Privacy Policy

Effective as of 15 January 2014

This privacy policy (hereinafter: Privacy Policy) has been adopted by Fortumo OÜ (hereinafter: Fortumo), a private limited company established under the laws of the Republic of Estonia, located at Ülikooli 6a, 51003 Tartu, Estonia, and registered in the Estonian Commercial Register under code 11378397. The Privacy Policy also applies to members of the Fortumo group, unless such members have adopted a separate privacy policy. The Privacy Policy has been adopted in compliance with the legal requirements of the Republic of Estonia and of the European Union.

The Privacy Policy describes how and for which purposes Fortumo collects, processes and distributes information (including personal information) provided by you or collected by Fortumo either on the website www.fortumo.com (hereinafter: Site) or when you use the services, products, content, features, technologies, applications, functions etc. that Fortumo provides or may provide in the future (hereinafter: Services).

By using the Site or the Services, you are giving your consent to this Privacy Policy. Please read this Privacy Policy each time before using the Site or the Services and before submitting any information to Fortumo. Fortumo may change this Privacy Policy unilaterally and without prior notice, but any changes will be posted on the Site. You are encouraged to review the Privacy Policy whenever you visit the Site or begin or continue using a Service to make sure that you understand how Fortumo may use any information you provide or Fortumo collects at any given time.

The privacy practices set forth in this Privacy Policy apply to the Site and Services only. If you link to other web sites (including sites that offer or use the Services or are promoted by Fortumo) or use the services of other service providers, please review the privacy policies posted at those web sites or by the relevant service providers.

Collection and Processing of Information

Fortumo collects your information using two approaches. Firstly when voluntarily submitted by you on the Site, in the process of using the Services or provided by you in any communication (e.g. e-mails) to Fortumo and secondly when obtained by Fortumo independently when you use the Site or the Services. The latter includes information which can be legally obtained using current technologies, for example information regarding your operating system, web browser, mobile operator, network connection, the mobile device you use, the mobile payment services that you use, how you use the mobile payment services etc.

The information that Fortumo collects differs between end users of the Services and merchants (e.g. publishers and developers). For example, from end users Fortumo collects information such as phone number, e-mail address, mobile network provider, type of mobile phone, operating system, payment behavior etc. From merchants Fortumo collects information such as names of representatives, identification details, country of residence, address, e-mail address, phone number, banking details etc.

Fortumo may collect and process (including automatically process) i) your personal or corporate information (e.g. the names of representatives of merchants, identification data of merchants) primarily to identify you; ii) your contact information (e.g. phone number, e-mail address, preferred language etc.) primarily to provide to you information and offers; iii) your transaction information (e.g. what product or service you purchased, banking details of merchants etc.) primarily to correctly process your transactions; iv) information regarding your preferences (e.g. what products or services you have most frequently purchased) primarily to be able to offer you related products or services and v) information regarding your trustworthiness (e.g. data about payment behavior and violations) primarily for proper risk assessment.

Additionally, Fortumo may collect and process the aforementioned information, information related to it and other information regarding you for the following purposes:

  1. deciding whether and on what terms to provide Services;
  2. provision of Services and customer support;
  3. processing and monitoring of transactions, the payment and billing thereof, and performance of other agreed tasks;
  4. understanding how you use the Services;
  5. resolution of disputes and enforcement of agreements;
  6. calculation and collection of fees;
  7. identification of you and verification of your transactions;
  8. prevention and investigation of, and protection against, prohibited or illegal activities or fraud;
  9. customization, updating, maintenance, protection and improvement of the Site and Services;
  10. provision of information, advertisements, offers, update notices;
  11. comparison of information for accuracy, identification and verification with third parties;
  12. statistical, research and reporting purposes;
  13. to prevent money laundering and terrorist financing;
  14. other reasonable business-related purposes or purposes related to the above.

Fortumo may use your information to offer or advertise to you Services offered by Fortumo, other companies of the Fortumo group or contractors of Fortumo. You may choose to not receive such offers or advertisements by notifying Fortumo thereof.

Fortumo does not collect or process your sensitive personal information (religious or political views, health related information etc.) in any manner.

Cookies and Tracking Technology

The Site and Services may use cookies and tracking technology depending on the features offered. Cookies and tracking technology are used for gathering information such as browser type and operating system, country of access, IP address, tracking the number of users, and understanding how you use the Site and the Services. Fortumo uses cookies and tracking technology to customize the Site and Services for users, to assess the use of the Site and Services and to improve the user experience and the overall quality of the Site and Services, but also to combat fraud and other violations. Personal information cannot be collected via cookies and other tracking technology, however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.

In the event you do not wish to receive cookies, you may configure your web browser to not accept cookies or to notify you if a cookie is sent to you. You are free to decline cookies if your web browser permits, but you may not be able to use all the features and the functionality of the Site or Services.

Distribution of Information

Fortumo may share your information that Fortumo has collected when: (1) permitted or required by law; or, (2) trying to protect against, prevent, investigate actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; or (3) trying to enforce the applicable terms of service or other agreements; or (4) protecting against violations to the rights, property or safety of Fortumo, our users or the public as required or permitted by applicable laws; or (5) you have given your consent to do so.

Fortumo may disclose your information to members of the Fortumo group or contractors of Fortumo to process it for Fortumo, based on Fortumo’s instructions and in compliance with the Privacy Policy and any other applicable confidentiality and security measures.

Fortumo may also disclose some or all of your personal, contact or other information to other companies of the Fortumo group and contractors of Fortumo, among other purposes, for the purposes of processing transactions, collecting fees, identifying you, but also for improving your user experience, performing business support functions or other related tasks.

Fortumo does not sell, lease, rent or make otherwise available your information to third parties for their marketing purposes without your explicit consent.

Commitment to Information Security

Your personally identifiable information is maintained and kept secure by applying physical, electronic and procedural measures conforming to industry standards. Only authorized employees, agents and contractors (who have agreed to keep information secure and confidential) of Fortumo have access to this information on a need to know basis. All emails, advertisements, promotions and newsletters from Fortumo allow you to opt out of further mailings.

Fortumo shall maintain the information you have provided if so required or permitted by applicable legal acts for the duration stipulated in the applicable legal acts.

You commit to notify Fortumo as soon as possible if any information provided by you to Fortumo has become outdated or has changed.

Fortumo reserves the right to make changes to this Privacy Policy. Any changes to this Privacy Policy will be posted on the Site and effective as of posting thereof.

For further information regarding the Privacy Policy and related practices, please contact Fortumo at support@fortumo.com.