MOBICOM PRIVACY POLICY

Thank you for using our products and services – including OneClubNet – which are licensed by MobiCom eCommune Inc ["MobiCom"]. When you use OneClubNet and/or its related internet and web components (collectively, the "MobiCom OneClubNet Software"), you search and share information with the OneClubNet ecosystem, MobiCom and the MobiCom Group (which include MobiCom eCommune Inc, MobiCom Commune Pte. Ltd and MobiCom Platinum Partners Inc). Therefore, this Privacy Policy is applicable to anyone who uses one or all of our services components. This includes but is not limited to members of clubs, clubs, brands, corporates and their employees, collectively "users". As you use our services, we want you to be aware of how we’re using the information and the ways in which you can protect your privacy. This Policy is effective from February 19th 2019 and this Policy was last modified on February 19th 2019.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of MobiCom OneClubNet Software AND you will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using MobiCom OneClubNet Software immediately.

You may not use the MobiCom OneClubNet Software if you (a) do not agree to these terms, (b) are not the older of (i) at least 18 years of age or (ii) legal age to form a binding contract with MobiCom, or (c) are prohibited from accessing or using the MobiCom OneClubNet Software or any of its contents, goods or services by applicable law. If you are a minor i.e. below the age wherein you can form a legally binding contract under applicable law, you may use the MobiCom OneClubNet Software only with the involvement of a parent or guardian.

ABOUT US

If you live in the United States or outside the European Union (EU), your information is controlled by MobiCom eCommune Inc., 15851 Dallas Parkway, #600, Addison, Texas, 75001, U.S.A. If you live within the EU, the data controller representative responsible for your information is Stefano Cardoni, Via Litoranea Km 6,900, Localita Pian di Spille, Tarquinia (VT) 01016 Italy.

At MobiCom, your privacy is very important to us. Our Privacy Policy explains:

INFORMATION WE COLLECT

We collect information to provide better services to all of our users. As such, there are three (3) basic categories of information we collect:

When you interact with our services, we collect and store personal information that you choose to share with us, as well as data related to your visit and usage of MobiCom OneClubNet Software. Personal information is any information about you that is personally identifiable, such as your name, address, email address or phone number, and any other information that is not otherwise publicly available. Given that most of our services require you to set up an account, we will need to collect some of these important personal, detailed information about you, such as: a unique username you’d like to go by, a password, an email address, and a phone number, as examples.

Additionally, you’ll provide us whatever information you send or create through the services, such as the creation of your profile and preferences, reservations you make, messages you exchange with other users, etc. Keep in mind that the users and service providers you share, and/or send content to, can always save that content or copy it outside our ecosystem. So, the same common sense that applies to the internet at large applies to the MobiCom OneClubNet Software as well: Don’t share information or content that you wouldn’t want someone to save or share.

Furthermore, when you contact customer support or communicate with us in any other way, we’ll collect whatever information you volunteer.

What Information Do We Collect?

When you use our services, we automatically collect certain aggregate information related to your MobiCom OneClubNet Software use, including information you share with any member of the MobiCom Group, in order to provide better services to you and all of our users. Aggregate information is generally non-personally identifiable or anonymous information about you, including the date and time of your visit, your IP address, your mobile device or computer browser information, the Internet address that you visited prior to and after reaching the MobiCom OneClubNet Software, the name of the domain and host you used to access the Internet, and the features of our MobiCom OneClubNet Software which you accessed.

In order to provide specific services which you opt for, such as reservations and trip experiences, we may collect personal information that you choose to share in order to avail of such services.

Information we collect from Third Parties

In order to create your Account, we may be provided with some personal information from your Club in order to verify your membership, such as your name, email id and club membership number. This information is used only used for the purpose of creating your Account and providing you with our services.

We may also collect information that other users provide about you when they use our services. For example, if are included in the connections list of another user, we may combine the information we collect from that user with other information we have collected about you.

We may also obtain information from our affiliates, or any other third-party sources, and combine that with the information we collect through our services.

Other Information that may be shared with us

Device information

We collect information from and about the devices you use. For example, we may collect:

Log information

When you use our services, we automatically collect and store certain information in server logs. This includes:

Location information

We may record your current location, using various technologies like IP address, GPS and other similar sensors. We also store your time zone settings in order to ensure our services operate correctly. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by turning off the location services settings for the MobiCom OneClubNet Software on your device.

Financial information

We do not collect Financial information like credit/debit card, bank details. When you execute a transaction in the MobiCom OneClubNet Software, you enter this information on a Payment Gateway solution provided by Stripe, Inc. We facilitate a seamless and secure transfer of your browsing from the MobiCom OneClubNet Software to the Payment Gateway. All financial information provided, and transactions are maintained and secured by Stripe, Inc and are subjected to their respective privacy policy.

Information Collected by Cookies and Other Technologies

Cookies are simple text files stored on your computer or mobile device for use by a browser when you visit a website. Like some online services and mobile applications, certain MobiCom OneClubNet Software features may only be available through the placement of a cookie. We may use such cookies to assist in data collection and to track MobiCom OneClubNet Software usage and trends to help us better serve you. The use of cookies is a standard practice among Internet and software applications; most Internet browsers permit a user to accept, decline or delete cookies. This MobiCom OneClubNet Software works with a first party cookie that collects anonymous traffic data at the MobiCom OneClubNet Software. Please note, that removing or rejecting cookies could affect the availability and functionality of our services.

We use various technologies to collect and store information when you use our services, and this may include using cookies or similar technologies to identify your browser or device. When you submit personal data on the MobiCom OneClubNet Software, you may be given options to restrict our use of your personal data. You may access certain areas of our MobiCom OneClubNet Software without providing any personal data at all. However, to use all features and functions available on the MobiCom OneClubNet Software you may be required to submit or allow for the collection of certain data.

HOW WE USE INFORMATION WE COLLECT

We use collected information to make available and to improve our high standard of reliable services. We use such information to: respond to inquiries or service requests and monitor such responses; provide information about and market our products or services to you and/or third parties; resolve problems; identify trends; make suggestions regarding our products; and manage the MobiCom OneClubNet Software and assess its usage.

We may use the name you provide across all of the services we offer and that require an Account. In addition, we may replace past names associated with your Account so that you are represented consistently across all of our services and your connected devices.

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

DISCLOSURE OF INFORMATION

In order to provide specific services which you opt for, such as trip experiences, we may share information across the MobiCom Group in order to provide you with such specific services, and all such information will be governed by this Privacy Policy. We do not sell or rent personally identifiable information to third parties who are not affiliates of MobiCom. With your consent, we may disclose personally identifiable information to appropriate affiliates of MobiCom, including Clubs, Brands and approved service providers, to respond to a request for service or to provide information about available products or services. When you sign up to services provided by our affiliates, we will share personal information only as necessary for the affiliate to provide that service.

We may share non-personally identifiable information (this is information that is recorded about users so that it no longer reflects or references an individually identifiable user) with certain third parties including marketing partners, national industry organizations, and prospective affiliates. In addition, we reserve the right to disclose aggregate information and personally identifiable information to third parties as required or permitted by law, including national security or law enforcement obligations and applicable law, rule, order, or regulation and when we believe that disclosure is necessary to protect your rights.

THIRD PARTY SITES

This Privacy Policy applies only to your use of the MobiCom OneClubNet Software. The MobiCom OneClubNet Software contains links to third party websites and may redirect you to third party websites ("Third Party Sites"). Third Party Sites are not under the control of MobiCom, and MobiCom is not responsible for such Third-Party Sites, including without limitation the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness thereof, any link contained therein, or any changes or updates thereto. The inclusion or access to Third Party Sites does not imply an endorsement thereof by MobiCom, or of the provider of such content or services, or of any third-party websites. MobiCom reserves the right to terminate any link or linking program at any time. Please be aware that when you enter a third-party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of that site and that we do not accept any responsibility or liability for these policies or for any information that may be collected through these websites or services. We advise you to check the privacy policies of any such websites before providing any data to them.

YOUR RIGHTS

You have certain rights around the use of your data, including the ability to manage the content and information which we can access when you use MobiCom OneClubNet Software. You can view and change your personal data or which data we can access by signing in to your account or by contacting us.

We will respond to your access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

To terminate and/or delete your account, or any specific data that we have access to, you can submit your request by contacting us. We will comply your request within 30 (thirty) days and send you a confirmation email. Please note that when you request to delete your account, we delete all your personal information and personally identifiable data, and we are not able to recover your account or data after that.

Please note: Even after your account is deleted, we may retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.

INTERNATIONAL DATA TRANSFER

We are a global business. Personal data may be stored and processed in any country where we have operations or where we request in services to our affiliates. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

General Data Privacy Regulation (GDPR)

The GDPR took effect on May 25, 2018 and is intended to protect the data of European Union (EU) citizens. If the data that you provide to us, in the course of your use of our site, services or products is governed by GDPR, we will abide by the relevant portions of the regulation. To make any requests related to your GDPR rights, please review the section above on Your Rights.

INFORMATION SECURITY

We regularly review our compliance with our Privacy Policy and data/security safeguards. To make sure your personal information is further secure, we routinely communicate our privacy and security guidelines to all MobiCom employees, affiliates and service providers, and strictly enforce privacy safeguards within the company. In particular, MobiCom shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, MobiCom cannot guarantee the security of information on or transmitted via the Internet.

Revisions of the Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at https://www.oneclubnet.com. If we make a change to this policy that, in our sole discretion, is material, we will notify you via a notification within MobiCom OneClubNet Software or email to the email address associated with your account. By continuing to access or use the services after those changes become effective, you agree to be bound by the revised Privacy Policy.

CONTACT US

To contact us with your questions or comments regarding this policy or the information collection and dissemination practices of the MobiCom OneClubNet Software, please email us at: support@oneclubnet.com.