Last Updated: December 23, 2020
FOR END USERS
How we collect and use information from the End Users
How long do we retain information collected from End Users?
We will retain personal data we process on behalf of our App Providers for as long as needed to provide services to our App Providers. We will also retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. An End User who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to our App Providers. If requested by App Providers to remove or access data, we will respond within 30 days.
App Providers are able to send you, the End Users, push notifications, thought In-apps or email communications through the MoEngage Service.
An End User who seeks to opt-out must direct their query to their App Providers. The App Providers may then request us to opt-out the said End User, which we shall do so within 30 days. Alternatively, the End User may contact us directly, by sending opt-out requests to email@example.com.
FOR APP PROVIDERS
Why do we collect information from App Providers?
We collect and use information from App Providers to provide our Service, to improve our Service, and to administer your Account, and to personalize End User experience.
When you, as an App Provider, create an Account or when you request information about the MoEngage Service, we’ll collect certain information that can be used to identify you, such as your name and email address (“PII”). We may also collect information that cannot be used to identify you, such as Account preferences.
Modifying and Deleting Your Information
You can access and modify the PII associated with your Account by accessing the user settings in the MoEngage Service. MoEngage acknowledges that EU individuals have the right to access and delete the personal information that we maintain about them. If you want us to delete your PII and your Account, please contact us at firstname.lastname@example.org with your request. We will respond to your request to access within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
FOR END USERS AND APP PROVIDERS
Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason you can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:
Information Related to Use of The Platform
We gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
Information Shared with our Subsidiaries
Information Shared with our Service Providers
Information Shared with Third Parties
We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes. We will not share the End User PII collected for one App Provider with third parties.
Information Disclosed for our Protection and the Protection of Others
It is our policy to protect App Providers and End Users from having their privacy violated through abuse of the legal systems, whether by individuals, entities or government and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about App Providers or End Users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary:
We take reasonable measures to protect the information that we collect from or receive from App Providers or End Users (including PII) from unauthorized access, use or disclosure. When you enter sensitive information (such as login credentials) on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL). Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) via email or conspicuous posting on our Platform in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Links to Other Sites
Social Media Features
Our Policy Toward Children
Our Service is not directed to children under the age of 13. MoEngage users must not be under the age of 13. We do not target any portion of our service to children under the age of 13, and we will delete any accounts or data of users that we believe to be under the age of 13 to be in compliance with the Children’s Online Privacy Protection Act. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at email@example.com.
California Privacy Rights.
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact MoEngage via email at firstname.lastname@example.org.
Additional Information for European Union Users
All references to “Personal Information”, “Personally Identifiable Information” or “Personal data” are equivalent to the definition of “personal data” under GDPR.
MoEngage as a Data Controller
For App Providers and visitors of the MoEngage website, MoEngage Inc. is the controller of your personal information for purposes of European data protection legislation.
MoEngage as a Data Processor
MoEngage processes the personal data of end users on behalf of the App Providers and acts as a Data Processor on behalf of App Providers, who act as Data Controller
Data Protection Officer
Our Data Protection Officer can be reached at email@example.com.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold -
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Additional Information for California Users
“Personal Information” for the purpose of this section has the meaning given to this term in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information specifically excluded from within the scope of the CCPA.
Collection of Personal Information: Depending on your use / interaction with us, we may collect the following categories of Personal Information from you:
|Statutory Category of Personal Information Collected||Nature of the Personal Information Collected||Purpose for Collection||Source|
|Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Data about what an individual has purchased from MoEngage (including tickets to MoEngage-sponsored events)|
· Data about what an individual has downloaded from the MoEngage Website
|Register for, attend and/or otherwise take part in our events webinars or contests|
|Identifiers. Real name, alias, postal address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.||Use our Services as an authorized user |
Receive communications from us
Responding to your requests for support or information;
|Inferences. The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.||Enabling us to understand who is interested in learning about our products, services, content, and company-related initiatives;|
|Online Identifiers. An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol (IP) address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology||Analyzing overall trends on our Website to help us to provide and improve our Website and to ensure its security and continued proper functioning;|
|Professional or Employment Information. information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations)||Sending messages to the users of our Services with respect to technical alerts, updates, security notifications, and educational and administrative communications|
|Audio, electronic, visual, thermal, olfactory, or similar information.||Audio and video recordings.|
|Protected Classification Characteristics. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||We do not intentionally collect this data, but certain characteristics may be revealed in identity data or other information we collect.|
We do not sell your Personal Information in any form. We do, however, use the Personal Information shared by you for the purpose of internet based targeted advertising of our own services. We do not offer any financial incentive programs to our users.
SHARING AND DISCLOSURE OF INFORMATION TO THIRD PARTIES
We may share and disclose Personal Data to the following types of third parties and for the following purposes:
- To customers – We may disclose information to our customers in the form of aggregated, anonymous data about the way the Services have been used to enable us to provide and improve our Services, to provide strategic advice to our customers, and to further and enhance our role as a thought leader in the industry;
- To vendors, consultants and other service providers - We may disclose information to third-party vendors, consultants and other service providers in connection with our marketing efforts, or in connection with our general business purposes;
- To comply with laws - We may disclose information to a third party where we are legally required to do so in order to comply with any applicable law, regulation, legal process or governmental request;
- To protect our legal rights - We may also disclose information where we believe it necessary in order to protect or exercise, establish or defend our legal rights;
- Business transfers - We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company;
- To provide our Services - We use sub-processors in our provision of the MoEngage Services to our customers, such as third-party hosting providers and third-party database support services. Some of these third-party sub-processors may have logical access to data about you, but in all cases, any subprocessor to whom we disclose any information will be subject to a written agreement containing confidentiality protections designed to protect any Personal Data that is shared with them;
- To advisors - In individual instances, we may share Personal Data with professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in countries in which we operate, who provide consultancy, banking, legal, insurance and accounting services, but only to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
- To affiliates - We may share Personal Data with affiliates within the MoEngage group and companies that we may acquire in the future when they are made part of the MoEngage group, to the extent such sharing of data is necessary to fulfill a request you have submitted via our Website or for customer support, marketing, technical operations or account management purposes; and
- Publicly shared data - Any Personal Data or other information you choose to submit in communities, forums, blogs or chat rooms on our Website may be read, collected and used by others who visit these forums, depending on your account settings.
Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third-parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Non-discrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services, increasing the price/rate of services, decreasing service quality, or suggesting that we may penalize you as described above for exercising your rights.
Exercising your Rights: You can request to exercise your information, access and deletion rights by writing to firstname.lastname@example.org. We will need to confirm your identity and California residency to process your information, access or deletion requests, and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Response Timing: We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) additional days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
International Data Transfers:
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation: