Date of last revision: October 4, 2019
Data controller: The mTAB group comprises mTAB LLC, mTAB Asia Pacific kk, mTAB Holdings LTD, and Gamma Associates LTD (collectively referred to as “mTAB,” “we,” “us,” “our”). Your data will be controlled by the mTAB undertaking that is providing services to you or communicating to you and each such entity is therefore regarded as an independent data controller of your personal information
Data Compliance Officer: Alex Gelman, Email: DCO@mtab.com
This Privacy Notice describes what information mTAB collects from customers, potential customers and any other individuals who contact us. mTAB uses this information for its legitimate business purposes and to better serve the needs of our current and prospective customers. mTAB is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
Information mTab collects about you
mTab collects and processes a range of information about you. This information may include, but is not limited to, your name, phone number, email address, billing address, delivery address, payment details, details about your previous purchases, the content of any email you send to us and any other similar information.
mTAB may collect this information in a variety of ways. For example, data might be collected through our online site, or obtained from correspondence with you. In some cases, mTAB may collect personal data about you from third parties, such as in the case of referrals from other businesses, customers or staff.
You may also give us information about you by filling in forms, setting up user account or profiles, subscribing to newsletters and other services, ordering a product, submitting an enquiry about a product, using our enquiry form or participating in surveys, or by communicating with us by email, phone or otherwise.
You are under no obligation to provide this information, but without it, we may not be able to provide you with some of our services or information you may request.
Why does mTab need to process your data?
mTAB uses this information for its legitimate business purposes and to better serve the needs of our current and prospective customers. This could include activities such as letting you know about product services, setting up user accounts, contacting you with billing enquiries, delivery of your products, dealing with your enquiries, or asking you about what sorts of services you may require mTAB’s assistance with.
We rely on your consent in order to make contact with you by email or phone for relationship and marketing purposes. You can withdraw that consent and ask us to delete your information at any time.
Data protection law also allows the use of personal data where the benefits (or “legitimate interests”) of doing so outweigh the possible negative implications for the relevant individuals. These are the grounds on which we usually rely when we use your information for anything other than making contact with you by email for marketing purposes. If you object to us using these grounds you can do so at any time. In some cases, mTAB also needs to process your data to ensure that it is complying with statutory and legal obligations.
How does mTab store and protect your data?
mTAB takes the security of your data seriously. mTAB has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.
Where mTAB engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality, and are obliged to implement appropriate technical and organizational measures to ensure the security of data.
Who does mTab share your data with?
mTAB shares personal data with third party hosting provider of cloud computing services. Additionally, mTAB shares personal data within the mTAB Group. We will not share your information with third parties for a purpose that is materially different from original purposes without your consent.
In the event that mTAB is required to disclose personal data, mTAB may do so, only to the extent necessary to comply with the requirement of law, legal process, valid order of a court competent jurisdiction or lawful request by public authorities including to meet national security or law enforcement requirements.
How does mTAB share your data?
Your data may be transferred to countries outside the European Economic Area (EEA) to enable processing in connection with mTAB services or products. Data is transferred outside the EEA on the basis of written instructions including the confirmation of relevant safeguards as outlined and approved by the ICO as supervising authority.
For how long does mTAB keep your data?
mTAB only collects Personal Data that it believes is necessary to perform the services that you seek from mTAB and to exercise its rights and comply with its obligations. We will keep your Personal Data only as long as we need it for the purposes for which we collect it or as otherwise permitted by current legislation.
What are your rights?
As a data subject, you have a number of rights. You can:
- Access and obtain a copy of your data on request;
- Require mTAB to change incorrect or incomplete data;
- Require mTAB to delete or stop processing your data, for example where the data is nolonger necessary for the purposes of processing; and
- Object to the processing of your data where mTAB is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact DSAR@mtab.com.
If you believe that mTAB has not complied with your data protection rights, you can complain to your supervisory authority (e.g. the Information Commissioner in the UK). Additionally, mTAB is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Please visit the FTC website for further information.
What is mTAB’s liability in cases of onward transfer of Personal Data?
In the context of an onward transfer mTab has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. mTab shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
Any claim arising out of or related to the misuse of your personal data shall, on the written request of any party, hereto, served on to mTAB may be submitted to binding arbitration and such arbitration shall comply with and be governed by the provisions of the American Arbitration Association Rules then in effect. The costs of arbitration shall be borne equally by the parties.
What if you do not provide personal data?
mTAB requires certain information in order to process your request and deliver its service to you. If you do not wish to provide this information, then we may be unable to process your request.
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mTab commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.