1. General

MOBY X Software Ltd. (hereinafter “MobyX” or “We”) attaches high importance to the protection of the privacy of their users. This privacy policy describes MobyX’s approach to handling personal data and the measures taken to ensure compliance with privacy regulations.

If you provide us with other people’s personal information, please ensure that those people are aware of this privacy notice. Only provide us with their personal information if you are entitled to do so and if the personal information is accurate.

This privacy notice is based on the EU General Data Protection Regulation (GDPR). Although the GDPR is a regulation of the European Union, it is relevant to MobyX. The Republic of Cyprus Data Protection Law is strongly influenced by EU law, and companies outside the European Union or EEA must comply with the GDPR under certain circumstances.

Websites of other providers that can be reached via the MobyX website are not subject to the privacy notice set out here. MobyX assumes no responsibility or liability for the observance of data privacy by third party websites.

2. Responsible Entity

Moby X Software Ltd., a legal entity, duly incorporated under the laws of the Republic of Cyprus with registration number 386967 having its registered address at Anexartisias & Athinwn Street, Nora Court, 2nd floor, office 201-202, 3040, Limassol, Cyprus, is responsible for the data processing described here, unless otherwise stated for specific cases. If you have any questions regarding data privacy, you can send them to us at the following contact address (if possible, please indicate which address you are referring to):  Anexartisias & Athinwn Street, Nora Court, 2nd floor, office 201-202, 3040, Limassol, Cyprus or [email protected].

3. Collection and Processing of Personal Data

We primarily process personal information received from our customers and other business partners in the course of our business relationship with them, or collected from users of our websites, apps and other applications.

To the extent permitted, we also extract certain data from publicly accessible sources (e.g. land register, commercial register, press, internet) or receive such data from other companies. In addition to the data that you provide directly to us, the categories of personal data that we receive about you from third parties include, in particular, information on you from the media and the internet (as far as this is indicated in a specific case, e.g. in the context of a job application, press review, marketing/sales, etc.), your addresses and, if applicable, your personal data. Interests and further sociodemographic data (for marketing purposes) and data in connection with the use of our website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content viewed, functions used, referring website, location information).

4. Purposes of Data Processing and Legal Basis

We use the personal data that we collect primarily to conclude and fulfil our contracts with customers and business partners and to fulfil our legal obligations at home and abroad.

In addition, we process personal data from you and other persons to the extent permitted and deemed appropriate by us, also for the following purposes in which we (and sometimes also third parties) have a legitimate interest corresponding to the purpose:

• Offer and further development of our offers, services and websites, if need be, apps and other platforms on which we are present;
• Communication with third parties and processing of their enquiries (e.g. job applications, media enquiries);
• Reviewing and optimizing procedures for requirements analysis to address customers directly and collecting personal data from publicly available sources for customer acquisition;
• Advertising and marketing (including organization of events), if you have not objected to the use of your data (if we send you, as an existing customer, advertising material you can opt-out at any time);
• Market and opinion research, media monitoring;
• Assertion of legal claims and defence in connection with legal disputes and official proceedings;
• Prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analyses to combat fraud);
• To assure our operations, particularly of our IT, our websites, apps and other platforms;
• Purchase and sale of business units, companies or parts of companies and other transactions under company law and the related transfer of personal data, as well as measures for business management and to the extent necessary to comply with legal and regulatory obligations. If you have given us your consent to process your personal data for certain purposes (for example, when you subscribe to our newsletters), we will process your personal data within the scope of this consent, unless we have another legal basis. Consent given can be revoked at any time, but this has no effect on any data processing that has already taken place.

5. Anonymous Tracking Information

When you visit the MobyX website, the service provider collects, stores and uses general, personal data. So-called “cookies” are used for this purpose. These are text files that are saved on the user’s system and enable an analysis of website usage. This technology makes it possible to recognize individual users as visitors. Users of the MobyX website can prevent the storage of cookies by selecting “do not accept cookies” in their browser settings.

The following personal data is collected when you visit mobyx.co :

• Your IP address;
• Date, time and duration of your visit to our website;
• The referral URL (the website from where the visitor came);
• Pages visited on our website; and
• Information on the device and the browser (e.g., browser type and version, operating system, etc.).

In our newsletters and other marketing e-mails, we may include visible and invisible picture elements, to the extent permitted, that we can use to determine if and when you have opened the e-mail, so that we can measure and better understand how you use our service and tailor it to your needs. You can block this in your email program; most are preset to do so.

By using our websites and consenting to receive newsletters and other marketing emails, you also consent to the use of these techniques. If you do not wish to do so, you must configure your browser or e-mail program accordingly.

We sometimes use Google Analytics or comparable services on our websites. This is a service provided by third parties that may be located in any country of the world (in case of Google Analytics, it is Google LLC in the USA, www.google.com), with which we can measure and evaluate the non-person-related use of the website. Permanent cookies set by the service provider are also used for this purpose. The service provider does not receive any personal data from us (nor do they keep any IP addresses), but can track your use of the website, combine this information with data from other websites that you have visited and that are also tracked by service providers, and use this information for its own purposes (e.g. advertising control). If you have registered with the Service provider yourself, the service provider will also know you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with their own privacy terms. The service provider merely informs us on how our respective website is used (no personal information about you).

We also use plug-ins from social networks such as Linkedin or Twitter on our website. This can be seen in each case (typically via corresponding symbols). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can determine that and where you are on our website and can use this information for their own purposes. Processing of your personal data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.

6. Disclosure of Personal Data to Third Parties

The disclosure of personal data to third parties is excluded, unless required by law or so ordered by a court decision. This does not apply to the passing on of personal data to third parties:

a) for the legal protection of users;

b) to comply with legal requirements;

c) to defend and protect the rights of the supplier;

d) to comply with the terms of use or the privacy notice;

e) to remedy technical problems of the products;

f) for cooperation with service partners requiring the transmission of data for contract fulfilment. In such cases, the transmission of data shall be limited to the minimum necessary for contract fulfilment.

g) for cooperation with the provider’s service partners, providing assistance particularly for marketing.

7. Consent

By agreeing with this privacy notice the user expressly authorizes MobyX to use collected data for analysis purposes.

By registering for the newsletter, the user agrees that MobyX may use the collected personal data for marketing purposes. This particularly includes contacting the user via e-mail. MobyX’s aim is to inform the user in this way about their own products and events, among other things.

8. Data Integrity

We take appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse, such as IT and network security solutions, access control and restrictions, and encryption of data carriers and transmissions.

9.Right to Information, Modification, Revocation, Cancellation and Blocking

Users have at any time and free of charge the right to request information on their personal data stored by MobyX, or to revoke their consent to the processing or storage of their personal data. MobyX commits to delete a user’s personal data within 30 days of receipt of a corresponding request for deletion.

In the event of questions or suggestions regarding MobyX’s privacy notice, requests for information regarding stored personal data or requests for changes, revocation or deletion, the user may contact MobyX’s by post and/or e-mail according to section 2.

10. Final Provisions
11. a) Partial Invalidity
    Should individual provisions of this privacy notice be or become invalid, this shall not affect the validity of the remaining provisions. An invalid provision shall be replaced by a new provision which comes as close as possible to the economic and legal effect of the invalid provision.
12. b) Adjustments
    We may change this privacy terms at any time and without notice. The current version published on our website applies. If the privacy notice is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.