Privacy Policy

This Privacy Policy (“Policy”) sets out the manner in which Mobylx Tech Mobile Trading Limited, a company incorporated under the laws of the United Arab Emirates (hereinafter referred to as the “Company”, “we”, “us”, “MobylX” or “our”), collects, uses, processes, discloses, stores, and protects personal data of individuals who access or use the MobylX application (the “Application”).

This Policy is intended to comply with applicable laws of the United Arab Emirates and India, including but not limited to the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“PDPL”), General Data Protection Regulation (GDPR), Information Technology Act, 2000 and any implementing regulations, as may be amended from time to time.

By accessing or using the Application, or by providing your personal data to us, you acknowledge that you have read, understood, and agree to the terms of this Policy.

MobylX provides services to the users through its app and website, and is committed to protecting and respecting the privacy of the users and has taken all necessary and reasonable measures to protect the confidentiality of the user information and its transmission through the World Wide Web.

In the course of using the MobylX website and app or availing the products and services, MobylX may become privy to the personal information of its users, including information that is of a confidential nature. MobylX shall not be held liable for disclosure of the confidential information if such disclosure is in accordance with this Policy or in accordance with the terms of any agreements entered with the users.

MobylX also assures not to disclose all information (except in some limited circumstances as mentioned below) that it learns during the transactions and payments made to the user’s account(s).

“Personal Data” means any information relating to an identified or identifiable natural person, including but not limited to name, contact details, identification data, location data, online identifiers, or any other data as defined under applicable law.

“Processing” means any operation or set of operations performed on Personal Data, whether by automated means or otherwise, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, dissemination, alignment, restriction, erasure, or destruction.

“Controller” refers to the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, the Company acts as the Controller unless otherwise specified.

“Processor” refers to any third party that processes Personal Data on behalf of the Controller.

“User(s)” shall mean and include all individuals, companies and private organizations that visit the Application and provide information to MobylX through any of the modes referred in this Policy.

This Policy applies to all visitors, users, customers, and any other individuals who access or interact with the Application or otherwise provide Personal Data to the Company.

This Policy governs the processing of Personal Data collected through:

• the Application;
• electronic communications (including email and online forms);
• customer support interactions; and
• any related services offered by the Company.

The Application is not intended for use by individuals under the age of 18. The Company does not knowingly collect Personal Data from minors. If the Company becomes aware that it has collected Personal Data from a minor without appropriate consent, it shall take steps to delete such data.

The Company may collect Personal Data directly from you, automatically through your interaction with the Application, or from third-party sources, as further described below. In particular, we collect:

• Registration information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, country of residence, gender, email address, username.
• Transaction information you provide when you request information, contact Services, or purchase a plan or service from us, such as your postal address and telephone number.
• In the case of companies or other legal entities, such information may include the name of the company, date of incorporation, GST or other tax identification number, registered and billing address, turnover details, operating locations (including countries and states), website details, nature and type of the entity, and authorized contact information such as the name, designation, email address, and phone number of the concerned person. In addition, the Company may collect personal information of individuals, including those accessing the Application, such as their name, contact details (email and phone number), address (where provided), login or account information, IP address, device and browser details, and usage data relating to their interaction with the Application.
• Information you provide in public forums on our sites and applications.
• Information sent either one-to-one or within a limited group using our message, chat, post, or similar functionality, where we are permitted by applicable law to collect this 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, applications, or physical properties, or associated with your IP address or other online or device identifier, 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 tenders you search, 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, or connect with our wireless Internet access services and other similar technologies, including your browser or device type, unique device identifier, and IP address.
• Call recordings when you call our Customer Care, Chat, SMS, and mails while if you opt for WhatsApp, Email etc and other services.
• Product Notifications: By signing up, you agree to receive product notifications that we consider integral to your overall product experience. These notifications may include important updates, promotions, and relevant information about our services. You can opt-out of receiving product notifications at any time by adjusting your account settings or following the instructions provided in the notifications.

• We collect information you provide to us when you request or purchase product, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), or other activities on our sites and applications, respond to guest surveys, visit our physical properties, call our Customers centers, or otherwise (including emails and WhatsApp) interact with us using one or more devices. You may provide information in a variety of ways, including by typing or using voice commands.
• We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered.
• We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.

MobylX, that is the data Controller for your information, is responsible for and may use your information for the purposes described in this Policy. Other group companies of MobylX may access your information where they perform services on behalf of the data controllers (as data Processors) and, unless prohibited under applicable law, for use on their own behalf (as data controllers) for the purposes described in this policy. Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:

• Provide you with the experiences, products, and services you request, view, engage with, or purchase.
• Communicate with you about your account or transactions with us and send you information or request feedback about features on our sites and applications or changes to our policies.
• Send you offers and promotions for our products and services or third-party products and services.
• Personalize content and experiences.
• Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications.
• Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations, including by using survey research and analytics tools.
• Detect, investigate and prevent activities that may violate our policies, pose safety issues, or be fraudulent or illegal.
• Notify you of product recalls or safety issues.
• MobylX will use the Data including personal data in the legitimate manner and the information will not be further processed by MobylX in any manner without asking for the consent.

We may disclose user’s information to such third parties to whom it transfers its rights and duties under the agreement entered into with the users. In such an event, the said third parties’ use of the information will be subject to such confidentiality obligations as contained in the policy. The Company may share your Personal Data with third parties where you have provided explicit consent. The Company does not sell Personal Data to third parties.

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:

• Correcting, updating, and deleting your registration account.
• Choosing or changing your choices for subscriptions, newsletters, and alerts.
• Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you.
• Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services.
• Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers.
• Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device’s advertising identifier and/or opting out of interest-based ads.
• Requesting removal of your personal information from a public forum on one of our sites or application.
• Requesting access to the personal information we hold about you and that we amend or delete it.

You may exercise these controls and choices in various ways, by contacting Customer Service Centre, following instructions provided in communications sent to you, or by using your device or other available settings (for example, by re-setting your device’s advertising identifier, unsubscribing emails, changing notification settings in your account and/or opting out of interest-based ads).

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact the Customer Service Centre.

MobylX takes the security of its user’s information very seriously. The Company implements appropriate technical and organizational measures to protect Personal Data against unauthorized access, disclosure, alteration, or destruction. Such measures may include encryption, firewalls, secure server infrastructure, and access control mechanisms. Access to Personal Data is restricted to authorized personnel on a need-to-know basis.

Notwithstanding the foregoing, no method of transmission over the internet or method of electronic storage is completely secure, and the Company cannot guarantee absolute security.

MobylX uses commercially reasonable safeguards to preserve the integrity and security of the users’ information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. MobylX doesn’t store any banking information (username, password etc) in any manner. All information provided to MobylX is stored on its secure servers whether outside or within India.

The information that is collected from the users may be transferred to and stored at a destination inside or outside India. By submitting information on the Application, the users agree to this transfer, storing and/or processing. MobylX will take such steps as it considers reasonably necessary to ensure that the users’ information is treated securely and in accordance with the Policy.

In using the Application, the users accept the inherent security implications of data transmission over the internet and the World Wide Web cannot always be guaranteed as completely secure. Therefore, the use of the Application will be at the own risk of the users. MobylX assumes no liability for any disclosure of information due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond its reasonable control and the user agrees not to hold MobylX responsible for any breach of security unless such breach has been caused as a direct result of gross negligence or willful default by MobylX.

In the event MobylX becomes aware of any breach of the security of the users’ information, it will promptly notify the users and take appropriate action to the best of its ability to remedy such a breach.

The Company retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying legal, regulatory, accounting, or reporting requirements. Upon expiry of the applicable retention period, Personal Data shall be securely deleted or anonymized.

This Policy does not apply to any information other than information collected by MobylX through the Application and applications including such information collected in accordance with the clause on “Collection of Information” above. This Policy shall not apply to any unsolicited information provided by the users through this website or through any other means. This includes, but is not limited to, information posted to any public areas of the Application. All such unsolicited information shall be deemed to be non-confidential and MobylX shall be free to use, disclose such unsolicited information without limitation.

MobylX shall obtain digital consent from the provider of the sensitive personal data or information regarding purpose of usage before collection of such information. During the use of the Application, MobylX may collect and process information from the Users as mentioned above.

While collecting information directly from the person concerned, MobylX or any person on its behalf shall take such steps as are, in the circumstances, reasonable to ensure that the person concerned is having the knowledge of:

1. the fact that the information is being collected;
2. the purpose for which the information is being collected;
3. the intended recipients of the information.

MobylX or any person on its behalf shall, prior to the collection of information including sensitive personal data or information, provide an option to the provider of the information to not provide the data or information sought to be collected. The provider of information shall, at any time while availing the services or otherwise, also have an option to withdraw its consent given earlier to MobylX. Such withdrawal of the consent shall be sent in writing to MobylX. In the case of a provider of information not providing or later on withdrawing his consent, MobylX shall have the option not to provide goods or services for which the said information was sought.

MobylX collects certain information from the user’s browser using small data files called “cookies.” MobylX uses session ID cookies to confirm that customers are logged in. This type of cookie helps MobylX recognize a customer if he or she visits multiple pages on the Application during the same session, so that separate passwords are not required to access each page. These cookies terminate once the customer closes the browser. By default, MobylX uses a persistent cookie that stores customer login ID (but not password) to make it easier for the customer to login when returning to the Application. MobylX encodes its cookies so that only MobylX can interpret the information stored in them. The user may remove or block this cookie using the user’s browser settings to disable the feature. MobylX also stores transaction history. MobylX may collect additional information in ways not specifically described herein. For example, MobylX may track information related to interactions with customer service or responses from surveys or other feedback tools. MobylX uses this information to continually improve the service provided to the customers. MobylX’s Privacy Policy does not cover the use of cookies by its partners and affiliates. MobylX does not have access or control over these cookies. MobylX’s partners and affiliates may use session ID cookies to provide a custom user experience and to track the success of MobylX’s partnership with them.

The web pages of the Application contain electronic images known as “web beacons” (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Application is used. Web beacons may also be used in some of MobylX’s emails so as to know which emails and links recipients have opened, allowing it to gauge the effectiveness of its customer communications and marketing campaigns.

User information will be retained for as long as the user account is active or as needed to provide services to the user or otherwise required under any other law for the time being in force. If the user wishes to cancel its account or requests that MobylX no longer uses its information to provide services, the user may contact MobylX at contact@mobylx.com. MobylX will retain and use user information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes.

All content made available on this website, including but not limited to text, graphics, logos, icons, images, audio clips, video content, data compilations, software, design elements, layout, and underlying code (collectively, the “Content”), is the property of the Company, its affiliates, licensors, or content suppliers, and is protected by applicable intellectual property laws, including copyright, trademark, and other proprietary rights under the applicable laws and applicable international conventions.

The trademarks, logos, and service marks displayed on the Application (collectively, the “Marks”) are the registered and/or unregistered trademarks of the Company or third parties. Nothing contained on this website or in this Privacy Policy should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any such Marks without the prior written permission of the Company or the relevant third party owner.

Users are granted a limited, non-exclusive, non-transferable, and revocable license to access and use the Application and its Content strictly for personal, non-commercial purposes, subject to compliance with applicable laws and this Privacy Policy. Any unauthorized use, reproduction, modification, distribution, transmission, display, performance, or other exploitation of the Content, in whole or in part, without prior written consent of the Company, is strictly prohibited.

Where Users submit, upload, or otherwise provide any content, materials, or information to the Application (including but not limited to feedback, comments, or business inquiries), the User represents and warrants that they have all necessary rights to do so. By submitting such content, the User grants the Company a worldwide, non-exclusive, royalty-free, perpetual, irrevocable, and sublicensable license to use, reproduce, adapt, publish, translate, distribute, and display such content for the purposes of operating, promoting, and improving the Application and its services, unless otherwise agreed in writing.

The Company respects the intellectual property rights of others and expects Users to do the same. If you believe that any content on the Application infringes your intellectual property rights, you may notify the Company by providing detailed information of the alleged infringement, including proof of ownership and identification of the infringing material. Upon receiving a valid complaint, the Company reserves the right to investigate and take appropriate action, including removal of the infringing content.

Nothing in this Privacy Policy shall be construed as transferring ownership of any intellectual property rights from the Company to the User or any third party.

In the event MobylX modifies this Privacy Policy, the same will be updated on the Application. This policy may be changed, but any changes will be posted, and changes will only apply to activities and information on a going forward, not retroactive basis. The users are encouraged to periodically review this page for the latest information on its privacy practices. In case of any material changes to the Policy, the users will be notified by email (sent to the email address specified in the user’s account) or by means of a notice on this website prior to the change becoming effective.

MobylX has made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

MobylX pledges that it shall not sell or rent users’ personal details to anyone. MobylX will protect every bit of the users’ business or personal information and maintain the confidentiality of the same. With this seal of trust, MobylX makes its services available to the users for assessment and analysis that include credit and behavior scoring, market and product analysis.

MobylX guarantees that it is going to keep all information confidential except in the following cases:

• MobylX may disclose users’ information to governmental and other statutory bodies who have appropriate authorization to access the same for any specific legal purposes.
• MobylX may disclose users’ information if it is under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply the Terms of Use (displayed on the Application), or to protect the rights, property or safety of MobylX, its users or others. This includes exchanging information with other companies / agencies that work for fraud prevention and credit reference.
• MobylX may disclose users’ information to its agents under a strict code of confidentiality.
• MobylX may disclose users’ information to such third parties to whom it transfers its rights and duties under the customer agreement entered into with the users. In such an event, the said third parties’ use of the information will be subject to such confidentiality obligations as contained in this Policy.
• MobylX may disclose users’ information to any member of its related or group companies including its subsidiaries, its ultimate holding company and its subsidiaries, as the case may be.
• In the event that MobylX sells or buys any business or assets, it may disclose the users’ information to the prospective seller or buyer of such business or assets. User, email and visitor information are generally one of the transferred business assets in these types of transactions. MobylX may also transfer or assign such information in the course of corporate divestitures, mergers or dissolution.

To opt out of email correspondence from MobylX or make a change to (or delete) the User information stored in MobylX’s records, please contact MobylX at contact@mobylx.com. MobylX will respond to the user’s request within 30 days of receipt.

In case of any grievance regarding the use of your Information, please write at contact@mobylx.com with all relevant details of your grievance. MobylX will respond to all relevant User queries within 30 days of receipt.

The Company reserves the right to amend or update this Privacy Policy at its sole discretion. Any changes shall be effective upon posting on the Application, and the “Last Updated” date shall be revised accordingly.

Continued use of the Application following such updates shall constitute acceptance of the revised Policy.