The Pubble Web Service Privacy Statement

This Privacy Statement explains how Pubble may collect, use, and disclose "Personal Data" and other information we obtain through Pubble's messaging applications.

Personal Data means any information processed by Pubble relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Pubble will only collect, process or use Personal Data for the purposes of providing the Services. Pubble does not sell, trade or otherwise transfer your personal information to third parties in any manner that could be harmful, dangerous or violating your privacy.

For citizens based in the EU, certain regulations apply to Personal Data stored on their behalf as set out by the EU General Data Protection Regulation (GDPR) - regulation (EU) 2016/679. For all Personal Data collected, regardless of location, Pubble will comply with the provisions of the GDPR in the context of its obligations as controller of the data to the extent applicable.

Pubble agrees to use commercially reasonable technical and organisational measures designed to prevent unauthorised access, use, alteration or disclosure of Personal Data. Pubble will have no responsibility for errors in transmission, unauthorised third-party access or other causes beyond Pubble's control. In certain situations, it may be a legal requirement for us to disclose Personal Data to the relevant authorities.

What information does Pubble collect?

Using Pubble Apps, you may voluntarily provide Personal Data (name, email, phone number) using the Service. In addition, one other form of Personal Data, namely IP address, is collected automatically. Pubble also stores your conversation history. You should note that, while not necessary for the purposes of the Service, you may voluntarily provide extra Personal Data in the course of a conversation. You consent that Pubble collects and processes such information for the purposes outlined in this Privacy Statement.

Other, non-personal information is also collected, namely User Agent (browser details) and pages browsed when using Pubble.

Where is your data stored?

Pubble stores all of its data in the EU. You should note that, depending on the information you provide, Personal Data may be temporarily transferred outside of the EU solely for the purposes of providing the service. As an example, if you voluntarily choose to submit your email address in order to be notified of a reply by email, your email address is temporarily transferred to a 3rd party service outside of the EU, in order to notify you. Note also that Pubble will only use 3rd party service providers that have adequate security measures in place aligned with the GDPR.

Your rights in relation to your Personal Data

As outlined in the GDPR, you have the following rights in relation to your Personal Data. Note, that the GDPR only stipulates that these rights are required for EU citizens. We, however, apply these rights to your Personal Data regardless of your location.

  1. Right to access – you have to access and view any Personal Data we store relating to you.
  2. Right to rectification – you have the right to request we update any information we hold about you that is inaccurate.
  3. Right to be forgotten – you have the right to request we erase any information we hold you on, except where we are subject to hold that data under legislation or for legal requirements.
  4. Right to restriction – you have the right to request we temporarily restrict the processing of your Personal Data under the conditions set out in the GDPR
  5. Right to data portability – you have the right to obtain a machine-readable copy of the Personal Data we store for you

Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legal purposes.

What about cookies?

Cookies are small text files which are stored on a user's computer and are designed to hold a modest amount of data specific to a particular user and website e.g. time on site. They can be accessed either by the web server or the client computer. It is important to note that accepting cookies used on our site does not give us access to any personal information. Most browsers automatically accept cookies by default, but you can usually refuse cookies or selectively accept certain cookies by adjusting the preferences in your browser.

Age Requirement

In line with the GDPR you must be 16 years or older to use the Pubble service. Pubble is committed to protecting the privacy of young children, and therefore does not knowingly collect or maintain personal information on the service from persons under 16 years of age.

Acceptance of Privacy Statement

By using Pubble's messaging applications, you agree to terms of this Privacy Statement. We recommend that you review this Statement periodically, as we may update it from time to time. If you continue to use the services after those changes are in effect, you agree to the revised Statement.

Contacting Pubble

Please use the contact options on the Pubble website www.pubble.io

12th May, 2018