This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through this website (Site). In this Privacy Policy Policy we, us or our means or our means Mumo Systems. When we collect, receive, store and use your personal information, we do so in accordance with the rules set in the European Union General Data Protection Regulation (EU) 2016/679 (the the GDPR).
Personal information
Personal information: The types of personal information or personal data data we may collect collect about you include:
your name;
your contact details, including email address, mailing address and/or telephone number;
your demographic information, such as post code;
your preferences and/or opinions;
details of the services we have provided to you and/or that you have enquired about, and our response to you;
your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behavior;
information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
any other personal information requested by us and/or provided by you or a third party.
We may collect these types of personal information directly from you or from third parties.
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We may collect, hold, use and disclose personal information for the following purposes:
to enable you to access and use our Site, associated applications and associated social media platforms;
to contact and communicate with you;
for internal record keeping and administrative purposes;
for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you; and
to comply with our legal obligations and resolve any disputes that we may have.
Disclosure of personal information to third parties
We may disclose personal information to:
third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting providers, professional advisors and payment systems operators;
our employees, contractors and/or related entities;
our existing or potential agents or business partners;
payment systems operators;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of the United State of America; and
third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of US.
Where we disclose your personal information to third parties, including data processors or data sub-processors, we will request that the third party handle your personal information in accordance with this Privacy Policy. The third party will only process your personal information in accordance with written instructions from us and we require that the third party either complies with the privacy shield principles set out in the GDPR or another mechanism set out by applicable EU & Swiss data protection laws for the transfer and processing of personal information. When we refer to ‘processing’ in this clause and this Privacy Policy in general, we mean any operation or set of operations which is performed on personal information, whether or not by automated means, such as collecting, recording, organizing, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available personal information.
Please note that we use the following third parties to process your personal information:
Atlassian
Google
Amazon Web Services and
Mailchimp
By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside US and, if you are a European Union (EU) citizen, to third parties that reside outside the EU. Where the disclosure of your personal information is solely subject to Australian privacy laws (and not subject to the GDPR), you acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.
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As a controller, we have certain obligations under the GDPR when collecting, storing and using the personal information of EU citizens. If you are an EU citizen, your personal data will:
be processed lawfully, fairly and in a transparent manner by us;
only be collected for the specific purposes we have identified in the ‘collection and use of personal information’ clause above and personal information will not be further processed in a manner that is incompatible with the purposes we have identified;
be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal information is processed;
be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);
be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal data was collected;
be processed securely and in a way that protects against unauthorized or unlawful processing and against accidental loss, destruction or damage.
We also apply these principles to the way we collect, store and use the personal information of our Australian clients.
Specifically, we have the following measures in place, in accordance with the GDPR:
Data protection policies: We have internal policies in place which set out where and how we collect personal information, how it is stored and where it goes after we get it, in order to protect your personal information.
Right to ask us to erase your personal information: You may ask us to erase personal information we hold about you.
Right to ask us to restrict data processing: You may ask us to limit the processing of your personal information where you believe that the personal information we hold about you is wrong (to give us enough time to verify if the information needs to be changed), or where processing data is unlawful and you request us to restrict the processing of personal information rather than it being erased.
Notification of data breaches:
WeWe will comply with the GDPR in respect of any data breach.
Our responsibilities as a ‘processor’ under the GDPR
Where we are a processor, we have contracts containing certain prescribed terms in our contracts with controllers. Depending on circumstances, we can be a controller or processor or controller and processor. In addition to:
our contractual obligations with controllers (where we are solely a processor); and
our legal obligations under the GDPR as a controller (where we are both a controller and processor) as a processor we also have the following responsibilities under the GDPR:
not to use a sub-processor without the prior written authorization of the data controller;
to co-operate with supervisory authorities;
to ensure the security of our processing;
to keep records of processing activities;
to notify any personal data breaches to the data controller; and
to employ a data protection officer and appoint (in writing) a representative within the European Union if required by the GDPR. (We are currently not required to take these measures).
Your rights and controlling your personal information
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