mBlox Inc. Privacy Policy

This privacy policy (“Privacy Policy”) applies to the website operated by mBlox located at http://www.mblox.com (the “Site”).  The Site is the exclusive property of mBlox, Inc. (“mBlox”, “We”, “Us” or “Our”).  All information collected on the Site is Our exclusive property.

Your privacy is important to Us.  The purpose of this Privacy Policy is to inform you about the information We may gather about you, how We may use that information, whether We disclose it to anyone, and the choices you have regarding Our use of the information we collect. 

I. Information Collected by mBlox. In general, mBlox will collect information from You based upon our business relationship and your use of the Site and Our services as set forth below: 

a. Content Registration.  In order to access and view some content on the Site You are required to register with mBlox before the content is made available to You.  During the registration process, You are required to provide Us with certain contact information, including your name, address, phone number and email address. We use this information to contact You about the services We offer in which you have expressed interest.

b. Client Support Portal.  When You contact mBlox customer support  ("Customer Support") using the mBlox Client Support Portal located at http://www.mblox.com/support/login.php (the "Client Support Portal"), We may ask you for personally identifiable information regarding your inquiry, such as your name, email address or telephone number. We will take reasonable steps to protect the information you share with Us from unauthorized access or disclosure.

c. Cookies.  When you contact Customer Support through the Client Support Portal the mBlox web server sends a cookie to your computer. Cookies are files that web browsers place on a computer’s hard drive and are used to tell Us whether customers and visitors have visited the Site previously.

(i)  The Client Support Portal uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Us to process your online data and requests. Session cookies help Us make sure you are who you say you are after you have logged in. We use persistent cookies, which only We can read and use, to identify the fact that you are an mBlox customer or prior site visitor. Users who disable their browser’s ability to accept cookies will be able to browse the Site but will not be able to successfully use certain Customer Support features.

(ii)  We also may from time to time engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to Our Site to help Us administer Our Site and improve its quality. Such third parties may use cookies to help track visitor behavior. Such cookies will not be used to associate individual Site visitors to any personally identifiable information. All data collected by such third parties on Our behalf is used only to provide Us with information on site usage and is not shared with any other third parties.  It is possible to configure your browser to reject cookies by modifying the browser settings or preferences. If you wish to do so, We recommend you consult the information provided in the browser or contact the browser vendor for help or instructions.

d. Correspondence.  If you send Us personal correspondence, such as emails or letters, We may collect such information into a file specific to you.

II. Use of Information. mBlox collects and uses your personal information to give you high quality customer service, to provide you with convenient access to Our products and services, and to make you aware of the latest offerings from mBlox.

a. Newsletter.  If you wish to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you have the option to unsubscribe from receiving some or all of the newsletters. Please see the "Choice and Opt-out" section below.

b. Service-related Announcements.  We will send you service-related announcements when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

c. Customer Service.  As discussed above, We will also communicate with you in response to your customer service inquiries, to provide the services you request, and to manage your account.

d. Mobile User Information.  As part of our services, we sometimes receive personal information from wireless carriers and operators in order to provision the specific content and data services requested by individual users. All such personal information is acquired from either the wireless carrier's website or from the user's mobile device via the wireless carrier's network. This personal data is usually limited to the user's cell phone number. In some cases, such as for prize fulfillment for a mobile contest, the user's mailing address is also provided. The user must explicitly "opt in" through the wireless carrier in order for any of this information to be collected and its use is governed by this Privacy Policy and any policies or procedures of the user's wireless carrier. We only use personal information we receive as part of our services for the purpose of providing those services to the wireless carriers and operators and their subscribers.

III. Disclosure of Information

a. General.  As a matter of policy, we do not sell or rent any of your personal information to third parties for any advertising or marketing purposes. However, the following describes some of the ways that we may disclose your personal information in the normal course of providing our services.

(i) Your Use of mBlog.  If you participate in the mBlog or other public forum offered by the Site, your User ID will be displayed on any content that you post and will therefore be available to the public. Therefore, if you associate your name with your User ID, your name may be available to the public. Any other information about yourself that you include in such posts will be publicly available.

(ii) Legal Requests.  We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on the Site.

b. Disclosure of Information to mBlox Foreign Affiliates.  Because mBlox is a global company, We may share your information with other mBlox affiliates and business units in other parts of the world in order to provide you with Our services.  Your personally identifiable information may be transferred by Us from your home country to mBlox employees in mBlox offices around the world, who may communicate with you regarding your inquiry. Please understand that We limit access to your personally identifiable information to only those mBlox employees who We believe need access in order to provide services to you or to otherwise do their jobs.

(i) Safe Harbor.  mBlox follows the European Union Safe Harbor framework as set forth by the Department of Commerce regarding collection, use, and retention of data from the European Union. Our privacy practices with respect to personal data collected from individuals residing in the European Union are self-certified to the Safe Harbor Program developed by the US Department of Commerce and the European Commission. For more information about the Safe Harbor Program, please go to http://export.gov/safeharbor/. Terms that are capitalized in Sections III(b)(ii) and III(b)(iii) below have the meanings attributed to them in the Safe Harbor Program.

(ii) mBlox Mobile Services in the European Union.  For mobile content and data services supplied through European Union wireless carriers and operators, We may receive Personal Data transferred by users in the European Union to the United States merely as a Data Processor on behalf of those carriers and operators. In this capacity, we act as the Data Processor and these carrier and operators act as the Data Controllers. We do not own or control any of the Personal Data we process on behalf of our carrier and operator partners. Processes performed by Us on behalf of our carrier partners are pursuant to the instructions of the applicable partner. We may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such data by the applicable partner.

(iii) Compliance with Laws.  Notwithstanding Section III(b)(ii) above, We may disclose Personal Data to governmental authorities when required or reasonably requested to do so by such governmental authorities. This Privacy Policy does not apply to the extent that it is in conflict with any law that may be applicable to the Personal Data of a Data Subject.

IV. This Site is not for use by children.  Protecting the privacy of children is important to mBlox. For that reason, the Site is structured specifically to not attract anyone under 13, nor do we collect or maintain personally identifiable information at the Site from those who mBlox actually knows are under 13. If mBlox learns or is notified that it has collected information from users under the age of 13, mBlox will immediately delete such personally identifiable information. 

V. Opt-Out.  We provide you the opportunity to 'opt-out' of having your personally identifiable information used for certain purposes, when we ask for this information. For example, if you register with Us but no longer wish to receive our newsletters and/or related communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing Us at privacy@mBlox.com.

VI. Security.  We take appropriate technical and organizational measures to guard against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. While no computer system is completely secure, We believe the measures implemented by Our site reduce the likelihood of security problems to a level appropriate to the type of data involved.  

VII. Disclaimer.  We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), We may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they collect from the Site.

VIII. Links to Other Sites.  Please be advised this Privacy Policy applies only to the Site and does not apply to the practices of companies that mBlox does not own or control, or to people that mBlox does not employ or manage. This includes links to other websites on the Site as well as any companies from whom you may have ordered services or products that are transmitted over mBlox’s mobile transaction network, and any companies from whom you may be purchasing telecommunications services.  mBlox recommends that you be aware when you leave the Site and read the terms of use and privacy policies of any site that collects personally identifiable information.

IX. Changes to this Privacy Policy.  We reserve the right to modify this Privacy Policy at any time, so please review it regularly. If We make changes to this Privacy Policy, We will post the revised Privacy Policy on the Site and other places We deem appropriate. All such changes shall be binding on you 30 days after they are initially posted on the Site unless you are a new user, in which case they are binding on you immediately.

X. How to Contact Us.  If you have any questions about the Privacy Policy or the information and data We collect, please send Us an email at privacy@mblox.com   

Effective May, 2010