GDPR and California Privacy Act
Definitions and interpretation
Data Collectively all information that you submit to Bubo AI Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws Any 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;
Bubo AI Ltd, we or us
Bubo AI Ltd, a company incorporated in England and Wales with registered number 11946009 whose registered office is at Bogglebeck, Dalton Piercy, Durham, TS27 3HS;
User or you Any third party that accesses the Website and is not either (i) employed by Bubo AI Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Bubo AI Ltd and accessing the Website in connection with the provision of such services; and
Website The website that you are currently using, bubo.flywheelsites.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
a. the singular includes the plural and vice versa;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. reference to any statutory provision includes any modification or amendment of it;
4. For purposes of the applicable Data Protection Laws, Bubo AI Ltd is the “data controller”. This means that Bubo AI Ltd determines the purposes for which, and the manner in which, your Data is processed.
5. We may collect the following Data, which includes personal Data, from you:
b. job title;
d. contact Information such as email addresses and telephone numbers;
How we collect Data
6. We collect Data in the following ways:
a. data is given to us by you; and
b. data is collected automatically.
Data that is given to us by you
7. Bubo AI Ltd will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you elect to receive marketing communications from us;
Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
Our use of Data
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. transmission by email of marketing materials that may be of interest to you;
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
11. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
c. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
Who we share Data with
12. We may share your Data with the following groups of people for the following reasons:
a. any of our group companies or affiliates – Geographical base;
b. our employees, agents and/or professional advisors – So they can engage with them with marketing information;
Keeping Data secure
13. We will use technical and organizational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a username that is unique to you.
b. we store your Data on secure servers.
14. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com.
15. 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.
17. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
18. You have the following rights in relation to your Data:
a. 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.
b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase – the right to request that we delete or remove your Data from our systems.
d. 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.
e. Right to data portability – the right to request that we move, copy or transfer your Data.
f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
19. 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 e-mail address: firstname.lastname@example.org.
20. 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/.
21. 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.
Links to other websites
Changes of business ownership and control
24. We may also disclose Data to a prospective purchaser of our business or any part of it.
25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
28. 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.
29. 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.
01 November 2019
bubo.flywheelsites.com (“the Website”) is owned and operated by Bubo AI Ltd. This policy explains how Bubo AI Ltd may use information we collect about you, as well as your rights over any personal information we hold about you. Please read this policy carefully; by accessing the Website you confirm you have understood and agreed to it.
Information we collect about you
We collect information about you when you:
• visit the Website, and other sites accessible from the Website
• register with and buy products or services on the Website
• take part in promotions, competitions, customer surveys and questionnaires
• contact us e.g. in writing, call customer services
Using your information
Collecting your personal information helps Bubo AI Ltd to better understand what you need from us. We use your information to:
• manage and improve the Website
• personalise our services to you
• process your quote requests
• tell you about important changes to the Website and our services
• understand your browsing behaviour to develop and improve our products and services
• manage promotions, competitions, customer surveys and questionnaires
• check and verify your identity and prevent or detect crime. In performing checks your information may be disclosed to credit reference agencies, who may keep a record of that information. This is not a credit check and your credit rating will be unaffected.
Your personal information is safe with us and will never be released to companies outside Bubo AI Ltd for their marketing purposes.
Marketing and research
If you agree, we may contact you:
• with offers and information about Bubo AI Ltd products or services
• with offers and information about partners’ products or services
• for customer research e.g. to help improve our services
Of course, the choice is entirely yours, but if you say you do not want to receive marketing
information from us this will prevent you from receiving offers or promotions that may be of interest to you.
From time to time, we may contact you to ask your opinion. Again, if you do not want to be contacted for this purpose, please let us know.
In order to comply with new rules, we use a system of classifying the different types of cookies which we use on the Website, or which may be dropped by third parties through our websites. The classification was developed by the International Chamber of Commerce UK and explains more about which cookies we use, why we use them, and the functionality you will lose if you decide you don’t want to have them on your device. Please be reassured that we are working on other privacy and cookie-related improvements to the Website.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
• Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
• Session cookies – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.
Cookies used on the Website
A list of all the cookies used on the Website by category is set out below.
• Strictly necessary cookies – These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
• Performance cookies – These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device. These cookies collect information about how visitors use the Website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.
• Functionality cookies – These cookies remember choices you make to improve your experience. By using the Website, you agree that we can place these types of cookies on your device. These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
• Targeting or advertising cookies – These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
Behavioural advertising and online privacy
A guide to behavioural advertising and online privacy has been produced by the internet advertising industry which can be found at www.youronlinechoices.eu. The guide contains an explanation of the IAB’s self-regulatory scheme to allow you greater control of the advertising you see.
Using browser settings to manage cookies
The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.
Disclosing your information
We will never disclose your information to anyone outside Bubo AI Ltd except where we have your consent; where we are required or permitted to do so by law; to other companies who provide a service to us; or any successors in title to our business.
Whenever we transfer personal information to countries outside the European Economic Area we will ensure that appropriate security measures are taken.
The Website may contain links to other sites which are outside our control and not covered by this policy. The operators of these sites may collect information from you that will be used by them in accordance with their policy, which may differ from ours.
Accessing your information
To obtain a copy of the information we hold about you, write to:
Data Protection Officer
Bubo AI Ltd
This may incur a fee. If any of the details are incorrect, let us know and we will amend them.
Changes to our policy
This policy replaces all previous versions and is correct as of September 2013. We reserve the right to change the policy at any time.
If you have any queries, please contact us