Onavo Mobile Ltd. ("Onavo") ("Onavo", "we", "us") respects your privacy. This policy explains the accepted privacy practices for the mobile data usage reduction services (the "Services"). It describes the ways Onavo collects and uses your personal information and the rights and options available to you with respect to your information.
Onavo Mobile Ltd. complies with the U.S. - Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the Switzerland. Onavo Mobile Ltd. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Onavo Mobile Ltd.’s certification, please visit http://www.export.gov/safeharbor/.
What personally identifiable information do you have to provide Onavo?
When you register to the Services or contact us, you may be asked to provide Onavo an active e-mail address, name, and to select a password. Registration with the Services is free of charge. However, Onavo may change certain free Services to fee-based Services, and request you to provide additional payment and transactions related personal information.
When you download and use our Services, we automatically collect information on the type of device you use, operating system version, mobile carrier and device identifier. We collect this information for the purpose of optimizing your use of our applications.
Please bear in mind that false, incorrect, or outdated information may prevent you from registering or impair Onavo's ability to provide you with the Services and to contact you.
We make it easy for you to share the app with your friends, if you choose to do so we will either open up the email client on your phone or the SMS message feature to allow you to do so. Your friend will be sent a one-time message inviting them to visit the application. We only use this information for the purpose of sending this one-time email and do not store it.
What Internet traffic does Onavo collect?
Onavo provides services for reducing data usage of certain mobile phones. To benefit from the Services and depending on the products you use, your access to the Internet through your mobile phone may be routed through Onavo's servers, which strive to reduce the volume of your downloads, and potentially your uploads as well. We may also collect information regarding your usage of applications and the consumption of data by such applications in order to provide you with detailed information with respect to the data consumption of applications that you use, and recommendations how to decrease such consumption.
When you use the Services and depending on the product you use, Onavo may collect information, such as session durations, page impressions, details of your mobile operator, Internet protocol (IP) addresses, the domain name that served you to access the Services, and content types and origins.
Onavo may also store information related to online data or metadata that is routed through Onavo's servers, such as webpages' addresses, structures, data fields, and images. However, Onavo will not store any content that you upload or download, such as message text, filled-in forms, and data that a website retrieved.
The stored data will be attributed to you in person, only to the extent necessary to provide you the Services, as set in the following chapter. Thereafter, Onavo will anonymize the data and will not knowingly use the data to personally identify you.
Further information may be collected when you and Onavo exchange communications, for example, when you submit an inquiry to the Service’s customer support at: email@example.com
Does Onavo collect location based information?
Onavo does not actively collect any personal information that is based on your geographical location, except for the country that you reside in when accessing the Services (if applicable), including when the Services are not activated, for example to detect that you are abroad and offer you to activate the Services. However, certain location based information may be stored on Onavo's servers, for example if you use the Services to access geographic based services, such as online maps services. Onavo will use such information subject to this policy and will anonymize such data as soon as it is no longer necessary for providing you the Services. We also collect your geo-location information for the purpose of monetizing your phone usage for roaming users. If you no longer wish to allow us to use this information you may turn this off at the device level or deactivate your account. Please note that if you turn off this feature some parts of our service may not work.
What does Onavo do with your personally identifiable information?
Onavo may use personally identifiable information for the following purposes:
•to provide and operate the Services; For example, to provide you with information on the extent of saved data volume, to provide you with support, to help you better understand your Internet use habits and accordingly increase the efficiency of the Services for you, and to provide you with information regarding data consumption of applications that you use. Onavo will retain such data in a manner that is attributable to you for a period of 12 months and will anonymize the data thereafter. Onavo may keep aggregated usage data in a manner attributable to you for as long as required in order to provide you with data usage reporting service.
•if Onavo decides to offer certain Services for a fee, then certain payment and transactions related information will be stored and used. Such data will remain personally identifiable for as long as necessary to provide you the fee-based Services, and any other purpose related to your use of such Services;
•to send you updates and notices and to provide you with information related to the Services; Onavo will not share your e-mail address or any other personally identifiable information with online advertisers and advertising networks, without your explicit consent
•to enforce the Master Subscription Agreement;
•to contact you as and when Onavo believes it to be necessary;
•to comply with any applicable law and assist law enforcement agencies as required, such as to comply with a subpoena, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
•in any case where Onavo believes that the use of the information is necessary to prevent imminent physical harm or damage to property;
•to collect fees and debts, and to prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services;
•to take any action in any case of dispute, or legal proceeding of any kind between you and Onavo, or between you and other users or third parties with respect to, or in relation with the Services
We send you push notifications to your mobile device in order to send you updates about the application, application usage and other important details about your use of the application. If you no longer wish to receive these types of communications you may opt-out at the device level.
Important notice about children's privacy
The Services are not intended for use by persons under the age of 13. If you are not 13 years old or older, then you may not use any of the Services and must not provide any of your personal details. We do not knowingly collect personal information from users under the age of 13.
How does Onavo Share your personally identifiable information with others?
Onavo does not sell, rent or lease your personally identifiable information to third parties. Onavo may share personally identifiable information with others in any of the following instances, or subject to your explicit consent:
•To operate the Services, including to store and process your information through a third party hosting services and to process payments;
•To contact you. For example, Onavo may use a third party's mailing platform to send you messages and updates from time to time;
•If Onavo believes that you have breached the Master Subscription Agreement, or abused your rights to use the Services, or performed any act or omission that Onavo believes to be violating any applicable law, rules, or regulations. Onavo may share your information with law enforcement agencies and other competent authorities as well as with other third parties, as may be required;
•if Onavo is required, or believes that it is required by law to share or disclose your information;
•In any case of dispute, or legal proceeding of any kind between you and Onavo, or between you and other users or third parties with respect to, or in relation with the Services;
•In any case where Onavo believes that sharing information is necessary to prevent imminent physical harm or damage to property;
•If Onavo is involved in a merger or acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;
•Onavo may also share personally identifiable information with companies or organizations connected, or affiliated with Onavo, such as subsidiaries, sister-companies and parent companies.
How does Onavo use aggregated information?
Onavo may also use anonymous, statistical or aggregated information to properly operate the Services, to improve the quality and functionality of the Services, to enhance your experience, to create new services, including customized services, to change or cancel existing content or services and for other internal and statistical purposes.
Onavo may share, sell, publish, post, disseminate, transmit or otherwise communicate or make available such information, to suppliers, business partners, sponsors, affiliates and any other third party, at Onavo's sole discretion, provided however, that Onavo will not knowingly, or intentionally use the information to reveal your identity without your consent.
How can you access your personal information?
If you are registered with the Services, then you may access your personal account and edit or amend your personal information at any time by contacting us at firstname.lastname@example.org. If you find that the information on your personal account is not accurate, complete, you wish to delete inaccuracies or update it, than you may request that we make all necessary changes to correct it. We will respond to your access request within 30 days.
We will retain your information (including geo-location data) for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
What opt-out and deletion options are available to you?
At any time you may opt out of Onavo's services, by sending Onavo a removal request to: firstname.lastname@example.org. It may take up to Thirty (30) business days for your opt-out request to take effect.
If you wish to delete your personally identifiable information that is stored in Onavo's database, you may send a request to delete information to: email@example.com. Onavo will inform you whether it can accept your request. Onavo may refuse your request, for example, if Onavo believes that removal of certain information may jeopardize certain activities of the Services, or harm other users. In any case, Onavo may keep any aggregated or anonymized information for statistical, marketing and other purposes, indefinitely.
How does Onavo secure your personal Information?
Onavo and third parties on its behalf implement information security systems and procedures to secure your personal information. While such systems and procedures reduce the risk of security breaches, they do not provide absolute security. Therefore, Onavo cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or unauthorized access to the information stored therein and to other information security risks, or that your private communications on or through the Services will remain private. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
We restrict access to personal information you provided Onavo to our employees, contractors, vendors and agents who need to know that information for the purposes described in this policy. These individuals are obligated to keep your personal information confidential and they may be subject to penalties, termination of relations and criminal prosecution, if they fail to comply with such obligations.
When we collect sensitive information (such as geo-location data) within our mobile applications, we encrypt the transmission of that information using secure socket layer technology (SSL).
Some of the cookies may expire when the session ends and you exit your browser. Other cookies may be stored on your computer’s hard drive. If you wish to block the cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Services, or certain features thereof.
Clear Gifs (Web Beacons/Web Bugs)
Our third party tracking utility partner employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile app.
Where is my personal information processed?
Onavo stores and processes the information through a third party's hosting services in the USA. If you are in the European Economic Area, or in any other jurisdiction that regulates the transfer of personal information outside that jurisdiction, then you hereby grant Onavo your explicit and unambiguous consent to transfer your personal information to the USA, for the purposes described in this policy.
What about Links to Third Party sites or apps?
Our Web site and mobile applications contains links to other sites or mobile applications that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites or applications.
We encourage you to be aware that when you leave our site or mobile applications and to read the privacy policies of each and every Web site and mobile application that collects personal information.
Onavo is doing its utmost to comply with this Policy. If you have any questions, concerns or complaints regarding this policy and the enforcement thereof, please refer them to: firstname.lastname@example.org. After receiving your complaint, Onavo may contact you to better understand your concerns and will make all efforts to promptly answer your question, or resolve your complaint to your full satisfaction.
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Social Media (Features) and Widgets
Onavo may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Last Updated: July 24, 2012