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| 1. | | RESPONSIBILITY FOR THE PROCESSING OF YOUR DATA | | |
| 1.1 | | This Privacy Policy describes how we collect, use, and share your personal data when you use our mobile applications, our websites and social media accounts, as well as our customer dashboard and other services we make available to our customers ("our services" or "Mastdata services") and how we use personal data collected in the course of operating and administering our business. | | |
| 1.2 | | The purpose of this Policy is to inform you about our privacy practices and to ensure that you understand the purposes for which we collect and process your personal data. The following is a brief summary of the manner and purposes for which we process your personal data. | | |
| 1.3 | | ESTATE SYSTEMS T/A MAST DATA LIMITED ("Mastdata", "we," "us" or "our") is the entity which is responsible for the control and processing of personal data that we collect from you when you use the services. If you have any questions or concerns about Mastdata’s use of your personal data, please contact us at privacy@mastdata.com. | | |
| 1.4 | | Our mission is to analyse and review the availability, service coverage, performance and signal quality of mobile networks in the UK and all over the world. We obtain the relevant data by collecting measurements relating to signal reception and quality from users of mobile devices. Where you agree to give us access to your data we collect location data to enable accurate phone signal surveying even when the app is closed or not in use. We will only access your phone's location in the background when you request a signal survey and turn the screen off. | | |
| 2. | | HOW WE COLLECT AND USE YOUR PERSONAL DATA | | |
| 2.1 | | Network performance data. If you are a user of one of our mobile applications, when allowed access to your data, we collect data from your mobile device both when you are using our app or when it is specifically in Survey Mode. | | |
| 2.2 | | We take repeated measurements from your device including location data (which include GPS coordinates or similar information regarding the location of your device), network type, network operator, cellular and Wifi signal strength and quality, and the identifiers of connected cell towers and Wifi routers (including both LAC and CID). We also measure how data is flowing, both passively (by monitoring how fast it moves through other apps), and actively (by running a test that downloads or uploads data within our SDK). We do not monitor the content of your data usage. The goal of collecting the above data is to measure the experience you have of wireless networks. | | |
| 2.4 | | To better understand differences between devices, we collect data on your device hardware such as the model, manufacturer, and manufacturers and models of sub-components (such as the cellular radio) and the capabilities of these components (for example the number of cores on the CPU). Similarly, to understand differences caused by software, we collect information on the mobile platform version used and whether custom ROMs or Android skins are installed. The goal of collecting this data is to understand how device properties affect experience of mobile networks. | | |
| 2.5 | | When you first use the Mastdata app a random identification code is generated by our software, allocated to your mobile device and used to identify your device whenever we take measurements. To further help us manage the data, we also collect related IP addresses, the device MAC number, the Android serial number. These fields are needed for statistical purposes, for example to understand how much data is contributed by each device. | | |
| 2.5.04 | | Cookies. When you use the services, we sometimes send one or more cookies (small text files containing a string of alphanumeric characters) to your computer that uniquely identify your browser and enhance your navigation on our services. A cookie may also convey information to us about how you use the service (e.g., the pages you view, the links you click and other actions you take), and allow us or our third-party analytics tools we use to track your usage of the services. There are at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent use of the service. Persistent cookies can be removed by following your web browser's directions for removal of cookies. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the service may not function properly if cookies are disabled. | | |
| 2.5.1 | | Use of information with Your Consent. We may use your personal data for any other purpose for which you specifically provide us with your consent. | | |
| 3. | | THE PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA | | |
| 3.1 | | The purposes for which we collect and store your personal data are the following: | | |
| 3.1.1 | | Measurements that we take from the mobile devices of individual network users allow us to create a detailed picture of the service availability, quality and performance of numerous communication networks across the world and over time. We publish some of the statistical data that we generate and we provide it to our customers (such as network operators) to help them understand their own network’s service coverage, performance and signal quality (and those of their competitors). Although the end-product we produce is made up of aggregated anonymised data, the underlying ‘raw data’ which contains personal data of individual users is important for us and our customers for generating statistical data, validating the results, quality control and further analysis; | | |
| 3.1.2 | | Personal data that we receive from you enables us to deliver our services to you and enables you to use them efficiently; | | |
| 3.1.3 | | Insofar as permitted under applicable law, we use your data to communicate with you in relation to our services; | | |
| 3.1.4 | | We use data to personalise, test, monitor, improve and upgrade our services, to meet our legal obligations and the regulatory requirements to which we may be subject, for loss prevention purposes and to protect and enforce our rights and meet our obligations to third parties, and for our internal business purposes, such as compiling and analyzing usage information for general operational, statistical and business purposes; | | |
| 3.1.5 | | We use personal data in the general operation and administration of our business including in recruitment of staff, engaging service providers to provide services to our business, in providing services to our customers and for marketing purposes. | | |
| 4. | | YOUR RESPONSIBILITIES | | |
| 4.1 | | It is important that personal data we hold about you is accurate and current. If you provided us with any details of personal data, please keep us informed if these details change. | | |
| 5. | | LEGAL BASIS FOR PROCESSING YOUR DATA | | |
| 5.1 | | We rely on the following lawful basis for the processing of your personal data: | | |
| 5.1.1 | | Our legitimate interests in (among other things) delivering the services, operating and administrating our business, complying with accounting, or reporting requirements, conducting commercial research, improving and maintaining the services, personalizing and tailoring content made available to you through the service, protecting the security or integrity of our databases, protecting our business or reputation, taking precautions against legal liability, dealing with our assets in the event of a business change (see further below), protecting and defending our legal rights or property, or for resolving disputes, investigating and attending to inquiries or complaints with respect to your use of the services; | | |
| 5.1.2 | | Where relevant, your express consent. If you give your consent for accessing your device data to take measurements, you can withdraw it through the personal settings on the Mastdata app); | | |
| 5.1.3 | | Where relevant, the fulfilment of our contractual obligations to you under our terms and conditions of service; and | | |
| 5.1.4 | | Where relevant, for compliance with legal obligations to which we are subject. | | |
| 6. | | HOW WE SHARE YOUR INFORMATION | | |
| 6.1.1 | | Joint and Independent Controllers. We share some of the raw measurements that we collect from users’ mobile devices with some of our customers under the terms of data license agreements and data sharing agreements. Some of the data we share with our customers contains personal data such as datasets containing location data of individual users. Our customers are permitted to use the data for the purpose of analyzing it and generating aggregated data relating to the performance of their networks or telecommunications equipment (and competing networks or equipment) and to use aggregated data in their sales activities. Our customers are not permitted to use your personal data to communicate with you or to influence you or to profile or track individual users. They are required to keep your personal data confidential and to use appropriate means to protect it. Our customers have access to data such as location data of users to enable them to analyse the data and create statistical information based on the aggregation of data from numerous users. Our customers that receive such data from us are not permitted to disclose any datasets that contain personal data relating to specific individuals to their own customers or any third parties. | | |
| 6.1.3 | | Business Change. If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer databases containing personal data of users to successor party or parties in connection with such transaction or change in ownership or legal structure. | | |
| 6.1.4 | | Necessary Disclosure. Regardless of the choices you make regarding your information and to the extent permitted or required by applicable law, we may disclose information about you to third parties to: (i) enforce or apply the terms and conditions of our services; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect our rights, reputation, safety or property, or that of our users or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; our rights, reputation, safety or property, or those of our users or others; violation of the Terms of Use, our policies or agreements; or as otherwise required by law. | | |
| 7. | | HOW WE PROTECT YOUR INFORMATION | | |
| 7.1 | | We take certain measures to protect personal data collected through the service against loss, theft, and unauthorised access, use, disclosure, destruction or modification. These include physical, technological and administrative measures. | | |
| 8. | | HOW LONG WE KEEP YOUR INFORMATION | | |
| 8.1 | | We will only retain your personal data 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. | | |
| 8.2 | | To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. | | |
| 8.3 | | Personal data (such as user’s location data or the user’s unique identifier which is created on first use of the Mastdata app) contained in the sets of measurements of mobile network signal performance is held for an unlimited period of time as it is required for the production of statistical data over different periods of time and to compare performance data between different time periods. | | |
| 8.4 | | Insofar as the data is collected to enable us to recognise you as a user of the services and to improve the services provided to you, we will dispose of the data within a reasonable time after you cease to be a registered user of the services. | | |
| 9. | | COUNTRY OF PROCESSING | | |
| 9.1 | | We operate the services from the United Kingdom (UK). Our data collection activities take place in the countries where personal data is collected from users of the services. We store and process data (including personal data) through third-party cloud service providers and other IT service providers which are located within the UK. | | |
| 10. | | CHILDREN'S PRIVACY | | |
| 10.1 | | The service is not directed to children and is intended for use by adults only. We do not knowingly collect personal data from individuals under 16 years of age. If you are under the age of 16, please do not submit any information through the service and do not provide your consent for the use of your data unless your parent or guardian has approved. | | |
| 11. | | THIRD-PARTY SITES AND SERVICES | | |
| 11.1 | | The service may reference or provide links to other websites, applications, or resources. If you access any website, application, or resources provided by a third party, our Privacy Policy will not apply. Your interactions with such websites, applications, and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information. | | |
| 12. | | DATA SUBJECT RIGHTS | | |
| 12.1 | | Data subjects have the following legal rights in respect of their personal data that we process: | | |
| 12.1.1 | | The right to require Mastdata to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information; | | |
| 12.1.2 | | The right to require access to the personal data and to require Mastdata to rectify inaccurate information without undue delay. | | |
| 12.1.3 | | Where Mastdata has relied on the ‘consent’ basis for processing that information (see paragraph 5(a) above), the right to withdraw their consent at any time. This right to withdraw consent does not affect the lawfulness of processing based on consent before its withdrawal; | | |
| 12.1.4 | | The right to request the erasure of their information. You can make a request for erasure where
a) the information is no longer necessary in relation to the purpose for which it was collected;
b) where the processing of the information is based on the data subject’s consent (and the other circumstances described in the ‘Legal Basis for Processing Your Data’ and ‘How We Share Your Information’ sections above no longer apply), if the data subject withdraws his or her consent; or
c) where the personal data is processed by Mastdata solely on the basis of our ‘legitimate interest’ referred to in paragraph 5(a) (and the other legal basis set out in paragraph 8 do not apply), if the data subject objects to the processing of his or her personal data and there are no overriding legitimate grounds for the processing (such as, for example, where the processing of the data is required to meet statutory obligations or for the defense of legal claims). | | |
| 12.1.5 | | The right to require Mastdata to restrict its processing of a data subject’s personal data in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, Mastdata will only process that information with the express consent of the data subject, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest; | | |
| 12.1.6 | | Where data is processed based on data subject’s consent or to fulfil a contractual obligation, the data subject has the right to receive his or her personal data from Mastdata in a structured, commonly used and machine-readable format; | | |
| 12.1.7 | | The right to object to the processing of personal data where:
a) Mastdata relies solely on the ‘legitimate interest’ basis for processing that data, in which case we will be legally required to stop processing the data subject’s information unless we have compelling legitimate grounds for the processing which override the data subject’s privacy rights and interests; or
b) the information is used for direct marketing purposes, in which case we will immediately stop processing the data subject’s information for such purposes; | | |
| 12.1.8 | | Data subjects have the right to lodge a complaint with the UK’s Information Commissioner’s Office or in some cases with the data protection supervisory authority of the EU member state where the data subject resides. | | |
| 12.1.9 | | The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment. | | |
| 13. | | AGGREGATED INFORMATION | | |
| 13.1 | | We may share aggregated, anonymised/deidentified data relating to users of our services with affiliated or unaffiliated third parties. | | |
| 14. | | CHANGES TO THE PRIVACY POLICY | | |
| 14.1 | | We may update this Policy from time to time, and the updated version of this Policy will be effective upon posting on the Mastdata services. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Please check this page to review the most up-to-date version of this Policy. | | |
| 15. | | QUESTIONS / CONTACTING US | | |
| 15.1 | | If you want to exercise your rights under section 12 of our privacy policy, please email privacy@mastdata.com with “Data Subject Request” in the subject line, or contact us by mail addressed to:
ESTATE SYSTEMS T/A MAST DATA LIMITED
North End House
Avon
Christchurch
United Kingdom
BH23 7BJ | | |