Mobi System Privacy Policy

1. Overview

1.1 Purpose

Mobi Systems Inc. (“Mobi Systems,” “we” or “us”) provides this Privacy Policy to inform you of our policies and procedures regarding the kinds of identifiable personal information (“Personal Information”) we may collect, how we intend to use and share that information, and how you can correct or change such information when you access or use our websites, (“Sites”),our products (“Products”), and services (“Services”). We encourage you to read this Privacy Policy in its entirety before submitting any Personal Information so you know how we collect and share your Personal Information. By using our Sites and Services you are consenting to our policies regarding your information, and the ways in which we may collect, use, process, transfer and otherwise deal with that information, as described in this Privacy Policy now and as amended by us.

1.2 Scope

This Privacy Policy applies to Personal Information that is processed by Mobi Systems in the course of our business, including on Company websites (together with any and all future websites operated by or on behalf of Mobi Systems, the “Sites”).

1.3 Privacy Shield

Mobi Systems complies with the requirements of the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of Personal Information transferred from the European Economic Area and Switzerland to the United States, respectively (collectively “Privacy Shield”). Mobi Systems has certified to the US Department of Commerce that it adheres to the Privacy Shield Principles and Supplemental Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Mobi Systems’ certification, please visit https://www.privacyshield.gov.

In compliance with the Privacy Shield Principles, Mobi Systems commits to resolve complaints about our collection or use of your personal information. European Union and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Mobi Systems by sending an email to privacy@takemobi.com. You may also have the right to lodge a complaint to the supervisory authority about the way we process your personal data.

Additionally, Mobi Systems may protect your data through other legally valid methods, including international data transfer agreements. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.

Adherence to the Privacy Shield Principles for Privacy Shield Covered Data may be limited (i) to the extent required or allowed by applicable law, rule or regulation; (ii) to the extent necessary to respond to lawful requests by public authorities, including to meet national security, law enforcement, legal or governmental requirements; and/or (iii) to protect the health or safety of an individual.

Mobi Systems is committed to protecting the privacy of individuals who visit the Company’s web sites (“Visitors”), and protecting the data of customers that obtain our products and services (“Customers”). This Privacy Statement describes Mobi System’s privacy practices in relation to the use of the Company’s Web sites and the related applications, services, and programs offered by Mobi Systems (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal information.

2. Information We Collect

We collect and process personal data with your consent or as required to meet our legitimate obligations such as providing services to our customers, meet our contractual and legal requirements, ensure compliance, and protect the security of our systems and customers.

2.1

We may obtain personal information from various sources, such as:

• Mobi Systems websites and mobile applications
• Businesses that obtain our products and services for use by their customers or employees (such as employers that use our travel-related services)
• Social media through which you may access our sites or communicate with us
• Surveys, marketing events, and other promotions
• Sales inquiries and related correspondence
• Requests for marketing information
• Our parent, affiliate or subsidiary companies, service providers, business partners and other third parties
• The types of personal information we may obtain include:
• Contact information such as name, address, phone, and email address
• Travel preferences including preferred meals & seats and emergency contacts
• Travel destinations, age and other required fields for booking transportation & accommodations, and other related information
• Information from partners and suppliers including airlines, Global Distribution Systems (GDS), and travel management companies that serve our customers.
• Website activity, including but not limited to page views, whitepaper downloads and video views
• Transaction information you provide when you request information
• Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices;
• Location information, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information;
• Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences;
• Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address.

2.2

In addition, when you visit Mobi Systems websites or use our applications, we may collect certain information by automated means, such as cookies and web beacons. A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We also may use third-party website analytics tools (such as Google Analytics ) that collect information about visitor traffic on our sites. The information we may collect by automated means includes:

• URLs that refer visitors to our sites, including whether you visited the website directly or were referred from another website or link
• Dates, times and duration of visits to our sites (including whether you are a repeat or first-time visitor)
• Information on actions taken on our sites (such as page views and site navigation patterns, the pages, links, banners, icons and other parts of the website on which you click or which you access during your visit)
• Search terms that visitors use to reach Mobi Systems websites
• Location information, such as the real-time geographic location of the device on which you install our mobile applications based on your consent

3. How We Use Information

3.1

Mobi Systems may use the Personal Data within the scope of Mobi Systems Services for the following:

• Provide products or services you request, such as travel booking
• Travel confirmations and other service-related communication
• Provide customer support, security alerts, and service notifications
• Understand your needs and interests and tailor our products and services to suit your personal interests and the manner in which visitors use our sites, products and services
• Provide Mobi Systems business customers (such as employers or financial institutions) with the information regarding transactions completed by their employees or customers on the Mobi Systems platform
• Communicate with you about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you
• Enable you to communicate with us through our blogs, social networks and other interactive media
• Manage your participation in our events, and other promotions
• Analyze and enhance our marketing communications and strategies (including by identifying when emails sent to you have been received and read)
• Analyze trends and statistics regarding visitors' use of our sites, mobile applications and social media assets, and the transactions visitors conduct on our sites
• Comply with applicable legal requirements and industry standards and our policies

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

4. Information We Share

4.1

Mobi Systems may share data about Mobi Systems’ Visitors and Customers with our service providers, business partners, and authorized third-parties in order to provide and support Mobi Systems’ Services. These service providers are authorized to use your personal information only as necessary to provide the requested services to us. Mobi Systems may also share data with providers whose products and services you may obtain on our sites, such as airlines, hotels, travel agencies, car rental agencies, car and taxi services and other merchants.

Mobi Systems may also share Data about Mobi Systems Visitors and Customers with the Company’s service providers to ensure the quality of information provided, and with third–party social networking and media Web sites, such as Facebook and LinkedIn, for marketing and advertising on those Web sites.

4.2

Unless described in this Privacy Statement, Mobi Systems does not share, sell, rent, or trade any information with third parties for their promotional purposes.

Section “Cookies and Web Beacons” of this Privacy Statement specifically addresses the information we or third parties collect through cookies and web beacons, and how you can control cookies through your Web browsers. We may also disclose your personal information to any third party with your prior consent.

5. Compelled Disclosure

5.1

Mobi Systems reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

6. Use of Mobi Systems Products and Services

6.1

Many of the Mobi Systems products and services are designed to facilitate and enhance consumers' ability to interact with and obtain products and services from third parties. This business model requires Mobi Systems to share information about you with various providers (such as airlines, hotels, restaurants, car services and reservation aggregators) and other third parties. These third parties are not our service providers or agents; they may process the personal information we provide to them in accordance with their own privacy practices and privacy notices. You may choose not to provide your personal information to Mobi Systems or such third parties by refraining from using our products or services. If you are using Mobi Systems products or services that a Mobi Systems business customer (such as your employer) obtained on your behalf, you must contact the relevant business customer to deactivate your account.

7. Marketing Emails

7.1

Mobi Systems sends you marketing, promotion and sales emails only with your prior consent. You may choose not to receive marketing email communications from us by clicking on the “unsubscribe” link in the marketing emails.

8. Web Analytics

8.1

To opt-out of the aggregation and analysis of data collected about you on our sites by Google Analytics, please click here: (https://tools.google.com/dlpage/gaoptout?hl=en)

9. Cookies and Web Beacons

9.1 General

Mobi Systems uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). As described more fully below, we use these cookies or similar technologies to analyze trends, administer Web sites and Services, track users’ movements around our Web sites and Services, serve targeted advertisements and gather demographic information about our user base as a whole. This section describes the types of Web Site Navigational Information used on the Company’s Web sites and Services, and how this information may be used.

9.2 Cookies

Mobi Systems uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, Mobi System’s servers send a cookie to your computer or device. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to Mobi Systems, either by responding to a promotional offer, opening an account, or filling out a Web form or have previously identified yourself to Mobi Systems, you remain anonymous to the Company.

Mobi Systems uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Web sites or Services.

9.3 Required Cookies

• Description: These cookies are required for the operation of our Services (for example, to enable you to log into secure areas of our website). These cookies enable you to move around the sites and use their features. Disabling these cookies will encumber the sites’ performance and may make the features and service unavailable.
• Manage Settings: Because required cookies are essential to operate the Company’s Web sites and the Services, there is no option to opt out of these cookies.

9.4 Functionality Cookies

• Description: These cookies are used to recognize you when you return to our sites. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region). Mobi Systems may track and analyze usage and volume statistical information from Visitors, and Customers to provide enhanced interactions and more relevant communications, and to track the performance of the Company's advertisements.
• Manage Settings: To learn more about how to control cookies using your browser settings click here (https://www.aboutcookies.org).

9.5 Targeting or Advertising cookies

Note: These cookies may be used for Marketing activities only and not for processing data related to other Services provided to our customers

• Description: These cookies record your online activities, including your visits to our sites, the pages you have visited, and the links and advertisements you have clicked. One purpose of this is to help make the content displayed on our sites more relevant to you. Another purpose is to allow delivery of advertisements or other communications to you that are designed to be more relevant to your apparent interests. Delivery of interest-based advertising may involve us, our service providers and partners such as publishers, data management platforms, and demand side platforms. For example, if you look at a page on one of our sites, we may cause an advertisement to be delivered to you, on our site or on other sites, for products referenced on that page or for similar products and services. We and our service providers and partners may also append other data to information collected by these cookies, including information obtained from third parties, and share this information with third parties for the purpose of delivering ads to you.
• Manage Settings: If you would like more information about this practice and to know your choices about not having this information used by these companies, click here (https://optout.networkadvertising.org/?c=1).

9.6 Web Beacons

A Web Beacon is a very small clear picture file used to keep track of your navigation through a single website or a series of websites. They may also be referred to as “Web Bugs” or “Clear Gifs.” Web Beacons may be used with cookies to gain an understanding of how a website’s users navigate through the website.

9.7 Your consent

By continuing to use this Site, you are agreeing to Mobi Systems placing cookies on your computer or mobile device as set forth in this policy. If you do not wish to accept cookies in connection with your use of this Site, you must stop using the Site.

9.8 Withdraw your consent

You can withdraw your consent at any time by deleting the cookies using your internet browser settings. For further information about deleting or blocking cookies, please refer to the relevant section on deleting and blocking cookies described in this policy.

9.9 How to delete and block our cookies

You can accept, reject or remove cookies by adjusting your browser settings. You can adjust your browser settings by using the “options” or “preferences” menu of your browser. Please refer to the “help” function of your internet browser for more details on how to adjust your browser settings. Please note that if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our site.

9.10 Additional useful information

For further information about cookies and online privacy matters, please refer to https://www.allaboutcookies.org and http://www.youronlinechoices.eu.

9.11 Do Not Track

Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user's browser DNT preference setting. Mobi Systems does not currently commit to responding to browsers' DNT signals with respect to the Company's Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Mobi Systems takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

10. Your California Privacy Rights

10.1

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Mobi Systems does not share Personal Information with third parties for their own marketing purposes. To submit such a request, please email privacy@takemobi.com.

11. Disclosure to Third Parties

11.1

Subject to applicable law in the country where you are located, you may have the right to direct us not to share your personal information with third parties, except (i) with service providers we have retained to perform services on our behalf or (ii) as indicated in the "Compelled Disclosure" section of this Privacy Statement. To submit your request, please email privacy@takemobi.com. In some circumstances, withdrawing your consent to Mobi System’s use or disclosure of your personal information will mean that you cannot take advantage of Mobi Systems products or services.

To update your privacy preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified below.

12. Access and Correction

12.1

If you believe other personal information we maintain about you is inaccurate, you may request that we correct or amend the information by contacting us as indicated in the "How to Contact Us" section of this Privacy Statement. Although Mobi Systems makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Mobi Systems is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy of other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Mobi Systems determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Mobi Systems will take commercially reasonable steps to verify your identify before granting access to or making any changes to your Personal Information. If we deny an access request, we will notify you of the reasons for the denial.

Subject to applicable law, you may have certain additional rights to request access to and receive information about the personal information we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate.

13. Your Choices and Ability to Opt Out

13.1 General

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy. Where you have consented to Mobi System’s processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this section or submitting a request using the instructions provided in “How to Contact Us” section. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.

13.2 Communications “Unsubscribe” instructions will be provided in any email marketing communications from Mobi Systems so that you can opt-out.

14. Data Retention

14.1

The time periods for which we retain your Personal Information depend on the purposes for which we use it. Mobi Systems will keep your Personal Information for as long as a registered subscriber or user of our products or for as long as we have another business purpose to do so and, thereafter, for no longer than is required or permitted by law, or Mobi Systems’ Records Retention Policy, reasonably necessary for internal reporting and reconciliation purposes, to provide you with information you might request, or to protect the security of our systems and prevent fraud. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of the data.

15. Cross Border Transfers

15.1

Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards, or obtain your consent. We also apply the substantive requirements of standard contractual clauses when transferring personal information from Australia.

16. Security

16.1

The security of your Personal Information is very important to Mobi Systems. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored ‘personal data’ (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

17. Lawful Basis for Processing

17.1

We will only collect and process personal data about you where we have lawful basis. Lawful basis include consent (where you have given consent) or contract (where processing is necessary for the performance of the contract with you).

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time, and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful basis upon which we collect and use your personal data, please contact our Data Protection Officer at privacy@takemobi.com.

18. European Privacy Rights

18.1

Mobi Systems adheres to applicable data protection laws in the European Economic Area, which, if applicable to you, include the following rights:

• You have the right to access your personal data held by us (“right to access”)
• You have the right to withdraw your consent at any time from future processing of Personal Data where processing is based on your consent
• You have a right to object to the processing of your Personal Data under certain circumstances (“right to object”)
• You have the right to rectify inaccurate Personal Data and ensure its completeness (“right to rectification”)
• You are entitled to request a transfer of your Personal Data to another controller to the extent possible or obtain copies of your Personal Data in an industry standard format (“right to data portability”)
• You have the right to request deletion of your Personal Data subject to applicable legal obligations (“right to be forgotten”)

19. Children's Privacy

19.1

Mobi Systems does not knowingly collect information from children under the age of 13 and does not target its websites to children under 13. If we learn that a user is under 13 years of age, we will promptly delete any personal information that the individual has provided to us. We encourage parents and guardians to take an active role in their children's online activities and interests.

20. Updates to this Privacy Statement

20.1

This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Statement and indicate at the bottom of the notice when it was most recently updated.

21. How to Contact Us

21.1

If you have any questions or comments about this Privacy Policy, would like to submit a request or have any privacy concerns, please contact us at: privacy@takemobi.com. Mobi Systems will address your concerns and attempt to resolve any privacy concerns in a timely manner. You also may write to us at:

Mobi Systems

Attn: Data Protection Officer – Privacy Rights
48 Grove St
Somerville, MA 02144