Blue Bottle Group – 25 May 2018
This Privacy Notice provides details of the personal data we
collect from you, what we do with it, how you might access it and who it might
be shared with.
We are committed to protecting your privacy. In general, we
will ask you when we need information that personally identifies you or allows
us to contact you. The amount of personal information you are required to
supply will normally be limited to that which is necessary to supply the
service or carry out the transaction that you have requested. If other
information is requested, it will be labelled as optional.
What we do With Your
We process personal data only for the purpose for which they
are collected. The purpose is dependent on whether you use only our website, or
additionally, our services. If you use our services, you are required to register,
and we collect your personal data. We use this personal data for the provision
of the service or the performance of the contract. We may use your personal
data for other similar purposes, including marketing and communications, but
that will only occur in the case we have your consent or another legal
justification for doing so.
From our Customers / Clients we process and retain personal
data for the following purposes and periods, with the applicable legal basis.
The processing of subject data is done for contact
management, sales and distribution of products and services, as well as for
communication and marketing. These steps are required prior to a contract with
the data subject, and retention of such data for a maximum of six years, or
what is required for tax and legal purposes.
From our Contractors we process and retain personal data for
the following purposes and periods, with the applicable legal basis.
Organisation’s administration and management, and these
steps are required prior to a contract with the data subject. The data is
retained for a maximum of six years, or what is required for tax and legal
What Personal Data do
The personal data we collect depends on whether you just
visit our website or use our services. If you visit our website, you do not
need to provide us with any personal data. However, your browser transmits some
data automatically, such as the date and time of retrieval of one of our web
pages, your browser type and settings, your operating system, the last web page
you visited, the data transmitted and the access status, and your IP address.
If you use our services, personal data is required to fulfil
the requirements of a contractual or service relationship, which may exist
between you and our organization.
We collect various information depending on the requirements
i.e Member joining our group, supplier information, clients entering a Blue Bottle
Information collected may include any of
Email, Social Network
Telephone contact details
Who Might we Share
Your Personal Data With?
To maintain and improve our services, your personal data may
need to be shared with or disclosed to service providers, other Controllers or,
in some cases, public authorities. We may be mandated to disclose your personal
data in response to requests from a court, police services or other regulatory
bodies. Where feasible, we will consult with you prior to making such
disclosure and, to protect your privacy, we will ensure that we will disclose
only the minimum amount of your information necessary for the required purpose.
How do we Look After
We limit the amount of personal data collected only to what
is fit for the purpose, as described above. We restrict, secure and control all
our information assets against unauthorised access, damage, loss or
destruction; whether physical or electronic. We retain personal data only for
as long as is described above, to respond to your requests, or longer if
required by law. If we retain your personal data for historical or statistical purposes,
we ensure that the personal data cannot be used further. While in our
possession, together with your assistance, we try to maintain the accuracy of
your personal data.
How Can You Access
Your Personal Data?
You have the right to request access to any of your personal
data we may hold. If any of that information is incorrect, you may request that
we correct it. If we are improperly using your information, you may request
that we stop using it or even delete it completely.
If you would like to make a request to see what personal
data of yours we might hold, you may make a request from our company website.
Where you have previously given your consent to process your
personal data, you also have the right to request that we port or transfer your
personal data to a different service provider or to yourself, if you so wish.
Where it may have been necessary to get your consent to use
your personal data, at any moment, you have the right to withdraw that consent.
If you withdraw your consent, we will cease using your personal data without
affecting the lawfulness of processing based on consent before your withdrawal.
The Blue Bottle Group does not make use of “cookies” except
to compile aggregated statistics about web site usage. A cookie is a text file
that is placed on your hard disk by a web page server. Cookies cannot be used
to run programs or deliver viruses to your computer. Cookies are uniquely
assigned to you or your computer and can only be read by a web server in the
domain that issued the cookie to you.
While they are only used for internal tracking purposes, you
have the ability to accept or decline cookies. Most web browsers automatically
accept cookies, but you can usually modify your browser setting to decline
cookies if you prefer.
In our regular mailings, we use technology to help track
interest in our features, to help us improve our service and the content we
share with our subscribers.
We are committed to maintaining the confidentiality, integrity and security of
personal information and we will take all appropriate technical and
organisational security measures to ensure that where any personal information
is provided to us it will be protected against loss, destruction and damage,
and against unauthorised or accidental access, processing, erasure, transfer,
use, modification, disclosure or other misuse.
We shall not disclose to any person any personal data of a
data subject that is processed or hosted by us where any such disclosure would
not comply in all respects with the provisions of any applicable data
protection legislation or regulations relating to the data subject concerned.
A User's phonebook, message content and MSISDNs indicating
to whom messages were sent to or received from belong exclusively to that User
and will not be disclosed to any third parties without the user's written
permission or unless compelled to do so by a court of law.
Where the personal data of any EU member state subject is
transferred to the Blue Bottle Group in a non-EU member state for processing, the
Blue Bottle Group undertakes to ensure technical and organizational security
measures that provide a level of protection appropriate to the risks
represented by the processing of such data and in order to protect such data
against accidental or unlawful destruction, accidental loss, alteration,
unauthorized disclosure or access or any other unlawful form of processing.
Any recipient of any message has the right to know the
identity of the sender, and this will be disclosed on request to the recipient.
Our Users may be required to submit limited personal
information when accessing the Services including a username, email address and
password for the purposes of protecting User accounts against unauthorized
access. In addition, messages, files or other data contained in the Services
may contain the personal information of third parties.
We may automatically record certain information about the
use of our Services such as account activity (e.g. usage, log-ins, actions
taken), data displayed or clicked on (e.g. GUI elements, links), and other log
information (e.g. browser type, IP address, date and time of access).
We may use this information to provide authorized persons
with usage reports and internally to deliver the best possible service to our
clients and Users, such as improving software user interfaces and maintaining a
consistent, reliable and secure user experience.
We may also detect and log a User's location and IP address to
identify the User’s geographic region or time zone for routing traffic to
geographically based servers or for managing time-sensitive tasks like the
sending of notifications.
Like many reputable companies, our Services, including our
website, other online services, applications, email messages and
advertisements, if any, may use "cookies" and other technologies such
as pixel tags and web beacons to collect information. A cookie is a small data
file stored on the web browser on your computer's hard drive. Cookies and other
technologies allow us to count how many Users visited certain web pages within
our web site, their personal preferences and to measure the effectiveness of
our website and electronic advertisements for different computing devices and
We use this information to understand and analyse trends, to
administer our websites and to learn about user behaviour on our websites. If a
user blocks cookies from being stored on a computer, the functionality of our
Services may be negatively affected.
We may carry out and perform functional, statistical,
textual, semantic and other forms of analysis of non-personally identifiable
data that is hosted or processed by us in relation to our Services. We do this
to improve the performance of our Services, to understand the way in which our
Services are being utilised, to identify usage patterns, market trends, to gain
insights and to formulate new products and service offerings. We may also
process, aggregate and anonymize personal data such that it does not reveal any
confidential, personal or sensitive data or any features from which
confidential, personal or sensitive data may be ascertained. We will never
disclose confidential, personal or sensitive data without the direct or
indirect consent of the party to whom we owe the duty of confidentiality and/or
the data subject concerned. We may process and transfer anonymized data in our
reasonable discretion including within the Licensor’s group of companies.
Where we make use of third party service providers to help
us provide the Services to you, including for the purposes of retrieving or
delivering information, records, notifications or other messages to you or any
User’s or for hosting or providing any component of our Services, we require
such third parties to maintain the confidentiality of any personal information
we provide to them for these purposes. Some of these third parties may be
situated outside of your country and you consent to your personal data and that
of any data subjects you provide to us being transferred cross-border so that
we can provide the Services to you. In this regard, we engage only with reputed
third-party service providers who have security and privacy policies and
procedures providing at least the same level of protection as we do ourselves.
You warrant that you have all necessary permissions to give us the above
We may share data, including Personal Data, collected from
Users of our Services with third-party service providers or consultants who
require access to that data to perform their work on our behalf for helping us
deliver our Services. These third-party service providers or consultants are
limited to only accessing or using this data to provide the services to us and
must provide reasonable assurances that they will appropriately safeguard the
data. We may also share non-personal or non-identifiable information, including
website visitor information and account usage data with third party analytics
We may communicate with User’s and other persons by email
and other messaging applications. You may opt out from promotional
communications from us that are not strictly related to the provision of the
Services to you.
We do not intentionally collect personal identifiable
information from anyone who is a minor. If it is discovered that we have
unintentionally collected personally identifiable information from a minor
other than for a legitimate purpose associated with the Services, we will
delete that information immediately.
discretion and changes will become effective upon posting to the site.
If the Blue Bottle Group merges with, or is acquired by, any
other business, you acknowledge that your personal information may fall under
the control of another person.
If you terminate your relationship with The Blue Bottle
Group, portions of your personal information may be retained in back-ups and
archives for as long as is reasonably necessary to assist us in meeting our
legal compliance obligations.
Questions and Comments
If you have questions, comments, concerns or feedback