Customer Privacy Policy

Protecting your personal information is important to us. So is following privacy laws. This Privacy Policy tells you how we will protect your privacy and collect and use your personal information (any reference to “we”, “us” or “our” is to Mobli Holdings Limited (NZCN 7385356), together with each other entity (wherever incorporated or domiciled) that is part of the Mobli group. 
“Personal Information” means any information that can directly or indirectly identify you or another person.
This Privacy Policy applies to anyone who uses our website (Website), buys or uses the products or services that we supply you (Products or Services), including  modular components to deliver great user experiences, user accounts, wallets, rider rewards, payments, planning, booking and optimisation services or interacts with us. 
If you have any questions, you can contact our Privacy Officer at info@mobli.io.
When you use these services, you’ll share some information with us. So we want to be upfront about the information we collect, how we use it, whom we share it with and the controls we give you to access, update and delete your information.

That’s why we’ve written this Privacy Policy. And it’s why we’ve tried to write it in a way that’s blissfully free of the legalese that often clouds these documents. Of course, if you still have questions about anything in our Privacy Policy, contact us at info@mobli.io. 

You should read our entire Privacy Policy, but when you only have a few minutes or want to remember something later on, you can always take a look at this summary – so you can review some of the basics in just a few minutes.

Some final notes before we dive in: we’re happy to report that we participate in the EU-US and Swiss-US Privacy Shield Frameworks, which you can read more about here. 

This policy is provided for your information and doesn't limit or exclude your rights under the Privacy Act 1993.


YOUR RIGHTS
We’ll only use your Personal Information for the reasons that we collected it, and in accordance with this Privacy Policy. If we don’t need your Personal Information anymore for those reasons, then we’ll stop using it. 
If you don’t agree with our Privacy Policy or don’t want us to collect your Personal Information, then you shouldn’t use our Website, Services or interact with us. If you change your mind and don’t agree with our Privacy Policy anymore, then you should stop using our Website, Services or interacting with us.  


Last updated: October 2022


WHAT PERSONAL INFORMATION DOES MOBLI COLLECT? 
We may collect the following Personal Information:

  • Your name, date of birth,  and contact details.

  • Your purchase and account history with us. 

  • Information about your use of our Products or Services. (such as your transaction history, how much you spend, and browsing activity when visiting one of our channels)

  • Information about the web pages you visit on our Website.

  • Location information

  • Content use and detection

  • How you use the transport system, such as the services you use, the time and date of your travel.

  • Lifestyle information 

  • Uploaded Images, video, audio and files

  • Information you provide to us when responding to our customer surveys.

  • Any other information you give us.


If you use one of our apps or websites to complete an online form, or create an account or register a card, we will only collect the information you provide as part of that process if you complete and submit the application or registration to us. If you log out of our websites or cancel your application or registration before submitting it, the information you had entered will be automatically deleted.

When you use our services, we collect information about which of those services you’ve used and how you’ve used them. We might know, for instance, that you watched a particular piece of content, saw a specific ad for a certain period of time and purchased certain products. Mobli’s fundamental principle is that you, the user, are in charge of your own data. If you don’t wish to share any information about yourself, you don’t have to. Our app, platform and services are opt-in. That means you have to decide to participate, not the other way around. If you do decide to share your data with us, you will receive a more personalised experience, and in some instances, be compensated for sharing that information.

Please don’t give us Personal Information about someone else unless you have their permission and they know about this Privacy Policy.


HOW WE COLLECT YOUR INFORMATION
We collect Personal Information:

  • From you directly (like when you provide your details to us in person, via email, or through any other medium).

  • From you indirectly (like when you use our Services, visit our Website or interact with us on social media).

  • From third parties (like contractors and agents that we engage to perform services on our behalf, such as to analyse traffic on our Website and social media).

  • Completion of forms

  • From places where the information is publicly available.


Content information
​We collect content you provide on our services, such as survey responses and information about the content you provide, such as if the recipient has viewed the content and the metadata that is provided with the content.
Device information. We collect information from and about the devices you use. For example, we collect:
information about your hardware and software, such as the hardware model, operating system version, device memory, advertising identifiers, unique application identifiers, apps installed, unique device identifiers, browser type, language, battery level and time zone.

Information from device sensors, such as accelerometers, gyroscopes, compasses, microphones and headphone connection.
information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address and signal strength.

Location Information 
When you use our services, we may collect information about your location. With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points and other sensors, such as gyroscopes, accelerometers and compasses.

Content Detect 
As part of our commitment to provide your users with the maximum value for their time, they have the option to turn on Content Detect, which detects whether you are watching the content being served to you. Content Detect works by us asking your phone throughout the time you are viewing content, whether you are actively watching the content or not. When we ask the phone, we get simply get a Yes or No response, and we record this response. We use this Yes / No response to let Content Providers know whether you are watching, to help them understand how their content is performing. This helps Content Providers improve their content in the future, as they will be able to understand things like the engagement of viewers and when viewers stop being engaged in the content. No person or machine, apart from your phone, has access to your camera. All processing of the camera feed is done using your phone. This means your data stays with you and doesn’t go to the cloud for processing or storage. We do not process or store any facial identification/detection data aside from the Yes / No response, to ensure maximum privacy to you. This feature is Opt-In, meaning you have to turn on in your settings on your app. You can opt-out at any time by going into the settings to turn off. You may be additionally rewarded (with more personalised content) for having this feature on, but you will still be able to use the product and consume content if it is turned off.


Information collected by cookies and other technologies. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage and unique advertising identifiers, to collect information about your activity, browser and device. We may also use these technologies to collect information when you interact with services we offer through one of our partners, such as advertising and commerce features. For example, we may use information collected on other websites to show you more relevant ads. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our services. 

COOKIES 
Cookies are small text files placed on your computer, mobile phone, tablet, or other electronic device to store data that can be recalled by a web server in the domain that placed the cookie. This data often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well. Some cookies are placed by third parties acting on our behalf. We may use cookies and similar technologies to store and honour your preferences and settings, enable you to sign-in, provide interest-based advertising, analyse how our Products or Services perform, and fulfil other business functions or operations set out in this Privacy Policy. 


To enable some of the features and functionality on our Website and products, you may need to permit us to place cookies on your device.  You can remove or block cookies by using the settings in your browser, but it may affect your ability to use our Website. 

 


We are legally obligated to retain payment records
This includes transaction history, time, merchants, purchases, value, transaction details, payment method. Your credit card details are held by a secure third-party provider, who’s terms and conditions we abide by in handling your information. We share the relevant payment information with third parties for the purpose of completing transactions on your behalf.
 
We hold payment records for seven years as per statutory regulations in New Zealand.


Feedback on the transit system 
You can opt-in to sharing feedback on the transit system with the transit operator you are rating. Any feedback you provide will be anonymised at our discretion and provided in bulk to transit authorities. You may be rewarded for providing this feedback at our discretion.

Journey information 
We collect information on your journey to be used for optimisation purposes in improving our services in future. This information will only be used by Mobli for this purpose and will not be shared with third parties.
This includes the start and end location of your journey, whether you booked a trip or not, your search history, the time of your trip, whether the trip was started or not, whether the trip was completed or not.

Log information 
We also collect log information when you use our website, such as:
details about how you’ve used our services;
device information, such as your web browser type and language;
access times;
pages viewed;
IP address; and
identifiers associated with cookies or other technologies that may uniquely identify your device or browser

 


HOW WE USE AND SHARE YOUR INFORMATION 
We use and disclose your Personal information:  

  • To provide you with our Products or Services.

  • To respond to your queries regarding the Website, our Products or Services. 

  • To administer your account with us.

  • To bill you and to collect money that you owe us.

  • To operate and maintain our Website. 

  • For our internal record keeping purposes.

  • To Send you communications, including by email

  • To develop, operate, improve, deliver, maintain and protect our products and services.

  • For analysis on a bulk basis for broad demographic content reporting and personalisation of our services including the development of non-attributable personas, which may be shared with third parties. Personas are developed based on pools of information from many people and are not able to be attributed to a single person.

  • To facilitate the sale or other disposition of our business or assets. 

  • To comply with our legal obligations.

  • For any other purposes that you authorise.


There may be times when we disclose your personal information to third parties. If we do this, we will only disclose your information to: those who provide products or services to us, or products or services that support the services that we provide, such as our partners, suppliers and transport operators;
persons to whom we may be required to pass your information by reason of legal, governmental or regulatory authority including law enforcement agencies and emergency services;
any person or organisation as authorised by the Privacy Act 1993.
Where possible, we will provide information to third parties in the form of an anonymised non-identifiable persona. An example of where this may be applicable below: 


Booking journeys
Settling accounts with those who provide related services to us.
dealing with your requests, enquiries or complaints and other customer care related activities;
carrying out market and product analysis and marketing our products and services generally;
registering your details and allocating or offering you rewards, discounts or other benefits and fulfilling any requests or requirements you may have in respect of our loyalty or reward programmes and other similar schemes;
carrying out any activity in connection with a legal, governmental or regulatory requirement on us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;
carrying out activities connected with the running of our business such as personnel training, quality control, network monitoring, testing and maintenance of computer and other systems and in connection with the transfer of any part of our business in respect of which you are a customer or a potential customer;
for general administrative and business purposes.


E-COMMUNICATIONS 
You consent to receiving information from us about our Products, Services, promotions and competitions via email, text message and social media. If you want us to stop sending you electronic communications, then you can simply unsubscribe at any time by following the instructions included in the electronic communication. 
Third-party content and integrations
​Our services may contain third-party content and integrations. Examples include third-party games and third-party transport provider integrations. Through these integrations, you may be providing information to the third party as well as to Mobli. In sharing your information, we will firstly undertake a due diligence vetting process to understand how and why a third party intends to use your data. These third parties who wish to integrate must first provide assurances to Mobli as to how they will sufficiently manage this data and what it will be used for.

Will my personal information be protected?
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from unauthorised access, use, modification or disclosure. Some of your identifiable info-account information is managed by our partners. These partners meet the identifiable managed data standards based on ISO2700. 

We may associate your personal information with a persona, but this persona is anonymised and is not attributable to you as an individual. The persona is not stored with your identifiable information. It is stored in a secure cloud environment and at no point can it be linked back to your account.
 
Your card on file and credit/debit card information is managed by our payments processing partner and is protected through their terms and conditions.


Our partners holds PCI compliance and your information is encrypted and securely held in their cloud environment.

 


HOW WE SAFEGUARD YOUR PERSONAL INFORMATION OUTSIDE NEW ZEALAND 
From time to time, we may disclose, and you authorise us to disclose, your Personal Information to an overseas service provider for the above purposes. We make sure that the overseas service provider is: 
      * A participant in a prescribed binding scheme for international disclosures of personal information; and/or
      * Is located in a country that provides comparable safeguards to New Zealand’s privacy laws, approved by the Privacy Commissioner.
If not, then we will take reasonable steps to ensure that the overseas service provider is required to protect your Personal Information in a way that, overall, provides comparable safeguards to those required under New Zealand’s privacy laws. 


How is my information retained and stored?
How long we keep your information

Mobli puts you in control of your data.
On our end, that means any action you take in Mobli is opt-in, and if you don’t want to share that information, we will stop collecting that information. We will continue to store the information as long as you are an active user. After 12 months of inactivity, we will delete any personally identifiable information.

We store other information for longer periods of time. For example:
We store your basic account information – such as your name, phone number and email address until you ask us to delete them.
We store location information for different lengths of time based on how precise it is and which services you use. For example, if you use the journey planner saved locations, we store information about your favorite places so we can personalize and improve your experience. 
We’re constantly collecting and updating information about the things you might like and dislike, so we can provide you with more relevant content and adverts. 
If you ever decide to stop using Mobli Services, you can just ask us to delete your account through the app or through our Support Center. We’ll also delete most of the information we’ve collected about you after you’ve been inactive for 12 months – but don’t worry, we’ll try to contact you first!

Keep in mind that, while our systems are designed to carry out our deletion practices automatically, we cannot promise that deletion will occur within a specific timeframe. There may be legal requirements to store your data and we may need to suspend those deletion practises if we receive valid legal process asking us to preserve content, if we receive reports of abuse or other Terms of Service violations, or if your account or content created by you is flagged by our automated systems for abuse or other Terms of Service violations. Finally, we may also retain certain information in backup for a limited period of time or as required by law.

Control over your information
We want you to be in control of your information, so we provide you with the following tools.

Access, correction and portability.
You can access and edit most of your basic account information right in our apps. You can also use Download My Data to obtain a copy of the information that isn’t available in our apps in a portable format, so you can move it or store it wherever you want. Because your privacy is important to us, we will ask you to verify your identity or provide additional information before we let you access or update your personal information. We may also reject your request to access or update your personal information for a number of reasons, including, for example, if the request risks the privacy of other users or is unlawful.

 


Revoking permissions
In most cases, if you let us use your information, you can simply revoke your permission by changing the settings in the app or on your device if your device offers those options. Of course, if you do that, certain services may lose full functionality.
Deletion. While we hope you’ll remain a lifelong user, if for some reason you ever want to delete your account, just go here to learn how. You can also delete some information in the app, such as journeys you have taken, transaction history and your search history.

Content preferences
We try to show you content that we think will be relevant to your interests. If you would like to modify the information we and our advertising partners use to select this content, you can do so in the app and through your device preferences. Go here to learn more.

Can I access my personal information?
You have the right to know whether or not we hold any personal information about you. You also have the right to access your personal information if we hold that personal information in a way that it can be readily retrieved.

You may also ask us to correct any personal information that we hold about you. It is your responsibility to ensure that personal information provided to us is accurate. If we do not correct your information in the way you have asked, you can request that we attach to that information a statement of the correction you asked for.

If you would like to contact us about how we collect and manage personal information, ask whether we hold information about you, ask for access to copies of the information we hold about you, or ask for a correction to information we hold about you, you can contact us by:
email to info@mobli.io

When contacting us, please quote your name and address. We would be grateful if you could also provide brief details of what information you want a copy of (this helps us to more readily locate your information).

Changes to our Customer Privacy Policy
We may change this Privacy Policy from time to time. But when we do, we’ll let you know one way or another. Sometimes, we’ll let you know by revising the date at the top of the Privacy Policy that’s available on our website and mobile application. Other times, we may provide you with additional notice (such as adding a statement to our websites’ home pages or providing you with an in-app notification).

Acceptance
The Customer Privacy Policy forms a part of our Website, Mobile App & Digital Platforms terms of use and should be read in conjunction with them. By viewing and using our websites or related services offered in conjunction with our websites, you agree to Mobli collecting and using your personal informal information as set out in this Customer Privacy Policy. If you do not agree to anything in this Customer Privacy Policy or if you do not wish to receive marketing material from Mobli, you can either contact us or you can stop accessing or using our websites, platforms or apps.

If you decide not to provide the personal information requested when you use, register or open an account on our website, this may result in services or products (including related services offered in conjunction with our websites) not being offered or provided to you.