Last updated April 6, 2021
When you visit our website http://www.bubbl.tech (the “Website”), and more generally, use any of our services (the “Services”, which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
DEFINITIONS AND INTERPRETATION
“Bubbl Ltd, or us Bubbl Ltd” a company incorporated in England and Wales with registered number 10103981 whose registered office is at The Hoxton Mix, 3rd Floor, 86-90 Paul Street, EC2A 4NE;
“Cookies” A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
“CCPA” The California Consumer Privacy Act (CCPA) is a state statute intended to enhance privacy rights and consumer protection for residents of California, United States.
“Data” Collectively all information that you submit to Bubbl Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
“Data Protection Laws” Applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
“GDPR” The General Data Protection Regulation (EU) 2016/679;
“Services” Application, implementation and maintenance services including the website provided by Bubbl Limited
“UK and EU Cookie Law” The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
“User or you” User or you any third party that accesses the Website and is not either (i) employed by Bubbl Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Bubbl Ltd and accessing the Website in connection with the provision of such services; and
“Website” The website that you are currently using, www.bubbl.tech, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
the singular includes the plural and vice versa;
a reference to a person includes firms, companies, government entities, trusts and partnerships;
“including” is understood to mean “including without limitation”;
reference to any statutory provision includes any modification or amendment of it;
For purposes of the applicable Data Protection Laws, Bubbl Ltd is the “data controller”. This means that Bubbl Ltd determines the purposes for which, and the manner in which, your Data is processed.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:
Personal Information Provided by You. We collect names; email addresses; contact preferences; billing addresses; debit/credit card numbers; and other similar information
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies (please see our Cookie Notice and Schedule for further details)
The information we collect includes:
Log and Usage Data: Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
2. HOW DO WE USE YOUR INFORMATION?
We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and logon process. We use the information you allowed us to collect to facilitate account creation and logon process for the performance of the contract.
To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.
To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies. For business purposes, to comply with legal and regulatory requirements or in connection with our contract.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To fulfill and manage your orders. We may use your information to fulfill and manage your orders and payments made through the Website.
To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes but only in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, marketing and your experience. We may use and store this information in aggregated and anonymised form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than sixty (60) months past the termination of the user’s account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: [email protected]
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
7. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected]
8. WHAT ARE YOUR PRIVACY RIGHTS?
Within EEA/EU/UK and subject to GDPR
If you are within the European Economic Area (EEA) or the European Union (EU) you have certain and specific privacy rights under The General Data Protection Regulation (EU) 2016/679 (GDPR).
These rights in relation to your data include:
Right to access: The right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
Right to correct: The right to have your Data rectified if it is inaccurate or incomplete.
Right to erase: The right to request that we delete or remove your Data from our systems.
Right to restrict our use of your Data: The right to “block” us from using your Data or limit the way in which we can use it.
Right to data portability: The right to request that we move, copy or transfer your Data.
Right to object: The right to object to our use of your Data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: [email protected]
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it. If you have questions or comments about your privacy rights, you may email us at [email protected].
If you would at any time like to review or change the information in your account or terminate your account, you can:
Log in to your account settings and update your user account.
Contact us using the contact information provided.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in our emails that we send or by contact us via [email protected].. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
Contact us using the contact information provided.
Access your account settings and update your preferences.
Within California and subject to CCPA
If you are a resident of California, United States, you have certain and specific privacy rights under The California Consumer Privacy Act (CCPA)
The California Code of Regulations defines a “resident” as:
every individual who is in the State of California for other than a temporary or transitory purpose and
every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
As well the CCPA, Californian Residents also have rights under California Civil Code Section 1798.83, also known as the “Shine The Light” law. This permits our users (who are California residents) to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us via [email protected]
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Example of type of data: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name
Do we collect this data? NO
B. Personal information categories listed in the California Customer Records statute
Example of type of data: Name, contact information, education, employment, employment history and financial information
Do we collect this data? YES
C. Protected classification characteristics under California or federal law
Example of type of data: Gender and date of birth
Do we collect this data? NO
D. Commercial information
Example of type of data: Transaction information, purchase history, financial details and payment information
Do we collect this data? YES
E. Biometric information
Example of type of data: Fingerprints and voiceprints
Do we collect this data? NO
F. Internet or other similar network activity
Example of type of data: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements
Do we collect this data? NO
G. Geolocation data
Example of type of data: Device location
Do we collect this data? NO
H. Audio, electronic, visual, thermal, olfactory, or similar information
Example of type of data: Images and audio, video or call recordings created in connection with our business activities
Do we collect this data? NO
I. Professional or employment-related information
Example of type of data: Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us
Do we collect this data? NO
J. Education Information
Example of type of data: Student records and directory information
Do we collect this data? NO
K. Inferences drawn from other personal information
Example of type of data: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
Do we collect this data? NO
We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at [email protected], or by referring to the contact details at the bottom of this document.
If you are using an authorised agent to exercise your right to opt-out we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.
Bubbl Limited has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Bubbl Limited will not sell personal information in the future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
you may object to the processing of your personal data
you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at [email protected] or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. COOKIE NOTICE AND SCHEDULE
Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Bubbl Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
This Website may place the following Cookies:
Type of Cookie
Strictly necessary cookies
Purpose: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Purpose: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Purpose: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.
Description of Cookie
Session cookie (Strictly necessary cookie)
Purpose We use this session cookie to remember you and maintain your session whilst you are using our website
Info and demo cookie (Strictly necessary cookie)
Purpose: We use this cookie to understand the pages that led you to the demo or further info pages
Performance cookie (Analytical/performance cookie)
Purpose: We use this cookie to help us analyse how users use the website
Function cookie (Functionality cookie)
Purpose: We use this cookie to identify your computer and analyse traffic patterns on our website
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
12. DO WE MAKE UPDATES TO THIS NOTICE?
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at [email protected] or by post to: Bubbl Limited, 124 Finchley Road, London, United Kingdom NW3 5JS
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: https://www.bubbl.tech or email [email protected]. We will respond to your request within 30 days.
You may contact Bubbl Ltd by email [email protected]