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1. Introduction

Bubbly is a real-time on location customer feedback kiosk for corporations and small businesses. The software that powers Bubbly is provided as an Application Service Provider (ASP) model, delivered through a modern browser, mobile application, or other connected device via the Internet. Surveys are delivered via the Bubbly kiosk, mobile device/SMS, a web link, and/or email. Consumers must explicitly opt-in to receive mobile, SMS, or email communication.

1.1.  This Privacy Policy (“Privacy Policy”) explains how Bubbly uses information that you provide to us. In this Privacy Policy “use” means collecting, storing, organizing, or analyzing the information.

1.2.  In this Privacy Policy, “Bubbly” means Bubbly Group, Inc., a Delaware corporation, with offices at 60 Madison Avenue, New York, NY 10010 and “Clients” mean a business with which Bubbly has an established relationship.

1.3.  We collect information on behalf of our clients who provide products and/or services to the public (“Suppliers”). We do this so that Suppliers can improve the way that they provide products and/or services in the future.

1.4.  Information that you give us about a Supplier, including your opinion about products and/or services you have purchased from a Supplier, is called “Feedback”.

1.5.  Personally Identifiable Information about you, including any information which identifies you as an individual or from which you can be identified by a third party, is referred to as “PII”. Bubbly does not collect sensitive PII such as: social security numbers, political opinions, medical information or religious beliefs. Bubbly does collect demographic information for statistical and analytics purposes. Demographic questions are completely voluntary.

 

 2. Personally Identifiable Information

2.1.  Bubbly collects PII on an explicit opt-in basis from you for the purposes of:

2.1.1.     Verifying and validating your identity to prevent misuse of the Bubbly kiosk and survey mechanisms.

2.1.2.     Correlating and linking multiple Bubbly kiosk and survey mechanism engagements.

2.1.3.     Survey and Feedback analytics.

   

3. Storage, Transport, and Security

3.1.  Bubbly will keep your PII and Feedback secure. We will not provide PII or Feedback to any other person or entity except as permitted under this Privacy Policy or as agreed upon by you in writing.

3.2.  Bubbly employs data centers that are certified ISO 27001 and ISO 27018 as well as certified for the EU-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU to the United States.

3.3.  Your PII and Feedback is stored using AES 256 encryption.

3.4.  Data communication is done via API calls using the TLS cryptographic protocol provisioned by DigiCert, one of the top trusted Certificate Authorities.

3.5.  Bubbly destroys PII and Feedback within 12 months from the last time you provided the information to Bubbly.

   

4. Access to Personally Identifiable Information and Feedback

4.1.  Bubbly only provides your PII and Feedback to our clients for whom the Feedback was originally captured.

4.2.  You have the right to a copy of the PII and Feedback that we hold by emailing privacy@bubblygroup.com.

5. Children’s Privacy

5.1.  Children (anyone under 18) may use Bubbly survey mechanisms and provide PII and Feedback. However, if you are under 18, Bubbly will not store your PII for more than 7 days.

6. Changes to the Privacy Policy

6.1.  If Bubbly decides to change this privacy policy, changes will be posted to the Bubbly website with the date of last revision clearly posted.

6.2.  We reserve the right to modify this privacy policy at any time, so please review it frequently. If material changes are made, we will notify you here, by email if one has been captured by Bubbly, or by means of a notice on our home page prior to the change becoming effective.

7. Privacy Contact

7.1.  If you have question or comments about this privacy policy, please contact Bubbly by emailing privacy@bubblygroup.com or writing Attention: Privacy Department, Bubbly Group, Inc., 60 Madison Ave, 3rd Floor, New York, NY 10010