Privacy Policy

BLUBEL PRIVACY POLICY

Last revised 10 April 2017

We, Blubel Tech Limited, a private limited company incorporated in England and Wales (“we“) are committed to protecting and respecting your privacy. For the purpose of the Data Protection Act 1998, we are a data controller are registered with the Information Commissioner’s Office under reference ZA244466.

SCOPE OF POLICY

This policy (together with our end-user licence agreement (“EULA“) and any additional terms incorporated by reference into the EULA, together “our Terms of Use“) applies to your use of:

  • the Blubel mobile application software, the data supplied with the software (the “App“) and any updates or supplements to it and the service you connect to via the App;
  • the associated Blubel device (the “Device“);
  • the content we provide to you through the App (the “Service“); and
  • any site in respect of the Service (a “Service Site“),

unless the EULA states that a separate privacy policy applies to a particular third party service, in which case that privacy policy only applies.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

  • Information you give us (Submitted information): This is information you give us about you by using the App, the Device whilst it is connected to the App or on Service Site, or by corresponding with us (for example, by e-mail). It includes information you provide when you register to use the App and the Service, download the App, subscribe to our Service, search for the App, share data via the App and when you report a problem with an App, our Service, or the Service Site. The information you give us may include your name, address, e-mail address and phone number, age, username, password and other registration information.
  • Information we collect about you and your mobile device. Each time you visit one the Service Site or use App we will automatically collect the following information:
    • technical information, including the type of mobile device you use, bluetooth id information in respect of your mobile device and the Device, your mobile operating system, time zone setting and language (“Device Information“);
    • details of your use of our App and Device or your visits to a Service Site including, but not limited to traffic data and other communication data whether this is required for our own purposes or otherwise and the resources that you access (“Log Information“).
  • Information from third parties. We provide an option for you to register to use the Service via either a Twitter, Facebook or Google profile. As a result we will pull your personal data across from such third party service for use in the App and our Service.
  • Location information. We, using third party ‘routing service’ technology (Skobbler by Scout), provide routes for your journey as part of our location-enabled Service. We collect your current location whilst the Device is connected to the App. The Service requires your location-enabled data, you will be asked to consent to your location-enabled data being used for this purpose in accordance with your smart-phone’s operation and terms. You can withdraw your consent at any time by turning off this functionality at any time by turning off the location services settings for the App on your smart phone but your user experience may be affected.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

  • To provide you, or allow third parties to provide you, with information or services, where you have consented to such.
  • To allow you to participate in interactive features of the App, the Service and any Service Site.
  • To maintain, protect and improve the App, the Service and any Service Site.
  • To notify the user about changes to the App or the Service.
  • To analyze App or Device usage and improve the Service.

We do not disclose information about identifiable individuals, but we may provide third parties with anonymous aggregate information about our users.
DISCLOSURE OF YOUR INFORMATION

You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We will only disclose anonymised data to third parties except that we will disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • if Blubel Tech Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; or
  • in order to:
    • enforce or apply the EULA or to investigate potential breaches; or
    • protect the rights, property or safety of Blubel Tech Limited, our customers, or others.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It will also be processed by staff operating outside the EEA who work for our data processors (IBM Softlayer and Bluemix). Staff at these data processors may be engaged in the fulfilment of the processing of your data and the provision of services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@blubel.co.

ACCESS TO INFORMATION

The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. As we pull your personal data from third party providers into our Service (as described above) you will need to refer to the relevant privacy policy (links to which is set out in the EULA) for the third party service you used to register to understand how to access information held about you.

CHANGES TO PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next start the App or log onto the Service Site. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Service.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@blubel.co.