Protecting the privacy and safeguarding the personal and financial information of our clients and website visitors is one of our highest priorities. The following Privacy Statement explains how Thinkmobiles collects and protects your personal information. References to "Thinkmobiles" in this Privacy Statement include all Thinkmobiles companies and divisions, including Thinkmobiles. By opening a Thinkmobiles account or by using Thinkmobiles websites, you give your consent to the collection and use of personal information by Thinkmobiles as explained in this Privacy Statement.
We understand the importance of protection of your privacy and personal data and commit a lot of efforts to develop and maintain high standards of inner security measures and technologies to provide you with secure processing and storage of the data we collect from you; and keep your data safe against unauthorized or unlawful processing and against accidental loss, destruction or damage.
Personal information refers to “information or an opinion, whether true or not, and whether recorded in a material format or not, about an identified individual, or an individual who is reasonably identifiable”. Any information or opinion that may lead to the reasonable inference to the identity of an individual may be considered personal information.
PERSONAL DATA WE COLLECT AND OBJECTIVE
When registering for an account via Thinkmobiles we collect and further process the following categories of data:
When you go through the registration process, you shall provide an e-mail address and create a password.
Information, which we may collect through automated means. Through your use of the Website and its tools, we also monitor and collect tracking information related to usage such as access date & time, device identification, operating system, browser type and IP address. This information may be directly obtained by Thinkmobiles or through third party services.
We do not collect any information that may identify you without your permission.
We use Google Analytics on Our Technology Platform. If you want to know more about Google Analytics and its “do not track” policy, please visit https://www.google.com/analytics/terms/us.html
We do not intend to solicit or collect Personal Information from anyone under the age of 16 or under the legal age of your country, if it is higher. If you are under 16 or are not of a legal age of your country, do not enter any personal information on our Website.
We collect and process the abovementioned data to fulfil our contractual obligations and legitimate interest before you, namely:
The above list may be extended depending on the development of the services.
We collect your personal information directly from you and indirectly as a result of your relationship with us. Thinkmobiles may use the information collected from you to verify your identity and contact information, issue you an account number and a secure password, maintain your account activity and contact you with account information, among other reasons. This information also helps us improve our services to you, customize your browsing experience and inform you about additional products, services or promotions that may be of interest to you. You directly provide us with the majority of information we collect. This information includes your contact details, including name, mailing address, telephone number and e-mail address, personal identification data we are required by law to collect, including your passport number and/or tax identification number. We also collect demographic information when you open an account, including gender, birth date, occupation and employment status.
You provide us with this information by completing the account application and related documentation, by sending us an e-mail or by submitting information in response to a promotion or special offer. The information we collect indirectly from you includes your Internet protocol ("IP") address, browser type, operating system, Internet service provider (ISP), time stamps and transaction history. Should you close your account with us, Thinkmobiles will retain your information, but only use it to comply with regulatory requirements and to periodically contact you to offer you the opportunity to reactivate your account or participate in other offers.
PROCESSING OF YOUR PERSONAL DATA
Your personal data may be received and processed:
Those subprocessors perform tasks on our behalf and are contractually obligated not to disclose or use collected information for any other purposes, then storage, help in facilitation of technical aspects of our services or perform functions related to the administration of services (collection and analysis) or other indicated under contractual closes.
If such subprocessors are outside of Swiss Confederation or the European Union or European Economic Area, the processing of personal data is done or will be done in accordance with applicable laws.
Subprocessors remain fully liable for all obligations subcontracted to, and all acts and omissions of, Thinkmobiles is not responsible in the event that information is disclosed at a result of a breach or security lapse at any such subprocessors, or for such subprocessors' non-compliance with the foregoing requirements.
If Thinkmobiles becomes aware of any breach of our security leading to the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of, or access to (excluding unsuccessful attempts or activities) personal data of Clients on systems managed or otherwise controlled by us we will notify you promptly and without undue delay and in compliance to the procedure prescribed under respective Regulation.
The notification will be made to your e-mail address at the discretion of Thinkmobiles or by other direct communication available to Thinkmobiles and allowed by Client (for example, by phone or e-mail). It is sole responsibility of the Client to provide us with the e-mail address and ensure that this e-mail address is valid and current.
None of Data Incidents notification from Thinkmobiles may not be and will not be construed as an acknowledgment of any fault or liability with respect to data incident by us.
CLIENT’S SECURITY COMMITMENTS
Client agrees that without prejudice to our security measures and data incidents that it is Client’s responsibility to make appropriate use of our services to ensure a level of security appropriate to the risk in respect of your personal data and securing your authorization credentials, system and devices which you use to access to our services.
We are not obliged to protect your personal data that you choose to store or transfer outside Thinkmobiles and our subprocessors’ systems.
CLIENT’S RIGHTS IN RESPECT TO ITS PERSONAL DATA
Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at [email protected]. In certain circumstances, you have the following rights in relation to your personal data:
In some case we may charge a fee (based on our reasonable costs) if the requests are excessive considering the nature of the request itself or nature and functionality of our services.
COOKIE & SIMILAR TECHNOLOGIES
SHARING PERSONAL INFORMATION WITH THINKMOBILES AFFILIATES AND NON-AFFILIATED THIRD PARTIES
Thinkmobiles does not sell, license, lease or otherwise disclose your personal information to any affiliate or third party for any reason, except as described below. Thinkmobiles may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer.
To help us improve our services to you, we may engage another business to help us carry out certain internal functions, such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a non-affiliated third party with client information from our database, including your name, address, phone number, and/or e-mail address, to help us analyze and identify client needs, notify clients of product and service offerings or conduct general marketing and market research for us.
Thinkmobiles also forges partnerships and alliances with non-affiliated third parties which offer high-quality products and services that might be of value to our clients. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, Thinkmobiles may share some personal information with these non-affiliated third parties.
We always require that all non-affiliated third parties to which we provide your nonpublic personal information agree to keep your information confidential and use such information solely for the limited purpose for which we have engaged them, or as otherwise required by law. In addition, where offers are made to you by non-affiliated third parties, we always require that they disclose that the offer is being extended because of your relationship with us. We also seek to ensure that these nonaffiliated third parties maintain appropriate data security procedures to guard against unauthorized use of, or access to, your personal information.
THE SECURITY OF YOUR PERSONAL INFORMATION
We employ security software, systems and procedures to offer you a safe and secure working environment and to protect your personal, financial information. When you open an account with us, you are issued a unique User ID and a password. Only a limited number of Thinkmobiles employees who have a need to know this information will have access to your User ID, and password. Remember that you are ultimately responsible for maintaining the secrecy of your User ID and password. We strongly recommend that you do not disclose this information to anyone. On our websites and online account application we use technology to encrypt information transmitted by or to you. We use certificate authority (CA) certificates to authenticate our websites and secure trading and customer-facing applications, allowing you to verify that you are connected to our websites.
CHANGES TO THIS PRIVACY STATEMENT AND OPTING OUT
You may contact Thinkmobiles for any reason under this Privacy Statement, or otherwise, as follows: [email protected].