LAST UPDATED: MAY 13, 2019
USE OF PERSONAL INFORMATION
We use your personal information in a number of ways, which may include the following:
We may need to collect and use some of the information as mentioned above because we are either legally required to do so, because it is necessary for us to provide you with requested products or services, because it is necessary for our legitimate interests or we have acquired your consent.
SHARING OF PERSONAL INFORMATION
For the purposes set out above, personal information either has been shared in the last 12 months or may be shared by us as follows:
The categories of personal information disclosed to third party service providers and other group companies mentioned above, include name, contact information (including contact number and physical and email address) and transaction information.In using the information we collect from you as described above, it may be necessary for us to transmit your personal information to other countries (including countries other than where you are based that have a different data protection regime), in particular, those countries where FPT and OneMob currently have operations (including New Zealand and the USA) and by using the Site, you consent to the transfer of information to countries outside of your country of residence which may have data protection rules that are different to those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information. Whenever we transfer your personal information out of your country or residence, we ensure a similar degree of protection is afforded to it by ensuring we only transfer your personal information after having put in place adequate measures, such as contractual clauses to protect your information. Please contact us if you want more information on the specific measures used by us when transferring your personal information.We require the Companies’ third party service providers and professional advisors to protect the confidentiality and security of personal information they receive from us, and only use personal information for the provision of services to the applicable Company, and in compliance with applicable law. Each Company will remain responsible for the personal information about you that it transfers and uses.We do not sell or disclose (except as stated in this Privacy Policy) personal information to other organisations without first informing you of such disclosures and, where required, obtaining your prior consent. If in the future, we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the California Consumer Privacy Act.We may also share aggregated and/or anonymized data with others for their own uses.
INFORMATION CHOICES AND CHANGES
Our marketing emails tell you how to “opt-out.” You can also request to opt-out of the use of your personal information by FPT for marketing purposes by contacting us at any time in accordance with the details set out in the “Contact Information” section below We will try to comply with your request(s) as soon as reasonably practicable.
If you opt out, we may still send you important, administrative, non- marketing emails that you cannot opt-out from. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about personal information to us as set out in our Contact Information section below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.
You can typically remove and reject cookies from our Site with your browser settings. For more information see the “Onemob Cookies Policy” section below.
STORAGE OF PERSONAL INFORMATION
FPT may retain personal information for the period necessary to fulfill the purposes outlined in this policy (including for the purposes of satisfying any legal, accounting, or reporting requirements) unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
For information about querying, identifying or deleting your personal data, see the ‘General Data Protection Regulation’ and California Consumer Privacy Act section below.
Please contact us in accordance with the “Contact Information” section below if you want further information in relation to the retention of your personal information.
SECURITY PRECAUTIONS
We are committed to preventing others from unauthorized access to and use, alternation or destruction of the personal information we collect from you, and we maintain commercially reasonable procedures, systems and technologies designed for this purpose. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the ‘Contract Information’ section below.
We have put in place procedures to deal with any suspected personal data breach and will notify the relevant people as we are legally required to do so.
GENERAL DATA PROTECTION REGULATION (GDPR), CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND HOW YOU CAN ACCESS, CORRECT OR DELETE PERSONAL INFORMATION
We understand the importance of the newly enacted European Union (EU) law regarding data protection for individuals within the EU, and the State of California law regarding privacy of individuals residing in the State of California. We have consulted legal counsel and other enterprise companies that provide outreach-related digital capabilities to ensure that we’ve enacted the appropriate tools and safeguards to comply with the GDPR.
According to the GDPR and CCPA, among other things, EU residents and Californian residents respectively have the right to understand what data is captured about themselves from vendors, how that data is processed, and the ability to request that such data be deleted. To that end, OneMob has built an internal tool that enables the querying, identification, and ability to delete any data captured by our platform about people located in the EU or resident in California. The identification of EU-specific and California specific data and the ability to delete such data were two areas that we focused on when building this tool.
We’re proud to implement a custom policy to comply with the GDPR and CCPA requirements as many of our customers interact with people located in the EU or California through our platform. Please reach out to us at [email protected] or contact our Data Protection Officer Nimesh Gupta at [email protected] with any further questions.
To access, correct, suppress/restrict or delete any personal information held by FPT, or if you would like to request that FPT transfer your personal information to another company (to the extent that this right to data portability is provided to you by applicable law), or if you want to withdraw your consent to the processing of data that you previously consented to (without affecting the lawfulness of processing before such consent is withdrawn), please contact us at [email protected].
In your request, please make clear what actions you would like us to take in relation to your personal information. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request and we may need to contact you to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
No fee is charged to access your personal information (or exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion, but we will advise you of this. There may also be residual information that will remain within our databases and other records, which will not, and cannot, be removed. If this is the case, such information will remain secure and protected.
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