For the purpose of the Data Protection Act 1998 and the General Data Protection Regulation 2016/679 (once in force on 25th May 2018 – both “Data Protection Law”), the data controller is Bulugo Ltd (”We”).
We are committed to protecting and respecting your privacy. This policy sets out the basis on which any of your personal data that we have received, by any means, will be processed by us. Please ensure that you understand and agree to the content of this policy when using the Website. Where you do not agree, please stop using the Website immediately.
INFORMATION WE COLLECT about you
Personal Data provided by you
Your “Personal Data” may include but not be limited to: your name, email address, residential address, address, telephone number, photograph, personal description etc.
In using the Website, we may ask you to provide some of the Personal Data in order to sign up for our mailing list, marketing and promotional materials, set up an account, request a call-back, information or other mode of contact, administer our services to clients’ personnel. We will not, however ask you to provide or ever use any sensitive personal data, such as your political opinions, medical information, sexual orientation, racial or ethnic origin etc.
Personal and Other Data collected while using our Website
We may collect other information about your computer, laptop or other electronic device when you make use of the Website, including browser type and version, internet protocol (IP) addresses, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit, including clickstream to, through and from the Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number (“Other Data”).
Some of this data may be classed as Personal Data, such as IP and phone numbers, as they are able to identify you.
USES MADE OF THE INFORMATION
We will only use your Personal Data as strictly required for the following legitimate purposes in order for us to carry out our business, to:
- perform our obligations as required by our contracts with you or your employer (were B2B services are provided);
- provide direct marketing where you have explicitly consented to receive such communications or are the personnel of our client or supplier;
- notify you of service information;
- share your Personal Data as required by the section ‘Sharing Your Personal Data’ below;
- respond to correspondence initiated or requested by you;
- improve the functionality, performance, efficiency or usability of the Website, customer platforms, technology development or our marketing processes or functions;
- obtain information about our services in order to improve service delivery.
We will only use your Other Data as strictly required for the following legitimate purposes in order for us to carry out our business, to:
- administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- improve the Website to ensure that content is presented in the most effective manner for users and their computers;
- allow you to participate in interactive features of our service, when you choose to do so;
- part of our efforts to keep the Website safe and secure;
- measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- make suggestions and recommendations to you and other users of the Website about goods or services that may interest you or them.
We will not use your Personal Data to make automated decisions about you which do not require human intervention.
As a website user, we will only keep your Personal Data for as long as you hold an account with us, we provide services to you or we are required for legal, regulatory or internal audit reasons.
Where you are the personnel of our clients or suppliers, we will keep your Personal Data for a period following the expiry of our contract with our client for legal, regulatory or internal audit reasons. You have the right to object to our processing activities.
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your Personal Data with:
- any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- third parties listed below:
- to business partners, suppliers and sub-contractors for the performance of any contract we enter into with them, our client (where relevant) or you;
- to analytics and search engine providers that assist us in the improvement and optimisation of the Website (however, in such case we would not provide information about any single identifiable individual, but provide high-level statistical information such as the number of men, women, age groups etc.;
- where you explicitly consent;
- in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the seller or buyer of such business or assets;
- if our company, 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 obligation (such as fraud prevention), or in order to enforce or apply our [terms and conditions]
WHERE WE STORE YOUR PERSONAL DATA
Your Personal Data may be transferred to and stored in a destination outside the European Economic Area (”EEA”) for the purposes of our legitimate interests in operating our business. Nevertheless, the law requires that we ensure that we only make such transfers outside the EEA where there are sufficient safeguards for your Personal Data or a transfer is made by means of mechanisms approved by the European Commission.
All information you provide to us is stored on our secure servers.
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
As a user of the website, you have the right to request: a copy of any/ all Personal Data we hold about you, us to correct any inaccuracies or update out of date Personal Data and that we delete any of your Personal Data or transfer it to another service provider. You can also exercise these rights at any time by contacting us at the below email.
You are also entitled to request that we stop sending you marketing materials or contacting you for any direct marketing purposes by. Please note that where we continue to provide you services or, we may still contact you with service-related information but these will not amount to marketing.
In addition, as our client’s employee or representative, you have the right to:
- opt out of survey and marketing communications above, by emailing the below email
- inform us if you are changing roles within your organisation or leaving your organisation which negates the need for our communication and we will cease further communications
- request access to the Personal Data we hold about you and portability to another provide
- request the rectification or erasure of your Personal Data or restrict the processing of it
- object to our processing of your Personal Data
- complain to a supervisory authority about our processing activities to do with your Personal Data, which in the UK is the Information Commissioner’s Office