We, Mobile VPS Ltd, are pleased that you have visited our web site and are interested in our company. We know that careful handling of your personal information is important to you and therefore take the protection of your personal data seriously and want you to feel safe and comfortable when visiting our website. It goes without saying that we comply with the statutory provisions of the UK’s Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR), as well as with good practice.
In order to keep this privacy as simple as possible and to avoid legal and technical jargon the following three concepts must be explained.
Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier. IP address or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Sensitive personal data is a specific set of “special categories” that must be treated with extra security. This includes information pertaining to: Racial or ethnic origin; Political opinions; Religious or philosophical beliefs;
Trade union membership; Genetic data; and Biometric data (where processed to uniquely identify someone).
- Information about us as the responsible party
Who is responsible for the processing of my personal data and whom can I contact if I have any questions?
The person responsible within the meaning of the legal provisions on data protection (e.g. GDPR and DPA) for the processing of your personal data is:
Mobile VPS Ltd
116-118 Finchley Road
NW3 5HT London UK
E-mail: [email protected]
III. Basic principles of processing your personal data
Rights of users
With regard to the data processing described in more detail below, users and data subjects have the right to:
- confirmation as to whether data relating to them is being processed;
- information about the data processed;
- further information about the data processing and to copies of the data;
- correction or completion of incorrect or incomplete data;
- immediate erasure of the data concerning them, or, alternatively, insofar as further processing or restriction is necessary;
- receive the data concerning them and provided by them and to transfer this data to other providers/controllers;
- lodge a complaint with the supervisory authority if they are of the opinion that the data concerning them is being processed by the provider in breach of data protection provisions.
In addition, we are obliged to inform all recipients to whom data has been disclosed by us of any correction or deletion or restriction of processing that take place as a result of a data subject access request. However, this obligation does not apply if such access request is impossible or involves a disproportionate effort.
Likewise, users and data subjects have the right to object to the future processing of data concerning them, insofar as the data is processed by us in accordance with our legitimate interest. In particular, an objection to data processing for the purpose of direct advertising.
In order to protect your personal data, Mobile VPS adheres to the following principles:
- Mobile VPS collects, processes and uses your personal data in compliance with the data protection laws of the UK’s Data Protection Act 2018 the EU’s General Data Protection Regulation which came into force on 24 May 2018.
- The extent to which personal data is collected depends on the level of interaction of the respective user with the services offered on the web site (‘data minimisation’).
- In any case, our aim is to protect the privacy of our users and to provide a secure service. The data of all users will remain confidential and will only be used for the purposes stated (‘purpose limitation’).
- Mobile VPS only processes personal data in a way that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. This is done through appropriate technical and organisational measures (‘integrity and confidentiality’).
The legal bases of processing
The following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Contract – This is where we process your information to fulfil a contractual arrangement we have made with you.
- Answering your business enquiries – This is where we process your information to reply to your messages, e-mails, posts, calls, etc.
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.
- Information on data processing
The content offered on this web site is generally available to you for informational use without registration. Personal data will only be processed if there is a legal reason for doing so or if we have your consent. You can revoke your consent at any time by contacting us. The revocation does not affect the lawfulness of the processing of your personal data carried out on the basis of the consent up to the time of the revocation.
Automatic information (server log files)
When you visit our web site, information is automatically collected and stored by the web server. This is done separately from your other data. The automatic information is evaluated for statistical purposes in order to be able to optimise our web site and is stored for statistical purposes. Such automatic information includes above all
- browser type/version;
- Operating system used;
- Referrer URL (the previously visited page);
- Host name of the accessing computer (IP address);
- Date and time of the server request;
- Pages you have visited on our website;
- the amount of data transferred;
- the access status (message whether the retrieval was successful, file transferred, file not found, etc.);
- IP address.
The legal basis for this is our legitimate interest.
The legal basis for the storage of cookies is our legitimate interest.
Processing of personal data when contacting us
We process information that you enter on our web site or transmit to us in another way in order to be able to provide you with advice and support following a corresponding enquiry. This includes, for example, data that you fill out in a contact form or send to us in an e-mail.
The legal basis for the processing of your personal data transmitted when you fill out a contact form is our legitimate interest.
Processing of personal data for the fulfilment of contractual obligations
Conclusion of a contract
We process your personal data if and insofar as this is necessary to carry out pre-contractual measures in response to your request and fulfilment (including billing) of a contractual relationship. If you wish to conclude a contract with us via our web site, it is necessary for the conclusion of the contract that you provide us with the personal data that we require for the performance of the contract. This includes, for example, your name and contact details as well as, if necessary, data for billing the contractual service. After complete fulfilment of the contract, your data will be blocked and deleted after expiry of the provisions of tax and commercial law, unless you have expressly consented to further data processing. The legal basis for the processing of your personal data for the purpose of the aforementioned actions is the provision of a contractual or pre-contractual measure.
You can set up a customer account on our web site. We will then revocably store the data provided during registration, such as name and contact details, as well as information that we collect when you use the customer account, until your customer account is deleted. You can manage your data in your customer account at any time. The legal basis is the provision of a contractual or pre-contractual measure.
The legal basis for the processing of your personal data in the context of direct marketing measures is either your consent or our legitimate interest in marketing and promoting our courses and services. The purpose of processing your personal data in the context of direct marketing measures is to send information, offers and, if applicable, to promote sales through the sale of goods or services. Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected; this is the case in particular upon receipt of the revocation or objection. You can revoke your consent at any time for the future or object to the processing of your personal data in the context of direct marketing measures at any time for the future.
When you send a data subject access request
The legal basis for the processing of your personal data in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of the data subject access request is both our legitimate interest and our legal obligation. The purpose of processing your personal data in the context of processing data when you send a data subject access request is to respond to your request. The subsequent documentation of the data subject access request serves to fulfil the legally required accountability.. Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the processing of a data subject access request, this is three years after the end of the respective process. You have the possibility at any time to object to the processing of your personal data in the context of the processing of a data subject access request for the future. In this case, however, we will not be able to further process your request. The documentation of the legally compliant processing of the respective data subject access request is mandatory. Consequently, there is no possibility for you to object.
Legal defence and enforcement of our rights
The legal basis for the processing of your personal data in the context of legal defence and enforcement of our rights is our legitimate interest. The purpose of processing your personal data in the context of legal defence and enforcement of our rights is the defence against unjustified claims and the legal enforcement and assertion of claims and rights.
Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. The processing of your personal data in the context of legal defence and enforcement is mandatory for legal defence and enforcement of our rights. Consequently, there is no possibility for you to object.
Within the Blog you may be able to display certain profile information, share certain details, engage with others, exchange knowledge and insights, post and view relevant content. Content and data ispublicly viewable. You have choices about the information on your comment. You don’t have to provide additional information on your profile; however, information helps you to get more from our Services. It’s your choice whether to include sensitive information on your comment and to make that sensitive information public. Please do not post or add personal data that you would not want to be available.The legal basis for the storage is our legitimate interest.
When you access a Google service, the browser sends this cookie along with your request for a page. The NID cookie contains a unique ID that we use to store your preferred settings and other information, such as your preferred language, how many search results to display per page (e.g. 10 or 20) and whether to enable the Google SafeSearch filter. The data processing is carried out on the basis of your consent and/or our legitimate interest. Our legitimate interest is the improvement of our offer and our web presence.
Our website uses plug-ins from the YouTube site operated by Google. The operator of the site is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. When you visit one of our pages equipped with a YouTube plug-in, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used in the interest of an appealing presentation of our online offers which represents a legitimate interest.
- Social media providers
We use plug-ins of the social network Facebook on our web site, which is operated by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA. The plug-ins are marked with a Facebook logo or the addition “Social Plug-In from Facebook” or “Facebook Social Plug-in”. You can find an overview of the Facebook plug-ins and their appearance here. When you visit our web site, Facebook receives the information that you have visited our site. Facebook can recognise you by your IP address. If you click the Facebook “Like” button while you are logged into your Facebook account, you can link the content of our pages on your Facebook profile. As long as and insofar as you are logged in, Facebook can assign the visit to our web site to your user account. We would like to point out that we, as the provider of the web site, have no knowledge of the content of the transmitted data or its use by Facebook.
We also use plug-ins from the micro blogging service Twitter, which is operated by Twitter Inc, 1355 Market St, Suite 900, San Francisco, CA 94103, USA. The plug-ins are marked with the Twitter logo, for example in the form of a blue “Twitter bird”. You can find an overview of the Twitter plug-ins here. By using Twitter and the “Re-Tweet” function, the web sites you visit are linked to your Twitter account and made known to other users. In the process, data is also transmitted to Twitter. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Twitter.
- Sharing and Security
Unless otherwise specified in this policy, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, the data processed by us will be deleted or restricted in their processing in accordance with the DPA, the GDPR and the statutory retention periods applicable to us. If the data is not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
When do we disclose your Personal Data?
We may share your information with organisations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support our online offer and our services.
Typically and unless otherwise stated in this policy, data may be shared on the basis of our contractual and pre-contractual obligations. Equally, if you have consented to it, or where we have a legal obligation to do so or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to perform our contractual obligations, administrative tasks and duties efficiently and effectively). If we commission third parties to process data on the basis of a so-called “processing agreement”.
In relation to meta data obtained about you, we may share a cookie identifier and IP data with analytic service providers to assist us in the improvement and optimisation of our website which is subject to our Cookies Policy.
We may also disclose information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website and its users.
Transfers to third countries
If we process data in a third country (i.e. outside the UK) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done in order to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests.
We take precautions to protect your data and to prevent misuse from the outside. In doing so, Mobile VPS uses measures such as encryption (SSL encryption) of user data. SSL encryption is active if the address begins with “https://”. Data transfer is then protected by SSL (Secure Socket Layer) with at least 128-bit encryption, which prevents third parties from unlawfully reading your data. If the encryption is not active, you should think twice before sending personal or sensitive information over the Internet.
We secure our web site and other systems through commercially reasonable technical and organisational measures against loss, destruction, access, alteration or disclosure of your data by unauthorised persons.
- Miscellaneous and closing
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).If we commission third parties to process data on the basis of a so-called ” processing agreement.
Obligation to provide personal data
You are not obliged to provide us with personal data. However, depending on the individual case, the provision of certain personal data may be necessary for the provision of the above services. If you do not provide us with this personal data, we may not be able to provide the service.
Automated individual decision-making including profiling
We do not make automated decisions in individual cases, including profiling.
Do Not Track
Do Not Track is a privacy preference you can set in most browsers. We support Do Not Track because we believe that you should have genuine control over how your info gets used and our site responds to Do Not Track requests.
Do Not Sell My Personal Information
We do not sell information that directly identifies you, like your name, address or phone records.
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Our website is not intended for children and we do not knowingly collect data relating to children. If you become aware that your Child has provided us with Personal Data, without parental consent, please contact us and we take the necessary steps to remove that information from our server.
Links to third party providers
Content Delivery Network
For the purpose of a shorter loading time, we use a so-called Content Delivery Network (“CDN”) for some offers. With this service, content, e.g. large media files, are delivered via regionally distributed servers of external CDN service providers. Therefore, access data is processed on the servers of the service providers. Our service providers work for us within the framework of order processing. If you have any questions about our service providers and the basis of our cooperation with them, please contact us.
This policy and our commitment to protecting the privacy of your personal data can result in changes to this policy. Please regularly review this policy to keep up to date with any changes.
Queries and Complaints
Any comments or queries on this policy should be directed to us. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.