Privacy Policy

Date of Last Revision: December 10th, 2024

This Privacy Policy sets out the ways in which we, C.F.M. Content For Mobile Ltd, collect and manage personal data through the service 1PLAY  and associated direct carrier billing payment processing (the “Service”), with whom it may be shared and your rights and choices in how your data is used.

Personal Data We Collect

The personal data we collect about you is solely used for and necessary to provide the Service.

We will collect some or all of the following information:
•    Your mobile number (which may be automatically requested from your network operator if you choose network operator billing)
•    Information about your browser and/or device and other attached metadata including language and locale settings;
•    Mobile network operator, or network connection identifiers.
•    Billing amount, product description and merchant.
Depending on the type of service we may also collect;
•    Email Address
•    Contact telephone number(s)

If you contact customer support you may be asked to share the following additional information which may be passed to us to help process your enquiry.
•    Your full name
•    Your email address(es)
•    Your residential or work address
•    Any other contact details provided to us by you including in email signatures

If you are a Customer then your mobile network operator may have passed to us some or all of the above data which we shall hold securely and use solely in accordance with this Privacy Policy.

When we conduct fraud monitoring, prevention and detection activities, we may also receive Personal Data about you from our business partners, financial service providers, identity verification services, and publicly available sources as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may use technology that helps us assess the risk associated with an attempted transaction that is enabled on the Merchant’s website or the application that collects information.

How We Use Personal Data

CFM  is committed to ensuring the information we obtain and use about you is processed in accordance with its intended purpose.
The ways we use your information are;
•    Authenticating and processing your transactions
•    Sending electronic communications to you as part of the service
Restricting access to services in the event of cancellation of recurring payments
•    Combatting and preventing fraud
•    Processing and responding to any Customer support enquires you make
•    Managing and understanding our ongoing relationship with you

All of the information that we process about you is done on the basis of one or more of the following;
•    Consent provided by you for us to process your data for a specific purpose;
•    For the provision of the Service to you;
•    To comply with legal obligations that we are subject to; and / or
•    For purposes which are in our legitimate interests, or those of third parties.
We will never offer your personal information for sale.

How We Disclose Personal Data
CFM does not rent, sell or share your personally identifiable information with non-affiliated third parties without your consent. We may, however, share personally identifiable information with trusted third-party contractors. These third party contractors are prohibited from using the information for purposes other than performing services for CFM.  CFM may disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person. We reserve the right to disclose aggregated, non-personally identifiable information collected to third parties for any purpose.  Finally, CFM may transfer information, including any personally identifiable information, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If CFM is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personally identifiable information, as well as any choices that are available to you.

Your Rights

In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:
The right to access;
The right to rectification;
The right to erasure;
The right to restrict processing;
The right to object to processing;
The right to data portability;
The right to complain to a supervisory authority; and
The right to withdraw consent.
You have the right to confirmation whether we process your personal data and, where we do, access to the personal data together with certain additional information including details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by emailing us at support@cfm.mobi

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The 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 defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and 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 data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

To the extent that the legal basis for our processing of your personal data is (a) Consent; or (b) that the processing is necessary for the performance of the Service with you or in order to take steps at your request prior to commencing the Service; and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. If you are in the EU or UK you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Otherwise you may do so with the data protection supervisory authority in your jurisdiction.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us via email to support@cfm.mobi or via post to Data Protection Officer, C.F.M. Content For Mobile Ltd, Georgiou Seferi 2, Fasoula 4551, Limassol, Cyprus

Security and Retention

The specific period for which CFM is required to retain personal data depends on the nature of the data held and the context in which it is held. It is also driven by legal, regulatory and contractual obligations. CFM will always retain data for the minimum period necessary. CFM maintains a comprehensive list of retention periods according to data category and has technical and organisational systems and procedures implemented to enforce these.

International Data Transfers

CFM is a company operating in multiple jurisdictions around the world. As described in this Privacy Policy, we may share your information with third parties which may require us to export your information described in this Privacy Policy across national boundaries. If this occurs such data transfers shall be made in compliance with local data protection laws which may include either transfers to countries on an approved list of safe destinations, or where CFM has ensured appropriate safeguards with such third parties for the transfer of your personal information in compliance with such organisational and technological safeguards as are necessary to protect your privacy.

Use by Minors

We do not knowingly collect or store personally identifiable information from anyone under the age of 16 unless or except as permitted by law. Any person who provides personally identifiable information through the Website represents to us that he or she is 16 years of age or older. If we are made aware that we have received personally identifiable information from someone under 16, CFM will use reasonable efforts to remove that information from our records.

Updates To this Privacy Policy and Notifications.

CFM may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to CFM’s Privacy Policy will be reflected here and the date new versions are posted will be stated at the top of this Privacy Policy. 

Links To Other Websites, Products or Services

The Services may also provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

Contact

If you have any questions regarding our Privacy Policy, please contact our privacy officer at:  support@cfm.mobi