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Last updated June 13, 2023
Thank you for choosing to be part of our community at Lulu Systems, Inc., (“Mobilo”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at hello@mobilocard.com.
This Privacy Policy applies to all information collected through our website (at https://www.mobilocard.com) (the “Site“), and any related services, applications, software, content, marketing, events, hardware, and technologies offered through or in connection with the Site (the “Services“).
When you visit the Site or use our Services, you trust us with your personal information. We take your privacy very seriously. In this Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not consent to, please discontinue use of our Site and Services. By accessing or using the Site or the Services, you acknowledge that you have read and understood this Privacy Policy.
In Short: We collect personal information that you provide to us such as name, address, contact information, and other information you voluntarily provide us.
We collect personal information that you voluntarily provide to us (i) when you sign up for the Site or Services, (ii) when you express an interest in obtaining information about us or our products and services, (iii) automatically as you use the Site or Services, or (iv) otherwise when contacting us.
The personal information that we collect depends on the context of your interactions with us and the Site or Services, the choices you make and the products and features you use. The personal information we collect can include the following, which for reference is categorized under the letters set forth in the California Privacy Rights Act (California Civil Code 1798.140(v)(1)) (“Your Data”):
Your Data that you provide to us must be true, complete and accurate, and you should notify us of any changes to Your Data.
In Short: We may collect information regarding Your Data when you use our Site or Services.
If you use our Site or Services, we, our service providers, and our third party partners may automatically log or collect information about you, your computer, or mobile device, and your activity over time on the Site or Services including:
In Short: We process Your Data for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use Your Data for a variety of business purposes described below. We process Your Data for these purposes in reliance on our legitimate business interests, in order to, among other things, provide the Site’s functionality, fulfill your requests, engage in analysis related to improving the quality of the Site, personalize your experience, enter into or perform a contract with you, track usage of the Site and Services, deliver targeted advertising, market the Site and Services, provide customer support, send you electronic communications, request feedback, allow for disaster recovery, enhance the security of the Site and Services, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
We may combine information we collect from or about you for any of the purposes set out above (depending on the types of information we receive).
In Short: We only share Your Data with your consent, to comply with laws, to provide you with access to the Site and Services, to protect your rights, or to fulfill business obligations.
We may share Your Data based on the following legal basis:
In Short: We may use cookies and other tracking technologies to collect and store Your Data.
This section (“Cookie Policy”) applies to all information collected through the Site, including the technologies we and third parties with whom we partner, use for automatic data collection. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store Your Data. This Cookie Policy explains the different types of cookies used on the Site and how you can control them. We may change this Cookie Policy at any time.
A browser cookie is a small piece of data that is stored on your device to help websites and mobile apps remember things about you. Other technologies, including Web storage and identifiers associated with your device, may be used for similar purposes. We use cookies, including third-party cookies, for a number of reasons, like protecting your data and account, helping us see which features are most popular, counting visitors to a page, improving our users’ experience, keeping our Site and services secure, providing targeted advertising, and to provide you with a better experience.
The cookies we use generally fall into one of the following categories:
Where applicable, we provide you with the opportunity to opt out of the use of Cookies. You may refuse to accept browser cookies by activating the appropriate setting on your device. However, doing so may affect the Site’s functionality.
In Short: We keep Your Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.
We will only keep Your Data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us to keep Your Data for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process Your Data, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store Your Data and isolate it from any further processing until deletion is possible.
You may also request to have Your Data deleted by emailing us at hello@mobilocard.com. Please note that we will need to verify that you have the authority to delete the account. Also, some information may remain in our records after your deletion of such information from your account, and public activity on your account prior to deletion may remain publicly accessible. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. We strive to respond to verifiable consumer requests within 30 days; however, if we require an extension (up to an additional 30 days) we will inform you of this extension and the reason in writing.
By submitting Your Data to us, or to a third-party via the Site or Services, you acknowledge that you will be voluntarily transferring Your Data to the United States, a jurisdiction which may not provide the same privacy framework as other regions. We take steps to ensure that the data we collect under this Privacy Policy is stored and processed in accordance with this Privacy Policy regardless of where the data is located.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
The Services are not intended for children under 13 years of age. We do not knowingly solicit data from or market to children under 18 years of age. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at: hello@mobilocard.com.
In Short: You may review, change, or terminate your account at any time.
You have the right to request that we correct or update Your Data. You can object to the processing of Your Data and your personal information and ask us to restrict processing of Your Data and your personal information. Similarly, if we have collected and processed Your Data or your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect processing of Your Data or your personal information conducted in reliance on lawful processing grounds other than consent. The Site generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. If you have any questions or comments about the processing of your personal information, you may contact us at: hello@mobilocard.com.
Please note that the personal information we obtain from or about you may be transferred, processed, and stored outside of your country for the purposes described in this Privacy Policy, including in the United States of America. We take the privacy of our users seriously and therefore take steps to safeguard your information, including ensuring an adequate level of data protection in accordance with applicable standards in effect as of the date of this Privacy Policy. These steps include use of the European Commission’s Standard Contractual Clauses for transfers of personal information by third party service providers and partners and further details can be provided upon request.
If you are a resident of the European Economic Area (“EEA”) and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you would at any time like to review or change the information in your account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete Your Data and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may contact us at: hello@mobilocard.com.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
In Short: Yes, if you are a resident of countries in the EEA or Switzerland (“European Resident”), California, or Nevada, you are granted specific rights regarding access to Your Data.
EUROPEAN RESIDENTS
Under the General Data Protection Regulation (“GDPR”), European Residents have additional rights regarding your Personal Data, subject to any conditions, exceptions, or limitations contained in GDPR, including:
You can withdraw your consent to our collection or processing of your Personal Data or your personal information at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect processing of your Personal Data or your personal information conducted in reliance on lawful processing grounds other than consent. However, we might not be able to provide the services you request if you withdraw your consent for processing.
To exercise any of the above rights, you must submit a request to us by email at: hello@mobilocard.com. Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. We cannot respond to your request if we are unable to verify your identity or authority. Your verifiable request must include the reference “Request for GDPR Privacy Information” in the subject line and the body of the message must:
- provide sufficient information that allows us to reasonably verify that you are the person whose Personal Information we have collected;
- describe your request with sufficient detail; and
- include an e-mail address or mailing address, as applicable, for us to send our response.
We strive to respond to verifiable consumer requests within 28 days; however, if we require an extension (up to an additional 28 days) we will inform you of this extension and the reason in writing.
You can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
Under the CPRA, California residents have the following rights, subject to any limitations stated in the CPRA:
- Right to Request Deletion. You have the right to request that we delete any Personal Information about you that we maintain.
- Right to Request Correction. You have the right to request that we correct any inaccurate Personal Information that we maintain.
- Right to Know What Personal Information is Being Collected. You have the right to request that we inform you of the (i) categories of Personal Information we have collected about you; (ii) categories of sources from which any Personal Information is collected; (iii) business or commercial purpose for collecting, selling, or sharing any Personal Information we have collected about you; and (iv) categories of third parties to whom we have disclosed any Personal Information. The categories of Personal Information collected over the past 12 months and the categories of sources from which we collect Personal Information are outlined in the section above entitled "Information We Collect and How We Collect It.” The business/commercial purpose for the collected information is outlined in the section above entitled "How We Use Information We Collect.” The categories of third parties to whom we have disclosed any Personal Information is outlined in the section above entitled “How and When We Share Information.”
- Right to Access. You have a right to request a copy of the Personal Information that we have collected and maintained in the period that is 12 months prior to the request date.
- Right to Know What Personal Information is Being Sold. You have the right to request the (i) categories of Personal Information that we have sold or shared to a third party and the category of the third party to whom we sold or shared your Personal Information; and (ii) categories of Personal Information we have disclosed to a third party for a business purpose and the category of the third party to whom we disclosed your Personal Information. The categories of third parties to whom we have disclosed any Personal Information is outlined in the section above entitled “How and When We Share Information.” We do not sell your Personal Information to third parties and have not sold Personal Information in the preceding 12 months.
- Right to Opt Out of Sale and Sharing. To the extent we sell or share Personal Information, you have the right to direct us to opt out of that sale or sharing. We do not sell your Personal Information to third parties and have not sold Personal Information in the preceding 12 months.
Nevada (“NV”) law also guarantees that Residents of NV have the Right to Opt-Out of any sale of your Personal Information. We do not sell Personal Information.
- Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the use of your Personal Information to only uses that are necessary to perform the services or provide the goods. We do not collect, use, or disclose any Sensitive Personal Information as defined in Section 1798.140(v)(1)(L)(ae) of the CPRA.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.
If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are a California resident and provide us with your Personal Information, you may exercise the above rights by submitting a verifiable consumer request to us by email at hello@mobilocard.com or at the mailing address below.
Only you or a person registered with the CA Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. We cannot respond to your request if we are unable to verify your identity or authority. Your verifiable request must include the reference “Request for California/Nevada Privacy Information” in the subject line and the body of the message must:
- provide sufficient information that allows us to reasonably verify that you are the person whose Personal Information we have collected;
- describe your request with sufficient detail; and
- include an e-mail address or mailing address, as applicable, for us to send our response.
We strive to respond to verifiable consumer requests within 30 days; however, if we require an extension (up to an additional 60 days) we will inform you of this extension and the reason in writing. Data disclosure request will only include data collected within the 12-month period preceding the receipt of the verified request. We do not charge a fee to process requests to exercise your rights unless the requests are found to be excessive, repetitive, or unfounded.
If you are under 18 years of age, reside in CA, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in CA. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.
If you have any questions or comments about the processing of your Personal Information, you may contact us at: hello@mobilocard.com.
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this Privacy Policy from time to time. All changes are effective immediately when we post them and we will use reasonable efforts to alert you about any changes by updating the “Last updated” date of this Privacy Policy. It is your responsibility to review this Privacy Policy frequently to be informed of how we are protecting your information. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted. We may, in our sole discretion, translate this Privacy Policy into other languages for your convenience, nevertheless, the English version governs your relationship with Mobilo and any inconsistencies among the different versions will be resolved in favor of the English version.
If you have questions or comments about this policy, you may email us at hello@mobilocard.com or by post to:
Lulu Systems, Inc.
1178 Broadway
3rd Floor #1021
New York, NY 10001
United States
