Overview

Mobaro prioritizes customer trust. We know that customer data is important to our customers’ values and operations. That is why we keep it private and safe.

Mobaro supports over 110,000 customers in over 160 countries and territories. Our customers entrust us with large amounts of sensitive information, stemming from a wide range of industries including healthcare, financial services, government, and technology.

Mobaro helps customers maintain control of their privacy and data security in a myriad of ways:

  • Data Security: We provide our customers compliance with security standards, such as encryption of data in motion over public networks, Distributed Denial of Service (“DDoS”) mitigations, and a Support team.
  • Disclosure of Customer Service Data: Mobaro only discloses Service Data to third parties where disclosure is necessary to provide the services or as required to respond to lawful requests from public authorities.
  • Trust: Mobaro has developed security protections and control processes to help our customers ensure a secure environment for their information. Independent third-party experts have confirmed Mobaro’s adherence to high industry standards.
  • Access Management: Mobaro does not access or use customer content for any purpose other than providing, maintaining and improving the Mobaro services and as otherwise required by law.

What is Service Data

Service Data is any information, including personal data, which is stored in or transmitted via the Mobaro services, by, or on behalf of, our customers and their end-users.

Ownership of Service Data

From a privacy perspective, the customer is the controller of Service Data, and Mobaro is a processor. This means that throughout the time that a customer subscribes to services with Mobaro, the customer retains ownership of and control over Service Data in its account.

Who are Mobaro’s sub-processors?

Mobaro maintains an up-to-date list of the names and locations of all sub-processors (including members of the Mobaro Group and third parties) used for hosting or other processing of Service Data, which can be found here. The list also may be obtained by contacting privacy@mobaro.com.

How does Mobaro use service data?

We use Service Data to operate and improve our services, help customers access and use the services, respond to customer inquiries, and send communication related to the services.

How does Mobaro secure Service Data?

Mobaro prioritizes data security and combines enterprise-class security features with comprehensive audits of our applications, systems, and networks to ensure customer and business data is always protected.

For example, Mobaro servers are hosted at Tier IV or III+, SSAE-16, PCI DSS, or ISO 27001 compliant facilities. Additionally, we engage third-party security experts to perform detailed penetration tests on a periodic basis, and our Support team is on call 24/7 to respond to security alerts and events.

Where is Service Data stored?

Mobaro has data centers in three main regions — United States, Asia Pacific, and the European Union. Service Data may be stored in any region. Customers can select the region in which data centers that host certain of their Service Data are located by purchasing the Data Center Locality Add-On. Please see the Regional Data Hosting Policy for additional information.

How does Mobaro respond to Information Requests?

Mobaro recognizes that privacy and data security issues are top priorities for customers.

  • Mobaro does not disclose Service Data except as necessary to provide its services to its customers and comply with the law as detailed in our Privacy Policy found here.
  • Mobaro has achieved a number of internationally-recognized certifications and accreditations demonstrating compliance with third-party assurance frameworks.
  • Where we need to act publicly to protect customers, we do. Mobaro has voiced its support for the USA Liberty Act that seeks to reform the surveillance program under Section 702 of the Foreign Intelligence Surveillance Act (“FISA”).

Legal requests for Service Data

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal data to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information with relevant law enforcement agencies or public authorities if we believe same to be necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Master Subscription Agreement, or as otherwise required by law.

EU Directive

The EU Data Protection Directive (also known as “Directive 95/46/EC“) addresses the processing of personal data and the free movement of such data. Broadly, this Directive sets out a number of data protection principles and requirements which must be adhered to when personal data is processed.

Directive 95/46/EC established the Article 29 Working Party (“WP29”), which is comprised of representatives from the data protection authorities of all the EU Member States as well as from the European Commission. WP29 works to harmonize the application of data protection rules throughout the EU and also advises the EU Commission on the adequacy of data protection standards in non-EU countries.

How does GDPR apply to Mobaro’s customers?

Mobaro customers that collect and store personal data are considered data controllers under Directive 95/46/EC. Data controllers bear the primary responsibility for ensuring that their processing of personal data is compliant with relevant EU data protection law, including Directive 95/46/EC and the GDPR as of May 25, 2018.

What is a DPA (“Data Processing Agreement”)?

Mobaro offers customers a robust Data Processing Agreement (“DPA”), governing the relationship between the customer (acting as a data controller) and Mobaro (acting as a data processor). The DPA facilitates Mobaro’s customers’ compliance with their obligations under EU data protection law. Our DPA contains strong privacy commitments that few software companies can match, and has been updated to confirm our compliance with the GDPR as and from May 25, 2018. Our DPA contains data transfer frameworks to ensure that our customers can lawfully transfer personal data to Mobaro outside of the European Union by relying on one of three mechanisms: our Binding Corporate Rules, our Privacy Shield certification, or Standard Contractual Clauses.

What are “Model Clauses”?

The European Commission has approved a set of standard provisions called the Standard Contractual Clauses (“Model Clauses”) which provide a data controller a compliant mechanism to transfer personal data to a data processor outside the European Economic Area (“EEA”). The Model Clauses are appended to the Mobaro DPA to help provide adequate protection for data transfer outside of the EEA or Switzerland.

Does Mobaro replicate the Service Data it stores?

Mobaro periodically replicates data for purposes of archival, backup and audit logs. We use Amazon Web Services (AWS) to store some of the information that is backed up, such as database information and attachment files. Please see our Regional Data Hosting Policy for further details.

Does Service Data hosted in the EU region ever leave that  region?

Mobaro customers who purchase the Data Center Location Add-on have the ability to select the region (from the available Mobaro regional options) where the data center which hosts their Service Data is located. Please see our Regional Data Hosting Policy for further details. Otherwise, Mobaro may utilize any of its global data centers to host Service Data.

 

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