1. How We Collect Information
Personal information is collected in the following ways:
1.1 Information you provide us directly, including information given from account registration or by phone, information submitted in an application form or agreement for our products and/or service, and information submitted through MOGO APP or the website;
1.2 Information we may receive from third parties, such as our overseas partner operators who provide telecommunication services, our distributors, any business partners or any related entities, or a representative by your consent;
1.3 Record of your product and service purchase and usage;
1.4 When you voluntarily provide to us when visiting our official website or participating in our online services, for example, when you contact us on our website or via email with a question or comment or participate in an online survey;
1.5 Other methods from which we may collect and add your Personal Information to our customer database. If you choose to restrict our collection or use of your personal information, it may affect the services provided to you.
2. Information We Collect
Information collected depends on the products and services you use or have used, including, but not limited to, the following:
2.1 Required information given in account registration, including your username, password, email, and phone number.
2.2 Payment details when purchasing A La Carte products, including your credit card number, savings card number, and other personal information you fill in.
2.3 Information provided by you on your product, service, lifestyle or recreational preferences, or our assumptions of your preferences based on your purchase history.
2.4 Communication details retained during your contact with us, such as call detail records or communication records in written form.
2.5 Information from your A La Carte account, such as payment date, recharge history, ordered service, and any other information related to your account.
2.6 If your mobile device has tracking and positioning abilities, information on your geographical location will be collected (e.g. with GPS or Wi-Fi) when using our service.
3. How We Use The Information We Collect
3.1 To facilitate A La Carte’s operations, such as importing your information into our database for the purposes of analysis, research, troubleshooting, testing, auditing, statistics and investigation.
3.2 Improvement of our products and services according to the information we collect.
3.3 A La Carte partners with other companies to send you recommendations (or through the platform of our business partners) of new products, special offers, or other information that may interest you (unless you choose to opt out of receiving them).
3.4 To help you manage your products and services from A La Carte and keep you up to date on your order status.
3.5 According to the information you provide, our customer service representatives can provide better customer support to answer queries from you, which could be related to data network, products or services.
3.6 According to the information you provide, we may contact you to conduct market research through phone call, fax, email, or mail. We can also customize our website based on the preferences of our consumers and users.
3.7 Used for authentication, customer service, security, fraud monitoring, archiving and backup purposes, to ensure the safety of the products and services we offer you.
3.8 Any other purpose that is directly related to the above situations. Remarks: We will only retain your personal information for as long as needed, to the extent permitted by law. After you contact us, we may retain your information for as long as it is reasonably required to facilitate your use of our products and services in the future.
4. Sharing Information
A La Carte will not sell your personal data to third parties, but will share them in the following cases:
4.1 Sharing under explicit consent: We will share your personal data to other parties with your knowledge.
4.2 Sharing to authorized partners: A La Carte may share your information to third-party logistics to arrange the delivery of your product or to provide you other services after making a purchase online. Your personal data is obtained and processed only for specified and lawful reasons, and only required information will be provided to our partners. We do not allow our affiliates and partners to share or use any of your personal data for any other purpose.
4.3 Sharing of information is based on law and reasonable basis, including, but not limited to: If law, legal process, litigation and/or requests from public and governmental authorities within or outside your country of residence requires, we may share your personal information. In the event that we are involved in reorganization, merger, bankruptcy or litigations, your information may be transferred as part of that transaction. A La Carte may also disclose your personal data under reasonable and necessary circumstances, such as to execute our terms and conditions or to protect the customer.
5. How To Visit Your Information
5.1 We will try to take appropriate technical measures to ensure that you can access, update and correct your registration information or use other personal information provided by our service.
5.2 When you visit, update, correct, and delete the aforementioned information, we may require you to authenticate to secure your account.
5.3 You can visit the A La Carte's website to login and help us ensure that your information is accurate, complete and update instantly.
5.4 Whenever you voluntarily disclose your personal information, such information may be collected and used by others. A La Carte is not responsible for your personal information disclosure. Therefore, we remind you to consider carefully whether it is necessary to disclose your personal information.
5.5 Our business may require us to transfer your Personal Data to other countries. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard contractual clauses. A copy of those clauses can be obtained by contacting our Support Center.
6.1 We use strict procedures and security measures to protect your personal information against unauthorized access, disclosure, use, alteration, damage, or loss of data.
6.2 We will take all reasonable steps to protect your personal information saved on our platform, such as from MOGO APP registration, recharge and so on. These measures include:
6.2.1 Using encryption to ensure data confidentiality;
6.2.2 Using reliable protection mechanisms to prevent your personal data from hackers and malwares.
6.2.3 Deploying an access control mechanism to ensure that only certain authorized employees within A La Carte can access our users’ personal data;
6.2.4 Conducting security and privacy training courses on a regular basis to strengthen internal staff knowledge on the importance of protecting personal data.
6.3 A La Carte makes every effort to ensure that personal data unrelated to our operations will not be collected. We will only retain your personal data within the time required to achieve the purpose of the Policy, unless an extension of the retention period is needed or if it is legally permitted.
6.4 While no security procedures are completely foolproof, we make every effort to protect your personal data.
7. Your Rights
7.1 Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.
7.2 Where the use of your information is based on consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.Requests should be submitted by contacting us through [Support Center].
7.3 If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.
7.4 We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.
8.1 We may send email or news to your devices. If you do not wish to receive this information, you can cancel the subscription on the device according to our instructions.
8.2 We may issue announcements to you when necessary (for example, when a service is suspended due to system maintenance). You may not be able to cancel these services and properties that do not belong to promotion.
8.3 We recommend that minors seek parental or guardian consent and guidance before submitting personal information.
9. Legal Basis For Data Processing
9.1 Our legal basis to process personal data includes processing:
9.1.1 Necessary for the performance of the contract with you. For example, to provide you with the services you request and to identify and authenticate you so you may use the Sites;
9.1.2 Necessary to comply with legal requirements. For example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement
9.1.3 Necessary for our legitimate interests. For example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services.
9.2 In some instances, you may be required to provide us with Personal Data for processing as described above, in order to provide you all of our services, and for you to use all the features of our Sites.
10. Final Note