SENDER PRIVACY POLICY

LAST UPDATED DATE: 05/24/2018

Middleware, Inc. and its affiliates (“Middleware”, “we” or “us”) are committed to respecting your online privacy and keeping your information secure and confidential.

This Privacy Policy (“Privacy Policy”) explains how Middleware collects, uses, discloses, and secures the Personal Information you (“customer”, “you” or “your”) provide during your online and offline interactions with us in connection with the website located at https://sender.mobi/ and any subdomains, as applicable (the “Site”) in order to use Sender service ("Product").

As used in this Privacy Policy, ”Personal Information“ means any information that can be used to individually identify a person, and may include, but is not limited to, name, home/work/mobile telephone number, and email address, and other personally identifiable information.

If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Information, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”).

Middleware will be the controller of your Personal Information that is provided, collected and/or processed pursuant to this Privacy Policy, except where otherwise expressly stated below. If you have any questions about whether any of foregoing applies to you, please contact us using the information set forth in the “Contact Us” section below.

This Privacy Policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our Site.

INFORMATION COLLECTED

This Privacy Policy applies to Personal Information we collect from you, but does not apply to any services or products offered by third parties and made available to you through our Site. We obtain Personal Information in the following forms: (i) information provided by you as part of the sign-up process, and (ii) information that we obtain or collect automatically from your use of the Site.

Personal Information provided by you: You may be required to register in order to access certain features of the Site. To become a registered user, you will be asked to sign up to create an account for the Site, and will be asked to provide:

  • Your name,
  • E-mail address,
  • Home/work/mobile telephone number,
  • IP addresses and other information collected passively, as further detailed in the “Information that we obtain or collect automatically from your use of the Site” section below.

Information that we obtain or collect automatically from your use of the Site: We may automatically collect certain information from your use of the Product, such as usage data, preferences, or any other data that includes Information concerning how you use the Product.

In particular, our servers automatically record certain information and/or we may use cookies (small text files placed on a device’s hard disk by a web service) or similar tracking technologies to collect the following types of information:

  • Your browser type, language, plug-ins, Internet domain and operating system;
  • Your Internet Protocol (IP) address;
  • The website(s) you visited before visiting the Site and the website(s) you visited after visiting the Site;
  • Unique identifiers, including mobile device identification numbers, that may identify the physical location of such devices;
  • Data related to your interactions with content on the Site, such as use patterns and the type of content viewed or favorited in the Site.

In addition, by using our Product, network information may be transmitted back to us such as Product usage information. This information is transmitted back to us so we can determine how users are interacting with our Products, to assist us with improving our Products, and to correct any problems that may occur.

GEOLOCATION

We collect your location based information for the purpose of optimizing your connection to our data center. We will only share this information with our data center provider for the sole purpose of providing you this service. If you do not wish to allow us to share your information in this manner you may opt-out of location based services at any time by editing the setting at the device level or by contacting us using the information in the “Contact Us” section of this Privacy Policy.

TRACKING TECHNOLOGIES

We and our partners may use cookies or similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. Please note that you may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser, but if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Site.

CHOICE

Please note that you may choose not to create an account. If you so choose, you will still have access to many of Site's web pages, however, you may be unable to access certain options and services that we offer only to registered users. You can choose whether to provide Personal Information to us, but note that you may be unable to access certain options, offers, and services if they require Personal Information that you have not provided. You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this Privacy Policy.

USE AND DISCLOSURE OF INFORMATION

Middleware uses your Personal Information to:

  • operate and improve the Site and/or Product,
  • customize your experience on the Site and/or Product,
  • send you communications that may be of interest to you, either electronically or otherwise,
  • enforce this Privacy Policy;
  • enforce terms and conditions of Sender’s use;
  • conduct market analysis, traffic flow analysis and related reporting to third parties;
  • provide reports based on information collected from use of our Product and Site;
  • keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information, provided that you can edit your marketing preferences;
  • provide support and assistance for our Product and Site;
  • provide the ability to create personal profile areas and view protected content;
  • provide the ability to contact you, and provide you with shipping and billing information;
  • provide customer feedback and support;
  • conduct questionnaires and surveys in order to provide better products and services to our customers and end users. Your completion of any questionnaires is voluntary;
  • understand more about you, so we can personalize newsletters and websites to your preferences. For example, allow you the opportunity to request specific information on products and services that may be of interest; for any other purposes disclosed to you at the time we collect your Personal Information.

SHARING YOUR PERSONAL INFORMATION

We may share certain Personal Information with third party vendors or subcontractors who provide software applications, web hosting and other technologies or services for the Site. We will only provide these third parties with access to Personal Information that is reasonably necessary to perform their work or comply with law. Those third parties will never use such Personal Information for any other purpose except to provide services in connection with the Site.

We will not share or sell any of your Personal Information to any third party except as otherwise stated in this Privacy Policy and in the following circumstances: (a) in response to subpoenas, court orders or legal process, to the extent permitted and as restricted by law; (b) when disclosure is required to maintain the security and integrity of the Site, or to protect any user’s security or the security of other persons, consistent with applicable laws; (c) when disclosure is directed or consented to by the user who has input the Personal Information; (d) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your Personal Information will, in most instances, be part of the assets transferred; or (e) in limited circumstances, we may disclose your email address in order to comply with laws and regulations, including the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM Act of 2003).

Please note that we may retain certain Personal Information after your account has been terminated. We reserve the right to use your Personal Information in any aggregated data collection after you have terminated your account with us, however we will ensure that the use of such information or data will not identify you personally. For avoidance of doubt, payment information will be deleted once your account is terminated.

SECURITY OF INFORMATION

Personal Information you provide to us is protected by the password you create when registering to use the Site. Please understand that you can help prevent the unauthorized disclosure of information by choosing and protecting your password appropriately. You can also help prevent unauthorized disclosure by not sharing your password and preventing others from using your computer or mobile device.

We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example:

  • Encryption of databases;
  • SSL encryption (https) everywhere where we deal with Personal Information.
  • Data is kept on secure servers, located in the EU.

We use commercially reasonable procedures to protect all collected Personal Information. Please understand that no security system is perfect and, as such, we do not guarantee the security of the Site, or that your Personal Information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, then we may either post a notice, or attempt to notify you by email, and we will take reasonable steps to remedy the breach.

DATA SUBJECT RIGHTS

You have certain rights with respect to your Personal Information as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Information, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.

To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this Privacy Policy.

  • Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
  • Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
  • Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
  • Erasure: You can request that we erase some or all of your Personal Information from our systems.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
  • Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
  • Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
  • Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State.

YOUR CALIFORNIA PRIVACY RIGHTS

California residents who have an established business relationship with us may make a written request to Middleware about whether we have disclosed any Personal Information to any third parties for the third parties’ direct marketing purposes during the prior calendar year. To make such a request, please contact us using the contact details referred to in the “Contact Us” section of this Privacy Policy.

COPPA AND ACCESS BY MINORS

Middleware does not knowingly collect or store any personal information from or about children under the age of 16. If you believe a child under the age of 16 has under any circumstances provided us with personal information and data, a parent or legal guardian can contact us using the contact details referred to in the “Contact Us” section of this Privacy Policy to request that their children’s information be deleted from our records.

CHANGES TO THIS PRIVACY POLICY

We will occasionally update this Privacy Policy to reflect customer feedback and changes in our Sender Services. When we post changes to a statement, we will revise the “last updated” date at the top of the statement. If there are material changes to the statement or in how Middleware will use Sender Services information, we will notify you either by posting a notice of such changes before they take effect or by directly sending you a notification.

USER CONSENT

By using Product and/or Site, you consent to the terms of this Privacy Policy and to our processing of Personal Information for the purposes given above as well as those explained where Middleware collects Personal Information. We may transfer your Personal Information to the United States, to any Middleware affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage, and by providing any Personal Information you fully understand and unambiguously consent to such transfer, processing and storage of such information.

CONTACT US

If you have any inquiries or complaints, you may contact us:

by email: support@sender.mobi

in writing: 541 Jefferson Ave., Suite 100, Redwood City, CA 94063

by phone: Tel:(650) 298-6000