Effective Date: January 23, 2017
Last updated: October 14, 2019
We respect your right to privacy and will only process your personal information in accordance with applicable data protection and privacy laws.
This Policy explains how Bambuser (the data controller) collects, stores, uses and discloses information from you when you use Bambuser products, services, mobile applications and websites. This Policy applies to users of the Bambuser “Service”, defined as the services, APIs, and functionality we make available either through our website at bambuser.com and related site pages (the “Website”), via separate sites, repositories or servers under our control, or through third party sites that utilize our services and functionality, as well as through our device software (“Software”). This Policy does not apply to websites, applications, or services that do not display or link to this Policy or that display or link to different privacy statements; nor does this Policy apply to practices of companies that we do not control or to people we do not employ or manage.
B. Information Collected
We collect information about you in various ways when you use our Service and as set forth in the Terms of Service. Some of this information may be Personal Data about you. As used in this Policy, “Personal Data” means any information (either alone or in combination with other information we hold) that specifically identifies you as an individual, such as your name, address and physical location, account numbers, email addresses, or telephone numbers.
As well as Personal Data, we also collect some information that is not personally identifying, including aggregate information, which is data we collect about use of the Service or about a group or category of users from which it is not possible to identify you (“Nonpersonal Data”; together with Personal Data, collectively “Information”).
When you register for an account, and in the course of your use of the Service, we collect the following Personal Data: your log-in information (username and password), email address, any profile or biographical information you elect to provide, company details (if your company is a sole trader), any personally identifying information to the extent revealed in your Content (as that term is defined in the Bambuser Terms of Service and, if applicable, financial information, including credit card and/or bank account numbers, that you provide to us in exchange for your ongoing use of the Service. It’s possible that we will be accessing or exposed to Personal Data in the form of video taken by you as you choose via intended and ordinary use of the Service.
When you use our Service, we automatically collect some Personal Data sent to us by your computer, mobile device or other access device, such as a device ID or unique identifier, geo-location information, internet protocol (IP) address, device identifiers. We also collect information about your usage and activity on the Service.
When you use our Service, we automatically collect Nonpersonal Data sent to us by your computer, mobile device or other access device, such as device type, model and brand, computer, network and connection information, access times, operating system and browser version, type and language, and the website you visited before our Website. This Policy does not restrict or limit our collection, disclosure and use of Nonpersonal Data. We may also collect Nonpersonal Data related to video and imagery taken by or for you via intended and ordinary use of the Service, including numerical latitude or longitude or similar coordinates, imagery, data derived from within images (such as without limitation street signs, landmarks, building names, etc.), and data generated by the capture of images (such as without limitation geolocation, time and date, network and system information, etc.).
The Service also includes a location feature, which may use geo-location technology to approximate your real-time location. This location feature is optional and may only be used with your affirmative consent; however, if you choose not to allow the Service to access your location, certain features of theService may not be available.
We may additionally collect Information using pixel tags, web beacons or other web site usage tracking technologies. Web beacons (also known as “tracking pixels”) are electronic images that may be used in the Service or in emails that we send to you. Amongst other things, we use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon. Such devices are used to collect Personal Data such as the IP address of the user’s personal computer and Nonpersonal Data, such as the identity of the applicable internet service provider , the type of browser software and operating system in use, the date and time of site access, the website address, if any, from which the user linked to the Website and other similar traffic-related information. We also may aggregate such information with similar data collected from other users. However, we do not use such data in any way to create or maintain additional Personal Data about you.
The following is an illustrative list of the cookies that may be used and installed on your computer or device:
Functional – these cookies are necessary for the Website to function properly.
Analytical – these cookies allow us to understand how visitors use our Website, so we can measure and improve how the Website works.
Duration – cookies may be session-only, in which they expire at the end of each browser session, or may expire at a certain date.
Do Not Track Disclosure
We do not engage in the collection of Personal Data from users across third party sites or applications.
Services Via Third Party Applications
We may provide Services functionality via or to third party applications. In such context, we collect Information such as device IP address, device model, brand, operating system, version, language/country and timezone, network and connection information. Any Personal Data that may be collected by third parties is subject to third parties’ policies and practices, over which we exercise no control. We will not be liable for the acts and omissions of such third parties or for any loss of privacy, use or control of data caused by such third parties. You must contact such third party application developers for any requests, questions or concerns you may have regarding your Personal Data and data collected via such third party applications.
C. Our Use of Information
We use Information collected through our Service for the purposes and as
described in this Policy as set out below:
- (i) operate and maintain our Service, and to fulfill the purposes disclosed when you provided your information to us;
- (ii) customize, measure and improve our Service, and to fulfill the purposes disclosed when you provided your information to us (for example by performing analytics and tracking on pages you have visited on our website and where you originally came from (for example Google search or Social Media);
- (iii) respond to your comments and questions and provide the Service and customer support you request;
- (iv) resolve disputes, collect fees, enforce our terms and policies, and troubleshoot problems;
- (v) understand you and your preferences to enhance your experience and enjoyment using our Service (for example by logging log interactions on how people use our product, e.g. how often someone logs in, how many broadcasts are made)
- (vi) communicate with you about new events, offers and other news about our products and services offered by us and our selected partners (for example by tracking interactions with our marketing activities and e-mails, such as: which forms users have filled out, which marketing assets (blogs, guides) users have read, as well as scoring marketing interactions. Our forms use a data processing opt-in checkbox for accepting these terms); and
- (vii) send you Services-related information, including confirmations, invoices, reminders, technical notices, updates, security alerts and support and administrative messages.
We may use and provide data and information to our partners for commercial purposes after we have anonymized the data by removing your name and any other personally identifying information from it, or have combined it with other people’s data in a way that it is no longer associated with you.
Further, we may use Personal Data to respond to legal requirements, in connection with a merger, sale of assets, or other similar corporate transactions, to respond to claims that content violates the rights of others, or to protect the rights, property, or safety of any person.
Our legal bases to process your Personal Data are the following:
Fulfilment of contract
If you are a private individual that have entered into a contract with us, we rely on the legal basis fulfilment of contract when we process personal data to operate our Service and respond to your comments in relation to customer support.
If you are a representative with a company that have entered into a contract with us, we rely on the legal basis legitimate interest when we process personal data to operate our Service and respond to your comments in relation to customer support.
Further, we rely on legitimate interest in relation to the processing of personal data for the purposes of customizing and improving our Services, resolve disputes, understanding your preferences to enhance your experience, communicate with you about new events etc and send you Services-related information.
Our legitimate interest is to provide the Services to our customers, to ensure continuous development and improvement of our Services, protecting our business from disputes, and being able to communicate with our customers and market our Services.
D. Sharing Information
We do not disclose, sell or rent your Personal Data to third parties for their marketing purposes without your prior consent. If you do consent but later change your mind, you may contact us and we will cease any such activity.
We only share your Personal Data as follows:
- (i) at your direction and control via your normal and intended operation of the Service, or with your consent, for example, when you agree to us sharing your Personal Data with other selected third parties for their own marketing purposes subject to their separate privacy policies;
- (ii) to the general public for content you submit in a public forum (such as YouTube or similar service) or via features of our Service that enable public display of content;
- (iii) with the operators or owners of Other Applications (as that term is defined in the Terms of Service) and third parties with whom you allow us to share information, for example other apps or websites that integrate with our application programming interfaces (APIs) or Services, or those with an API or Service with which we integrate;
- (vi) under written obligations of confidentiality, in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company;
- (vii) with your employer (or similar entity) and any necessary third parties engaged by us or your employer (e.g., an expense management service provider) if you are using the Service on behalf of such party; and
- (viii) we may also share and disclose Nonpersonal Data, e.g., by publishing a report on trends in the usage of its Service.
E. No Guarantee of Security
We take all reasonable steps to help protect your Personal Data in our Services in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
In the unlikely event of a data breach, we will conduct an appropriate risk assessment and, if required, communicate the breach to the supervisory authority along with information on the severity of the incident and the measures taken to limit or mitigate the possible adverse effects of the data breach. If it is deemed likely that the data breach results in a high risk to your rights and freedoms, we will always communicate the breach to you with information on, inter alia, the nature of the breach.
F. International Transfers
We may process Information on servers located in a number of countries. Accordingly, we may share Information with our affiliated companies for such companies to carry out any of the activities specified in this Policy. We may also subcontract processing to or share Information with third parties located in countries other than your home country. Information collected within the European Economic Area and Switzerland may, for example, be transferred to, and processed by our affiliates or other third parties identified above that are located in, a country outside of the EEA and Switzerland, where you may have fewer legal rights in relation to your information. However, we will only process your information as described in this Policy in every country.
When we process Information outside of the EEA and Switzerland, we have taken necessary safeguards for such transfer in accordance with the GPDR namely the Standard Contractual Clauses.
When choosing data processors for our users’ data, we conduct thorough research into: the processor’s security practices, their server locations, and how they maintain security in compliance to data protection regulations like the General Data Protection Regulation (GDPR).
The Services are not directed at or intended for children under thirteen (13) years of age, and we do not knowingly collect Personal Data from such children. If you believe that we might have any Personal Data from a child under 13 years of age, please contact us at firstname.lastname@example.org.
H. Policy Changes
We may amend this Policy from time to time. If we make any changes to this Policy, we will post the amended terms, change the “Effective Date” above, and/or where appropriate, notify you by email.
I. Your Information and Choices
You have the right to ask us not to process your Personal Data for marketing or promotional purposes. We will 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 may also opt out of receiving promotional emails from us by following the instructions in the emails themselves or via email sent to email@example.com. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
You can see, review and change your Personal Data by logging into the Service or by contacting us at firstname.lastname@example.org. You should promptly update your Personal Data if it changes or is inaccurate.
You may also send requests about access the Personal Data we have about you, and to request that we update or correct any out-of-date or incorrect Personal Data we have about you (please note that some Personal Data we have about you may be made available to you for your own review, modification, or deletion).
You may also request restriction of our processing, make an objection or request data portability.
Upon receipt and process of an request, we will respond to such request in accordance with applicable legislation. Note that requests to terminate disclosure to third parties may frustrate or render impossible our ability to provide the Service or conduct transactions initiated by you.
For using our product we require a certain amount of data to be stored according to your personal details for identifying you as a customer. If for any reason, you wish to request we delete your data, y ou can fill out a request here or you can contact us by emailing email@example.com to request deletion of your data. Please ensure to use the email address that it is regarding as we will have to verify the validity of the request.
Should you have any complaints you may contact the supervisory authority (in Sweden the Data Inspection Board, Datainspektionen).
J. Data Integrity and Request for deletion
Data is stored in the tools we use for marketing and sales along with our user database if you are using our product. We do not share personal information with any third parties other than those used by Bambuser with the purpose of data processing. The data stored and processed is solely used by Bambuser for our user base and Marketing purposes.
We retain Personal Data from closed accounts, if and to the fullest extent permitted by applicable law, including in order to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our agreements and policies, and take other actions otherwise permitted by law or as specified elsewhere in this Policy.
If you have any questions about this Policy, please contact us at firstname.lastname@example.org.