MOBLE PRIVACY POLICY

Definitions

Personal information (or “personal data”) means information about an identifiable individual. Services means our websites, platform and modules. Customer means the business that contracts with MOBLE. End user means a visitor, shopper or other individual interacting with a Customer’s experience powered by MOBLE.

1. Purpose & scope

This Privacy Policy applies to:

• Visitors to our websites and help centre.
• Customers and their teams who use the MOBLE platform and modules.
• End users of customer websites, stores, chatbots or forms that run on our platform (where we process data on behalf of a customer).
• Prospective customers who receive MOBLE marketing (subject to opt-out at any time).

2. Our role (controller vs. processor)

Controller. We act as a controller when we decide why/how to process personal information (e.g., account details, billing, platform telemetry, MOBLE marketing lists).

Processor / service provider. We act as a processor when we process personal information strictly on a Customer’s documented instructions (e.g., orders, contact forms, chatbot transcripts, CRM records). For these activities our Data Processing Addendum (DPA) applies in addition to this notice.

3. Personal information we collect

No special categories by default Please do not upload health, biometric or other sensitive categories unless permitted by law and covered by written terms with us.

4. How & why we use data (and legal bases)

• Provide & improve the Services. Operate the platform, host content, process orders, provide chat, maintain security, fix bugs, and ship new features. Legal basis (EEA/UK/CH): contract; legitimate interests.
• Support & communications. Respond to tickets, notify about changes, send transactional emails. Basis: contract; legitimate interests.
• Security & fraud prevention. Detect abuse, investigate incidents, protect accounts and infrastructure. Basis: legitimate interests; legal obligations.
• Analytics & optimisation. Understand aggregate usage to improve reliability and UX (often using de-identified data). Basis: legitimate interests; consent where required.
• Marketing (opt-out any time). Send product news and offers to business contacts. Basis: consent or legitimate interests as permitted.
• Compliance. Meet legal, tax and regulatory obligations; respond to lawful requests. Basis: legal obligations; public interest.

5. Cookies & similar technologies

We use cookies, pixels and local storage to keep you signed in, remember preferences, measure audience and performance, and—if enabled—support attribution and advertising on our sites. You can manage preferences via our cookie banner and browser settings. For vendor detail and retention, see our Cookie Policy.

Do Not Track: there is no industry consensus; we currently do not respond to DNT signals.

6) How we share information

• Service providers (sub-processors). Hosting, storage, security, email, logging, analytics, support and optional AI providers—under contract and limited to their task. See our Sub-Processor List.
• Integrations you enable. If you connect third-party platforms, we share the data needed to make them work, per your configuration and that provider’s terms.
• Legal & safety. To comply with law, protect rights, prevent fraud or abuse, and respond to lawful requests.
• Business transfers. As part of a merger, acquisition or restructuring, subject to this policy or equivalent safeguards.

We do not sell personal information. Where our use of advertising partners on MOBLE-owned sites could be deemed “sharing” for targeted advertising, you can opt out via our cookie banner or the Your Privacy Choices section.

7. International transfers

We may process data in Australia and other countries. Where laws require, we use valid transfer mechanisms—such as the EU Standard Contractual Clauses and the UK Addendum—and conduct transfer risk assessments. For US vendors that participate in the Data Privacy Framework, we may rely on their certification as part of our safeguards.

8. How we secure information

• Encryption in transit (TLS) and at rest (where applicable).
• Least-privilege access, MFA for staff, role-based controls.
• Network segmentation, logging & monitoring, vulnerability management, secure SDLC.
• Vendor due diligence and contractual data protection terms.
• Incident response processes and breach notification consistent with applicable laws.

9. Data retention

We retain personal information only as long as needed for the purposes above, to operate the Services, to defend or establish legal claims, and to meet legal obligations. Certain records (e.g., tax and accounting documents) may be retained for up to seven (7) years or as required by law.

10. Your rights & choices

Australia (APPs)

You can request access to and correction of your personal information. If you have concerns, see Contact & complaints.

EEA/UK/Switzerland (GDPR)

Depending on context: access, rectification, erasure, restriction, portability, and objection to processing (including profiling) based on legitimate interests; withdrawal of consent at any time (without affecting prior processing). You can lodge a complaint with your supervisory authority.

United States (state privacy laws)

Residents of certain US states may have rights to know/access, correct, delete, portability, and to opt-out of “sale”/“share” or targeted advertising. We do not sell personal information. Where our use of advertising partners on MOBLE-owned sites may constitute “sharing,” you can opt-out via cookie preferences and by contacting team@moble.com.au. Appeals processes are available where required by law.

Appendix — Data Processing Addendum (overview)

When MOBLE processes personal information on your behalf, our Data Processing Addendum (DPA) applies (roles, instructions, security, sub-processors, international transfers, assistance, breach notice, deletion/return, and audits). To obtain the current DPA, contact team@moble.com.au. Our current sub-processors are listed at www.moble.com/terms-sub-processor-list.