Last updated March 18, 2019
TABLE OF CONTENTS
- What information do we collect
- How we use information
- How we share information
- Third party services
- Data retention
- Data processor and data ownership
- Processing outside of EU/EEA
- Your choises
- Minors and children's privacy
- Contact us
"Agreement" means an agreement signed between Bluugo and Client concerning Client Service(s).
"Client" means a Customer of Bluugo.
"Client Data" means Personal Data and any Client business related data that Client or User stores within the Services.
"Client Service" means the Service or App that can be accessed only by User with authentication and log in is required.
"Open Service" means the Service or App that can be accessed without authentication or without needing to log in.
"Personal Data" shall mean any information relating to an identified or identifiable natural person.
"User" means an employee or other representative of a Client, who uses Client Service.
"Unregistered User" means i) an individual who uses Open Service but has no access to Client Service, ii) visitors on our website, iii) user of our mobile applications that do not require user account and registration.
2. WHAT INFORMATION DO WE COLLECT
We may collect and receive information about users of our Services & Apps from various sources, including: (i) information you provide through your user account on the Services if you register for the Services; (ii) your use of the Services as User or iv) your use of our Services, Apps and/or website as Unregistered User. The legal basis for Bluugo's processing of Personal Data are that the processing is necessary for providing the Service in accordance with our Terms of Service, Agreement and that the processing is carried out in Bluugo's legitimate interests as explained in paragraph "How we use the information".
2.1. Information You Provide
User Registration When you register as an User to our Services and/or Apps, we may collect Personal data by asking for your contact information, including items such as i) name, ii) company name, iii) company address, iv) business location, v) email address, and vi) telephone number. Personal data also includes additional profile information like language and time zone preferences.
User Content. Our customer service / service desk feature allows you to post service related content on our Services. You agree that your profile information and the content you post may be viewed and used by other Users within the same Client.
Information Created by Client. A Client may register and add Users into the Client Service. Bluugo has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its Users and third parties like unregistered Users concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service.
Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.
2.2. Information We Collect
Cookies and Other Tracking Technologies. We collect certain information automatically and store it in log files. In addition, when you use our Services, we may collect certain information automatically from your device. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), operating system, date/time stamp. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. You can obtain more information about cookies by visiting http://www.allaboutcookies.org
Service Usage Data. When you use our Services we may collect information about your login and transactions you use within our service. This information may include IP addresses and browser type, operating system and timestamp. We use this data to operate the Services, protect the security and safety and provide customer support. We also use this data to aggregate analysis that enable us to report on Client Data volumes.
3. HOW WE USE THE INFORMATION
We use the information that we collect in various ways in providing the Service and operating our business, including the following:
Provide, operate and maintain our Services. We use the information – other than Client Data - to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service.
Improve, personalize and expand our Services
Understand and analyze how you use our Services
Communicate with you. We may use a visitor’s or User’s email address or other information – other than Client Data – to contact that visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, (ii) with updates on promotions and events, relating to products and services offered by us. You have the ability to opt-out of receiving any such promotional communications.
Send you (as a registered user) messages and push notifications
Cookies and Tracking Technologies. We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed;
For Analytics purposes. We use Google Analytics to measure and evaluate access to and traffic to our website and other Open Services, and create user navigation reports for our Site administrators. For more information, see Google Analytics Privacy and Data Sharing (https://policies.google.com/privacy)
For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
4. HOW WE SHARE INFORMATION
We only share information with your consent, to comply with laws, to protect your rights or to fulfill business obligations. We may disclose information to third parties, including the following:
Service Providers. We work with third party service providers who act as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service. These third party service providers may have access to, or process Personal Data or Client Data as part of providing those services for us. We carefully choose partners to ensure that Personal Data is processed in accordance to current privacy legislations. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information. We cooperate with the following categories of processors of personal data:
- Server and hosting companies
- Transactional e-mail and push notification service companies
- Maps and location service companies. If you use our location services features, information about location in connection with the device, including GPS coordinates will be stored on our Service. As some of the location services are provided by third parties, those third parties may also collect such information.
5. THIRD PARTY SERVICES
You may access other third-party services through the Services or Apps, for example by clicking on links to those third-party services. Bluugo is not responsible for the privacy policies and/or practices of these third-party services to which links or access are provided through the Service.
Bluugo is committed to protecting your Personal Data. To do so, we utilize reasonable and appropriate organizational, technical and physical measures to safeguard the information we collect and process. We follow generally accepted industry standards, technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing personal information. This includes, for example, firewalls, strong password protection and other access and authentication controls. We utilize SSL technology to encrypt all data transfers and we also have application-layer security features to further protect all Client and Personal Data.
However, transfers of information over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that Users also take responsibility to ensure that their data is protected. It is the responsibility of the User that their login information is kept secret. If you believe that your Personal Data has been compromised, please contact us at firstname.lastname@example.org.
7. DATA RETENTION
We retain Personal Data where we have an ongoing legitimate business need to do so (for example, to provide you with a service according the Agreement or to comply with applicable legal, tax, or accounting requirements).
After the expiry of the Agreement, we shall return or delete, according to the guidelines of the Client, all the Personal Data of the Client and delete all duplicates, unless applicable legislation requires the retention of Personal Data.
8. DATA PROCESSOR AND DATA OWNERSHIP
Bluugo does not own or control any of the Client Data stored or processed by a Client or User within the Service and/or Apps. We are not acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (“GDPR”). Bluugo shall process Personal Data of the Client on behalf of, and commissioned by the Client, on the ground of the terms set in mutual Data Processing Agreement (DPA).
Bluugo is not responsible for the content of the Personal Data that you as a Client store in the Client Data nor is Bluugo responsible for the means which the Client / User collects, discloses, distributes or otherwise processes Client Data.
9. PROCESSING OUTSIDE OF EU/EEA
As a general rule, the processing is conducted in the EU/EEA. Any relocation to a third country is permitted to the extent this will be required for the performance of the services provided by Bluugo. The transfer shall be governed by the EU-US Privacy Shield system or the EU Standard Contractual Clauses ("Model Clauses").
10. YOUR CHOICES
You can use some of the features of the Services without registering (i.e. as an Unregistered User), thereby limiting the type of information that we collect. You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for Service related purposes.
11. MINORS AND CHILDREN’S PRIVACY
13. CONTACT US