about AdMost, see https://resources.admost.com/privacy-policy/.


g) We use Microsoft Clarity on our website, which is a GDPR compliant user
behavior analytics tool. It helps us understand how users are interacting with
your website through features such as session replays and heatmaps. For further
details, please see Microsoft Hotjar’s privacy policy at
https://privacy.microsoft.com/en-us/privacystatement


9.3.2 Service Providers of Advertising Data:


a) AdMob by Google is provided by Google Inc. You can opt-out from AdMob by
Google service by following the instructions described by
Google: https://support.google.com/ads/answer/2662922?hl=en. For more
information on how Google uses the collected information, please visit the "How
Google uses data when you use our partners' sites or app"
page: http://www.google.com/policies/privacy/partners/ or visit the Privacy
Policy of Google: http://www.google.com/policies/privacy/.


b) Meta Audience Network is used in our Android and iOS apps when conducting our
marketing campaigns. They have developed a targeting technology which allows
advertisements to reach a specific audience. While posting an ad, an advertiser
is provided a set of characteristics that will define his target market. For
in-depth information about Meta Audience Network, please see
https://www.facebook.com/audiencenetwork/.


c) Google Ads remarketing service is provided by Google Inc. You can opt-out of
Google Analytics for Display Advertising and customize the Google Display
Network ads by visiting the Google Ads Settings
page: http://www.google.com/settings/ads. Google also recommends installing the
Google Analytics Opt-out Browser Add-on
- https://tools.google.com/dlpage/gaoptout - for your web browser. Google
Analytics Opt-out Browser Add-on provides visitors with the ability to prevent
their data from being collected and used by Google Analytics. For more
information on the privacy practices of Google, please visit the Google Privacy
Terms web page: http://www.google.com/intl/en/policies/privacy/.


d) A4G - is an advertising service provider. It manages mobile ad sources in our
Android and iOS app by providing full suite of video, rich media, interstitial &
native ad formats. For more information on the privacy practices of A4G, please
visit: https://a4g.com/privacy.


e) CJ is an affiliate marketing company. Their services help us meet consumer
needs by providing up-to-date offers. Please visit their Services Privacy Policy
at https://www.cj.com/legal/privacy-policy-services if you want to learn more
about the personal data they collect and use about consumers when providing
affiliate marketing services.


f) Trustpilot is a a digital platform that hosts reviews to help consumers shop
with confidence and deliver rich insights to help businesses improve the
experiences they offer. Please visit their Privacy Policy at
https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms.


9.4 Service Providers of Payments. Our Service is provided not only for free but
also against monetary consideration. In the latter case, we use payment/ banking
service providers who adhere to the standards set by PCI-DSS as managed by the
PCI Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the
secure handling of payment information.  Once collected by us, your credit or
debit card number  is provided directly to our third-party payment service
providers whose use of your Personal Data is governed by their Privacy Policies.
They are as follows:


 1. a) Microsoft Store at https://www.microsoft.com/en-us/store/apps/windows

 2. b) Huawei App Gallery at https://appgallery.huawei.com/

 3. c) Apple Store In-App Payments at https://www.apple.com/legal/privacy/en-ww/

 4. d) Google Play In-App Payments at https://www.google.com/policies/privacy/

 5. e) Stripe at https://stripe.com/us/privacy

 6. f) PayPal at https://www.paypal.com/webapps/mpp/ua/privacy-full

9.5 Others:


a) Behavioral Remarketing used by us to advertise on third party websites to you
after you visited our Service. We and our third-party vendors use cookies to
inform, optimize and serve ads based on your past visits to our Service. You can
prevent the Service Providers engaged in behavioral advertising, which collect
data about your online browsing activities and use it to show you targeted ads
by submitting opt-outs. Opting-out will only prevent targeted ads, so you may
continue to see generic (non-targeted) ads. You may opt out to behaviorally
targeted ads anytime by deleting your browser's cookies.


b) "Do Not Track" Signals. We do not support Do Not Track ("DNT"). DNT is a
preference you can set in your web browser to inform websites that you do not
want to be tracked. You can enable or disable it by visiting the Preferences or
Settings page of your web browser.


c) Conversion Tracking. We use Facebook Pixel for conversion tracking, which is
the measurement of media performance with reference to campaign key performance
indicators (KPIs). For more information, please visit this link:
https://www.facebook.com/business/learn/facebook-ads-pixel.


d) Sentry.io is used in our Windows apps for error and performance monitoring to
help us diagnose, fix, and optimize our applications. For more information,
please visit this link: https://sentry.io/privacy/.


e) mconverter.eu is used in our apps and websites as a provider of file
conversion related services. For more information on their privacy, please visit
this link: https://mconverter.eu/#privacy.


f) Zamzar is used in our apps and websites as another provider of file
conversion services. For more information on their privacy, please visit this
link: https://developers.zamzar.com/privacy.


g) ABBYY is used in our apps and websites as an automated cloud OCR service that
transforms documents into structured, actionable, process-ready content. For
more information on their privacy, please visit this link:
https://www.abbyy.com/privacy/.



X. LINKS TO OTHER WEBSITES


Our Service may contain links to other websites that are not operated by us. If
you click on a third-party`s link, you will be directed to that third party's
website. We strongly advise you to review the Privacy Policy of every site you
visit. We have no control over and assume no responsibility for the content,
privacy policies or practices of any third-party websites or services.



XI. ACCOUNT


11.1 Some of our Services may require that you create an account with us
("Account"). When you create a personal Account, you will be asked to provide
certain Personal Data and we will assign a unique ID number to identify your
Account and the associated information. Thus, you become an Account Holder.
Signing into your Account enables personalization, consistent experiences across
products and devices, permits you to use cloud data storage, allows you to make
payments using payment methods stored in your Account, and enables other
features such as chats, file sharing and others. We may use the Personal Data
provided therein for the purposes as enumerated in item 5.1 above, including but
not limited to contact you via email messages regarding your Account and
maintenance related issues, newsletters, as well as marketing or promotional
information that may be of your interest. You may object/ opt out of receiving
any or all these marketing communications from us by following the unsubscribe
link or instructions provided in any email we send or by contacting us using the
details provided herein.


11.2 Once created, the use of your Account is at your own risk. Please do not
buy, sell, transfer, rent, and/ or lease your Account and/ or password to
anyone. We will not take any responsibility for the use of your Account by
others that is caused by your actions or negligent password keeping.


11.3 Please keep your Personal Data accurate and up to date. Whenever made
possible, you can also update your Personal Data directly within your Account
settings. If you are unable to do this by yourself, please contact us to make
the necessary changes.


11.4 You can also close your Account. When you close your Account, we begin
deleting certain Personal Data and Information that we no longer have a business
reason to retain. However, we typically retain Personal Data related to our
contracts and business transactions for five years after your last interaction
with us or upon the contract expiration. Please be advised that in this case you
will lose your Account`s preferences, synchronized settings on different devices
and any data stored in MobiDrive and Chats. We cannot restore any of these once
your Account is closed. For more information on this topic please check our
Terms of Use.



XII. SECURITY OF DATA


12.1 The Data Controller undertakes to apply appropriate technical and
organizational measures to ensure an appropriate level of security of your
Personal Data. In assessing the appropriate level of security, account shall be
taken of the risks associated with the Processing, and in particular the risks
of accidental or unlawful destruction, loss, alteration, unauthorized
disclosure, or access.


12.2 With regard to automated processing, the Data Controller is applying
measures aiming at:


12.2.1 control over access to equipment - to deny unauthorized persons access to
the equipment used for Personal Data Processing


12.2.2 control of data carriers - to prevent reading, copying, modification or
removal of data carriers by unauthorized persons


12.2.3 control over storage - to prevent the entry of Personal Data by
unauthorized persons, as well as the performance of checks, modification, or
deletion of stored Personal Data by unauthorized persons


12.2.4 consumer control - to prevent the use of automated processing systems by
unauthorized persons through the use of data transmission equipment


12.2.5 control over access to data - to ensure that persons who are allowed to
use an automated processing system have access only to the Personal Data covered
by their access authorization


12.2.6 control over communication - to ensure the possibility of verification
and establishment of which persons have been or may be transferred Personal
Data, or which persons have access to Personal Data through data transmission
equipment


12.2.7 control over data entry - to ensure the possibility for subsequent
verification and establishment of what Personal Data have been entered into the
automated processing systems, as well as when and by whom they were entered


12.2.8 control over the transfer - to prevent the reading, copying, modification
or deletion of Personal Data by unauthorized persons during the transfer of
Personal Data or during the transfer of data carriers


12.2.9 recovery - to ensure the possibility of recovery of the installed systems
in case of failure of the functions of the systems


12.2.10 reliability - to ensure the implementation of the functions of the
system and the reporting of defects in the functions


12.2.11 integrity - to ensure that the stored personal data is not damaged due
to improper functioning of the system.


12.3 Through measures under the previous point, the Data Controller is aiming to
ensure the protection of Personal Data at the design stage, considering the
achievements of technical progress, implementation costs and the nature, scope,
context, and objectives of Personal Data Processing, as well as risks to the
rights and freedoms of individuals.


12.4 We follow generally accepted standards to protect the Personal Data
submitted to us during Processing including HTTPS. However, no method of
transmission over the Internet, or method of electronic storage, is 100% secure.
Therefore, we do not guarantee the Personal Data absolute security.



XIII. YOUR RIGHTS AS DATA SUBJECT. GENERAL STANDARDS


The Data Controller respects your privacy no matter where your habitual
residence is. We hereby provide you with the right to request access,
correction, completion, update, and/ or erasure of your Personal Data. We will
aim to address all you request, complaints and/ or worries within reasonable
time as of their receipt by being compliant with our high standards for Personal
Data protection and the applicable legislation.



XIV. YOUR RIGHTS AS DATA SUBJECT IN CASE YOU HAVE HABITUAL RESIDENCE IN EU. GDPR
COMPLIANCE


14.1 Although the main establishment of the Data Controller is in California
(USA), this Privacy Policy takes under consideration and is made to comply with
the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27
April 2016 on the protection of natural persons regarding the processing of
personal data and on the free movement of such data ("GDPR"). In addition, we
have implemented processes in place to support Users having habitual residence
in EU to receive information how their Personal Data is processed and how to
exercise their rights, which are as follows:


14.1.1 Right of access: you have the right to obtain from the Data Controller
confirmation as to whether or not Personal Data concerning you are being
processed, and, where that is the case, access to the Personal Data and the
following information: (a) the purposes of the Processing; (b) the categories of
Personal Data concerned; (c) the Recipients or categories of Recipient to whom
the Personal Data have been or will be disclosed, in particular Recipients in
third countries or international organizations; (d) where possible, the
envisaged period for which the Personal Data will be stored, or, if not
possible, the criteria used to determine that period; (e) the existence of the
right to request from the Data Controller rectification or erasure of Personal
Data or restriction of Processing of Personal Data concerning you or to object
to such Processing when it is marketing purposes; (f) the right to lodge a
complaint with a supervisory authority; (g) where the Personal Data are not
collected from you, any available information as to their source; (h) the
existence of automated decision-making, including profiling or at least in those
cases, meaningful information about the logic involved, as well as the
significance and the envisaged consequences of such Processing for you and (i)
other processing-relevant information.


14.1.2 Right to rectification: you shall have the right to obtain from the Data
Controller without undue delay the rectification of inaccurate Personal Data
concerning you - right to have incomplete Personal Data completed, including by
means of providing a supplementary statement.


14.1.3 Right to erasure ("to be forgotten"): you have the right to request the
Data Controller to delete without undue delay the Personal Data that concern
you, when they are no longer needed for the purposes for which they were
collected and/ or processed; when you withdraw your consent, on which their
processing is based and there is no other legal basis for it; when you object to
their Processing for the purposes of direct marketing and there are no
legitimate grounds for processing to take precedence; when your Personal Data is
processed in violation of the principles outlined above; when it must be deleted
in order to comply with a legal obligation for the Data Controller or the
Personal Data have been collected in relation to the offer of information
society services. This right shall not apply to the extent that Processing is
necessary: (a) for exercising the right of freedom of expression and
information; (b) for compliance with a legal obligation to which the Data
Controller is subject or for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the Data Controller;
(c) for reasons of public interest in the area of public health; (d) for
archiving purposes in the public interest, scientific or historical research
purposes or statistical purposes in so far as the right is likely to render
impossible or seriously impair the achievement of the objectives of that
Processing; or (e) for the establishment, exercise or defense of legal claims.


14.1.4 Right to restriction of Processing: the Data Controller restricts the
processing of Personal Data without deleting them when: (i) the accuracy of the
Personal Data is disputed by you as a Data Subject and this cannot be verified,
or (ii) Personal Data must be kept for evidentiary purposes.


14.1.5 Right to data portability: you have the right to receive the Personal
Data concerning you, in a structured, commonly used, and machine-readable format
and have the right to transmit those data to another controller without
hindrance from the Data Controller to which the Personal Data have been
provided, when the Processing is based on a contractual obligation and is
performed in an automated manner. This right of yours cannot adversely affect
the rights and freedoms of others.


14.1.6 Right of objection: If you have consented to the Processing of your
Personal Data for the purposes of direct marketing, you have the right to object
to this Processing at any time, including when it involves profiling. In any
such case, the Processing of your Personal Data for the purposes of direct
marketing is suspended.


14.1.7 In addition you have the right not to be the subject of a decision based
solely on automated processing, including profiling, which has legal
consequences for you and affects you significantly. In case you exercise this
right, the Data Controller is obliged to apply appropriate measures to protect
your rights, freedoms, and legitimate interests, ensuring human intervention and
giving you the right to express your point of view and challenge its decision.


14.2 As a Data Subject, you may exercise the rights above by submitting a
written application to the Data Controller. The application can be submitted by
mail (at the address of the Data Controller or by e-mail). The application must
contain: (i) name, surname, habitual residence, IP address (if applicable); (ii)
a description of the request; (iii) a preferred form of obtaining information in
the exercise of rights; (iv) signature, date of filing of the application. When
the Data Controller has reasonable concerns, it may request additional
information needed to verify your identity. The Data Controller satisfies your
requests completely free of charge within (1) month of receipt. The period may
be extended by two (2) months when this is necessary due to the complexity or
number of requests. Where requests from a Data Subject are manifestly
unreasonable or excessive, in particular because of their recurrence, the Data
Controller may: (i) charge a fee commensurate with the administrative costs of
providing the information or correspondence, or of acting on the request, or
(ii) refuse to act on the request. Each time the Data Controller refuses to
accept an application submitted by you for the exercise of the rights above, you
will receive a written refusal, as well as the reasons for it. In these and
other cases, the Data Controller will also inform you of your right to appeal or
seek a court redress.


14.3 A register that contains information on submissions, considerations, and
responses to all Data Subjects` requests will be kept by the Data Controller.


14.4 In case of the Personal Data breach, and provided that, it is likely to
result in a high risk to your rights and freedoms, we will notify you thereof
without undue delay and describe in clear and plain language the nature of the
Personal Data breach, the likely consequences of it and the measures taken or
proposed to be taken by us to address it, including, where appropriate, measures
to mitigate its possible adverse effects. In some cases the communication shall
not be required, especially when: (i) we have implemented appropriate technical
and organizational protection measures, and those measures were applied to the
Personal Data affected by the Personal Data breach, such as encryption; (ii) we
have taken subsequent measures which ensure that the high risk to your rights
and freedoms is no longer likely to materialize; (iii) it would involve
disproportionate effort, in which case, you will be informed in an equally
effective manner like via a public communication or other.


14.5 In case of a violation of your rights under GDPR you have the right to
refer to the competent supervisory authority at your habitual place of residence
within six (6) months as of the violation discovery, but not later than two (2)
years from its occurrence. You have an additional opportunity to file a claim
against us before the competent court. In this proceeding you can seek
compensation for the damages suffered by you as a result of illegal Processing
of your Personal Data.



XV. YOUR RIGHTS AS DATA SUBJECT IN CASE YOU ARE A CALIFORNIA RESIDENT. CCPA
COMPLIANCE


15.1 WE DO NOT SELL OR RENT ANY COLLECTED PERSONAL DATA AND INFORMATION WITH ANY
THIRD PARTY. However, while providing you with the Service, we may share some
personal information about you with third parties with which the Data Controller
develops joint programs or uses as Service Providers. Such information sharing
may be considered a “sale” under the California Consumer Privacy Act of 2018, as
amended ("CCPA").


15.2 The CCPA defines Personal Information as information that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular consumer or
household, inter alia, (i) identifying information, such as real name, postal
address, unique personal identifier, IP address, email address, account name,
social security number, passport number, driver’s license number, or other
similar identifiers; (ii) commercial information, including records of personal
property, products, or services purchased; purchases considered; or other
purchasing histories; (iii) browsing history, search history, and information
regarding a consumer’s interaction with a website or advertisement; (iv)
geolocation data; (v) education information; (vi) inferences drawn from this
information, such as personal characteristics, predispositions, intelligence,
aptitude, etc. Therefore, if you are a California resident and a User of our
Service, please be advised of the additional rights for California consumers,
which are summarized below.


15.2.1 Right of access: you have the right to request (and receive) disclosure
from us regarding: (i) specific pieces of Personal Information collected about
you; (ii) categories of Personal Information collected; (iii) categories of the
sources from which the information was collected; (iv) categories of Personal
Information that we share or disclosed for a business purpose; (v) categories of
third parties with whom the Personal Information was shared or disclosed; and
(vi) the business or commercial purpose for collecting or sharing Personal
Information. This disclosure is limited to information collected, sold, or
disclosed in the past 12 months and does not cover sensitive information like
consumer's social security number, driver's license number, account password or
financial account numbers. In addition, we are not required to search for
Personal Information if we: (i) do not maintain the Personal Information in a
searchable or reasonably accessible format; (ii) maintain the Personal
Information solely for legal or compliance purposes; (iii) do not sell the
Personal Information and do not use it for any commercial purpose; and (iv)
describe to you the categories of records that may contain Personal Information
that we did not search because it meets the three conditions stated above.


15.2.2 Right to request deletion: you also have a right to request your Personal
Information to be deleted. In this case, we will: (i) permanently and completely
erase your Personal Information on existing systems and direct our partners and/
or Service Providers to do so, provided that, no exceptions are in place, or
de-identifying the information or otherwise modifying it to make it unreadable
or undecipherable through any means, and notify you that your Personal
Information have been backed up or archived and will be deleted when those
systems are next accessed. Neither we, nor our Service Providers are required to
comply with your deletion request, if the Personal Information is necessary to:
(i) complete a transaction for which the Personal Information was collected,
provide a good or service requested by you, or otherwise perform a contract
between us and you; (ii) detect security incidents, protect against malicious,
deceptive, fraudulent, or illegal activity (or prosecute those responsible);
(iii) debug to identify and repair errors that impair existing intended
functionality; (iv) exercise or ensure the right of another to exercise free
speech or another legal right; (v) comply with a legal obligation; or (vi)
otherwise use the information internally in a lawful manner compatible with the
context in which you have provided it.


15.2.3 Right to opt-out of the sale of personal information. CCPA Regulations
require us to treat your user-enabled global privacy controls, such as a browser
plug-in or privacy setting, device setting, or other mechanism, that communicate
or signal your choice to opt-out of the sale of your Personal Information as
valid opt-out requests. We must comply with it as soon as feasibly possible, but
at least within 15 days from receiving the request. Please be advised that in
practice the following scenarios involving transfers of Personal Information
between entities are potentially excluded from the scope of a "sale": (i) the
linking, at the consumer's request, of one online account to another; (ii)
sharing a particular device identifier with vendors to give effect to a
consumer's opt-out request; (iii) standard relationships with third party
vendors or service providers who process data, provided appropriate contractual
restrictions are in place; or transfers of data on a merger, acquisition or
insolvency event.


15.2.4 Right to opt-out of receiving electronic communications from us. If you
no longer want to receive marketing-related emails from us, you may opt-out via
the unsubscribe link included in such emails. We will try to comply with your
request(s) as soon as reasonably practicable. Please note that if you opt-out of
receiving marketing-related emails from us, we may still send you other messages
in connection with providing our Service.


15.3 Upon verifying your identity, we will notify you that your request has been
received and is being processed. We will respond within 45 days after
verification to any of your access requests and deletion requests. The 45-day
response time can be extended but only with appropriate notice and explanation.
The Data Controller maintains records of your requests.


15.4 To meet CCPA requirements under item 15.2.3, provide links to the relevant
opt out methods of our Service Providers as per item 9.3 above.


15.5 Non-discrimination: the CCPA provides that you may not be discriminated
against for exercising the above rights. You can also designate an authorized
agent to exercise these rights on your behalf. We may require that you provide
the authorized agent with written permission to act on your behalf and that the
authorized agent verify their identity directly with us.


15.6 In addition to the above, we comply with the requirements of the Privacy
Rights for California Minors in the Digital World Act ("the Eraser Law") as far
as it is applicable to our Service. This law provides additional protections to
individuals under the age of 18 in California, including a right to be
forgotten, which enable minors to remove their own posts (but not republications
of their posts or posts about them by others). The Eraser Law also prohibits
companies who operate websites or online services directed at minors from using
the minor's personal information to market or advertise certain enumerated
products and services deemed potentially harmful for them.


15.7 Data Breach Notification under Cal. Civ. Code §§1798.29, 1798.82 and
1798.84. We will notify you in due time of any unauthorized acquisition of
unencrypted computerized data that contains your Personal Information. This is
in addition to any other specific notification obligations for data breaches
contained in other statutes.



XVI. YOUR RIGHTS AS DATA SUBJECT IN CASE YOU ARE A VIRGINIA RESIDENT. VCDPA
COMPLIANCE



The Virginia Consumer Data Protection Act (the "VCDPA") takes effect on January
1, 2023, and affects companies and organizations that do business in Virginia or
that deliver products or services to residents of Virginia. The VCDPA requires
companies and organizations to adhere to several duties when processing
consumers data. In a nutshell, what the VCDPA requires from companies and
organizations to do is to discover what personal data is processed, map out how
and to whom they share personal data, and manage how personal data is stored, as
well as protect personal data from breaches and abuse. By being in compliance
with the GDPR and the California’s CCPA/CPRA, MobiSystems also complies with the
VCDPA and commits to address all requests of consumers from Virginia within 45
days as of their receipt.




XVII. AMENDMENTS AND SUPPLEMENTS



We may update this Privacy Policy from time to time. The updated version of this
Privacy Policy will be posted on the Service. Please review it periodically
because any and all amendments and/ or supplements will become effective when
posted.


Please do not hesitate to contact our Data Protection Officer (DPO) Mr. Stoyan
Gogov at privacy@mobisystems.com in case you need assistance or clarification,
want to exercise your legal rights, or file a complaint.



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