Our Privacy Policy

Last Updated: April 20, 2020

Effective Date: April 23, 2020.

In the following, information about the processing of your personal data by Mowico, and the rights you are entitled to under the data protection regulations may be found.

This Privacy Policy is an explanation by Mowico with its affiliates, which is an international software development company, located at 530 Lytton Ave, 2nd Floor Palo Alto, CA 94301, the U.S. (“Mowico” or “We”/”Us”) to persons residing in the European Economic Area (the “EEA”) protected under the GDPR (who may include our customers) (the “Data Subject”) regarding how we collect and process personal data as the data controller if personal data is provided or disclosed by the Data Subject or if personal data is received or acquired through a third party. We process the personal data in accordance with the GDPR (and other applicable EU and Member State regulations on data protection, if such regulations exist).

Processing of personal data in this Privacy Policy means processing of personal data of persons who are in the EEA in any of the following cases:

  • (i) if carried out in connection to activities of our establishment in the EEA,
  • () if related to the offering of goods or services to the Data Subjects, or
  • () if related to the monitoring of the Data Subject’s behavior as far as their behavior takes place within the EEA.

Collection and Processing of Personal Data

We will always process the Data Subject’s personal data based on the legal bases provided in the GDPR (Articles 6 and 7). In addition, if processing personal data that requires special care, we will do so in accordance with the special rules provided for in the GDPR (Articles 9 and 10).

Principles that dictate the data processing;

MOWICO, when processing your personal data, complies with the principles governing lawful data processing (No. 5 GDPR), namely:

-The principle of legality, objectivity and transparency, according to this particular principle, the data are submitted in a fair and lawful manner in a transparent manner.

-The purpose limitation principle that data is collected for specified, explicit, and legitimate purposes and is not further processed in a manner incompatible with those purposes.

-The principle of proportionality, “minimizing data”, according to which the data processed are relevant and necessary for the purposes of processing.

-The principle of data accuracy, according to which the data is accurate and when necessary updated.

-The principle of integrity and confidentiality, according to which the data are processed in a way that guarantees their security and protection against unlawful processing, loss, destruction or deterioration.

-The principle of determining the length of the processing period, “storage period limitation”, according to which data must be kept in a format that allows the identification of data subjects only for the time necessary to achieve the purposes of the processing.

-The accountability principle of the controller, according to which the controller is responsible and should be able to demonstrate compliance with the Regulation before the supervisory authorities and the courts.

We may collect and process the Data Subject’s personal Data in the following cases :(ⅰ) if required in order to provide the Data Subject with adequate services and products and we otherwise have a legitimate interest; (ⅱ) if required in order to perform an agreement with the Data Subject or carry out procedures before execution; or (ⅲ) if we have obtained the Data Subject’s express prior consent. In that case, we will give notification of the purpose of that collection and processing to the Data Subject through notification when obtaining consent, agreement, or other appropriate means.

The Data Subject is entitled to withdraw his or her consent to the collection and processing of the personal data at any time, but this withdrawal will not affect the lawfulness of processing based on the consent before withdrawal thereof.

We will process the Data Subject’s personal data for the above specified, explicit and legitimate purposes, and will not further process the personal data in a way which is incompatible with those mentioned purposes. If we intend to process personal data originally collected in order to attain other objectives or purposes, we will ensure that the Data Subject is informed of this. We will keep personal data for as long as it is necessary for us to comply with our legal obligations, ensure that we provide an adequate service, and support our business activities (Articles 5 and 25(2) of the GDPR).

We ensure that the personal data processed shall be limited to what is adequate and necessary in relation to the purposes for which they are processed.

Sensitive Data

We do not generally seek to collect sensitive data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

Below is also a chart describing the categories of personal data we collect:

Additional personal details, contact details and identifiers. In addition to the personal details listed above, MOWICO may collect additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history.
Education information and professional or employment-related information. MOWICO may collect information about your education and professional or employment-related information, such as your employment history.
Sensitive data for recruitment purposes. MOWICO may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. MOWICO collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.
Documentation required under immigration laws. MOWICO may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).
Financial information for payroll/benefits purposes Your banking and other relevant financial details we need for payroll/benefits purposes.
Talent management information. Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.
Requested recruitment information Information requested to provide during the recruitment process, to the extent allowed by applicable law.
Recruitment information you submit Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).
Information generated by us during recruitment Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.
Recruitment information received from third parties Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.
Recommendations Recommendations related information provided on your behalf by others.
Immigration Documentation and related information required under immigration laws.
Employment history and background checks Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.
Diversity related information Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the MOWICO workforce, subject to legal limits.
Assessment information Information generated by your participation in psychological, technical or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.

 

Please view the table below for (i) a list of the purposes for which MOWICO uses your personal data and (ii) an overview of the legal basis for each such purpose.

Purpose Legal basis
Managing our contractual and/or employment relationship with you. Necessary for the performance of a contract to which you are a party.
Recruitment. Justified on the basis of our legitimate interests for ensuring that we recruit the appropriate employees.
Facilitating communication with you (including in case of emergencies, and to provide you with requested information). Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing our business operations. Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements. Necessary for the compliance with a legal obligation to which we are subject.
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use). Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Social listening (Identifying and assessing what is being said about MOWICO and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.) Justified on the basis of our legitimate interest of protecting our assets and our brand on social media
Improving the security and functioning of our website, networks and information. Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within MOWICO and/or to provide a better user experience. Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Marketing our products and services to you Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.
Specific Recruitment/Employment Purposes Legal basis
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available. Justified on the basis of MOWICO’s legitimate interests of ensuring that it recruits the appropriate employees.
Manage your application. Justified on the basis of MOWICO’s legitimate interests of ensuring that it recruits the appropriate employees.
Facilitate communication with you. Justified on the basis of MOWICO’s legitimate interests of ensuring proper communication within the organization and with you.
Perform administrative functions (e.g. reimburse you for interview-related expenses). Justified on the basis of MOWICO’s legitimate interests of ensuring that it recruits the appropriate employees.
Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at MOWICO and how to attract and keep top talent. Justified on the basis of MOWICO’s legitimate interests of ensuring that it continually improves its recruitment processes.
In some cases, record your online interview for review by additional recruiters and hiring managers. Justified on the basis of MOWICO’s legitimate interests of ensuring that it recruits the appropriate employees.
If you register on our Careers website, we will enter you into a database to receive future mailings about MOWICO positions and events. You may also receive personalized job recommendations while browsing our Careers website. Justified on the basis of MOWICO’s legitimate interests of ensuring that it recruits the appropriate employees.
Transfer your contact information, education data, employment data, application information and the CV, all as supplied by you in our recruitment system, to the MOWICO System—a site that we maintain to notify you about new positions that may be of interest to you. Justified on the basis of MOWICO’s legitimate interests of ensuring that it recruits the appropriate employees.
Administration of employee benefits Justified on the basis of MOWICO’s legitimate interests of ensuring that our employees receive the applicable benefits.
Perform any legally required reporting and respond to legal process. Compliance with a legal obligation.

Sharing Personal Data

We may share personal data with our group entities and with third-parties in accordance with the GDPR. When we share personal data with a data processor, we will put the appropriate legal framework in place in order to cover data transfer and processing (Articles 26, 28 and 29 of the GDPR).

Furthermore, when we share personal data with any entity outside the EEA, we will put appropriate legal frameworks in place, notably controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) Standard Contract Clauses approved by the European Commission, in order to cover such transfers (Chapter 5 of the GDPR).

Collaborative Partners

Subject to the Data Subject’s prior consent, personal data may be transferred to, stored, and further processed by collaborative partners that work with us to provide our products and services or help us market to Data Subjects.

Outsourcing

(1)We may outsource all or part of the personal data processing in sales services, enquiry response services, equipment maintenance services, fee related services, marketing services, and other services.

(2)When executing an outsourcing agreement, the eligibility of the counterparty as an outsource is sufficiently investigated. Safety management measures, confidentiality, conditions for the outsource to outsource to another party, and other matters regarding the appropriate processing of personal data are prescribed in the outsourcing agreement, and our outsource are appropriately supervised by implementing periodic monitoring, etc. of the outsourcing conditions.

(3)The personal data provided (deposited) by the outsourcer in the services outsourcing is utilized within the scope necessary to perform the agreement with the outsourcer.

 

Corporate Affiliates and Corporate Reorganizations

We may share the personal data with all corporate affiliates. In the event of a merger, corporate reorganisation, civil rehabilitation, acquisition, joint venture, assignment, transfer, sale or disposition of all or any portion of our business (including in connection with any bankruptcy or similar proceedings), etc., we may transfer any and all personal data to the relevant third party.

Legal Compliance and Security
It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside the Data Subject’s country of residence – to disclose personal data. We may also disclose personal data if we determine that, for purposes of national security, law enforcement, or other issues concern of public importance, disclosure is necessary or appropriate.

We may also disclose personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our internal regulations, investigate fraud, or protect our operations or users.

Data Transfers
Disclosures or sharing of personal data as described above may involve transferring personal data out of the EEA. For each of these transfers we shall make sure that we provide an adequate level of protection to the data transferred, in particular by entering into Standard Contract Clauses as defined by the European Commission decisions 2001/497/EC, 2002/16/EC, 2004/915/EC and 2010/87/EU.

Our Records of Data Processes

We handle records of processing of personal data in accordance with the obligations established by the GDPR (Article 30), where we might process personal data. In these records, we reflect all the information necessary in order to comply with the GDPR and cooperate with the supervisory authorities in accordance with the GDPR (Article 31).

Security Measures

We process personal data in a manner that ensure such data undergoes appropriate security (including protection against unauthorized or unlawful processing and against accidental loss, destruction damage, etc.) using appropriate technical or organizational measures to achieve this (Articles 25(1) and 32 of the GDPR).

We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.

If any personal data leak occurs we will do everything to eliminate it and to assess a level of risk connected with the leak according to our Personal data breach policy. If it turns out the leak may lead to physical, material or non-material damage for you (e.g. discrimination, identity theft, fraud or financial loss) we will contact you without undue delay unless the law provides otherwise. All our steps will be taken in full cooperation with competent supervising authority.

Notification of Data Breaches To The Competent Supervisory Authorities

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess the details of the breach promptly. Depending on the outcome of our assessment, we will make the necessary notifications to the supervisory authorities and communications to the affected data subjects (Articles 33 and 34 of the GDPR).

Processing Likely To Result in High Risk To The Data Subject’s Rights and Freedoms

We have mechanisms and policies in place in order to identify data processing activities that may result in high risk to the data subject’s rights and freedoms (Article 35 of the GDPR). If any such data processing activity is identified, we will assess it internally and either stop it or ensure that the processing is compliant with the GDPR or that appropriate technical and organizational protective measures are in place in order to proceed with it.

In case of doubt, we will contact the competent Data Protection Supervisory Authority in order to obtain their advice and recommendations (Article 36 of the GDPR).

Data Subject’s Rights

We will notify the Data Subject of the details of the rights granted to the Data Subject under the GDPR when notifying the Data Subject of the purpose of processing personal data.

If the Data Subject will exercise such rights, please contact us at the address set forth section 13 below.

If the Data Subject is not satisfied with the way in which we have proceeded with any request, or if the Data Subject has any complaint regarding the way in which we process personal data, the Data Subject may lodge a complaint with a Data Protection Supervisory Authority.

  • Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
  • Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
  • Object to the processing of your personal data: this right entitles you to request that MOWICO no longer processes your personal data.
  • Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
  • Request the restriction of the processing of your personal data: this right entitles you to request that MOWICO only processes your personal data in limited circumstances, including with your consent.
  • Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to MOWICO, or request MOWICO to transmit such personal data to another data controller.

Children

If we collect and process personal data from a child who is under 16 years of age or who has not reached the age limits under the laws of a Member State, we will process that data appropriately (Article 8 of the GDPR).

 

1.Which sources and data do we use?

We process personal data that we receive from you during the use of our website and, if applicable, our business relationship.

In the case of purely informative use of the website, i.e if you do not register or otherwise provide us with information, we will only collect the personal data that your browser transmits to our server. When you visit our website, we collect the following access data that is technically necessary for us to display our website and to ensure stability and security. The access data include the IP address, date and time of the request, Greenwich mean time (GMT) time zone difference, content of the request (ie name of the specific website retrieved), access status / HTTP status code, amount of transmitted data, referrer URL (previously visited page), browser type and version, operating system and its user interface, language and version of the browser software,

Furthermore, we will receive your personal data, if you contact us via contact form or e-mail. Personal data are eg name, address, e-mail, telephone number (hereinafter called “contact data”).

2.How long will my data be stored?

For security reasons (e.g. to investigate abusive or fraudulent actions) logfile information is stored for a maximum of thirty days and then deleted, if the user deletes his/her account. Data whose further retention is required for evidential purposes are excluded from the erasure until the final clarification of the incident.

If necessary, we process and store your personal data for the duration of our business relationship, which includes, for example, the initiation and execution of a contract via contact form or by e-mail.

In addition, we are subject to various storage and documentation obligations. The deadlines for storage and documentation are two to ten years if the user does not delete his/her account.

3.Are data transmitted to a third country or to an international organization?

The data provided are processed within the European Union as well as in the U.S.A.. Please note that we have agreed EU standard data protection clauses with recipients of your data for non-adequacy states of the Commission, as is the case with the U.S, to protect your data and to achieve an adequate level of protection of your personal data.

4.What privacy rights do you have?

Every affected person has

the right to information under Art. 15 of the GDPR,

the right to a correction under Art. 16 of the GDPR,

the right to cancellation under Art. 17 of the GDPR,

and, the right to restriction of processing according to Art. 18 of the GDPR

Furthermore, you can revoke consent, basically with effect for the future.

In addition, there is a right of appeal to a data protection supervisory authority (article 77 of the GDPR).

In addition, we would like to point out your right of objection under Art 21 of the GDPR:

Information about your right to object according to Art. 21 of the GDPR

You have the right at any time, for reasons arising from your particular situation, against the processing of personal data concerning you, pursuant to Article 6 (1) (e) GDPR (Data Processing in the Public Interest) and Article 6 (1) (f) of Data Protection -Ground Regulation (data processing based on a balance of interests) takes place, objecting; this also applies to a profiling based on this provision within the meaning of Article 4/4 of the GDPR, which we use for questionnaire evaluation or for advertising purposes.

If you object, we will no longer process your personal information unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, pursuing or defending legal claims.

In individual cases, we process your personal data in order to operate direct mail. You have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is associated with such direct mail. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.

The objection can be made in a form-free manner and there are no other than the transmission costs according to the basic rates.

The objection, if possible, should be addressed to by e-mail to privacy@mowico.com.

5. To what extent is there automated decision-making in individual cases, including profiling?

As part of the access to our website or in the context of contact via form or e-mail, we generally do not use fully automated automatic decision-making according to Article 22 of the GDPR. If we use these procedures in individual cases, we will inform you about this separately, if this is required by law.

We do not process your data automatically with the aim of evaluating certain personal aspects (profiling).

6. Is there an obligation for me to provide data?

Our website requires you to provide the personal information required to use our site for technical or IT security reasons. Unless you provide the above data, you cannot use our website.

When contacting us by form or e-mail, you only need to provide the personal information necessary to process your request. Otherwise we cannot process your request.

7. Newsletter

With the following information, we will inform you about the contents of our newsletter as well as the registration, shipping and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.

Content of the newsletter: We will send you newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission.Where in the context of an application to the newsletter whose contents are described concretely, they are For the rest, our newsletters contain information about our products, offers, promotions and our company.

Double opt-in and logging: Registration for our newsletter is done in a so-called double opt-in procedure. This means you will receive an e-mail after logging in to ask for confirmation of your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. Registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the logon and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.

E-mail Service: The newsletter is distributed using “Customer.io”, a newsletter shipping platform, located at 921 SW Washington Street Suite 820 Portland, Oregon, 97205, United States. The privacy policy of the service provider can be found here: https://customer.io/legal/privacy-policy/

Customer.io is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000PCaFAAW)

Furthermore, the service provider may, according to its own information, use this data in pseudonymous form, ie without assignment to a user, to optimize or improve its own services, eg for the technical optimization of shipping and the presentation of newsletters or for statistical purposes in order to determine which countries the recipients come from. However, the shipping service provider does not use the data of our newsletter recipients to address them themselves or to pass them on to third parties.

Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.

For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavor nor that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The dispatch of the newsletter and the success measurement are made on the basis of a consent of the recipients acc. Art. 6/1/A, and Art. 7 of the GDPR.

The logging of the registration process is based on our legitimate interests in accordance with. Art. 6/1/f of the GDPR and serves as proof of consent to the receipt of the newsletter.

Termination / Revocation – You can cancel the receipt of our newsletter at any time, ie revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. If the users have only subscribed to the newsletter and terminated this registration, their personal data will be deleted.

8. Google Analytics

We use Google Analytics, a web analysis service of Google Inc. (“Google”), based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6/1/f of the GDPR) Google uses cookies The information generated by the cookie about users’ use of the online offer is usually transmitted to and stored by Google on servers in the United States.

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offering and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous user profiles of the processed data can be created.

We use Google Analytics to display the advertisements displayed within Google’s advertising services and its affiliates, only those users who have shown an interest in our online offering or who have certain characteristics (eg interest in specific topics or products visited by them) Web pages) that we provide to Google (“Remarketing” or “Google Analytics Audiences”) .With the help of Remarketing Audiences, we also want to ensure that our ads are in line with the potential interest of users and do not seem annoying.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of such data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

For more information about Google’s data usage, hiring and opt-out options, please visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“Google’s use of your data when you use websites or apps our partners “), http://www.google.com/policies/technologies/ads (” Use of data for promotional purposes “), http://www.google.com/settings/ads (” Managing information that Google uses, to show you advertising “).

9. Google Re / Marketing Services

Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art/1/f of the GDPR), we use the marketing and remarketing services (“Google Marketing Services”) of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (“Google”).

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).

Google Marketing Services allows us to better target advertisements for and on our website so that we only present to advertisers ads that are potentially in their interests. For example, if a user sees advertisements for products he’s been interested in on other websites, this is referred to as “remarketing.” For these purposes, when we visit our and other websites where Google Marketing Services is active, it’s instant Google implements a code from Google and incorporates so-called (re) marketing tags (invisible graphics or code, also known as “web beacons”) into the website that allow the user to create an individual cookie, ie a small file is saved (instead of cookies, comparable technologies can also be used). The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file is noted which websites the user visited, for what content he is interested and what offers he has clicked, as well as technical information about the browser and operating system, referring websites, visit time and other information on the use of the online offer. It also collects the IP address of the users, with Google Analytics reporting that that the IP address is shortened within member states of the European Union or other parties to the Agreement on the European Economic Area and only in exceptional cases completely transferred to a Google server in the USA and shortened there. The IP address will not be merged with data of the user within other offers from Google. The above information may also be linked by Google with such information from other sources. If the user subsequently visits other websites, they may be shown according to his interests, the ads tailored to him. The above information may also be linked by Google with such information from other sources. If the user subsequently visits other websites, they may be shown according to his interests, the ads tailored to him. The above information may also be linked by Google with such information from other sources. If the user subsequently visits other websites, they may be shown according to his interests, the ads tailored to him.

The data of the users are pseudonym processed in the context of the Google marketing services. For example, Google does not store and process users’ names or e-mail addresses, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. That is, from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google’s servers in the United States.

Google marketing services we use include the Google AdWords online advertising program, and in the case of Google AdWords, each advertiser receives a different “conversion cookie.” Cookies can not be served through AdWords websites. The information gathered through the cookie is used to generate conversion statistics for conversion-tracking advertisers who see the total number of users who have clicked on their ad and have been redirected to a page that has a conversion tracking tag, but you will not receive any information that personally identifies users.

We can embed third-party ads based on Google’s DoubleClick marketing service . DoubleClick uses cookies that enable Google and its affiliate sites to serve ads based on users’ visits to this site or other sites on the Internet.

We may use third-party ads based on the Google AdSense marketing service AdSense uses cookies that enable Google and its affiliate sites to serve ads based on users’ visits to this site or other sites on the Internet becomes.

We can also use the service ” Google Optimizer ” Google Optimizer allows us within the framework of so-called “A / B-Testings” to understand how various changes to a website affect (eg changes in input fields, the design, etc.) For testing purposes, cookies are stored on users’ devices, whereby only pseudonymous data of users are processed.

In addition, we may use the ” Google Tag Manager ” to integrate and manage the Google Analytics and Marketing Services on our website.

For more information about Google’s data usage for marketing purposes, see the overview page: https://www.google.com/policies/technologies/ads , Google’s Privacy Policy located at https://www.google.com/policies/privacy available.

To opt-out of Google Marketing Services Interest-based Advertising, you can take advantage of Google’s recruitment and opt-out options: http://www.google.com/ads/preferences .

10. Facebook, Custom Audiences and Facebook Marketing Services

Within our online offering, due to our legitimate interests in the analysis, optimization and commercial operation of our online offering and for these purposes, the so-called “Facebook Pixel” of the social network Facebook, published by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland operated (“Facebook”).

Facebook is certified under the Privacy Shield Agreement, providing a guarantee to comply with European privacy legislation ( https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ).

With the help of the Facebook pixel, it is on the one hand possible for Facebook to determine the visitors to our online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads we have been sent only to those Facebook users who have also shown an interest in our online offering or certain features (eg interests in certain topics or products that have been visited by them) We also use the Facebook pixel to ensure that our Facebook ads are in line with the potential interest of users and are not annoying.

The Facebook pixel is integrated when calling our website directly through Facebook and can store on your device a so-called. Cookie, ie a small file. If you subsequently log in to Facebook or visit Facebook in the logged-in state, the visit to our online offer will be noted in your profile. The data collected about you are anonymous to us, so do not give us any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and can be used by Facebook as well as for its own market research and advertising purposes. If we should submit data to Facebook for reconciliation purposes, These are encrypted locally in the browser and then sent to Facebook via a secured https connection. This is done solely with the purpose of establishing a comparison with the equally encrypted by Facebook data.

Furthermore, when using the Facebook pixel we use the additional function “extended comparison” (data such as telephone numbers, e-mail addresses or Facebook IDs of the users) for the formation of target audiences (“Custom Audiences” or “Look Alike Audiences”) Facebook (encrypted) For more information about “advanced reconciliation”: https://www.facebook.com/business/help/611774685654668 ).

Also based on our legitimate interests, we use the “Custom Audiences from File” method of the social network Facebook, Inc. In this case, the email addresses of newsletter recipients are uploaded to Facebook, the upload process is encrypted serves alone to identify recipients of our Facebook ads, to ensure that the ads are displayed only to users who are interested in our information and services.

The processing of the data by Facebook is part of Facebook’s data usage policy. Accordingly, general notes on how to display Facebook Ads, in Facebook’s Data Usage Policy: https://www.facebook.com/policy.php . For specific information and details about the Facebook Pixel and how it works, visit the help section of Facebook: https://www.facebook.com/business/help/651294705016616 .

You may object to the capture by the Facebook Pixel and use of your data to display Facebook Ads. To set which types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions for the usage-based advertising settings: https://www.facebook.com/settings?tab=ads . The settings are platform-independent, ie they are adopted for all devices, such as desktop computers or mobile devices.

You can also use the Cookies for distance measurement and promotional purposes via the deactivation page of the Network Advertising Initiative ( http://optout.networkadvertising.org/ ) and in addition the US website ( http://www.aboutads.info/ choices ) or the European website ( http://www.youronlinechoices.com/uk/your-ad-choices/ ).

11. Other services

On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art/6/f of the GDPR), we make use of third-party content or service offerings in order to provide their content and services, eg Include videos or fonts (collectively referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer. how the visitor traffic is evaluated on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer. how the visitor traffic is evaluated on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.

The following presentation provides an overview of third-party providers as well as their contents, as well as links to their privacy statements, which contain further notes on the processing of data and, in some cases already mentioned here, possibilities of objection (so-called opt-out):

If our customers use the payment services of third parties (eg PayPal or BillPay), the terms and conditions and the privacy notices of the respective third party providers apply, which can be accessed within the respective websites or transaction applications.

External fonts from Google, LLC., Https://www.google.com/fonts (“Google Fonts”) The Google Fonts integration is done through a server visit to Google (usually in the US) Privacy Policy: https: //policies.google.com/privacy , opt-out: https://adssettings.google.com/authenticated .

Maps provided by the Google Maps third-party service Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA Privacy Policy: https://www.google.com/policies/privacy/ , opt-out: https: / /www.google.com/settings/ads/ .

Third-party platform “YouTube” videos Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://policies.google.com/privacy , opt-out: https://adssettings.google.com/authenticated .

Within our online offer functions of the service Instagram are integrated. These features are provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, United States. If you are logged in to your Instagram account, you can link the contents of our pages to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate the visit of our pages with your user account. We point out that we as the provider of the pages do not receive any knowledge of the content of the transmitted data and their use by Instagram. Privacy Policy: http://instagram.com/about/legal/privacy/ .

Features of the Service or the Twitter Platform may be incorporated into our online offering (hereinafter referred to as “Twitter.”) Twitter is an offer from Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, United States the presentation of our contributions within Twitter within our online offer, the link to our profile on Twitter as well as the opportunity to interact with the posts and features of Twitter, as well as to measure whether users are using the advertisements we have posted on Twitter for our online offer Twitter is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active ). Privacy Policy: https://twitter.com/privacy , opt-out: https://twitter.com/personalization .

Web analytics and optimization using the Optimizely service provided by Optimizely Inc., 631 Howard Street, Suite 100 San Francisco, CA 94105. We use Optimizely to evaluate your use of the website and to compile reports on website activity. The data transmitted by Optimizely from your browser will not be merged with other Optimizely data. You can prevent the storage of cookies by a corresponding setting of your browser software; however, we point out that in this case you may not be able to use all the functions of this website in full. In addition, you can deactivate Optimizely tracking at any time (and thus the collection of data generated by the cookie and related to your use of the website – incl.follow http://www.optimizely.com/opt_out .

Web analytics and optimization using Hotjar service, Hotjar Ltd. Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta. With Hotjar, movements can be traced on the websites where Fullstory is used (so-called Session Replay). For example, you can see how far users are scrolling and which buttons users click as often. Furthermore, technical data such as selected language, system, screen resolution and browser type are recorded. Here, at least temporarily during the visit to our website profiles of users can be created. It is also possible to use Fullstory to get feedback directly from the users of the website. In this way, we gain valuable information to make our websites faster and more customer-friendly. Data protection:https://www.hotjar.com/legal/policies/privacy

Personal Data Retention

We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).

We will only keep the data while your account is active or for as long as needed to provide services to you.

We retain your data for as long as needed in order to comply with our global legal and contractual obligations.

Uptades To Privacy Policy

We may change this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy via the Website. If we make changes which we believe are significant, we will inform the Data Subject through the Website to the extent possible and seek for the Data Subject’s consent where applicable.

Contact and Data Protection Officer (DPO)

The MOWICO is headquartered in California, the US. The MOWICO has appointed an internal data protection officer for you to contact if you have any questions or concerns about our personal data policies or practices. The email of MOWICO data protection officer is privacy@mowico.com

For any questions or requests relating to this Privacy Policy, please contact us as follows:

E-mail: privacy@mowico.com

Website: www.mowico.com

 

Cookie Policy

Last updated: April 23, 2020.

As is true of most other websites, this website collects certain information automatically and stores it in log files. This includes Internet Protocol (IP) addresses, geographic location of your computer or device, browser type, operating system and other information about visiting this website, for example, pages viewed. This information is used to improve this website and, thanks to this constant improvement, to better serve to our users. Your IP address may also be used to diagnose problems with our server, administer this website, analyze trends, track a user’s movement on the site, and collect demographic information to help us understand visitor preferences and their needs. This website also uses cookies and web beacons.

What is a Cookie? Whenever you visit a website, your device downloads a number of small files called “cookies.” The cookies are widely used to make online services work and operate more efficiently, and to provide the owners of the websites with information regarding the user experience and efficiency of the websites. The cookies also let the website recognise your particular device, this means it can remember your preferences, you can navigate between pages more quickly, as well as do a number of other useful things.

Cookies serve many valuable purposes but you may wish to not allow them or to limit their use. Most browsers allow you the ability to manage the cookies in a way that suits you by changing the browser’s settings. The settings of your browser should give you the ability to disallow cookies from sites on site by site basis and to disallow cookies from sites that you do not trust. Please note that disabling cookies or other tracking technologies on our websites may diminish and/or disable some of the features or whole parts of our websites, and functionality may no longer work as intended.

If you like more detailed information about cookies, you can find everything you’ll need to know over at www.allaboutcookies.org and www.youronlinechoices.eu.

Strictly Necessary Cookies: We use cookies and similar technologies that are necessary to the operation of our Services. This includes technologies that allow you access to our website, services, mobile app or that are required to identify irregular site behaviour, prevent fraudulent activity and improve security, or that allow you to make use of our functions such as saved search or similar functions.

Functionality Cookies: We use cookies and similar technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our website, keeping you signed in as you browse or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our website and mobile app.

Performance Analytics Cookies: We use cookies and similar technologies to assess the performance of our Services. We use this information to analyse and help us understand how you and other visitors use our Services so we can improve the content or layout of our Services. We also use this information to track the number of our visitors and analyse the popularity of the features we offer.

Advertising Cookies: We may use first-party or third-party cookies and similar technologies to deliver content, including ads relevant to your interests. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

We use cookies for necessary functional, statistical and marketing purposes. You can modify your current cookie settings at any time.

Cookies are information transmitted by our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Cookies can be small files or other types of information storage. In part, the cookies are used for security or to operate our website (eg for the presentation of the website) or to save the user’s decision when confirming the cookie banner.

We use “session cookies” that are created when visiting our online presence (eg to enable the storage of your login status and thus the use of our online offer at all) A session cookie stores a randomly generated, unique identification number. In addition, a cookie contains the information about its origin and the storage period Session cookies are deleted if you have finished using our online offer (eg by logging out), the validity of the cookie expires or the cookies are deleted in the browser ,

The use of cookies in the context of pseudonymous range measurement informs users in the context of this privacy policy.

If users do not want cookies stored on their machine, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

You may opt for the use of cookies for distance measurement and promotional purposes through the Network Advertising Initiative’s opt -out page (http://optout.networkadvertising.org/ ) and, in addition, the European website ( http://www.youronlinechoices.com/uk/your-ad-choices/ ).

How to control and delete cookies We will not use cookies to collect personally identifiable information about you.

However, if you wish to restrict or block the cookies which are set by our websites, or indeed any other website, you can do this through your browser settings. The ‘Help’ function within your browser should tell you how.

Alternatively, you may wish to visit AboutCookies.org – How to control cookies which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies.

Please be aware that restricting cookies may impact on the functionality of our website.

If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie.

For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual. To opt-out of third-parties collecting any data regarding your interaction on our website, please refer to their websites for further information below: https://www.aboutcookies.org/

For any questions or requests relating to this Cookie Policy, please contact us as follows:

E-mail: privacy@mowico.com

Website: www.mowico.com