Privacy Policy - Bubbling App Privacy Policy

Privacy Policy

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.


For example, you can ask us to erase personal data:

  • 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
    • you make a justified objection, or
    • 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:
    • search queries
    • streaming history
    • Bubbels you create
    • your use of the Bubbling Services
    • account settings
    • 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:
    • device IDs
    • network connection type (e.g. wifi, 4G, LTE, Bluetooth)
    • provider
    • network and device performance
    • browser type
    • language
    • information enabling digital rights management
    • operating system
    • Bubbling application version
  • information which enables us to discover and connect with third party applications. Examples:
    • 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:
    • 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
    • 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.
For example, when we use cookies to understand your interests or the law requires consent for email marketing.

  • 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.
This might be:

  • 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
  • EU law that applies to us
  • 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.
This will only apply when a competent law enforcement authority contacts us. These include the police, the courts or prisons.

  • 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.
These service providers include those we hire to:

  • 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 comply with a legal obligation

  • 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.
In this case, we may transfer your personal data to a successor or affiliate as part of that transaction.

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. Miscellaneous Provisions

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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