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.

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

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

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.

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.