Privacy Policy

Route Mobile Limited and its subsidiaries (“Route Mobile,” “we,” “our,” or “us”) are committed to protecting the privacy and security of your personal data. We encourage you to read this Privacy Policy (“Policy”) carefully to understand how, where, and why we process your personal data when you use our website https://routemobile.com/, (“Website”), services, or other digital platforms.

In this Privacy Notice, the words “you” and “your” refer to the individual interacting with Route Mobile (“Customer”), as well as our Customer’s end user.

1. Purpose

This Policy outlines the way in which we process your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws and regulations.

2. Applicability

This Policy applies to individuals visiting our website, using our services, or otherwise engaging with our digital platforms. It describes the information we collect, how we process it, and your rights regarding your personal data.

3. Information We May Process (“Personal Data”)

3.1. We may collect various types of personal data, including your email address, demographic information (e.g., country, postcode), first name/last name, job title, mobile number, social media profile, preferences, and interests. Additionally, we may capture usage metrics when you interact with our website, such as cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage history, MAC address, mobile unique device ID, and other similar data.

3.2. Personal Data we receive from third party sources such as aggregators of telecoms data:

3.2.1. Telco Data: Information to assess the risk profile of a phone number such as the phone type (e.g. mobile, landline, VoIP, pre-paid, premium number), active status, current and previous carriers, call forwarding settings, contract and account type, SIM swap history, porting history and the city/country where the phone number was initially registered. We also receive confirmation about whether Personal Data provided by the Customer matches with the Personal Data held by the phone carrier.

3.2.2. Aggregator Data: Information which supplements or confirms the data already held by the Customer such as name, address, email address, date of birth and (in certain limited countries, where permitted) national identification numbers.

3.2.3. IP Data: City/country where the IP address is located

3.2.4. End User identifiers: Date of birth and confirmation of whether the person to whom the phone number is registered is aged 18 or over, and the national ID number.

3.3. Personal Data inferred by Route Mobile:

3.3.1. Services Data: Risk scores based on telephone number or SIM card behavior, data intelligence and the reasons why (e.g. “call center-like activity” or “VoIP number”)

3.3.2. Log Data: Records about how we provide our services to our Customers, such as the date, time and phone number of an SMS is sent as well as the sent status of the message and error codes.

4. How We may collect the Personal Data:

4.1. Information Provided

The information we collect includes your name, title, company or organization name, information contained in your resume / work profiles submitted to us, work e-mail, work phone, work or home address, and information about your job function / company. We may also collect the following information:

(a) information about your use of this Website;
(b) information that you provide using for the purpose of registering with the Website and / or providing any feedback (including your personal details, email address, user name, password);
(c) information about your preferences pertaining to this Website;
(d) geographic information such as location and pin code;
(e) information that you provide for the purpose of subscribing to the Website’s services; and
(f) any other information that you voluntarily send to Route Mobile.

4.2. Information from Social Networking Sites

Our Website might contain features enabling you to connect with social networking platforms. By connecting to these platforms through our Website, you grant us permission to retrieve, utilize, and retain the information allowed by your settings on such social networking sites. We will handle this information in line with our Privacy Notice. If you wish to withdraw our access to this information, you can do so anytime by adjusting the relevant settings within your account settings on the respective social networking sites.

4.3. Information Automatically Collected

a) We collect information pertaining to system requirements to enhance the services offered on our Website, including information such as your internet protocol (IP) address, browser type, referring/exit pages, and operating system.
b) We also compile summarized data about visitors accessing the Website, encompassing viewed pages, clicked links, and other actions related to the Website and services provided. Additionally, specific information is collected from your browser, such as IP address, browser type and language, access times, and the Uniform Resource Locator (URL) of the referring website. This information aids in improving the content of our Website. It’s important to note that we do not utilize this information to track individual visitor activities.

4.4. Automated Decision Making and Profiling

Unless otherwise required under applicable laws, we do not use your information for the purposes of automated decision-making.

5. Legal Basis for Processing Personal Data

We process your personal data based on various legal grounds, including your consent, the performance of a contract, our legitimate interests, or compliance with legal obligations. Our primary purposes for processing your personal data are marketing, sales, and promotion of services we provide or that are procured using our services, as well as improving and enhancing the range of those services and offerings.

6. Use of Personal Data

We use your personal data for several purposes, including:

Website

Purpose/Activity Personal Data Lawful basis for processing including basis of legitimate interest
To process and deliver your order including:
1. Manage payments, fees and charges
2. Collect and recover money owed to us
Contact Information • Necessary for our legitimate interests (to be paid and recover debts due to us)
To manage our relationship with you which will include:
1. Notifying you about changes to our terms or privacy policy
2. Asking you to leave a review or take a survey
Contact Information Product Information Marketing and Contact Preferences • Necessary to comply with a legal obligation such as under data protection laws
• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our Websites (including troubleshooting, security, data analysis, testing, system maintenance, support, reporting and hosting of data) Contact Information Self-service account registration data online identifiers • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, for login authentication purposes, to prevent fraud and for improvement of other Route Mobile services, including Intelligence services, and in the context of a business reorganization or group restructuring exercise)
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Online Identifiers Product Information Marketing and Contact Preferences • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
• Where required, with your consent
To contact customers and prospective customers about products, services, sector developments and events we think may be of interest to you Contact Information Product Information Marketing and Contact Preferences • If required by marketing laws, we seek consent before sending marketing materials to individuals and in such cases consent is our lawful basis for sending marketing to you
• Where consent is not required, to send marketing materials based on our legitimate interest (to grow our business)

Services

Purpose/Activity Personal Data Lawful basis for processing including basis of legitimate interest
To provide the services to our Customers such as
1. to ensure that messages sent on behalf of Customers are correctly routed
2. to select and consolidate third party data sources to deliver accurate data to Customers and
3. to provide data intelligence and/or fraud risk assessment to our Customers.
Customer Data
Telco Data
Aggregator Data
Services Data
• Necessary for our legitimate interests (to grow our business) for those of our Customers (to detect and prevent fraud) and for those of our Customer’s end users (to enjoy a safe and efficient online experience)
To manage billing queries of Customers Log Data
Customer Data
• Necessary for our legitimate interests (to correctly bill our Customers)
To filter and block messages in accordance with Route Mobile’s policies, legal obligations and arrangements with carriers Customer Data • Necessary for our legitimate interests (to maintain a working relationship with carriers who deliver messages on behalf of our Customers)
• Necessary to comply with a legal obligation
To comply with legal and auditing requirements Log Data
Customer Data
• Necessary to comply with a legal obligation
To resolve bugs and errors and for general improvement of our models and Products Customer Data
Log Data
• Necessary for our legitimate interests and those of our Customers (to provide a quality service to our Customers)
To protect our business and the services (including troubleshooting, security and system maintenance) and to detect violations of Customer agreements Log Data
Cutsomer Data
• Necessary for our legitimate interests and those of our Customers (to protect the services, our business and our Customers)
• Necessary to comply with a legal obligation such as maintaining appropriate technical and organizational security measures under data protection law
To resolve common issues affecting multiple Customers. Support Data • Necessary for our legitimate interests and those of our Customers (to provide a quality service to our Customers)

A summary of how We use your Personal Data:

6.1. To provide and maintain our services and to monitor and analyze their usage.

6.2. To communicate with you regarding our services, promotions, or updates. We may use your information to send you promotional communications via email, WhatsApp, and RCS channels.

6.3. To personalize and improve your experience on our website and digital platforms.

6.4. To conduct market research and analysis to develop and enhance our product and service offerings.

6.5. To comply with legal obligations and to protect our rights and interests.

7. Cookies

Our website uses cookies, which are small text files stored on your device, to collect information and improve our services. You can accept or reject cookies by adjusting your browser settings. Please note that disabling cookies may affect your experience on our website and limit the functionality of certain features. For more information on managing cookies, refer to our Cookie Policy.

8. Transferring Your Personal Data

As a global business, we may transfer your personal data to servers, entities, and partners located outside the European Economic Area (EEA) or to other trusted third parties based in other countries for processing on our behalf. We ensure that your personal data receives an adequate level of protection when transferred outside the EEA by executing Intercompany Transfer Agreements containing standard contractual clauses in accordance with EU and data protection laws. We may also transfer your data to third-party service providers and web analytics tool providers, such as Google Analytics and Double Click Cookies. By using our website or services, you consent to the transfer of your personal data in accordance with this Policy and applicable data protection laws and regulations.

9. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, or resolve disputes. The retention period may vary depending on the type of personal data and the specific purpose for which it was processed.

10. Children’s Privacy

Our services are not intended for users under the age of 16. We do not knowingly collect personal data from children under 16 or market to or solicit information from anyone under the age of 16. If we become aware that a person submitting personal data is under 16, we will delete all the information as soon as possible unless it is with the consent and involvement of a parent or guardian. If you believe we might have any information from or about a child under 16, please contact us at privacy@routemobile.com.

11. Security Measures

We have implemented appropriate physical, electronic, procedural, and managerial measures to safeguard your personal data against loss, unauthorized access, misuse, or modification. We require any third parties processing your personal data to implement the same levels of protection. We strive to use commercially acceptable means for protecting your personal data.

12. Changes to the Policy

We reserve the right to update or change this Policy at any time. We will provide you with the updated Policy when we make any substantial updates, either through email or by providing a prominent notice of change on our website. You should check the Policy periodically. Your continued use of our website or services after we post any modifications to the Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Policy.

13. Your Privacy Rights

We respect your legal rights in relation to your personal data. Under the GDPR, you have the right to:

13.1. The Right to Access:

You can confirm whether we are processing your Personal Data, ask to know the specific pieces of Personal Data we have about you, and ask for a copy. You also may have the right to know the categories of Personal Data we have collected, the categories of sources from which we collected Personal Data, the business or commercial purposes for collecting, selling, or sharing Personal Data, and the categories of third parties to whom we disclose Personal Data.

13.2. The Right to Rectification:

If your Personal Data is incorrect or incomplete, you can ask us to update it.

13.3. The Right to Object:

You can object to the processing of your Personal Data. For example, you have a choice about whether or not you wish to receive marketing information from us.

13.4. The Right to Restrict:

You can object to the processing of your Personal Data.

13.5. The Right to Data Portability:

If applicable, you can ask to receive the Personal Data you provided to us in a structured, machine-readable format, commonly used, portable format.

13.6. The Right to Withdraw Consent:

At any time, you can withdraw any consent you previously provided to us. This will not affect any processing we have already carried out based on your past consent.

13.7. The Right to Delete:

You can request to delete or erase your Personal Data and we will honor it to the extent that it is no longer necessary for any services contracted by our Customer or required for our legitimate business purposes, legal or contractual record keeping requirements.

13.8. Right to grievance redressal

Lodge a complaint with a supervisory authority if you believe your data protection rights have been infringed.

If you have any questions, comments, or concerns about this Policy or wish to submit your grievance or exercise any of the above-mentioned rights, you can contact us at privacy@routemobile.com.

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