Last Updated: September 17, 2021
Mobilize Networks Inc. (“Mobilize“, “we“, “our” or “us“) develops and operates a community management platform (the “Platform“), used by various organizations, businesses and community organizers to manage and engage with members of their communities (“Communities“).
We also maintain and operate the website www.mobilize.io, its subdomains and its related features, such as our blog and newsletters (collectively, the “Site“) as well as the Mobilize mobile application (the “App“), and access to the Platform is made possible through both (the Platform, together with the Site and App – the “Services“).
We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please discontinue and avoid using our Services.
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience when using our Services.
We collect data regarding users of our platform, as well as visitors to our site and app.
Such data is typically collected and generated through your interaction with our services, through automatic means, or directly from you or your community owner or manager.
We collect the following categories of data, which, to the extent, it may enable the identification of a specific person, or is linked to such identifying data, we will deem it as “Personal Data”:
1. Data automatically collected or generated: when someone visits, interacts with, or uses our Services, including any e-mail or text messages sent to them via our Services, we may collect certain technical data about them. We collect or generate such data either independently or with the help of third-party services (as detailed below), including through the use of “cookies” and other tracking technologies (as further detailed below). Such data mainly consists of technical and aggregated usage data, such as IP address, non-identifying data regarding a device, operating system and browser, and user activity on our Services. It does not enable us to learn a person’s true identity or contact details and serves mostly so we could better understand how our users typically use our Services and how we could improve their user experience, our marketing campaigns and engagements, and the overall performance of our Services.
2. Data received from you: you may provide us Personal Data when you create your account and Community user profile (as an Owner, Manager, or Member), such as your name, workplace or community role, contact details (such as e-mail, phone, and address), profile image, location, gender, account login details (such as usernames and hashed passwords) (collectively, “Account Data”), as well as any other data you choose to provide when you visit our Services, post and share content with your Community or other Managers or Members, or when you contact us. Owners may also provide us additional Account Data in order to complete their selected transaction (such as their credit card number and related account and billing information, which we may update from time to time should you grant us permission to bill you for recurring charges), as well as their Community’s information and preferences. To the extent that such information concerns a non-human entity (e.g., a company or business), we do not regard it as “Personal Data” and this Policy shall not apply to it. As the Platform enables Owners and Managers to require or ask their Members to submit additional Personal Data, and as Owners, Managers, and Members may choose to submit additional Personal Data and share it with their Community or certain other Members, the list above is not exhaustive. We will, however, indicate on the Platform, for each Personal Data parameter, if it is “required” or “optional” for either the adequate performance of our Services or per the Community Owner’s or Manager’s requirements. When you submit information, you are transferring such information into the United States and you hereby consent to such transfer and have gained the necessary consent to do so.
3. Member Data received from Community Owners and Managers: Community Owners and Managers may use the Platform to add and invite Members to their Community. When doing so, they may already submit such Members’ Personal Data as listed in paragraph 2 above, in whole or in part. Any Community Owner and Manager doing so are solely responsible to ensure the legal basis and authority for processing such Personal Data, its accuracy and completeness, and for providing sufficient notice and choice to their Members regarding the use of their data. The Community Owner is the “Data Controller” of such data, and Mobilize solely acts as their “Data Processor” (as such roles are further explained below).
4. Data from Other Sources: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your personal information, we will only use that personal information for the specific reason for which it was provided to us.
Using Personal Data
We use personal data (a) in order to provide and improve our Services including services that display posts, account information, documents, reports, and communications such as emails (b) in accordance with our contractual obligations towards community owners; (c) to contact our visitors and users; (d) in order to comply with applicable laws, the Agreement and our policies, (e) to contact our Visitors, our Owners and their Managers and Members, with general or personalized service-related messages (such as password-retrieval or billing) or with promotional messages (such as newsletters, webinars, new features, etc.); and (e) to create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services.
Sharing Personal Data
We may share your data with certain third parties, including certain service providers, law enforcement agencies, and our affiliated companies – but only in accordance with this Policy.
Sharing Personal Data with Owners, Managers, and Members of your Community: Once you join a Community, your user profile will be made available to all Owners and their appointed Managers of such Community. All or part of your user profile may also be made available to other Members of a Community you join, according to the discretion of the Owners and Managers of that Community. Please note that Mobilize is not responsible or controls any further disclosure, use or monitoring by or on behalf of your Community Owners, Managers or Members.
Compliance with Laws, Legal Process, and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant, or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting and server co-location services, data analytics services, marketing agencies and advertising services, data and cybersecurity services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution, and monitoring services, session recording, remote access services, and our business, legal, financial and privacy advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes. Mobilize remains responsible and liable for any Personal Data processing done by Service Providers on its behalf, other than for events outside of its reasonable control.
Third-Party Integrations: The Services may allow you to integrate with certain third-party services, in which case you will be bound by the terms of service and privacy notices of said third parties – so please make sure you read and accept them. We do not receive or store your passwords for any of these third-party services.
Protecting Rights and Safety: We may share your Personal Data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Mobilize, any of our users or any members of the general public.
Mobilize Subsidiaries and Affiliated Companies: We may share Personal Data internally within our family of companies, for the purposes described in this Policy. In addition, should Mobilize or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or a prominent notice on our Services.
For the removal of doubt, Mobilize may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or we have successfully rendered such data non-personal and anonymous. We may transfer, share, or otherwise use non-personal data at our sole discretion and without the need for further approval.
Links to Other Websites
Using Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers, and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns. A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the user. While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
Mobilize uses certain monitoring and tracking technologies, such as cookies, beacons, pixels, tags, and scripts (collectively, “Cookies”). These technologies are used in order to maintain, provide and improve our website and services, and in order to provide our users with a better experience (for instance in order to track users’ preferences, to better secure our services, to identify technical issues, and to monitor and improve the overall performance of our services).
What are Cookies?
Cookies are small text files that are stored by the browser (for example, Google Chrome or Safari) on your computer or mobile device. They allow websites to store things like user preferences. You can think of Cookies as providing a ‘memory’ for the website so that it can recognize you when you come back and respond appropriately.
Performance Cookies: This type of cookie remembers your preferences for tools found on the services, so you don’t have to re-set them each time you visit.
Analytics Cookies: Every time someone visits our services, analytics services we use generate Cookies which can tell us whether or not you have visited the services in the past, and provide additional information regarding how our users use our services (such as regarding where users tend to click on our services). Your browser will tell us if you have these Cookies and, if you don’t, we generate new ones. This allows us to track how many individual users we have and how often they visit the services. Unless you are signed in to our services, we cannot use these Cookies to identify individuals. We use them to gather statistics. For example, the number of visits to a page.
Registration Cookies: When you register and sign in to our Services, we generate Cookies that let us know whether you are signed in or not. Our servers use these Cookies to work out which account you are signed in with and if you are allowed access to a particular service. While you are signed in to our services, we combine information from your registration Cookies with analytics Cookies, which we could use to identify which pages you have seen.
Third-Party Integration Cookies: On some pages of our services, other organizations may also set their own cookies. They do this to track the performance of their applications that are integrated with our services, or to customize their services for you. Because of how cookies work, our website cannot access these cookies, nor can the other organization access the data in cookies we use on our services.
Cookies Source & Description
How do I turn Cookies off?
All modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘Options’ or ‘Preferences’ menu of your browser. In order to understand these settings, the following links may be helpful, or you can use the Help option in your browser for more details.
If you are primarily concerned about third party cookies generated by advertisers, and you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.yourchoicesonline.com (for European users).
If you like to find out more about cookies and their use on the Internet, you may find the following websites useful:
Some web browsers may transmit Do Not Track signals to websites with which the browser communicates, telling the site not to follow its online movements. Because of differences in how web browsers interpret this feature, it is not always clear whether Users intend for these signals to be transmitted, or whether they are even aware of them. Therefore, we currently do not respond to such Do Not Track signals.
We or our partners may send promotional communications, that you can easily opt-out of receiving. We may also contact you with service-related communications. You will not be able to opt-out of receiving such communications.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also send notifications about new services, events, and special opportunities or any other information we think our Owners and Managers will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile, or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you wish not to receive such promotional communications, you may notify Mobilize at any time by emailing us at [email protected] or by following the “unsubscribe”, “stop” or “change e-mail preferences” instructions contained in the promotional communications you receive.
Information Related to Data Collected for through the Mobilize Platform
Mobilize collects information under the direction of its clients, and has no direct relationship with the individuals whose personal data it processes. Mobilize works with its clients to help them provide notice to their customers concerning the purpose for which personal information is collected.
We collect information for our clients, if you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our Service, please contact the client that you interact with directly.
Mobilize may transfer personal information to companies that help us provide our Service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our clients.
Mobilize has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Mobilize client (the data controller). If the client requests Mobilize to remove the data, we will respond to their request within 30 days.
Mobilize will retain personal data we process on behalf of our clients for as long as needed to provide Service to our client. Mobilize will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Securing Personal Data
We are committed to securing your personal data and use many security measures to better protect it. However, as we can’t guarantee absolute protection, we encourage you to be aware of the risk when using the services or providing us with your personal data.
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of the security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data.
Compliance with Children’s Online Privacy Protection Act
As a business service, Mobilize does not target its offerings toward, and does not knowingly collect any personal information from users under 13 years of age. If you believe that your child has provided us with personal information without your consent, you may contact us at [email protected] If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
Supplemental California Privacy Notice
Under the CCPA, California residents have certain rights around our collection, use, and sharing of their personal information as explained in the “Additional Privacy Rights” section below. If you wish to exercise any of your rights as a California resident, please contact us as set forth below.
In exercising any rights under the CCPA, we will ask certain questions in order to verify your identity and your status as a California resident. An agent may also submit a request on your behalf, but we may require that you verify the agent has been authorized by you.
Category of 3rd Parties Information Is Disclosed To
A real name, alias, postal address, unique personal identifier, title, online identifier, Internet Protocol address, email address, telephone number, account name, or other similar identifiers.
· Advertising networks · Internet service providers · Social networks · Service providers · Operating systems and platforms · Other technology vendors with whom we partner
Internet or other electronic network activity
Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.
We do not “sell” personal information and have not “sold” personal information, as such term is defined in the CCPA, in the previous 12 months. We do not have actual knowledge that we have “sold” any personal information of minors under 16 years of age.
Additional Privacy Rights
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties., provide you a different level or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please send an email with your request to [email protected]
To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address, account number, or phone number.
Accessing and Updating Personal Information
Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. When you use the Mobilize website or Service, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not for legitimate business purposes. You may update your account information by logging into your account. When requests come to Mobilize with regard to personal information, we ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. We retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. We will respond to these requests within a reasonable timeframe.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Updates and amendments
237 Kearny St
San Francisco, CA 94108
“GDPR-Rep.eu” has been designated as Mobilize’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. GDPR-Rep.eu may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please add ‘GDPR-REP ID: 14653978’ to all correspondence, which may be addressed to:
iuro | Dr. Andreas Mätzler
Attorney at Law
c/o Mobilize Networks
1010 Vienna, Austria