Privacy Policy

The mTab group comprises mTab LLC, mTab sp. z o.o., and Gamma Associates LTD (collectively referred to as “mTab,” “we,” “us,” “our”). This Privacy Policy applies to all mTab undertakings. 

This Privacy Policy sets forth our current privacy practices with regard to the information and data we collect when you interact with our site or by using our services. This online Privacy Policy applies only to information and data collected online. 

Please note that if you are a California resident special provisions of section X. Additional Notice for California residents apply to you, in accordance with the California Consumer Privacy Act.

Please note that this privacy policy is supplemented with information about the Data Privacy Framework program (section XI). This information, however, is relevant only to Personal Information processed by mTab LLC which is making efforts to join this program.

The integral part of this Privacy Policy is our Cookies Policy, where you can learn more about our use of cookies or other similar technologies.

We may revise this Privacy Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.

This Policy covers the following:

I. Glossary

Below you will find an explanation of the basic terms used in this Privacy Policy. 

Applicable laws” means all the laws and regulations relevant to the collection, processing and storage of data, especially all the data protection laws, including and the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

Cookies” means small text files placed by the browser on the end device of the user visiting the website. Cookies most often contain the name of the website they come from, the storage time on the end device and a unique identifier.

Legal Grounds” means the legal basis for the collection, processing and storage of your Personal Information, as defined in Applicable laws.

Personal Information” means any information relating to an identified or identifiable natural person, such as e-mail address, name, home or work address, telephone number, online identifiers (i.e. IP address), as defined in Applicable laws, particularly in article 4.1 of GDPR and Section 1798.140 of CCPA. 

Website” means the mTab website https://www.mtab.com/ 

Services” means services provided by mTab via Website in accordance with the Terms of Service.

II. Data controller

When you are visiting the Website your Personal Data will be collected and controlled by mTab LLC 22800 Savi Ranch Parkway, Suite 218 Yorba Linda, CA 92887 US. 

When you are using the Services, your Personal Data will be collected and controlled by the mTab undertaking that is providing Services to you or communicating to you and each such entity is therefore regarded as an independent data controller.

The contact addresses of mTab: 

mTab LLC - 22800 Savi Ranch Parkway, Suite 218 Yorba Linda, CA 92887, e-mail:dsar@mtab.com
Gamma Associates LTD -  4 Argent Court, Sylvan Way, Laindon, Essex SS15 6TH UK, e-mail:dsar@mtab.com.

III. Personal Information we collect and where we get it

‍mTab collects and therefore processes the following Personal Information that you give to mTab (including when you use the Website, email us or contact us through various methods, use our Services) or that mTab obtains from its clients, partners or suppliers:

  • when visiting the mTab Website: in our effort to better understand how visitors use mTab's Website, you may provide us with information such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, and Internet Protocol address.
  • when signing up for mTab Services: when you sign up for newsletters, webinars, events or obtain any of our services, or when you contact us with queries, or respond to our communications the information you provide may include your full name, title, telephone number, email address and additional content, and information about your current or previous employers or your business.
  • when providing mTab Services: if you are a client, partner or preferred supplier of mTab, you may provide us with information when you, or the company you represent, become a client, partner or preferred supplier with us. If you are not a client, partner or preferred supplier we may still collect or receive your personal information because you are involved in one of our client’s activities.

IV. How we use the Personal Information and what are the Legal Grounds

Below we listed the description of processing activities that we may perform on your Personal Information. As your local law may require to set out the Legal Grounds that we rely on in order to process your Personal Information, we also listed them below. 

Purpose Legal Ground
  • Providing mTab Services 
Processing is necessary to the performance of a contract (article 6.1. point b) of GDPR).
  • Responding to your inquiries 
  • looking into any complaints, concerns or issues you may have
  • establishing, exercising or defending our legal rights or for the purpose of legal proceedings
  • preventing and responding to actual or potential fraud or illegal activities
  • undertaking business research and analysis, managing the operation of our business and improving our Websites and interfaces
  • recording and monitoring your use of our Website, social media or our other services for mTab business purposes. (This may include analysis of usage, measurement of website performance and generation of marketing reports. This data is used to deliver customized content and advertising within mTab to customers whose behavior indicates that they are interested in a particular subject area).
Processing is necessary for the purposes of the legitimate interests pursued by us (article 6.1. point f) of GDPR), namely in order to:
  • respond to your inquiries 
  • look into any complaints, concerns or issues you may have
  • establish, exercise or defend our legal rights or for the purpose of legal proceedings
  • prevent and respond to actual or potential fraud or illegal activities
  • undertake business research and analysis, manage the operation of our business and improve our Websites and interfaces
  • record and monitor your use of our Website.
  • Engaging in marketing and business development activities in relation to our Services (this may include sending you information to inform you of other products or services available from mTab and its affiliates, marketing communications and other information that we believe may be of interest to you) mTab may also contact you using surveys to gather research about your opinion of current services or of potential new services that may be offered. You can unsubscribe at any point.
Your consent to the processing of Personal Information (article 6.1. point a) of GDPR). You can withdraw your consent at any time by contacting us (see section XI. How to contact us).
  • Complying with legal and regulatory obligations that we have a duty to discharge
Processing is necessary for compliance with a legal obligation to which we are subject (article 6.1. point c) of GDPR). 

V. How we share information with third parties

We share Personal Information internally with the various entities that make up our company especially to mTab sp. z o.o. - ul. Krolowej Jadwigi 43, 61-871 Poznan. We may also share your Personal Information outside of mTab. This may include:

  • Third party agents/suppliers or contractors, bound by obligations of confidentiality in connection with the processing of your Personal Information, for the purposes described in this Privacy Policy. This may include, but is not limited to, our IT and communications service providers.
  • Third parties relevant to the Services that we provide. This may include, but is not limited to, counterparties to transactions or litigation, other professional service providers, regulators, authorities, governmental institutions.
  • mTab may share data with trusted partners to help us perform statistical analysis, send you email or postal mail about Services you are interested in, provide customer support, or arrange for deliveries. All such third parties are prohibited in writing from using your Personal Information except to provide these services to mTab, and are required to maintain the confidentiality of your information.
  • To the extent required by law, regulation or court order. For example, if we are under duty to disclose your personal information in order to comply with any legal obligation.

VI. International transfer of Personal Information

If you are a citizen of the European Union/European Economic Area (EU/EEA) your Personal Information may be transferred to locations outside of the European Union/European Economic Area (EU/EEA) for the purposes previously described above. If we transfer your personal information outside Europe as a matter of course, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. 

For instance mTab have signed a contract based on “contractual clauses” approved by the European Commission, obliging them to protect the personal information

In other circumstances, the law itself may permit us to otherwise transfer your Personal Information outside Europe. In all cases, however, any transfer of your Personal Information will be compliant with the applicable data protection law and with appropriate safeguards in place.

If you are located in the EU / EEA, you may contact us if you require a copy of the safeguards which we have put in place to protect your Personal Information transferred outside of the EU / EEA and your privacy rights in these circumstances.

VII. Retaining your Personal Information and how we secure it

mTab keeps your Personal Information no longer than it is necessary for the purposes for which they are processed, using generally accepted security standards and in compliance with Applicable Laws. 

How long mTab keeps your Personal Information in a specific case will vary and will depend primarily on:

  • the purpose for which we are using your Personal Information – we will need to keep the Personal Information for as long as it is necessary to fulfill the relevant purpose of processing; the appropriate retention period is determined by the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process and whether we can achieve those purposes through other means, and the applicable legal requirements.
  • legal obligations – in some cases, Applicable Laws or regulation may set a minimum period of time for which we have to keep your Personal Information.

Upon expiry of the applicable retention period, we will securely destroy your Personal Information in accordance with the Applicable Laws and regulations. mTab ensures that the Personal Information that we hold is subject to the appropriate security measures. 

If you need more detailed information about the retention of your Personal Information or applicable security standards adopted by mTab, please contact us (see section XI. How to contact us). 

VIII. mTab Cookies Policy

The mTab Web site use “cookies” to help you personalize your online experience. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize mTab’s pages, or register with mTab site or services, a cookie helps mTab to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same mTab Web site, the information you previously provided can be retrieved, so you can easily use the mTab features that you customized.

Before entering our website, you have the option to accept or reject the use of cookies. For additional information, including: how to see what cookies have been set, how to manage and delete them or how long they are stored, as well as who our cookie providers are, please visit Cookie Settings.

If you would like to find out how to change your cookie settings, please visit Cookie Settings.

IX. Your rights

You have a number of rights in relation to the Personal Information that mTab hold about you and you can exercise your rights by contacting us directly. These rights include:

Right to be informed the right to obtain information related to the processing of your Personal Information by the controller; mTab exercises this right by publishing this Privacy Policy and Cookies Policy.
Right of access the right to access your Personal Information and request a copy of Personal Information that we hold about you.
Right of rectification the right to request us to immediately correct your Personal Information if it is inaccurate or incomplete.
Right to erasure sometimes also called as ‘right to be forgotten’; in some cases you have the right to obtain from us the erasure of your Personal Information without undue delay. Those cases include situations when Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; Personal Information has been unlawfully processed.  However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
Right to restriction of processing in some cases you have the right to restrict the processing of your Personal Information. Those cases are the following: you contest the accuracy of Personal Information; processing is unlawful but you oppose erasure; we no longer need Personal Information for the purposes of our processing, but you require Personal Information for the establishment, exercise or defense of legal claims; you have objected to processing, pending the verification of that objection.  Where processing has been restricted on this basis, we may continue to store your Personal Information. However, we will only process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
Right to data portability the right to receive Personal Information that you provided to us, in a structured, commonly used, machine-readable format, and the right to transfer this Personal Information to another controller without obstruction on our part, if the Personal Information processing is carried out by automated means.  The right to data transfer is applicable to you if your Personal Information is processed in an automated form based on your consent or on the basis of a contract.
Right to object the right to object at any time - for reasons related to your particular situation or in connection with the processing of your Personal Information for direct marketing purposes - to the processing of your Personal Information, when the processing is necessary to perform a task carried out in the public interest or for purposes arising from legitimate interests pursued by us.
Right not to be subject to a decision based solely on automated processing the right not to be subject to a decision which is based solely on automated data processing, including profiling, and produces legal effects on you or similarly significantly affects you. Please note that this right does not apply, for example, when the processing is based on your explicit consent.
Right to withdraw consent the right to withdraw at any time consent to the processing of your Personal Information granted to us; withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal.

mTab LLC will offer individuals the opportunity to choose (opt-out) whether their personal information is to be disclosed to a third party, or to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. mTab LLC will provide individuals with reasonable mechanisms to exercise their choices.

If you believe that the processing of your Personal Information by mTab violates the Applicable Laws, you also have the right to lodge a complaint with the data protection supervisory authority

Additionally, mTAB is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Please visit the FTC website for further information.

X. Additional Notice for California residents

If you are a California resident as defined in the California Code of Regulations (i.e. (1) individual who is in the State for other than a temporary or transitory purpose or (2) individual who is domiciled in the State who is outside the State for a temporary or transitory purpose) – please note that special additional provisions of this section apply to you, in accordance with the CCPA.

In matters not covered in this section, the remaining provisions of this Privacy Policy apply to you.

A. California residents rights

CCPA provides additional privacy protections including: 

  • the right to request deletion of your Personal information (right to delete),
  • the right to request correction of inaccurate Personal Information (right to correct)
  • the right to request access to your Personal information and request additional details about our practices regarding the processing of your Personal information (right to access), 
  • the right to request information what Personal Information is sold or shared and to whom (right to know what information is sold or shared and to whom)
  • the right to opt out of the sale or sharing of your Personal information (right to opt out), 
  • the right to limit use and disclosure of sensitive Personal Information (right to limit use), and
  • the right to not be discriminated against for exercising any of your rights granted under the CCPA (right not to be discriminated). 

To submit any of the above mentioned request please contact us by e-mail dsar@mtab.com.

mTab does not sell your Personal information, hence the right to opt-out does not apply to you (please check detailed information below in this section).

Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

B. Disclosure

Categories of Personal Information. 

We may collect the following categories of Personal information about you: 

  • Name and surname
  • Mobile telephone number
  • E-mail address
  • when you interact with our Website, we may also automatically collect information from your activities through the usage of Cookies, log data and similar technologies on our Website.

We may have collected all of the above listed categories of your Personal Information during the 12-month period prior to the effective date of this Privacy Policy.

Categories of sources from which Personal Information is collected. 

We collect your Personal Information directly from you, including through your usage our Website. 

Purposes of use of Personal Information. 

We may use the categories of Personal information listed above for the purposes of: 

  • responding to your inquiries,
  • monitoring compliance with our Terms of Service,
  • improving Services, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement,
  • pursuing claims or defending against claims,
  • ensuring accountability (demonstration of compliance with our obligations under the law),
  • storing data for archiving or statistical purposes,
  • performing marketing of our products and Services.

In addition, we may use these categories of Personal information for certain business purposes, as specified in the CCPA, in particular as described in this table:

Categories of Personal Information Business purposes of use of Personal Information
All of the above listed categories.   Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
All of the above listed categories.   Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes
All of the above listed categories.   Debugging to identify and repair errors that impair existing intended functionality.
All of the above listed categories.   Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
All of the above listed categories.   Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
All of the above listed categories.   Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers.
All of the above listed categories.   Undertaking internal research for technological development and demonstration.
All of the above listed categories.   Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

We may have used your Personal Information for the above listed purposes during the 12-month period prior to the last update of this Privacy Policy.

Categories of third parties to whom we may disclose Personal Information. 

If it is necessary to perform our business purposes we may share your Personal information in the manner, however, that does not constitute “sell” under CCPA (for example with the parties on behalf of which we operate). Particularly, we may share your Personal information with third parties or allow them to collect Personal information from our sites or services if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal information.

We may have disclosed (shared) the following categories of your Personal information during the 12-month period prior to the last update of this Privacy Policy: all of the above listed categories. 

For detailed information concerning categories of third parties with whom we may share your Personal information please see section VI. How we share information with third parties.

C. Sale of Personal Information

Please note that mTab does not and will not sell Personal information of their customers, as defined in in section 1798.140 of the CCPA.

XI. Data Privacy Framework

mTab LLC is an American company headquartered in Yorba Linda. As part of mTab LLC's cooperation with other business entities, Personal Information may be transferred from member countries of the European Union or the United Kingdom to the United States. As of July 10, 2023, the rules for such transfer are set forth in the Commission Implementing Decision of 10.7.2023 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate level of protection of personal data under the EU-US Data Privacy Framework [LINK].

The EU-U.S. DPF is based on a system of certification by which U.S. organizations commit to a set of privacy principles (“Principles”) [LINK]. 

mTab LLC hereby undertakes to apply the DPF Principles to all Personal Information that mTab LLC receives from member countries of the European Economic Area and the United Kingdom based on the relevant DPF.

mTab LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. mTab LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

In this Privacy Policy, mTab informs you about the actions it takes with respect to Personal Information received by mTab LLC, including:

  • the types of Personal Information collected;
  • the purposes for which mTab LLC collects and uses Personal Information;
  • the type or identity of third parties to which mTab LLC discloses Personal Information and the purposes for which it does so;
  • the right of individuals to access their Personal Information;
  • the choices and means mTab LLC offers individuals for limiting the use and disclosure of their Personal Information;
  • its liability in cases of onward transfers to third parties;
  • how to contact mTab LLC;
  • mTab LLC's liability and how to resolve disputes arising in connection with the Principles.

The types of Personal Information collected

To find out what types of Personal Information mTab LLC collects, please take a look at section III (“Personal Information we collect and where we get it”).

The purposes for which mTab LLC collects and uses Personal Information

To find out what are the purposes for which mTab LLC collects and uses Personal Information, please take a look at section IV (“How we use the Personal Information and what are the Legal Grounds”).

The type or identity of third parties to which mTab LLC discloses Personal Information and the purposes for which it does so

To find out about the type of identity of third parties to which mTab LLC discloses Personal Information and what are the purposes for which it does so, please take a look at section V (“How we share information with third parties”).

The right of individuals to access their Personal Information

You have right to access Personal Information about you that mTab LLC holds. You also have right to correct, amend, or delete that Personal Information where it is inaccurate, or has been processed in violation of the Principles. However, the exception is where the burden or cost of providing access would be disproportionate to the risks to your privacy in a particular case or where the rights of persons other than you would be violated.

To learn more about other rights that you have, please take a look at section IX (“Your rights”).

The choices and means mTab LLC offers individuals for limiting the use and disclosure of their Personal Information

To find out about the choices and means mTab LLC offers you for limiting the use and disclosure of your Personal Information, please take a look at section VII (“Retaining your Personal Information and how we secure it”). Please remember that if we process your data with your consent, then you are entitled to withdraw it at any time. The withdrawal of consent shall not, however, affect the lawfulness of processing based on consent before its withdrawal.

mTab LLC’s liability in cases of onward transfers to third parties

Any transfer of Personal Information by mTab LLC to a third party acting as an controller will be made in accordance with the notice provided by us and based on the choice you made. In order for such transfer to take place, mTab LLC is first required to enter into an agreement with the third-party controller. Such agreement will stipulate, among other things, that the data may only be processed for limited and specified purposes consistent with the consent you gave, and that the recipient will provide the same level of protection as the Principles and will notify mTab LLC if it makes a determination that it can no longer fulfill this obligation. The agreement will provide that upon such determination, the third-party controller will cease processing or take other reasonable and appropriate steps to remediate.

In order for us to transfer Personal Information to a third party acting as an agent, mTab LLC must: (i) transfer such data only for limited and specified purposes; (ii) ensure that the agent is required to provide at least the same level of privacy protection as required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the transferred personal data in a manner consistent with mTab LLC's obligations under the Principles; (iv) require the agent to notify mTab LLC if it determines that it is no longer able to meet its obligation to provide the same level of protection as required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) upon the Department's request, provide a summary or representative copy of the relevant privacy provisions in its contract with the agent.

mTab LLC shall remain liable under the Principles if its agent processes such Personal Information in a manner inconsistent with the Principles, unless mTab LLC proves that it is not responsible for the event giving rise to the damage.

How to contact mTab LLC

To find out how you can contact mTab LLC, please take a look at section XI (“How to contact us”).

mTab LLC's liability and how to resolve disputes arising in connection with the Principles

The statutory authority with jurisdiction to hear any claims against mTab LLC for possible unfair or deceptive practices and violations of laws or regulations governing privacy is the Federal Trade Commission.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, mTab LLC commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

For more information about JAMS please visit their website: https://www.jamsadr.com/

Before you file a complaint with JAMS or submit your case to arbitration, you should contact mTab LLC by sending your complaint to the e-mail address: DSAR@mtab.com. You can also send your complaint to the postal address: mTab LLC, 22800 Savi Ranch Parkway, Suite 218, Yorba Linda, CA 92887.

Please remember that, under certain conditions, you may be able to invoke binding arbitration. The purpose of this option is to provide a prompt, independent, and fair mechanism, at the option of individuals, for resolution of any claimed violations of the Principles not resolved by any of the other EU-U.S. DPF mechanisms. To learn more, please see Annex I to the Principles (https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf).

XII. How to contact us 

If you would like further information on the collection, use, disclosure, transfer or processing of your personal information by mTab or the exercise of any of the rights listed above, please contact us. You can do this by:

  • Writing to us: mTab LLC, 22800 Savi Ranch Parkway, Suite 218, Yorba Linda, CA 92887
  • Emailing us: DSAR@mtab.com
  • Telephone us: (800) 693-3111

Date of last revision: March 25, 2024