Effective Date: 22 April, 2022
PROMOBI TECHNOLOGIES PRIVATE LIMITED (CIN: U74900PN2014PTC150210) (Referred to as “ProMobi”, “we”, “us” or “our”) is the sole owner of (i) the domain scalefusion.com, (ii) its associated website(s) (Referred to as “Website(s)”), (iii) its associated software/application “Scalefusion” (Formerly, “MobiLock” & “MobiLock Pro”), (iv) and any of its corporate business entities or affiliates. (Collectively referred to as “Scalefusion”).
ProMobi has established this policy for its User(s) (Referred to as “User(s)”/ “You”/ “Your”/ “Yourself” / “Customer”) since your privacy is important to us and so is being transparent about the information/ data that we collect and process. This policy covers the information/ data that is collected by ProMobi and shared with trusted third-parties when you use any of our Services or interact with us or browse our Websites.
We consider protecting your Personal Information (Defined Below) to be of paramount importance. We never sell your Personal Information and we carry out Processing of your Personal Information in accordance with the EU General Data Protection Regulation (“EU GDPR”) i.e. Regulation (EU) 2016/679, UK General Data Protection Regulation (“UK GDPR”) i.e. Regulation (EU) 2016/679 as it forms part of law of England and Wales, Scotland and Northern Ireland by virtue of Section 3 of the European Union (Withdrawal) Act, 2018 and the Data Protection Act, 2018 (UK) as well as the Laws of India (together “Applicable Law”), as amended, replaced or superseded.
- What is Personal Information?
- “Personal Data” i.e. any information relating to an identified or identifiable natural person (Referred to as “Data Subject”); wherein an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- Information about your use of the Services availed by you from either ProMobi or any third party vendor or service provider;
- Any data/ information uploaded, posted, exhibited, displayed, linked, saved, shared, communicated, updated, downloaded or transmitted by you through the Services, including your search queries and commands;
- Information about your location using methods that include Global Positioning System (GPS), wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers and compasses.
- Collection of Information
- What information we collect about you?
- We collect information about you when you provide it to us by either signing up for our Services (or) when you directly contact us requesting for our information or expressing your interest in one of our Services by subscribing to our marketing emails.
- Under most circumstances and unless ProMobi is required by law, the types of sensitive data listed below are never collected and/or processed by ProMobi:
- Race or ethnic origin;
- Political opinions;
- Religious or philosophical beliefs;
- Trade union/ any association memberships;
- Genetic or biometric data;
- Health or mortality;
- Sexual preferences or orientation;
- Information that you provide to us: We collect your name, email address and phone number when you sign up to use any of our Services (or) when you use contact form / contact email to request information from us (or) when you fill-in the contact form to be notified about upcoming features of our Services as and when we launch them.
- Payment Information: When you purchase a paid subscription plan for one of our Services, we ask you for billing contact details, including the organization name, address and phone number. ProMobi also collects transaction information which may include an unique identifier of your debit and/or credit card information (not your full card details see https://stripe.com/docs/security/guide) and other payment related information.
- Information we collect automatically when you use the Services
- When you use any of our Services, we collect the information as detailed in https://scalefusion.com/security/data-collections.
- Some of the cookies Scalefusion commonly uses are listed below. This list is not exhaustive, but it is intended to illustrate the primary purposes for which Scalefusion typically generates cookies. A visit to a page on Scalefusion may generate any or all of the following types of cookies:
lang: Language cookie (essential)
_scalefusion_*_session: Scalefusion session cookie (essential)
intercom-*: Intercom live chat session (essential)
- In addition to the cookies Scalefusion sets when you visit its pages, third parties can also set cookies when you visit and/or access Scalefusion. For example:
- Corporate entities and/or affiliates of ProMobi [such as respective service agents, web hosting providers, mail and E-mail service providers, communication services and web analytic providers that facilitate ProMobi in providing certain functions and/or providing the Services] may place cookies when you visit Scalefusion, including but not limited to the Trusted Third Party Entities mentioned herein below;
- Companies that deliver content on the Services may also place cookies on their own. These corporate entities use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across websites, apps or online services.
- What information we collect about you?
- Trusted Third-party tools we use
- We use third-party analytics services to help understand your usage of our Services. In particular, we provide a limited amount of your information (such as sign-up date and some Personal Information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our Website or use our Services. As a data processor acting on our behalf, Intercom analyzes your use of our Website and/or Services and tracks our relationship by way of cookies and similar technologies so that we can improve our Services being provided to you.
- We may also use Intercom as a medium for communications, either through email, or through messages within our Services. As part of our service agreement, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience.
- For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy.
- Intercom’s visitor data is automatically deleted after 9 months from the last incidence of you visiting our Websites.
- Lucky Orange
- We use Lucky Orange in order to better understand our Users’ needs and to optimize the service and their experience. Lucky Orange is a technology service that helps us better understand our user’s experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.), in turn enabling us to build and maintain our Services in accordance with user feedback.
- You can opt-out from (i) creation of a user profile; (ii) Lucky Orange’s storing of data about your usage of our Website; and (iii) Lucky Orange’s use of tracking cookies on other websites, by following this opt-out link.
- Microsoft Clarity
- ProMobi Companies: We share information we have about you with other ProMobi corporate entities or affiliates in order to operate and improve our Services and to offer other ProMobi affiliated services to you.
- With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties.
- Communication with you:
- You shall be entitled to unsubscribe or opt-out from some of these emails from your account’s notification settings or by contacting our Support team.
- The following email communication types can be opted-out:
- All types of Marketing emails;
- Updates in Services or emails pertaining to new releases.
- The following are transactional emails that are necessary in order to provide effective Services and to fulfil our service commitment to you:
- Updates in Terms of Service. (Changes in Terms of Service may impact your usage of the Services)
- Payment complete or failure notification. (You have the right to receive the invoice or confirmation of your payment. In case of failure, our Support team may get in touch with you)
- Subscription expiry and account health. (These two types of emails are necessary for you to effectively use the Service)
- Notification of a data breach. (We are required by Applicable Law to inform you, in case an event of data breach happens in future)
- Your Data & Rights
- You have certain choices available to you when it comes to your information that is stored with us. Below is a summary of those choices, how to exercise them and any limitations.
- You have the right to request a copy of your information in electronic format or object to our use of your information (including for marketing purposes) or request removal of your account and all associated data. Below we describe the processes and tools which you can use to do so, where your account is managed by your employer or an administrator, you may need to contact your administrator to assist you in your request.
- Should you request to receive a copy of your information, we will provide you an electronic file that contains your basic account information and the information that you created which are under your sole control on (i) Scalefusion Enterprise Store i.e. app bundles. (ii) All files in Scalefusion Content Management (iii) All wallpaper images in Scalefusion Branding; (iv) All allowed/ blocked list of websites; and (v) all location data from all of your devices.
- Your choices or requests may be limited in certain cases, for example, deletion of your information which we or your administrator or your employer are permitted by Applicable Law to keep or have compelling legitimate interest to keep; or when your data is shared with third-parties, then you will be required to contact those third-party service providers to delete or restrict your information.
- ProMobi enables you to access and modify certain information about you, which you can access or modify by logging into the dashboard and your user profile.
- You may opt-out from receiving promotional email communications from us while signing up or using the ‘unsubscribe’ link from the emails received from us. You can also change your notification preferences from your user account notification settings in Scalefusion.
- You may be able to opt out of receiving personalized advertisements from other companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info, http://optout.networkadvertising.org/ and http://www.youronlinechoices.eu.
- You can request for removal of your account and associated data (excluding the information which we are required and/or permitted by Applicable Law to retain), you can login to your Scalefusion dashboard and request deletion of your account from your profile settings. The invoices or previous payment information will not be removed, as we need to retain such information for accounting purpose.
- In some circumstances, you have the right to request for erasure of your information without undue delay, i.e.
- when your Personal Information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- when you intend to withdraw your consent to consent-based processing;
- when you object to processing of your Personal Information under certain provisions of Applicable Law;
- when the processing of your Personal Information is for direct marketing purposes; and
- when your Personal Information has been unlawfully processed.
- Data Portability is the ability to obtain some of your information in a format that you can move from one service provider to another. In the industry where we operate, there is no particular standard for data-portability yet, hence this applies to some of your information, but not to all of your information.
- There may be certain exceptions to your rights as contemplated herein, including but not limited to where processing of Personal Information is necessary for compliance with any legal obligation or for the establishment, exercise or defense of legal claims.
- Furthermore, ProMobi wishes to keep its Users advised that ProMobi may acquire such deleted/ erased/ removed data from various legitimate sources and such contact details may be purchased and added back into its database which may, therefore, mean that you could be contacted in a future marketing campaign.
- Data Security & Permissions
- We use appropriate technical and organizational safeguards to protect your Personal Information, taking into account the nature of the Personal Information and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your Personal Information secure. For more information, visit our Security Practices here.
- Please visit our App Permissions page to know more about the permissions asked by Scalefusion.
- Notice to End Users
- Please take note that the administrators are able to:
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services;
- access information in and about your account;
- access or retain information stored as part of your account;
- install or uninstall third-party apps or other integrations.
- In some cases, administrators can also:
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information.
- Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified by us on the happening of such an event.
- If you do not want an administrator to be able to assert control over your account or use of the Services, use your personal email address to register for or access the Services. If an administrator has not already asserted control over your account or access to the Services, you can update the email address associated with your account through your account settings in your profile. Once an administrator asserts control over your account or use of the Services, you will no longer be able to change the email address associated with your account without administrator approval.
- Please contact your organization or refer to your administrator’s organizational policies for more information.
- Policy towards minors or children
Where we process your information based on consent, we will ask for your explicit consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your information prior to such withdrawal. Where we rely on a contract, we will ask that you agree to the processing of information that is necessary for entering into or performance of your contract with us. We will rely on legitimate interests as a basis for data processing where the processing of your information is not overridden by your interests or fundamental rights and freedoms.
If we share your Personal Information with third parties as contemplated herein, we ensure that such third parties provide an adequate level of protection and in accordance with the requirements of Applicable Law.
- When formal written complaints are received by ProMobi, it is the policy of ProMobi to assist the complaining User regarding his/her/their concerns. ProMobi will co-operate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between ProMobi and an individual.
- Contact Details
Your information is controlled by ProMobi Technologies Pvt. Ltd. If you have questions or concerns about how your information is handled, please send your inquiry to ProMobi Technologies Pvt. Ltd.
ProMobi Technologies Pvt Ltd
101-B, Gamma 1, Giga Space IT Park,
Viman Nagar, Pune, 411014,
Scalefusion Support: support[at]scalefusion.com
GDPR Questions & Comments: dpo[at]scalefusion.com
Data Requests: support[at]scalefusion.com
ProMobi Legal: legal[at]scalefusion.com
Phone (USA): +1-415-650-4500
Phone (UK): +44-7520-641664