Data Deletion Policy

1. Purpose

   This document sets out our policy for responding to requests for deletion of data under UK data protection law. This document explains the rights of the data subject in relation to data deletion and the responsibilities of Mobcup in responding with such a request.

2. Individual Rights

   An individual has the right to erasure, also known as ‘the right to be forgotten’. The principle underpinning this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing.

3. When does the right to erasure apply?

   As stipulated in UK data protection law, individuals have a right to have personal data erased and to prevent processing in specific circumstances:
   • Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed;
   • When the individual withdraws consent;
   • When the individual objects to the processing and there is no other legal ground for the relevant processing activity;
   • When the personal data was unlawfully processed;
   • Where the personal data has to be erased in order to comply with a legal obligation.

4. What information does Mobcup retain?

   The Mobcup online system “Interplace” stores data about individuals in order to create a Team Role Report. We store the name, e-mail address, gender, organisation/department (if provided) and subsequent Team Role scores for each individual in order to create a report, which is stored on our secure servers in the UK for a period of 90 days. This data is stored and used in accordance with our Privacy Policy, which can be found at: Privacy policy.
   
   If consent is provided, personal data (including the above, plus address, telephone number and notes) may be stored in our CRM system for the purposes of contacting you regarding Mobcup news, products and promotions.

5. How can data be deleted?

   If you have purchased a Team Role Report directly from Mobcup, Mobcup acts as data controller. In this case, we will delete the Team Role data (scores) upon request (via email to mobcup.my@gmail.com), upon closure of your account, or after three years. If an organization purchases access to the Mobcup Online Account, Mobcup acts as the data processor and the customer acts as data controller. In this case, it is the responsibility of the customer, as data controller, to ensure that data is not held longer than necessary for the purposes for which it is intended.
   
   A user of the Mobcup Online Account, acting on behalf of their organization, can delete data from their Interplace system whenever they wish. This data is deleted from the system immediately and cannot be recovered by any users or Mobcup employees after this point. Data which has been deleted or otherwise destroyed can not be recovered at any time. Sufficient warning is given to the account administrator before data are permanently deleted.
   
   Data may still remain in the systems back-up files, which will be deleted periodically.
   
   Information may be deleted from our CRM upon request to mobcup.my@gmail.com. We undertake to perform the deletion within one month (30 calendar days) and will send you a confirmation once the information has been deleted. Wherever possible, we will aim to complete the request in advance of the deadline.