Adopted:    February 9, 2009

GSMA MOBILE INNOVATION EXCHANGE PRIVACY POLICY

Introduction.   We take the privacy of your information very seriously. The GSMA Mobile Innovation Exchange Privacy Policy (“Policy”) explains how and for what purposes we use the information collected about you through the www.mobileinnovation.org site (referred to below as the “Site”).  Please read this Policy carefully.

By accessing, viewing, downloading or otherwise using the GSMA Mobile Innovation Exchange website or any webpage or feature available through the Site, any information provided as part of the Site services, or any related emails, newsletters or services (hereinafter collectively  the “Site” or the “Services”),  or by registering with the Site,  , you are agreeing to be bound by this Policy in respect of the information collected about you via this Site. You acknowledge and agree (on your own behalf and duly authorized on behalf of any third party whose details you supply) that the processing (including disclosure) of personal information is necessary or desirable for the provision of relevant services and the operation of the Site.  The references to information “relating to you” or “about you” include references to information about your employees, representatives, agents, directors, officers, shareholders, or other relevant parties whose details you have provided, and those of your affiliates and subsidiaries and sub-contractors, and those of any third party whose details you supply to the Site.

We may update this Policy from time to time to take account of changing requirements, and we request that you refer back to this Policy frequently to review any revisions. If at any time we decide to use personal information in a manner that reduces your rights under this policy or otherwise disclosed to you at the time it was collected, we will notify you by e-mail, and you will have a choice as to whether or not we use your information in this new manner. If you have any queries about the Policy, please get in touch with us using the contact details set out at Contact Us below, and we will do our best to answer your questions.

Collection and Use of Information.  We collect personal information about you on this Site when you volunteer such information to us, such as when you complete the online registration form or use the Contact Us function. We will use your this information in order to respond to any queries submitted by you. The information collected may include the following:

• Your profile information
• Payment information
• Information related to your company and its products
• Information you supply to use to engage features and functionality of the Site.

We may also use this information to provide you with information, including marketing information in relation to upcoming GSM Association or industry events, meetings, conferences, seminars, offers, products, or services which we believe could be of interest to you or your organization; to carry out surveys and to get your views in relation to the products or services which we or third parties provide;  to invite individuals to be speakers at seminars/training events; or to participate in other meetings or events held by us or third parties. We may also use this information for research and analysis to improve the Site, to ensure that the Site functions appropriately, and to develop new Services that will be available on the Site. We may contact you by any means of communication for which you have given us contact details, including e-mail, telephone, and post. However, you may choose not to receive such information by so indicating on the online registration form at the time of providing your information, or by simply using the Contact Us function below. Any financial details supplied to us such as bank details and/or credit card details are used solely for the purpose of processing payments.

We may offer a number of services that do not require you to register for an account or provide any personal information to us.  In offering such services, we may collect the following types of information:

• Cookies – When you visit the Site, we send one or more cookies – a small file containing a string of characters – to your computer that uniquely identifies your browser. We use cookies to improve the quality of our service by storing user preferences and tracking user trends, such as how people search, as discussed in more detail below.
• Log information – When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. 
• User communications – When you send email or other communications to the Site, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. 

Sharing of information. Your information may be passed to third-party companies who provide training courses, mailing services, and event management on our behalf or on behalf of our affiliates.   In addition, we may pass your information to our affiliates, carefully selected business partners, or other carefully selected third parties who may contact you to provide you with information, including marketing information in relation to upcoming industry events, meetings, conferences, seminars, offers, products, or services which could be of interest to you or your business, and/or to carry out surveys and to get your views in relation to the products or services which third parties provide. If you do not wish us to provide your information to third parties for these purposes, please indicate that to us at the time of providing your information by contacting us at info@mobileinnovation.org. On occasion, we may use third-party agents and service providers to assist us in the use of your information as outlined above.

We may provide your personal information to a third party as part of a sale or transfer of some or all of our business and assets to any third party, or as part of any business restructuring or reorganization, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Other than as set out above, we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the prevention of fraud or other crime).

Transferring your Information Outside of the European Economic Area (“EEA”).  In using your information as set out in this Policy, it may be transferred to countries outside the EEA. By way of example, this may happen if one of our service providers is located in a country outside the EEA. We also share information between our affiliated companies, business partners, or other carefully selected third parties which are located in countries worldwide. These countries may not have similar data protection laws to the EEA. If we transfer your information outside of the EEA in this way, we will take steps aiming to ensure that your privacy rights continue to be protected.

Information Automatically Collected from your Computer.  When you visit the Site, our Web server automatically records your IP address. This IP address may be linked to any of your personal information. We use IP addresses to help us administer the Site and to collect demographic information for marketing and aggregation purposes.  We may also gather other non-personal information (from which we cannot identify you), such as the type of your Internet browser, which we use to provide you with a more effective service.

Cookies.  When you visit the Site, we may store some information (commonly known as a “cookie”) on your computer. Cookies are pieces of information that a Web site transfers to your hard drive to store – and sometimes track – information about you.    A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number. Most major websites use cookies. Cookies cannot be used by themselves to identify you. You have the ability to accept or decline cookies by modifying the settings in your browser. Please reference the help functions of your specific browser for information on how to change these settings.

Cookies are used on www.mobileinnovation.org for improving the user experience, site analytics, and site engagement.  Mobileinnovation.org cookies are set based on your viewing of web pages in and do not contain any information that can identify you personally. The server will place a cookie containing a unique number on your computer when they arrive on mobileinnovation.org. The cookie is used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page.

The Site uses Google Analytics to help us understand how our visitors engage with the Site.  Google Analytics collects information anonymously via cookies and reports website trends without identifying individual visitors. Analytics uses its own cookie to track visitor interactions. The cookie is used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. Google Analytics enables us to view a variety of reports about how visitors interact with the Site so we can improve the Site and how people find it.

Changes to your details.  We aim to keep our information about you as accurate as possible. If you would like to review or change the details that we hold about you, please contact us at info@mobileinnovation.org.

Security.  We are committed to protecting the security of your personal information. We have implemented appropriate technology and policies to safeguard your personal information from unauthorized access and improper use. However, the nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet.

Linking to Third-Party Web Sites.  We are not responsible for the privacy policies and practices of other sites, even if you access such sites using links from this Site.   In addition, if you linked to this Site from a third-party site, we are not responsible for the privacy policies and practices of the owners or operators of that third-party site. We strongly recommend that you check the policy of all third-party sites that you visit and contact its owner or operator if you have any concerns or questions.

Contact Us.    If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, or if you do not wish us to continue using your information as outlined above, you can do so by sending an e-mail to info@mobileinnovation.org or write to GSMC Limited, 1000 Abernathy Road, Suite 450, Atlanta, Georgia  30328, Attention:  Legal Department.