MobileIron Privacy Notice

 

MobileIron is the secure foundation for modern work. We establish a zone of trust around clouds and endpoints to help everyone work more efficiently from anywhere. This notice explains how MobileIron, Inc. and our subsidiaries and affiliates (as a group, MobileIron) handle the information that can identify you (personal data) that we collect for our own purposes:

  • from you when you visit and use a MobileIron website, social media asset or mobile application (each, a Site),
  • from you when you register to use our services offered through the Sites, request products, services or information from us, participate in public forums or other activities on our Sites, respond to customer surveys, or otherwise interact with us in connection with the administration of our business, business development efforts, marketing programs, surveys, offers, events and other promotions (Services),
  • automatically through tracking technologies, such as when you visit our Sites, or
  • from other trusted sources to update or supplement the information we collect, with your authorization if required by local law.

This notice does not apply to:

  • personal data we receive as a result of a customer’s use of our enterprise products and services (Products), which we handle as described in our Product Privacy Statement,
  • personal data you provide on a third-party site or platform,
  • information that cannot reasonably identify you (anonymous data and aggregate data), or
  • any Site or Service, to the extent disclosures describe more or different details about our handling of your personal data.

Your personal data and how we use it
Your controls and choices
Cookies and other tracking technologies
Storage and processing locations
Security and retention
EEA and Swiss residents
Children
Updates
Comments and questions

Your personal data and how we use it

The personal data we collect depends on the context of your interactions with MobileIron, the choices you make, including your privacy settings, and the aspects and features of a Site, Service or other means of interaction. If you are a MobileIron employee, contractor or job candidate, in limited circumstances we may collect data revealing your racial or ethnic origin, religious or philosophical beliefs, physical or mental health or condition, sexual orientation, trade union membership, or criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws (Sensitive Personal Information).

The following table describes:

  • the general categories of personal data that we process, with specific examples,
  • the purposes for which we process the personal data,
  • the legal basis of processing of personal data of residents of the European Economic Area (EEA) subject to the European Union’s General Data Protection Regulation (GDPR),
  • the source from which we obtain personal data and
  • the categories of those who receive personal data from us, which in some cases may be subject to your prior consent.

 

Data Category:

Purposes of Processing:

GDPR Legal Basis:

Source:

Recipient Categories:


Log and device data – error reports and other data about your consumption, configuration and use of the Sites and Services, such as your Internet Protocol (IP) address and device identifier

Analyzing your use of the Sites, Services and Products and ensuring their proper functioning and security, optimizing the Sites and Services, and interacting with you on third-party social networks (subject to that network’s terms of use)

Consent or our legitimate interests, namely IT security, marketing, and improving the Site and the Services

First and third-party tracking technologies, our analytics tracking tools

MobileIron group companies, advertising network vendors and their participants, other service providers

 

Account data – data used when creating an account, such as your name, email address, postal and street address, user ID, password, password hints, security questions

Operating Sites, providing Services, providing support or other services relating our Sites, Services and Products, ensuring the security of the Sites, Services and Products, and communicating with you

Our legitimate interests, namely IT security, administering the Sites, Services, Products and business, or the performance of a contract between you and us and/or taking steps at your request to enter into a contract

You, your organization, our channel partners

MobileIron group companies, channel partners, service providers, your organization


Profile data – data included in your personal profile on the Site or in our Services, such as your name, organization, postal address, telephone number, email address, profile pictures, gender, date of birth, interests, educational details, employment details and preferences

Enabling your use of the Sites, the Services and our Products, delivering Products, provisioning access to Products, providing support or other services relating to our Sites, Services and Products including Product updates, fixes and recommendations, marketing and selling relevant Products and/or Services to you, and complying with corporate governance and legal requirements

Our legitimate interests, namely customer relationship management, supplier management, marketing, administering our Site and business, or the performance of a contract between you and us and/or taking steps at your request to enter into such a contract, or compliance with a legal obligation we are under

You, your organization, our channel partners, third-party data services that supplement the data we collect

MobileIron group companies, channel partners, service providers, your organization


Service data – data provided while using the Sites or Services, which varies by service but may include data about your device to facilitate its registration and the operation of the service, the Wi-Fi network you use to connect to Sites or Services, and data about authentication requests contained in authentication tokens and Single Sign On certificates

Operating the Sites, providing Services, communicating with you and authenticating your access to company IT resources

Our legitimate interests, namely IT security, fraud prevention and administering our Sites and business, or the performance of a contract between you and us, or taking steps at your request to enter into such a contract

You, your organization

MobileIron group companies, service providers, your organization


Publication data – data you post for publication on our Sites or through our Services, such as product reviews, comments and search queries on public forums that do not have a restricted audience, such as blogs, message boards, chat features, social communities and online meeting platforms

Enabling publication on and administering our Sites and Services

Consent, our legitimate interests, namely administering the Sites, the Services and our business, the performance of a contract between you and us, or taking steps at your request to enter into such a contract

You

MobileIron group companies, service providers, other visitors of public forums


Inquiry data – data in any inquiry you submit to us regarding the Sites, the Services, or our Products, such as in made via our web forms or telephone numbers, contact preferences submitted to our subscription center, event registrations, and subscriptions to our electronic notifications and newsletters

Providing customer service support, offering, marketing and selling relevant Products and/or Services to you, sending you notifications or newsletters

Consent, the performance of a contract between you and us and/or taking steps at your request to enter into such a contract, or our legitimate interests, namely marketing or administering the Site, the Services and our business

You, your co-worker, your organization, services that supplement the data we collect with demographic data, channel and business partners with which we engage in joint marketing activities or offer MobileIron- or co-branded services

Your organization, MobileIron group companies, service providers, other participants and sponsors of events you register for, and channel and business partners with which we engage in joint marketing activities or offer MobileIron- or co-branded services


Transaction data – billing, banking and other transactional data relating to transactions you enter into with us and/or through our Site (including event registration and orders and purchases of goods and services), such as your contact, payment card and transaction details

Supplying purchased Products and Services, making payroll, reimbursing job-related expenses and keeping proper records of those transactions

Performance of a contract between you and us and/or taking steps at your request to enter into such a contract, or our legitimate interests, namely fraud prevention and administering the Site, the Services and our business

You, your organization, our local event organizing partner or host, and our channel partners

MobileIron group companies, channel partners, payment card processors and other service providers


Correspondence data – data in or about any communication you send to us either one-to-one or in a limited group, such as by a Site’s contact forms or your emails, chat or instant messages, and voicemail messages

Communicating with you about your requests or the Site, the Services or our Products

Our legitimate interests, namely administering the Site, the Services and our business, and communicating with users

You, your co-worker, your organization, or the Sites and the Services (in the case of metadata)

MobileIron group companies, service providers


Survey data – data from surveys we conduct, including product feedback

Understanding and improving customer service support and our Site, Services, Products and events

Our legitimate interests, namely administering the Site, the Services, our Products and our business, and communicating with users

You

MobileIron group companies, service providers


Candidate data – data from materials and other information submitted to us by or about an applicant or other candidate (such as a CV, resume, references, transcripts, background checks, compensation requests), including educational and employment background, contact info and preferences, job qualifications, career opportunities, disabilities for which we need to make reasonable accommodations

Processing and evaluating your application and making hiring or engagement decisions; communicating with you or your staffing agency or executive search firm; and informing you of current and future career opportunities; managing and improving our recruiting processes; conducting reference and background checks where required and/or permitted by applicable local law; and complying with corporate governance and legal and regulatory requirements, such as for monitoring of recruitment statistics or internal policies related to diversity and anti-discrimination

Our legitimate interests, namely reviewing your suitability as an applicant and managing the recruitment process, compliance with a legal obligation we are under, or performance of a contract between you and us, and/or taking steps at your request to enter into such a contract, or consent

For Sensitive Personal Data, as required or permitted by applicable laws, necessary to carry out our obligations and exercising specific rights in relation to employment, necessary to establish, exercise or defend legal claims, when manifestly made public by you, or prior explicit consent

You, third parties you name (such as employers, educational institutions and references) and, subject to their privacy policies, third parties we engage (such as employment research firms, staffing agencies, executive search firms, background check providers, identity verification services, other publicly-available websites on the Internet)

Third parties you name (such as employers, educational institutions and references), MobileIron group companies, technology service providers, subject to their privacy policies third parties we engage (such as employment research firms, staffing agencies, executive search firms, background check providers, identity verification services, other websites on the Internet), and governmental entities in compliance with applicable laws (such as equal opportunity laws)


Employment data – data from any employment- or engagement-related materials and other information submitted to us by or in connection with an employee or contractor, such as contact info and preferences, job description, performance, benefits and compensation details, government identification number, disabilities for which we need to make reasonable accommodations, the device used by the employee, health status

complying with corporate governance and legal and regulatory requirements, such as for background checks, equal opportunity monitoring or internal diversity and anti-discrimination policies, for employment and corporate management such as establishing a basic employment record, providing compensation and benefits, authenticating and authorizing you as a user of company resources and premises required to carry out your job responsibilities, communicating with you and securing corporate resources and premises

Our legitimate interests, namely managing your employment or engagement and IT security, ensuring compliance with a legal obligation we are under, or the performance of a contract between you and us and/or taking steps at your request to enter into such a contract

For Sensitive Personal Data, as required or permitted by applicable laws, carrying out our obligations and exercising specific rights in relation to employment, or establishing, exercising or defending legal claims, or when manifestly made public by you

You, benefits and payroll service providers and other third parties we engage

MobileIron group companies, service providers, subject to their privacy policies other third parties we engage, and governmental entities in compliance with applicable laws (such as tax and equal opportunity laws)


Any category

Effecting a corporate transaction such as a sale of assets or merger

Our legitimate interests in administering our business

Any of the above sources

Acquiring or target company, new legal entity, and their professional and technology services providers


Any category

Ensuring the safety and security of our personnel and others

To protect vital interests of you or another natural person

Any of the above sources

Government agencies, your organization


Any category

Enforcing our legal rights pursuant to the laws of the jurisdiction from which the data was collected, or in other cases if we believe in good faith that disclosure is required by law

Compliance with a legal obligation to which we are subject, or our legitimate interests, namely administering our business and defense of claims

Any of the above sources

A court, tribunal, law enforcement agencies, regulatory authorities, government agencies, other involved parties and their professional service providers


Any category

Complying with legal process (such as a subpoena or court order), or a request by public and governmental authorities within or outside your country of residence, including international agreements (such as a mutual legal assistance treaty) when your data is in another jurisdiction

Compliance with a legal obligation to which we are subject

Any of the above sources

A court, tribunal, law enforcement agencies, regulatory authorities or government agencies, or another requester


Any category

Obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes, or in connection with an investigation of suspected or actual illegal activity

Compliance with a legal obligation to which we are subject, or our legitimate interests, namely administering our business

Any of the above sources

Our insurers and/or professional advisers

 

The MobileIron group companies are MobileIron, Inc., MobileIron International, Inc., Mobile Iron India Software Private Limited and MobileIron Software (Beijing) Co., Ltd. Details of MobileIron’s third-party service providers are available on our Legal webpage or by request via privacy@mobileiron.com.

We do not sell, rent, or otherwise disclose personal data about you, except as described in this notice.

Your controls and choices

You can exercise certain controls and choices about our collection, use and sharing of your personal data. Providing your personal data in the first place is optional but it may be necessary for certain MobileIron offerings, for example, to access whitepapers and other content, or to qualify your suitability as a vendor. In such cases, you may not be able to take advantage of requested offerings and some Site features, and some of our offerings may not be able to account for your interests and preferences.

Your online access and control. You can view, edit or delete your personal data online for some of the Sites and Services. You also can make choices about MobileIron's collection and use of your data. How you can access or control your personal data will depend on which Sites or Services you use. For example:

Your communication preferences. You can always choose whether to receive promotional email, short (text) message services, telephone calls and postal mail from MobileIron. To manage your communication preferences:

  • Visit our Subscription Center to opt out of receiving email.
  • Visit the Preference Center in the MobileIron Insider mobile app to opt out of notifications.
  • Follow the instructions included in a promotional email from us to unsubscribe.
  • Send us a message to the email or postal address listed below under Comments and questions, including your name, email address and specific, relevant information about the communications you no longer wish to receive.
  • Reply "STOP", "END", or "QUIT" to a text message.
  • Send us a message with your name to partnermarketingcenter@mobileiron.com to opt out of our sharing of your personal data with our channel and business partners so that they can send you information about products and services that may be of interest to you.

These choices do not apply to service notifications or other communications required for the purposes of carrying out your instructions, enabling you to make purchases you request and register for events or access to a Site or Service, administering your account, or as required by law, which you may receive occasionally unless you stop using or cancel the Site, Services and Products in accordance with their terms and conditions.

By using the Sites or Services or otherwise providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use. For example, if we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on one or more Sites, sending an email or contacting you in another way.

Browser-based controls. Browser-based controls related to cookies and other tracking technologies are described below in the Cookies and other tracking technologies section.

Community forums. You can choose whether to publish content in MobileIron’s community forums, user-editable documents and/or commenting systems made available by the Site or Services. Any information you provide there (including any personal data) may be indexed by search engines and made available in response to search queries and may be published, read, collected and used by others. We are not responsible for personal data you choose to submit in these forums.

Linked websites. You can choose whether to visit websites or third-party applications or widgets operated by other companies that we do not own or control via links on the Sites or Services. The links may have been added by us or by a visitor, such as in a submitted comment. The links do not signify our endorsement of the other website, its contents, or the third party that offers the site or contents. We are not responsible for the privacy practices of websites or other services operated by third parties. Linked sites may have their own privacy notices.

Your responsibilities. You are responsible for the information you provide or make available to MobileIron, and you must ensure it is honest, truthful, accurate and not misleading in any way; does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. If you provide any personal data concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for MobileIron to collect and use personal data as described in this notice before you provide it to MobileIron.

Cookies and other tracking technologies

Like many websites, the Sites use automatic data collection tools, such as cookies, embedded web links and web beacons. These tools collect certain standard information that your browser sends to the Sites.  Examples include your browser type and the address of the website from which you arrived at a Site.

They may also collect information about your Internet Protocol (IP) address, a number automatically assigned to your computer or device whenever you connect to the Internet. It is a unique address assigned by your Internet service provider or IT department on a TCP/IP network. Among other things, the IP address allows web servers to locate and identify your device. The automatic data collection tools also may collect information about your clickstream behavior. This includes, for example, the pages you view and the links you click. These tools help make your visit to our website easier, more efficient and more valuable by providing you with a customized experience and recognizing you when you return. You can block or delete cookies.

Some web browsers may give you the ability to enable a Do Not Track feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different from blocking or deleting cookies, as browsers with a Do Not Track feature enabled may still accept cookies. No industry standard currently exists on how companies should respond to Do Not Track signals, although one may develop in the future. The Sites do not currently recognize and respond to Do Not Track signals.

We partner with third parties to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies to provide you with advertising based on your browsing activities and interests. You may opt out of this advertising if you are located in the European Union or if you are located in all other parts of the world. Generic, non-personalized ads will continue to be displayed.

Our Sites include social media features, such as social media widgets that link to a social media website or allow you to share website content. These features may collect your IP address and the URL of the page you are visiting on a Site, and may set a cookie to enable the feature to function properly. Social media features such as widgets are either hosted by a third party or hosted directly on a Site. Your interactions with these features are governed by the privacy policy of the company providing it.

Storage and processing locations

Personal data collected by MobileIron may be stored and processed in your region or in any other country where MobileIron and our service providers maintain facilities, including any of MobileIron’s offices. As an integrated group of companies, MobileIron stores data primarily in the United States, where MobileIron and many of our service providers maintain processing operations. Wherever your personal data is transferred, stored or processed by us, we will take reasonable steps to safeguard it.

Security and retention

The security of your information is extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect personal data from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. 

We may scan messages automatically and check for spam, viruses, phishing and other malicious activity, illegal or prohibited content or violations of our agreements, this privacy notice or our other policies.

We will retain your personal data for the length of time needed to fulfill the purposes outlined in this notice unless a longer retention period is required or permitted by law. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The criteria we use to determine the retention periods include:

  • a specific retention period for a certain data type adopted and announced by us
  • the period for which the personal data is needed to provide our Services and Products and to operate our business (including maintaining and improving the performance of our Services and Products, keeping our systems secure, and maintaining appropriate business and financial records), as a general rule that establishes the baseline for most data retention periods
  • the period until you actively delete the data if it is the type you provided with the expectation that we will retain it until you affirmatively remove it
  • a longer period if there is no automated control that enables you to access and delete the personal data at any time
  • a shorter period if the personal data is a sensitive type
  • a period required by a legal, contractual, accounting or similar obligation to retain the data (such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation or legal holds in anticipation of litigation)
  • a period dictated by the statute of limitations on legal actions related to the subject matter of the data
  • a period necessary to protect your vital interests or the vital interests of another natural person

EEA and Swiss residents

This version of the notice includes changes made to prepare for the GDPR, including the following paragraphs.

Data Controller. If you are resident in the EEA or Switzerland, MobileIron, Inc. is the data controller responsible for your personal data. If you are an applicant to or personnel of any other MobileIron group company, the data controller will be MobileIron, Inc. jointly with that company.

Data subject rights. Under certain circumstances, you have the right to request access to your personal data and to rectify it, to object to personal data processing, to request erasure of your personal data, to withdraw your consent and to lodge a complaint with a competent data protection authority.

International transfers. We use a variety of legal mechanisms to help ensure that your rights and protections follow personal data transferred from the EEA and Switzerland to countries that have not been determined by the European Commission to have an adequate level of data protection. These mechanisms include standard contractual clauses approved by the European Commission, your consent and, for transfers to MobileIron, Inc. or MobileIron International, Inc. in the United States, the EU-US and Swiss-US Privacy Shield in accordance with our Privacy Shield Policy Statement.

Data protection representative. MobileIron International, Inc. is our data protection representative.

Children

Our Sites and Services are not intended for use by children. We will promptly delete any personal data collected from someone under the applicable age of consent.

Updates

We will update this notice occasionally and without prior notice to you to reflect changes in our practice. We will post a prominent notice on this Site if we make material changes to the notice.

Comments and questions

If you have a comment or question, please contact us by email at privacy@mobileiron.com or by post at 401 East Middlefield Road, Attn: Legal, Mountain View, CA 94043, USA.

Effective:  December 18, 2013
Updated: September 30, 2016
Updated:  May 15, 2018