This Privacy Policy explains how Gomobee LTD (“the Company”, “we”, “us” or “our”) collects, uses, shares and protects your personal data when you visit downloadexy.com (the “Website”) or use the DownloadExy subscription service (the “Service”).
Contact Details
Company: Gomobee LTD
Address: Mindo, 113, Mdina Road, Qormi QRM 9016, Malta
Email: help@gomobee.xyz
Website: downloadexy.com
Gomobee LTD is the data controller responsible for your personal data.
General Information
The Company is committed to respecting your privacy and to ensuring the protection and security of your personal data. This policy explains how we collect, process and protect the personal data you provide to us.
Please read this Privacy Policy carefully. It has been written in a clear and simple manner so that you can freely and voluntarily decide whether you wish to provide your personal data to the Company.
Necessary Data
The data requested during the subscription process is mandatory unless a field is marked as optional. If you do not provide the mandatory data, we may not be able to provide the Service to you.
What Data Do We Collect?
We collect the data we request from you and, in all cases, the data marked as mandatory to provide the Service. This includes:
When you visit the Website:
- Technical data: IP address, browser type and version, device type and operating system.
- Location data: approximate location (such as country or city) derived from your IP address.
When you subscribe or register:
- Identification and contact data: mobile phone number and email address.
- Subscription and billing data: mobile operator, subscription start and end dates, subscription status and records of charges.
When you contact us with a question or complaint:
- Identification and contact data: first name, last name, mobile phone number and email address.
- Refund data: bank account details and mobile operator invoices, used only to verify charges and process refunds.
- Correspondence: the content of your messages and our replies.
We do not intentionally collect special categories of personal data, such as data about health, religion or political opinions.
If you provide personal data about a third party, you confirm that you have their consent and that you will inform them of the contents of this Privacy Policy. The Company is not responsible for any failure on your part to do so. However, the Company may carry out reasonable checks to verify this, in accordance with applicable data protection laws.
How Do We Collect Your Personal Data?
We collect data about you through the following methods:
Direct interactions. You may provide data by filling in forms on our Website or by contacting us by post, phone, email or otherwise, including when you:
- order our products or services;
- create an account on our Website;
- subscribe to our Service or publications;
- request resources or marketing to be sent to you;
- enter a competition, prize draw, promotion or survey; or
- give us feedback.
Automated technologies or interactions. As you use our Website, we may automatically collect technical data about your device and browsing actions using cookies, server logs and similar technologies. We may also receive technical data about you if you visit other websites that use our cookies. See the Cookies section below for more information.
Third parties or publicly available sources. We may receive personal data about you from:
- mobile operators and billing aggregators that process subscription payments;
- business partners, suppliers and subcontractors, for the performance of any contract we enter into with them or with you;
- advertisers and advertising networks that use the data to select and serve relevant adverts to you and others;
- analytics and search engine providers that help us improve and optimize our Website; and
- regulatory due diligence checks, which may involve personal data.
Why Do We Use Your Personal Data?
We only use your personal data when the law allows us to. The purposes and legal bases are:
- To perform our contract with you: managing the products and subscription plans you select, delivering the Service, and processing the mobile payments you authorize.
- To handle your requests: managing, processing and responding to your questions, incidents, complaints and claims and, where applicable, processing refunds.
- For our legitimate interests, where your interests and fundamental rights do not override them: producing anonymous statistical reports on how users access and use the Website; maintaining, supporting and updating the Website; resolving technical incidents; and preventing fraud and misuse of the Service.
- To comply with legal obligations: meeting tax, accounting and regulatory requirements, and responding to lawful requests from public authorities.
- With your consent: sending you marketing communications by email or SMS, and placing non-essential cookies on your device.
You can withdraw your consent at any time by emailing help@gomobee.xyz or by using the unsubscribe link in our marketing messages. Withdrawing consent does not affect the lawfulness of any processing carried out before you withdrew it.
Who Can Your Personal Data Be Shared With?
Your data may be shared with:
- Mobile operators and billing aggregators, to process subscription charges, cancellations and refunds.
- Our suppliers, such as hosting, IT and customer support providers, where access is necessary to provide the Service or meet legal obligations. These suppliers act only on our instructions and do not use your data for their own purposes.
- Public authorities, where required by law.
- Companies within our group, for the purposes described in this Privacy Policy.
We do not sell your personal data.
International Data Transfers
The Company is based in Malta, within the European Union. Some of our suppliers or group companies may be located outside the European Economic Area (EEA). When we transfer personal data outside the EEA, we make sure it is protected by appropriate safeguards, such as an adequacy decision of the European Commission or the Standard Contractual Clauses approved by the European Commission. You can request a copy of these safeguards by contacting us.
How Long Do We Keep Personal Data?
We keep personal data only for as long as necessary for the purposes it was collected for:
- Subscription data: while your subscription is active, and afterward for as long as needed to handle complaints, refunds or legal claims.
- Billing and payment records: for the period required by applicable tax and accounting laws.
- Customer service data: for as long as needed to resolve your request and any related claims.
- Marketing data: until you withdraw your consent or object to the processing.
When personal data is no longer needed, we securely delete or anonymize it.
User Responsibilities
By using the Service, you:
- confirm that you are at least 18 years old and that the data you provide is true, accurate, complete and up to date, and agree to update it whenever it changes;
- confirm that you have informed any third parties whose data you provide of the contents of this Privacy Policy, and that you have their permission to share their data with the Company for the purposes described; and
- accept responsibility for any false or inaccurate information you provide.
Your Rights
You can exercise the following rights at any time, free of charge, by emailing help@gomobee.xyz or writing to the address in the Contact Details section, with the subject “Data Protection”:
- request access to your personal data;
- request correction of your personal data;
- request erasure of your personal data;
- object to the processing of your personal data;
- request restriction of the processing of your personal data;
- request the transfer of your personal data (data portability); and
- withdraw your consent to the processing of your personal data.
We will respond within one month of receiving your request. We may ask you to verify your identity before acting on it.
You also have the right to lodge a complaint with a data protection authority. In Malta, this is the Information and Data Protection Commissioner (IDPC), idpc.org.mt. You can also contact the data protection authority in your country of residence.
You can read more about these rights at https://gdpr.eu/what-is-gdpr/.
Security Measures
The Company treats your data as strictly confidential, in accordance with applicable law. We use the technical and organizational measures necessary to protect your data against alteration, loss and unauthorized processing or access. These measures take into account the state of technology, the nature of the data stored and the risks it is exposed to.
Cookies
Our Website uses cookies to distinguish you from other users. This helps us give you a good experience when you browse the Website and allows us to improve it.
A cookie is a small file of letters and numbers that is stored in your browser or on your device’s hard drive. Strictly necessary cookies are placed automatically because the Website cannot work without them. All other cookies are placed only with your consent, which you can give or refuse through our cookie banner and change at any time.
We may use the following types of cookies:
- Strictly necessary cookies: required for the Website to work, for example to let you log in to secure areas.
- Analytical/performance cookies: let us recognize and count visitors and see how they move around the Website. This helps us improve how the Website works, for example by making sure users can easily find what they are looking for.
- Functionality cookies: recognize you when you return to the Website, so we can personalize content for you and remember your preferences.
- Targeting cookies: record your visit to the Website, the pages you have visited and the links you have followed. We use this information to make the Website and its advertising more relevant to your interests.
Third parties, such as advertising networks and web traffic analysis providers, may also place cookies, which we do not control. These are usually analytical/performance or targeting cookies. Examples of third-party cookie providers include:
- Google Analytics
- X (formerly Twitter)
- Hotjar
More information about these cookies is available on each provider’s website.
To learn more about cookies, you can visit www.aboutcookies.org, an independent third-party resource that explains what cookies and clear GIFs are and how to manage them. We are not responsible for and have no control over the content of this third-party website.
You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you block all cookies, including strictly necessary cookies, some parts of the Website may become inaccessible or not work properly.
Except for strictly necessary and functionality cookies, all cookies expire within two years.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The latest version will always be published on this page, with the date of the last update shown at the top.