MMS Ltd. (“MMS”,“we”, “us”, “our”) is committed to maintaining customer privacy through an ethical performance culture that is based on trust, simplicity and confidence. It is one of our core principles to secure customer information while using our Web sites and our Mobile applications (“products”), and provide privacy protection that is critical in maintaining trust and providing better services. MMS´s individual privacy protection policy ensures the confidentiality of customer information under the defined terms and conditions below. MMS complies with the U.S-E.U. Safe Harbor framework and the with respect to the collection, use, retention and transfer to the United States of personal data from customers in European Union member countries (“European Customer Information”). To learn more about the Safe Harbor program, please visit https://www.export.gov/safeharbor_eu/.

1 Effective date and update

Effective date of this privacy policy: 2013/05/01
Revised : 2017/08/18 – Added sections to detail privacy policy with our antivirus products
Revised : 2020/03/01 Guardy service added.

Specific to antivirus Products: MYAndroid Protection, Tele2 Security Package, One Call Sikkerhetsapp and SecurityWarrior Antivirus

Data we collect
We use data to improve our products and services; provide support; send notifications, offers, and promotions. We’ve included below the data elements we think are important for you to know that we may collect, and how we use them, as well as key things we don’t collect that we think may be of interest to you.

Data we DO NOT collect
We only collect the data stated in the previous version, none other. Rest assured that we do not collect the following type of data:

Data we SHARE

Except in limited circumstances described in our full privacy policy, MYMobileSecurity Antivirus products do NOT share any data that can be used to personally identify you. We do use and share non-personal data to improve our products and services; provide support; send notifications, offers, and promotions;

We DO NOT share your personal data with

App permissions and their purpose

The list of permissions required by our Antivirus Products to work are listed below, along an explanation that details which feature of our app makes use of them

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior inside the app

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out

Google Analytics for Firebase (Google Inc.)
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google’s use of Data, consult Google’s partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
This Application uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: USA – Privacy Policy

Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy

Generic data treatment with insight on child related data (family protection/guardy)

2 Information we will collect and trace

2.1 MMS’s official websites may be accessed anonymously. However, the use of our products and services as well as certain activities such as payment transactions, surveys, and forum communications will require customer information input and customer consent. This information may include: name, address, telephone number, as well as the brand name and model of the user’s mobile phone. When using our parental control mobile application we will collect a parent’s email address, password and a child’s name or display name as well as their age range and a parents mobile number. Some examples may include:

2.1.1 If you submit an order online or use our products and services, the required information will be collected, including but not limited to yours or your child’s MMS UID, the number, brand and model of yours or your child’s mobile phone as well as your credit card number.

2.1.2 If you ask for online technical support, certain required information will be collected, including but not limited to your name and address, the information relating to the hardware and software of your mobile phone as well as the specific problems you have encountered.

2.1.3 MMS’s products and services may at times need to access the internet (fees incurred thereby are charged by the local carrier) in a variety of circumstances, including without limitation to:

  1. a) Connect to the server to register for services;
  2. b) connect to cloud security platform to get basic data needed for anti-virus, anti-annoyance and other services to improve the quality of security service, ensure the MMS product in your phone can protect you against the latest threats and reject the latest annoyance calls, etc;
  3. c) Detect user type to ensure smooth provisioning of Pro Member services and non-Pro Member services;
  4. d) Inquire about version update of product or service to ensure timeliness of the product or service;
  5. e) Connect to the server to synchronize events information to ensure better services from SmartCalendar; or
  1. f) Provide other services.

2.1.4 To provide comprehensive security services for you to monitor and protect you or your child’s phone usage or read yours or your child’s location information, the products and services we provide may read private information concerning your phone and your using of the phone, including without limitation: SMS, MMS, Email, Contacts, call log, call conversation, location information, the phone number, the IMSI, the IMEI, the ICCID, the ESN and the model of the phone, the software that is installed and apps that are running in the phone, and information about analytics on your operation, your favorites, network connection and downloading, which is unique and may contain yours or your child’s personal information. If you no longer wish to allow us to read or collect yours or your child’s location information you may turn this off at the device level or turn it off through the settings within the application or on the web portal.

2.1.5 MMS may also read the device identifier of yours or your child’s phone in a variety of circumstances, including without limitation:

  1. a) When you activate the products or services or register;
  2. b) When you subscribe to our products or services;
  3. c) When you or your child connect to the server with the products or services to update virus protection or anti-spam policy;
  4. d) Providing targeted and customized security service according to your country or region;
  5. e) When you use the locate service of anti-lost to track the location of your phone; or
  6. f) According to other needs to provide services to the user or the needs to customize services for the user.

2.1.6 MMS may read your or your child’s SMS/MMS in a variety of circumstances, including without limitation:

  1. a) Scan websites and attachments in the messages to ensure no malicious website or virus is contained;
  2. b) Block spam messages;
  3. c) Filter private messages;
  4. d) Block fee-deduction SMS sent by apps to prevent malicious fee deduction;
  5. e) When you use SMS to recommend the product;
  6. f) SMS report for SIM change in anti-lost service, remote control report and alert, etc; or
  7. g) When you report suspicious spam messages to MMS; h) when you wish to view who your child talks to and allow or deny that user;
  8. i) When you want to view the photos your child has uploaded to their device.

2.1.7 MMS may access your or your child’s contacts in a variety of circumstances, including without limitation:

  1. a) When you use the contacts backup service;
  2. b) When you use our products and services to group and manage contacts; or
  3. c) When you recommend the product or when you select import contacts as product/service requires you to input the phone number;

d)when you want to view the contacts your child has on their device and choose to either allow them to continue to communicate with them or block that contact.

2.2 Prior to requesting information from you on our websites, we will define the purposes for which such information is to be used. You, the customer, may then choose whether or not to proceed with the transaction and use our products and services and provide the appropriate information. If you prefer not to provide the required information, then the transaction shall be canceled.

2.3 For the information we may collect from you or your child while using our products or services in the circumstances listed above or beyond, yours and your child’s personal information collected in such circumstances will be kept confidential and shall not be used for illegal purposes, or copied, used or provided to any third party illegally, or accessed by our staff.

2.4 A child’s participation or access to an activity cannot be conditioned on him or her providing more Personal Information than is reasonably necessary for that activity.

3 The purpose of collecting information functions:

3.1 We expect to use your personal information for the following purposes.

3.1.1 To provide you with information related to virus warnings, product upgrades, customer service, newsletters, and email updates, and to further increase our customer feedback for our future products and to better receive your suggestions for the improvement of our products and services.

3.1.2 To help us create content relevant to you;

3.1.3 To provide you with additional information that is tailored to your specific needs or interests;

3.1.4 To help us provide better products and services to exceed customer expectations;

3.1.5 To enable you to purchase and download our products, access our services or participate in the activities you select;

3.1.6 To help you to quickly find the appropriate software, service or product information; and

3.1.7 To provide updated, comprehensive security services for you.

3.2 To allow copartners of MMS to use the information you provide. We will request these copartners to guarantee the security of customers’ personal information and keep this information confidential. Copartners may only use information provided by our customers when they are working on behalf of MMS.

3.3 To allow parents to keep track of their child’s location, messages, call history, applications and photos.

3.4 To limit when your child can unlock their phone, make phone calls, use the web and text.

3.5 To protect your child against bad influences by blocking calls, and messages to and from contacts that you add to the block list.

3.6 To allow you to have your child check in, which helps your child let you know where they are at the tap of a button.

3.7 To allow us to access your call logs, contacts, photos and videos in order to prevent eavesdropping, encrypt photos, videos, SMS, calls, keep contacts private, send private Facebook messages, view your account through your online account, block numbers from calling you or sending you text messages, and back up your contacts, as you may request.

4 The principle for limiting utilization and sharing. We do not sell your personal information to third parties. We will not share your or your child’s information with third parties other than the necessary service providers as indicated below.

4.1 Limiting utilization may occur in the following circumstances;

4.1.1 With customers’ written consent;

4.1.2 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;

4.1.3 To prevent the rights and interests of others from material detriments;

4.1.4 To promote public interests without damaging your vital interests;

4.1.5 To comply with laws or regulations, such as to comply with a subpoena, or similar legal process;

4.1.6 We may provide your or your child’s personal information to companies that provide services to help us with our business activities such as processing your payments, providing mapping services or offering customer service. These companies are authorized to use your and your child’s personal information only as necessary to provide these services to us;

4.1.7 If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

5 Recommend this website to your friends

5.1 If you select to use our products and services, we recommended that you refer our website and products and services to a friend for the better protection of his or her mobile devices. This may be done simply by giving us your friend’s name or email. We will automatically send a one-time email to your friend to invite him/her to access our website, and store his/her emails for the sole purpose of sending this onetime email and tracking the success of our referral program. Your friend may contact us at info@mymobilesecurity.com to request we remove this information from our database.

5.2 MMS complies with international information criterion to protect your personal information. These measures include some technical and programmed steps that can protect your data against misuse, illegal access, disclosure, losing, modification or destruction. We use security socket layer (SSL) to transmit credit card and yours or your child’s geo location information. 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.

5.3 As an international company, MMS provides company information to our local branch offices all over the world to further aid in providing products and services. It is possible that the personal information you submit to us may be transmitted to these other MMS branch offices. For example, the personal information provided by a European customer at the time of product registration may be transmitted to a server in the USA and then transmitted to one or more servers of our branch offices in Europe. Meanwhile, in some countries or regions, our subcontractors may handle your information in the process of helping MMS provide products and services to you and/or in handling information collection, transmission, storage and processing for us.

6 Content of Email

6.1 MMS will not read or disclose to any third party any private email communication information that is transmitted using our products and services, unless given appropriate explicit consent to do so.

7 Log

7.1 We have provided logging functions for emails and other communications transmitted in the process of using MMS products and services. Any user can select to turn his own log record function on or off. MMS will not read or disclose to any third party any users’ private information it records as part of the logging functions without further consent.

8 UID information

8.1 When you use MMS products and services and activate/register them, our system will generate a user ID (UID) for you at random, by which we identify the user and provide the services. We may collect your phone number and associate it with UID and/or any of our other internal tracking tools or service account, such as MMS Account to complete the billing process and provide certain service such as anti-lost remote control.

8.2 MMS respects the request of any user or third party to verify his own UID information, and will correct or allow the correction of any possibly incorrect information. Any user and third party can ascertain whether his information has been appropriately corrected by either email or phone at any time.

9 Cookies and other Tracking Technologies

9.1 Cookie. A cookie is a unique text file our websites send to your explorer software.

9.1.1 Cookies are frequently used on MMS’s websites. This helps customers customize the information based on browsing preferences. We may also use cookies for statistical and/or marketing purposes, to improve our technologies, to provide information about our company and to deliver advertising and promotional information.

9.1.2 Cookies are used to personalize webpages and / or recognize you when you are accessing our websites, in order to conveniently browse and access our websites after having registered for our products, services and/or other support services.

9.1.3 Cookies are also used to trace your access to our websites. We will acquire information in personal, identifiable modes including your IP address. However, such information will merely be used for analysis and will be limited to the use according to the minimum requirement for the execution of such analysis.

9.1.4 If you do not want MMS to transfer Cookies into your web browser, you may change your web browser setting to refuse Cookies or notify you when any website is attempting to this transaction. This refusal shall affect your option to use certain products and/or services provided on our websites.

9.2 Network beacons

9.2.1 Network beacons on our websites and in our products and services analyzes traffic mode, such as the frequency of use on a specific part of the websites. The acquired data will help us learn about the kind of information our customers are most interested in, and what preferential terms our customers are most interested in obtaining. With respect to our websites, if you are unwilling to allow such data collection which help MMS improve our websites, you may refuse such website analysis by disabling JavaScript on your computer. If you disable JavaScript, some functions on our websites may not be able to operate normally.

9.2.2 We can also use network beacons in promotional emails to further determine whether emails have been opened and/or acted upon. We develop more your favorite sales promotional activities according to the information thus provided by email responses. Except for the email address you previously provided, the information collected would not identify you.

9.3 By means of various tracing technologies as mentioned above, we can trace the domain names, IP addresses and the type of explorer used by the users who access our websites and use our products or services. We use such information to trace the traffic modes congregating on the whole MMS website. Such information is independent of any personal information the user may otherwise provide in using MMS’s products and services.

9.4 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 applications.

9.5 We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users 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.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

10 Discussion group/forum/blog/social media

10.1 The information you submit on any discussion group, forum, or blog will be regarded as public information instead of confidential information. The information released in these areas are at risk of being collected and used by others. Please be cautious and responsible when submitting information when you are online. To request removal of your personal information from our blog or community forum, contact us at info@mymobilesecurity.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.

10.2 Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

11 Third party website

11.1 On the websites and within the mobile applications of MMS, there are many links to other companies or mobile applications, which have established cooperative relationships with us. MMS assumes no responsibility for the privacy criteria adopted by our commercial copartners. We recommend that you read their privacy policies, which may involve different contents.

11.2 We are also linked to joint websites that are maintained by MMS in coordination with one or more of our commercial copartners. When you are submitting information to one of our joint websites, it is possible that you are submitting such information to both MMS and our commercial copartners, but the privacy policy adopted by the joint websites may be different from this privacy policy of MMS. Therefore, we recommend that you read the privacy policy on any linked joint websites, so as to obtain the most complete information regarding the privacy criteria of such websites.

12 Disclaimers

12.1 In case any competent government authority requests us to disclose any personal user identification information in accordance with relevant legal procedures, laws or regulations, we will provide such personal user information according to the requirements of the government authority or for the purpose of public safety. MMS will assume no liability for any disclosure in such case.

12.2 MMS will not assume any responsibility for any of your personal information that is disclosed for your own reasons (for example, when you voluntarily disclose to other people your password or when you share your account with other people).

12.3 MMS assumes no responsibility for any personal information that is lost, disclosed, or falsified due to forces beyond MMS’s control, including but not limited to events that may affect normal network operations, such as hacker attack, intrusion or attack of computer virus and temporary closure of websites due to government regulations or actions.

12.4 MMS assumes no responsibility for the disclosure of personal particulars or other customer information caused by (i) the other websites linked with our website or referred to in our website, products or services; (ii) third party software or coding incorporated in our website, products or services; or (iii) the incorporation of any part of our products into the websites, products or services provided by third parties, as well as any legal dispute and consequence resulting from any of (i)-(iii).

12.5 MMS assumes no responsibility when it or a third party uses your personal information in accordance with provisions of relevant laws or regulations or this privacy policy.

12.6 MMS assumes no responsibility when your personal information is disclosed due to unpredictable and inevitable risks of the internet, including without limitation: virus attack, hijacking, temporary site closure or server closure resulted from government control and inevitable technical defects of the software due to technical level at the time of development.

13 Policy modifications

13.1 We 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 email 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. If we make material changes to how we use Personal Information collected from children under age 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child’s Personal Information.

14 Access to Personal Information

14.1 If yours or your child’s personally identifiable information changes, or if you no longer desire our service, you may correct, update, delete inaccuracies or remove it by making the change on our member information page or by emailing us at info@mymobilesecurity.com. We will respond to your request to access within 30 days.

14.2 Parents have the right to access their child’s information, refuse further collection and use, request to have it deleted or request that we no longer have further contact with their child by accessing their child’s account through the Web site or by emailing us at info@mymobilesecurity.com.

14.3 Data Retention: We will retain yours or your child’s information (including geo-location data) for as long as your account is active or as needed to provide services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at info@mymobilesecurity.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

15 Contact us

15.1 We have appointed an executive agent for our privacy protection policy, who will be responsible for MMS’s compliance with the privacy criteria as described in this statement.

15.2 If you have any questions or concerns regarding this policy, would like to modify the communications option, update or refer to your personal information we possess, or withdraw your decision to allow us to collect, use or publish your personal information, please feel free to contact us at any time: info@mymobilesecurity.com