Privacy Policy

1. Introduction

This Privacy Statement applies to MobieTrain NV (“we”, “us”, “our”), with registered office at C-Mine 12, 3600 Genk, Belgium, and registered in the Crossroads Bank for Enterprises under number 0598.943.326.

When processing personal data in connection with the use of the MobieTrain software (the “Software”), we act as a data processor on behalf of your employer or client organization (“Client Organization”). That organization is the data controller, and this Privacy Statement is complementary to the privacy policies or notices issued by them.

The Software, known as the MobieTrain Mobile Micro Learning Platform, is a training solution designed to help employers train and engage employees. This Statement outlines how we collect, use, store, and protect personal data when delivering this service.

We are committed to protecting your privacy. This Policy explains how we collect, use, and protect personal data when you:

• Visit our website at www.mobietrain.com

• Submit a form or sign up for updates or a demo

• Interact with marketing communications

• Use our learning platform (the “Software”) via your employer

Depending on the context, we may act as:

• A data controller (e.g., for website visitors and leads)

• A data processor (e.g., when your employer provides access to the Software)

2. Personal Data We Process

a. Website Visitors and Leads

If you interact with our website or marketing channels, we may collect:

• Name, email, phone number (if submitted via forms)

• IP address, browser/device data

• Cookie preferences and usage tracking (if consented)

b. Platform Users (Software)

As a data processor for your employer (our client), we may process:

• First name and last name

• Email address

• Phone number

• Job title

• Store/department

• User group

• Employee ID

• Training session data and completion progress

3. Legal Basis for Processing

We rely on the following legal grounds:

As a data processor, MobieTrain only processes user data on instruction from the client organization (data controller).

4. Use of Cookies

We use HubSpot’s cookie management system to inform you and collect your preferences.

Our website uses:

• Strictly necessary cookies (for login/session security)

• Functional cookies (to remember user preferences)

• Analytics cookies (e.g., Matomo or HubSpot tracking – only with consent)

• Marketing cookies (e.g., LinkedIn or retargeting – only with consent)

You can review and change your cookie preferences at any time via the Cookie Settings in the footer.

More details are available in our Cookie Policy (link to separate policy page).

5. Purposes of Processing (Software Users)

When you access the MobieTrain Software, we process your data on behalf of your employer for purposes including:

• Providing secure access to the platform

• Assigning and tracking training modules

• Supporting learning analytics and progress reports

• Improving user experience and administrative efficiency

MobieTrain does not use this data for independent commercial purposes.

6. Data Retention

• Website contact submissions and lead data: up to 24 months unless you request deletion

• Marketing subscriptions: until you withdraw consent

• Software user data: retained as long as your account is active, or as instructed by your employer

• Data may be retained longer for compliance, legal obligations, or ongoing litigation

Deletion is performed by anonymisation or secure erasure.

7. Who We Share Data With

We may share personal data with trusted service providers under data processing agreements:

We do not sell or rent personal data. All subprocessors are bound by strict confidentiality and security obligations under GDPR.

8. Data Security

We implement both technical and organisational measures to protect your data, including:

• ISO27001-certified information security management

• Encryption (AES-256 at rest, TLS 1.3 in transit)

• Role-based access control and MFA

• Device management (JAMF) and firewall protections

• Physical access controls and staff NDAs

• Regular penetration testing and audits

No method of transmission is 100% secure, but we follow best industry practices.

9. Automated Decision-Making

We do not use automated decision-making or profiling that has legal or similarly significant effects on individuals.

10. Your Rights (GDPR)

As a data subject, you have the right to:

• Access your personal data

• Correct or update inaccurate data

• Request deletion (“right to be forgotten”)

• Restrict or object to processing (where applicable)

• Receive your data in portable format

• Withdraw consent (for marketing or analytics cookies)

To exercise your rights:

📧 Email: support@mobietrain.com
📧 DPO: rui.oliveira@mobietrain.com

If we are processing your data on behalf of your employer, we may redirect your request to them.

In some cases, we may request proof of identity before fulfilling your request.

11. Complaints

If you have concerns about how your data is handled, you may:

• Contact us directly at support@mobietrain.com

• Contact your employer (data controller)

• File a complaint with the Data Protection Authority in your country

Belgium’s supervisory authority:
Gegevensbeschermingsautoriteit (GBA)
📄 https://www.gegevensbeschermingsautoriteit.be

12. International Data Transfers

Some of our processors (e.g., HubSpot, Microsoft) may store data outside the EEA. In such cases, we ensure:

• Use of Standard Contractual Clauses (SCCs) approved by the European Commission

• Adequate security and data protection commitments

13. Updates to This Privacy Policy

We may update this Privacy Policy to reflect changes in the law or our services. When we do, we will revise the “Last updated” date above.

We encourage you to review this page periodically.

14. Contact

MobieTrain NV
C-Mine 12, 3600 Genk, Belgium
📧 General inquiries: support@mobietrain.com
📧 Data Protection Officer: rui.oliveira@mobietrain.com