Effective as of: February 14th, 2023
Identification number: Bubbling Platform_PP_1
Version number: v2
Privacy Policy
1.
Introduction
Welcome to Bubbling!
Bubbling
understands that your privacy is important to you and that you care about how
your personal data is used. We respect and value the privacy of every user. Our
Privacy Policy sets out standards which apply to your use of this Bubbling
Platform when communicating via our Bubbling Platform, uploading Your Content,
using the Bubbling Services or otherwise interacting with it. It is recommended
that you print a copy of this Policy for your future reference.
Any defined terms used in this Policy will have the
meaning given in this Policy or, if not defined in this Policy, the meaning
given in the Bubbling Terms and Conditions.
Personal data we collect about you.
2.
What are your
rights?
|
It’s your right
to … |
How? |
Be informed |
be informed
about our collection and use of your personal data. |
·
This
Privacy Policy should tell you everything you need to know, ·
but
you can always contact us to find out more or to ask any questions using the
details in Part 8. |
Acces |
request access
to the personal data we hold about you. |
·
You can contact us using the details in Part 8 to find out more. |
Rectification |
to
have your personal data rectified if any of your personal data held by us is
inaccurate or incomplete. |
·
You can edit your User Data under the personal settings icon, or ·
you can edit your data in the specific Services, or ·
you can contact us using the details in Part 8 to find out more. |
Erase |
the
right to be forgotten or delete, i.e. the right to ask us to delete or
otherwise dispose of any of your personal data that we hold.
·
that we no longer need for the purpose it was collected for ·
that we process based on the legal basis of consent, and you
withdraw your consent ·
when you object (see section ‘Object’ below) and o
you make a justified objection, or o
you object to direct marketing There
are situations where Bubbling is unable to delete your data, for example
when: ·
it’s still necessary to process the data for the purpose we
collected it for ·
Bubbling’s interest in using the data overrides your interest in
having it deleted. For example, where we need the data to protect our
services from fraud ·
Bubbling has a legal obligation to keep the data, or ·
Bubbling needs the data to establish, exercise or defend legal
claims. For example, if there’s an unresolved issue relating to your account
|
·
you can
remove content from your profile by selecting the relevant content and
choosing to update it. ·
you
can contact us using the details in Part 8 to find out more. |
Restriction |
to restrict (i.e. prevent) the processing of all or some of your
personal data. |
• you can contact
us using the details in Part 8 to find out more. |
Object |
to object to us using your personal data for a particular
purpose or purposes. |
• you can contact
us using the details in Part 8 to find out more. |
Data portability |
This means that, if you have provided personal data to us
directly, we are using it with your consent or for the performance of a
contract, and that data is processed using automated means, you can ask us
for a copy of that personal data to re-use with another service or business
in many cases. |
·
you can
contact us using the details in Part 8 to find out more. |
withdraw consent |
This means that, if we are relying on your consent as the legal
basis for using your personal data, you are free to withdraw that consent at
any time. |
·
you can
contact us using the details in Part 8 to find out more. |
automated decision-making |
not to be subjected to automated decision-making and profiling.
We do not use your personal data in this way. |
·
you can
contact us using the details in Part 8 to find out more. |
Right to lodge a complaint |
to contact your local data protection authority about any
questions or concerns. |
You can go to the website of your local
data protection authority. We would welcome the opportunity to resolve your
concerns ourselves, however, so please contact us first, using the details in
Part 8. |
It is important that your personal data is
kept accurate and up-to-date. If any of the personal data we hold about you
changes, please keep us informed as long as we have that data.
Further information about your rights can
also be obtained from the Information Commissioner’s Office or your local
Citizens Advice Bureau.
3.
Personal data
we collect
Personal data is defined in Article 8(1)
of the Charter of Fundamental Rights of the European Union (collectively, “the
General Data Protection Regulation”), an important component of EU privacy law
and of human rights law as ‘any information relating to an identifiable person
who can be directly or indirectly identified in particular by reference to an
identifier’.
Personal data is, in simpler terms, any
information about you that enables you to be identified. Personal data covers
obvious information such as your name and contact details, but it also covers
less obvious information such as identification numbers, electronic location
data, and other online identifiers.
Depending upon your use of our Bubbling Platform, we
may collect and hold some or all of the personal and non-personal data set out
in the table below, using the methods also set out in the table.
Collected
when you sign up or when you update your account |
|
Data Category |
Description |
User Data |
Personal data that we need to create your Bubbling
account and that enables you to use the Bubbling Service. The type of data collected and used depends on the
type of Bubbling Services you are using and the country you are in. This may
include your: ·
First Name ·
Middle Name ·
Last Name ·
Title ·
Date of Birth ·
Nationality ·
Gender ·
Email Addresses ·
Phone Number We receive some of this data from you e.g. from the
sign up form or account page. We also collect some of this data from your
device e.g. country or region. For more information about how we collect and
use this data, see ‘Your general (non-precise) location’ in the Usage Data
category. |
Collected through your use of the Bubbling Platform
and Bubbling Services |
|
Data Category |
Description |
Usage Data |
Personal data collected and processed about you when
you’re accessing or using the Bubbling Platform and Services. There are a few types of information this includes,
listed in the following sections. Information about how you use the Bubbling Platform
and Services Examples include: ·
information about your Bubbling Service Option ·
your actions with the Bubbling Service (including date and
time), such as: o
search queries o
streaming history o
Bubbels you create o
your use of the Bubbling Services o
account settings o
interactions with other Bubbling users ·
inferences (i.e., our understanding) of your interests and
preferences based on your usage of the Bubbling Service ·
content you post to any part of the Bubbling Service. For
example: images, audio, text, titles, descriptions, communications, and other
types of content
Your technical data Examples include: ·
URL information ·
online identifiers such as cookie data and IP addresses ·
information about the devices you use such as: o
device IDs o
network connection type (e.g. wifi, 4G, LTE, Bluetooth) o
provider o
network and device performance o
browser type o
language o
information enabling digital rights management o
operating system o
Bubbling application version ·
information which enables us to discover and connect with third
party applications. Examples: o
Bubbling partner applications to determine whether the
application is installed on your device
Your general (non-precise) location Your general location includes country, region or
state. We may learn this from technical data (e.g. your IP address, language
setting of your device) or payment currency. We need this to: ·
meet geographic requirements in our agreements with the owners
of content on the Bubbling Service ·
deliver content that’s relevant to you
Your device sensor data Motion-generated or orientation-generated mobile
sensor data (e.g. accelerometer or gyroscope) if needed to provide features
of the Bubbling Service that require this data. |
Additional data you may choose to give us |
|
Data Category |
Description |
Voice Data |
If voice features are available in your market and
where you’ve chosen to use a voice feature, we collect and process voice
data. Voice data means audio recordings of your voice and transcripts of
those recordings. |
Payment and Purchase Data |
If you make any purchases from Bubbling or sign up
for a trial, we will need to process your payment data. This includes if you
buy a paid Service Option. The exact personal data collected and used will vary
depending on the payment method. It will include information such as: ·
name ·
date of birth ·
payment method type (e.g. credit
or debit card) ·
if using a debit or credit card,
the card type, expiration date, and certain digits of your card numberNote:
For security, we never store your full card number ·
ZIP/postal code ·
mobile phone number ·
details of your purchase and
payment history |
Contact list |
In
order to invite users to your Bubbles or to advertise the app, you can grant
us access to your contact list. Your address book’s contact list includes the
phone numbers, email addresses, first names, middle names, and last names. If
any of your contacts aren’t yet using our Services, we’ll manage this
information for you in a way that ensures those contacts cannot be identified
by us. |
Survey and Research Data |
When you respond to a survey or take part in user
research, we collect and use the personal data you provide. |
Location data |
We collect and use precise location information from
your device with your permission when you choose to use location-related
features, like when you decide to share your location with your contacts or
view locations nearby or locations others have shared with you. There are
certain settings relating to location-related information which you can find
in your device settings or the in-app settings, such as location sharing.
Even if you do not use our location-related features, we use IP addresses and
other information like phone number area codes to estimate your general
location (e.g., city and country). We also use your location information for
diagnostics and troubleshooting purposes. |
Third party sources that we collect your data from |
|
Categories of third parties |
Description |
Third party Services your using through the Bubbling
Platform |
If you are using third party Services through the
Bubbling Platform, we may collect, share and use certain information from
them to make the integration possible. We’ll ask your permission before you are able to use
those third party Services. |
Technical service partners |
We work with technical service partners that give us
certain data. This includes mapping IP addresses to non-precise location data
(e.g., country or region, city, state). This makes it possible for Bubbling to provide the
Bubbling Service, content, and features. |
Payment partners and Merchants |
If you choose to pay through third parties (e.g.
telco carriers) or by invoice, we may get data from our payment partners. This allows us to: ·
send you invoices ·
process your payment ·
give you what you’ve purchased If we direct you to a merchant, we receive data from
the merchant that is related to your purchase. For example, we might direct
you to a merchandise store on a third party platform. Receiving this data allows us to: ·
calculate any commissions owed to us ·
analyze the effectiveness of our partnership with these merchant
partners ·
understand your interests |
If you download the Bubbling mobile app and try the
Bubbling Platform using a logged out user experience, we will collect limited
information about your usage of the Bubbling Platform and the Bubbling Services,
including Usage Data. We do this to understand how you are accessing and using
the Service. We also do this to ensure we provide the right experience for you,
for example based on your country or region. If you decide to create a Bubbling
Platform account to experience our service in full, then we will combine this
data with your Bubbling Platform account data.
4.
Our purpose
for using your personal data
Under the Data Protection Legislation, we must always
have a lawful basis for using personal data. The following table describes how
we may use your personal data, and our lawful bases for doing so:
The table below sets out:
·
our purpose for processing your personal data
·
our legal justifications (each called a ‘legal basis’) under data
protection law, for each purpose
·
categories of personal data which we use for each purpose. See
more about these categories in Section 3 ‘Personal data we collect’
Here is a general explanation of each ‘legal basis’ to
help you understand the table:
·
Performance of a Contract: When it’s
necessary for Bubbling (or a third party) to process your personal data to:
o
comply with obligations under a contract with you. This includes
Bubbling’s obligations under the Terms and Conditions to provide the Bubbling Platform
and the Services to you, or
o
verify information before a new contract with you begins.
·
Legitimate Interest: When Bubbling or a third party
has an interest in using your personal data in a certain way, which is
necessary and justified considering any possible risks to you and other
Bubbling users. For example, using your Usage Data to improve the Bubbling
Service for all users. Contact us if you want to understand a specific
justification.
·
Consent: When Bubbling asks you to actively indicate your agreement to
Bubbling’s use of your personal data for a certain purpose.
·
Compliance with Legal Obligations: When
Bubbling must process your personal data to comply with a law.
Purpose for processing your data |
Legal basis that permits the purpose |
Categories of personal data used for the purpose |
To provide the Bubbling Platform and Services (as
defined in Section 1 ‘Introduction’.) |
·
Performance of a Contract ·
Legitimate Interest ·
Consent |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data |
To understand, diagnose, troubleshoot, and fix
issues with the Bubbling Platform and Bubbling Services. |
·
Performance of a Contract |
·
User Data ·
Usage Data |
To evaluate and develop new features, technologies,
and improvements to the Bubbling Platform and Bubbling Services. |
·
Legitimate Interest |
·
User Data ·
Usage Data ·
Voice Data |
For
marketing or advertising where the law requires us to collect your consent. |
·
Consent |
·
User Data ·
Usage Data ·
Survey and Research Data |
For other
marketing, promotion and advertising purposes where the law does not require
consent. |
·
Legitimate Interest |
·
User Data ·
Usage Data ·
Survey and Research Data |
To comply with a legal obligation that we are
subject to. ·
an obligation under the law of the country / region you are in ·
an obligation under the law of the country / region where we are
active
|
·
Compliance with legal obligations |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data ·
Survey and Research Data |
To comply with a request from law enforcement. |
·
Compliance with legal obligations ·
Legitimate interest |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data ·
Survey and Research Data |
To fulfill
contractual obligations with third parties. For example, our agreements with
owners of content on the Bubbling Platform. |
·
Legitimate interest |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data |
To take appropriate action with reports of
intellectual property infringement and inappropriate content. |
·
Legitimate interest |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data |
To establish, exercise, or defend legal claims. |
·
Legitimate interest |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data ·
Survey and Research Data |
To conduct business planning, reporting, and
forecasting. |
·
Legitimate Interest |
·
User Data ·
Usage Data ·
Payment and Purchase Data |
To process your payment. |
·
Performance of a Contract
|
·
User Data ·
Payment and Purchase Data |
To detect and prevent fraud. For example, fraudulent
payments and fraudulent use of the Bubbling Platform. |
·
Legitimate Interest |
·
User Data ·
Usage Data ·
Payment and Purchase Data |
To conduct research and surveys. |
·
Legitimate Interest
|
·
User Data ·
Usage Data ·
Voice Data ·
Survey and Research Data |
We will only use your personal data for the purpose(s)
for which it was originally collected unless we reasonably believe that another
purpose is compatible with that or those original purpose(s) and need to use
your personal data for that purpose. If we do use your personal data in this
way and you wish us to explain how the new purpose is compatible with the
original, please contact us using the details in Part 8.
If we need to use your personal data for a purpose
that is unrelated to, or incompatible with, the purpose(s) for which it was
originally collected, we will inform you and explain the legal basis which
allows us to do so.
In some circumstances, where permitted or required by
law, we may process your personal data without your knowledge or consent. This
will only be done within the bounds of the Data Protection Legislation and your
legal rights.
5.
Sharing your
personal data
This section sets out the categories of recipients of
the personal data collected or generated through your use of the Bubbling Platform
and the Bubble Services.
5.1. Information for users of the Bubbling Platform
The following personal data will always be public to
users who are in possession of your email address or phone number.
·
your profile photo
5.2. Information for members or users who are invited for Bubbles in the
Bubbling Platform
The
following personal information will always be publicly available on the
Bubbling Platform and the Bubbling Services to Members or Users invited to a
Bubble that you are a part of:
·
your first name
·
your last name
·
your profile photo
·
your email address
When this sharing occurs, the third party Services may
store a copy of it to support their features.
5.3. Personal data you may choose to share
We will only share the following personal data with
those outlined in the table below:
·
where we need to share personal data for the use of a Bubbling
Platform or Bubbling Services, or
·
if you otherwise grant us your permission to share the personal
data. For example, you can do it by selecting the appropriate setting in the Bubbling
Service or by giving your consent
Categories of
recipients |
Categories of data you
can choose to share |
Reason for sharing |
Bubbling Services you
are using through the Bubbling Platform |
·
User Data ·
Usage Data ·
Voice Data |
To use third party Services through the Bubbling platform we
need to connect your Bubbling account
with those Services Examples of such third party Services: ·
ChatIT ·
DocIT ·
FinIT ·
ShopIT ·
CardIT ·
TaskIT |
Other Bubbling users |
·
User Data ·
Usage Data ·
Voice Data |
To share information
about your use of the Bubbling Service with other Bubbling users. These could
include your Bubbles in the Bubbling Platform. |
Information we may share
See this table for details of who we share to and why.
Categories of
recipients |
Categories of data |
Reason for sharing |
Service providers |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data ·
Survey and Research Data |
So they can provide
their services to Bubbling. ·
give customer support ·
operate the technical infrastructure we need to
provide the Bubbling Service ·
assist in protecting and securing our systems and
services ·
help market Bubbling’s (and our partners’)
products, services, events and promotions |
Payment partners |
·
User Data ·
Payment and Purchase Data |
So they can process
your payments, and for anti-fraud purposes. |
Marketing Partners |
·
User Data ·
Usage Data |
To promote Bubbling
with our partners. We share certain User Data and Usage Data with these
partners where necessary to: ·
enable you to participate in Bubbling promotions,
including trials or other bundled offers ·
to promote Bubbling in media and advertising
published on other online services ·
help us and our partners to measure the
effectiveness of Bubbling promotions Examples of partners
include: ·
marketing or sponsorship partners ·
websites and mobile apps who sell us advertising
space on their services ·
device, app and mobile partners who also offer
Bubbling promotions Our partners may also
combine the personal data we share with them with other data they collect
about you, e.g. your use of their services. We and our partners may use this
information to present you with offers, promotions, or other marketing
activities that we believe will be relevant to you. |
Other partner sharing |
·
User Data ·
Usage Data ·
Survey and Research Data |
To help us understand
and improve the performance of our products and partnerships. |
Academic researchers |
·
User Data ·
Usage Data |
For activities such as
statistical analysis and academic study, but only in a pseudonymised format.
Pseudonymised data is where your data is identified by a code rather than
your name or other information that directly identifies you. |
Other Bubbling group
companies |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data ·
Survey and Research Data |
To carry out our daily business operations and so we can
maintain and provide the Bubbling Service to you. |
Law enforcement and other authorities |
·
User Data ·
Usage Data |
When we believe in
good faith it’s necessary for us to do so, for example: ·
to respond to a valid legal process (such as a
search warrant, court order, or subpoena) ·
for our own or a third party’s justifiable
interest, relating to: o national security o law enforcement o litigation (a court
case) o criminal investigation o protecting someone’s safety o preventing death or
imminent bodily harm |
Purchasers of our
business |
·
User Data ·
Usage Data ·
Voice Data ·
Payment and Purchase Data ·
Survey and Research Data |
If we were to sell or
negotiate to sell our business to a buyer or possible buyer. |
6.
How and Where
Do You Store or Transfer My Personal Data?
We only store your personal data within the European
Economic Area (the “EEA”). The EEA consists of all EU member states, plus
Norway, Iceland, and Liechtenstein. This means that your personal data will be
fully protected under the EU GDPR and/or to equivalent standards by law.
7.
Keeping your
personal data safe
We’re
committed to protecting our users’ personal data. We put in place appropriate
technical and organizational measures to help protect the security of your
personal data. However, be aware that no system is ever completely secure.
We have
implemented various safeguards to guard against unauthorised access and
unnecessary retention of personal data in our systems.
To protect
your user account, we encourage you to:
·
use a strong password
which you only use for your Bubbling account
·
never share your
password with anyone
·
limit access to your
computer and browser
·
log out once you have
finished using the Bubbling Platform on a shared device
8.1. No Third Party Beneficiaries
The Parties acknowledge that the covenants set forth
in these Privacy Policy are intended solely for the benefit of the Parties,
their successors and permitted assigns. Nothing herein, whether express or
implied, will confer upon any person or entity, other than the Parties, their
successors and permitted assigns, any legal or equitable right whatsoever to
enforce any provision of these Privacy Policy.
8.2. Transfer Of The Privacy Policy
You may not transfer your rights and obligations under
these Privacy Policy. Bubbling has the right to transfer all or some of its
rights and obligations under these Privacy Policy to a third party, without
your consent.
8.3. Governing Law; Jurisdiction
These Privacy Policy shall be governed by and
construed solely and exclusively in accordance with the laws of Belgium,
without giving effect to any law that would result in the application of the
law of another jurisdiction or to the United Nations Convention on the
International Sale Of Goods. Any dispute arising out of or in connection with
these Privacy Policy that shall not be amicably settled by the parties through
good faith negotiations within three (3) months after notification in writing
by any of the parties, shall be under the exclusive jurisdiction of the courts
of Ghent. Notwithstanding the foregoing, any party may seek immediate
injunctive or other interim relief from any court of competent jurisdiction
with respect to any matter for which monetary damages would not adequately
protect such party’s interests or otherwise to enforce and protect Intellectual
Property Rights owned by or licensed to such Party.
8.4. Entire Privacy Policy
The Parties agree that the provisions of this Privacy
Policy are the entire Privacy Policy between them regarding the matters that
these Privacy Policy addresses, including the Parties’ respective
confidentiality obligations. You agree that you will have no claim against us
for any statement which is not explicitly set out in this Privacy Policy. The
Parties also agree that any prior Privacy Policy or representations about those
same matters, whether written or oral, are superseded by this Privacy Policy,
and previous oral Privacy Policy about those matters does not have any legally
binding force.
8.5. Enforceability
Even if the law will not enforce a provision of this
Privacy Policy in a particular instance, the Parties intend to remain bound by
the other, enforceable provisions. If the unenforceable provision could be
interpreted in a manner or be modified so that would render it enforceable,
while still reflecting the Parties’ mutual intent, they intend for that
interpretation or modification, as applicable, to apply. If permitted by law,
the Parties also intend for the provision that cannot be enforced in that
instance to remain applicable in any other instances when it can be enforced.
8.6. Privacy Policy Amendments
As Bubbling operates in a changing
commercial, technological and regulatory environment, it may be compelled to
amend the terms of this Privacy
Policy from time to time. In such case, you will be prompted to accept the
amended Privacy Policy via Bubbling, and the continued use of the Bubbling by
you shall represent your acceptance of such amended Privacy Policy.
Any such changes
will not apply to any dispute between you and us arising before the date on
which the Privacy Policy was changed. If you do not wish to continue using
Bubbling under the updated Privacy Policy, you may terminate your account by
contacting us. The effective date set forth at the top of this document
indicates when this Privacy Policy were last changed.
In case of a
rate increase or price indexation for use of the Bubbling Platform, you may
terminate this Privacy Policy, without having to pay a penalty, by sending a
letter addressed to Bubbling by no later than the last day of the month
following the receipt of the first bill issued after the changes entered into effect.
A rate increase or price indexation of Services available on the Bubbling
Platform shall not entitle you to terminate this Privacy Policy.
8.7. Waivers
Even if a Party fails to enforce its rights under
these Privacy Policy in a particular instance, the other Party must still
perform its duties in that instance unless the non-enforcing Party physically
signs a paper that expressly waives its rights in that instance, and any such
waiver only applies to the particular instance and particular rights expressly waived.
8.8. No implications of section titles
The titles to each of the sections of this Privacy
Policy are intended only to facilitate convenient reference; the Parties agree
that those titles are not part of the Privacy Policy and should not be used to
interpret any part of this Privacy Policy.
8.9. Languages
We may translate this
Privacy Policy into multiple languages. If there is any difference between the
English version and any other language version of these Privacy Policy, the
English version will apply (to the extent permitted by applicable laws and
regulations).
8.10.
Communication
You hereby accept the use of email
for the transmission of information requested regarding the conclusion or
performance of the Privacy Policy and, in general, for all exchanges under the
Privacy Policy. You furthermore agree that (i) the presence of an
identification code shall validly identify the author of a document or message
and establish the authenticity of the document or message, (ii) the parties may
avail themselves of a paper printout of an email message from an email service
to prove the content of exchanges they have had about the performance of these
Privacy Policy, and (iii) the data recorded by Bubbling via the Bubbling
Platform shall constitute proof of all transactions made by you.
8.11.
Customer
service contact
You must turn
to the third party offering the Service in case of problems with the operation
or use of it.
You can turn
to the ombud service or Bubbling help center via info@bubbling.eu for questions
about the operation of the Bubbling Platform, for questions about the execution
of the Privacy Policy and for questions about payments. You will be offered
help in French, Dutch and English.
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