PRIVACY NOTICE GSMA MOBILE APPLICATION
- Who we are and what is the purpose of this document?
The GSMA is a global organisation unifying the mobile ecosystem to discover, develop, and deliver innovation foundational to positive business environments and societal change. Our vision is to unlock the full power of connectivity so that people, industry, and society thrive.
This privacy notice (“Privacy Notice”) describes how GSM Association (“GSMA”, “we”, “us” or “our”) collects, uses, and shares Personal Information of our GSMA mobile application (“App”) users.
- What types of personal data we collect about you?
“Personal Information” refers to any information about you. Personal Information, sometimes referred to as “personal data”, may also have specific meanings under different privacy laws.
When you use our App, we may collect Personal Information about you. In some cases, you may choose what Personal Information you provide. In other cases, certain Personal Information is mandatory for us to be able to provide the service.
When you use our App, we may collect the following Personal Information about you:
- When you use the App without the registered User Profile:
- Usage Data: i.e. device IDs and/or models, location data, usage data, information on your use of the App.
- When you use the App with the registered User Profile:
- Contact Data: your first name, last name, email address;
- Profile Data: job title, company name, industry, country;
- Profile Image: an image or a photograph that you upload to the App(optional);
- Data on Interests: topics of interests you have selected in the App (i.e. mobile networks and connectivity, spectrum, internet of things, artificial intelligence, eSim, security, identity, etc.) as well as pinned GSMA content (optional);
- Biography Data: short description of your professional and academic background, preferences, and professional interests (optional);
- How do we use your data?
In the table below you may find information on the purposes we may use your data for, categories of information we collect about you and the legal basis for processing we rely on.
| Purpose | Data category | Lawful basis |
| Provision of the App for unregistered users You may use our App without User Profile. In such case we will collect limited information about you to provide the App service. | Usage Data | Legitimate interest Our legitimate interest includes providing our services to users and running the App efficiently and effectively. |
| User Profile registration and provision of the App for registered users All users can create User Profile in the App to have access to personalized newsfeed and content. | Contact Data Profile Data Usage Data Profile Image Biography Data | Legitimate interest Our legitimate interest includes providing our services to users successfully, meeting their professional interests with tailored newsfeed. |
| Personalised newsfeed All registered users who provided information about their interests and preferences may receive personalized newsfeed with content tailored to their interests. | Contact Data Profile Data Data on Interests Usage Data | Legitimate interest Our legitimate interest includes meeting professional interests of users and provide tailored content, news, and insights that will be interesting and useful for them. |
| Fixing bugs We may use your data to diagnose, troubleshoot, and fix issues with our App or services. | Contact Data Usage Data | Legitimate interest Our legitimate interest includes improving the security and safety of our Services and detect malicious activities. |
| Marketing based on consent We may send you marketing emails if you provide consent. We will ask for your consent in jurisdictions where it is required. | Contact Data Profile Data Data on Interests Biography Data Usage Data | Consent |
| Marketing based on legitimate interests We may use your data for marketing, promotion, and advertising purposes where the law does not require consent (e.g. when we use your Personal Information to tailor marketing emails or push notifications to your interests). | Contact Data Profile Data Data on Interests Usage Data | Legitimate Interest Our legitimate interest includes advertising to develop our services and improve our sales. |
| Push notifications All registered users upon their consent can receive push notifications regarding marketing and newsfeed updates. | Contact Data Profile Data Data on Interests Usage Data | Consent |
| Data subjects’ requests and support We may process your data if you make a data subject request (e.g. if you would like to access your data or erase your data), submit an enquiry or complaint. | Contact Data Profile Data Profile Image Data on Interests Biography Data Usage Data | Compliance with legal obligations / legitimate interest Our legitimate interest includes responding to your enquiry where the law does not require us to do so. |
| Analytics and App development To evaluate and develop new features, technologies, and improvements to the App. We may also analyse how you use our App to improve the services we provide within the App. | Contact Data Profile Data Profile Image Data on Interests Biography Data Usage Data | Legitimate Interest To enhance the App, grow our business, and ensure that our users will receive quality services. |
| Business planning, reporting, and forecasting We may analyse aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in. | Contact Data Profile Data Data on Interests Biography Data Usage Data | Legitimate Interest Our legitimate interests include researching and planning so that we can keep providing the App successfully. |
| Security We will use your data to keep the App secure and to detect and prevent fraud. | Contact Data Profile Data Usage Data | Legitimate Interest Our legitimate interests include protecting the App and our users against fraud and illegal activity. |
| Legal obligations We may use your Personal Information to comply with our legal obligations, for example to comply with a request from law enforcement, courts or other authorities. | Contact Data Profile Data Profile Image Data on Interests Biography Data Usage Data | Compliance with legal obligations |
If you do not register in our App and do not give us certain Personal Information, you can still enjoy many of the services in the App as many of our services and information in our App is available to unregistered users.
However, you will need to create your Profile in the App which involves providing some mandatory and optional Personal Information (i.e., Contact Data, Profile Data, Profile Image, Data on Interests, Biography Data) to receive personalised newsfeed and personalised push notifications on your mobile device.
Consent
Where we process your Personal Information based on consent, you can withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of processing we conducted before. We may still process your Personal Information on other lawful grounds.
Legitimate Interest
If we process your Personal Information based on our legitimate interests (or of a third party), you may object to such processing. In that case we will no longer process your Personal Information unless there are compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defence of legal claims.
Legal Obligations
When we rely on legal obligations as a lawful basis for processing your Personal Information, it means that such processing is necessary for us to comply with laws applicable to us.
- Marketing.
We may process your Personal Information for direct marketing purposes using different channels of communication (e.g. via the App, email, or phone) if you provide us with your consent or we have another lawful basis for sending marketing communications.
You can update your preferences and choices in relation to our marketing communications anytime, including unsubscribing from marketing communication in the App settings.
- Automated processing.
We will not use your Personal Information for ‘automated decision-making’ within the meaning of the GDPR. However, we will process your personal data automatically, but this will have no legal consequences for you or significantly affect you in any way.
- How do we collect your data?
We collect your data when you download and use the App or when you create a user profile. We may also collect your data when you communicate with us for example via emails.
- Who has access to your data?
We may share your Personal Information with the following recipients:
- Vendors, or service providers who perform functions on our behalf or for the purposes of providing services to us; for example, IT service providers or marketing agencies;
- Authorities, such as law enforcement, where we are required to do so by law or court order or where otherwise necessary to prevent or detect crime or serious wrongdoing;
- Auditors or legal counsels, or other professional service provider, where required for financial statements, reporting purposes, or where we need legal advice or other services to support our business operations;
- Our Affiliates where required for administrative purposes, group reporting, or receiving data processing services.
- International data transfers
As we operate via a global network of corporate offices, service centres, and data centres, it may be necessary to transfer your data internationally.
This means that Personal Information from the App may be transferred to a country outside of the country where it was originally collected or outside of your country of residence or nationality.
Where we transfer information that originates in the European Union (“EU”), the United Kingdom (“UK”) or Switzerland to a country outside the EU, the UK or Switzerland, we will take steps to make sure such transfer is carefully managed to protect your privacy rights. We use a variety of legal mechanisms, including Standard Contractual Clauses adopted by the EU Commission, to ensure your rights and protections travel with your data.
- How long do we keep your personal data?
Our general approach is to only retain your Personal Information for the duration of our legal relationship with your organization unless a longer period is required or allowed by law to comply with applicable legal, tax, or accounting requirements and thereafter to allow us to analyze the data for GSMA own operations, and for statistical, historical and archiving purposes for as long as is required to satisfy the purpose for which it was collected by us and where we have a legitimate business or legal need to do so (for example, to comply with applicable legal, tax or accounting requirements).
- Your European Union privacy rights as a data subject.
Find below a description of your privacy rights specific for the European Union.
Confirmation of processing – you can ask us to confirm if we are processing your Personal Information;
Access – you can ask us to provide a copy of the personal data that we hold about you;
Rectification – you can ask us to rectify the record of your personal data that we maintain;
Restrict or object to data processing – you can ask us to restrict the processing of your personal data or object to the processing of your personal data, including for marketing purposes and we will deal with such request in accordance with applicable law;
Deletion – you can ask us to delete some or all of the personal data that we hold about you; we will deal with such requests in accordance with applicable law;
Portability – in certain circumstances, you can ask GSMA to provide you a copy of your personal data in a structured, electronic format, or to transmit it directly to another data controller, where technically feasible.
- Contact us for information about how we use your personal data.
You can contact us with any enquiry relating to your Personal Information by filling out this form, sending an email to [email protected] or writing to Data Privacy – GSM Association, a trade association with its principal headquarters located at 1 Angel Lane, London EC4R 3AB, United Kingdom.
You also have a right to lodge a complaint with a relevant data protection authority if you have concerns about how GSMA processes Personal Information.