Impulse Brands Group Ltd (“Bubbleology”, “we” or “us”) are committed to protecting and respecting your privacy.
- This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
- This policy together with the Terms & Conditions apply to your use of:
- Our website at bubbleology.co.uk (the “Site”);
- Any of the services accessible through the site (the “Services”).
We are the data controller responsible for your personal data and we are registered with the Information Commissioner’s Office with reference number A8280140.
DATA PROTECTION OFFICER
We have appointed a data protection officer (“DPO”). Our DPO has a number of important responsibilities including:
- Monitoring Bubbleology’s compliance with the GDPR and other data protection laws;
- Raising awareness of data protection issues, training Bubbleology staff and conducting internal audits; and
- Cooperating with supervisory authorities such as the ICO on our behalf.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us or our DPO here:
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
SO THAT WE’RE CLEAR AND THERE’S NO MISUNDERSTANDING ABOUT HOW WE HANDLE YOUR PERSONAL DATA, WE WILL:
- Always keep your data safe and private.
- Never sell your data.
- Allow you to manage and review your marketing choices at any time.
INFORMATION WE COLLECT ABOUT YOU
- We may collect and process the following data you give to us by filling in forms on the Site, or by corresponding with us (for example, by e-mail or telephone). It includes information you provide when you register for the loyalty scheme, subscribe to our newsletter, enter a competition, promotion or survey, apply for a franchise, apply for vacancy or provide feedback. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, password, memorable name, medical history (for example medical treatments or conditions), criminal record such as convictions of any offence, specific information (for example skills, franchise investment objectives, amount available to invest for a franchise, salary, real estate income, other income, bankruptcy record, franchise ownership, franchise location preference), property ownership details (for example address, purchase date, original cost, present value, mortgage balances), assets & liabilities (for example cash on hand & in banks, business holdings, marketable securities, accounts/notes receivable, real estate, other assets, credit card balances, accounts payable, unpaid taxes, notes payable, other liabilities) and any other information you provide us.
USES MADE OF THE INFORMATION
- We may use information held about you in the following ways:
- To provide customer service and respond to any feedback, questions or complaints we receive from you;
- To keep you informed and up-to-date about new store openings, new products, promotions, events and other relevant marketing activities. You can opt out of marketing pushes at any time by clicking ‘Unsubscribe’ at the bottom of any marketing communication;
- To assess your eligibility and interest in a Bubbleology franchise;
- To evaluate your candidacy for employment;
- To notify you about changes to our service.
- We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION
We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our support team via email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
What we use your information for Our reasons Our Legitimate interests To provide customer service and respond to any feedback, questions or complaints we receive from you. Our legitimate interests Developing products and services.
Our commercial interest in providing you with a good service and customer experience
To keep you informed and up-to-date about new store openings, new products, promotions, events and other relevant marketing activities. Our legitimate interests Developing products and services
Seeking consent when we need it to contact you.
To assess your eligibility and interest in a Bubbleology franchise Our legitimate interests Being efficient about how we fulfil our legal and contractual duties
Our commercial interest in developing a successful business relationship
To evaluate your candidacy for employment Our legitimate interests Our commercial interest in developing a successful business relationship To notify you about changes to our service Our legitimate interests Our commercial interest in providing you with a good service and customer experience
WHAT DO WE MEAN WHEN WE SAY:
Legitimate Interest: this means the interest of ours as a business in conducting and managing Bubbleology to enable us to provide to you the Bubbleology Services and offer the most rewarding experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Our Legal Obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- We may use information held about you in the following ways:
- We want to make it crystal clear how we use your data for marketing purposes and how you can unsubscribe from receiving any marketing communications from us whenever you want.
- You will receive marketing communications from us if you have signed up to and/or utilise the Bubbleology Services and, in each case, you have not opted out of receiving marketing communications.
- You can ask us to stop sending you marketing messages at any time by adjusting your marketing preferences via ‘View account’ section found within the ‘Loyalty’ tab of the Site or by following the ‘Unsubscribe’ link on any marketing message sent to you.
DISCLOSURE OF YOUR INFORMATION
- We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws.
- We send personal data to the following sets of data processors in order to perform the Bubbleology Services:
- Digital marketing agencies
- This is in order to manage our marketing communications to newsletter subscribers and provide customer service via the ‘Feedback’ tool on the Site;
- Loyalty scheme providers
- This is in order to operate a loyalty scheme and issue a loyalty card;
- Companies within the Bubbleology group
- In order to provide a unified service across all of our products and services, we may disclose your personal information to any member of the Bubbleology group, which means any of our subsidiaries or related entities. Companies in the Bubbleology group will be acting as joint controllers or processors in order to provide the Bubbleology Services.
- Digital marketing agencies
- We may also disclose your personal information in the following circumstances:
- If Bubbleology 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 or regulatory obligation or request.
- All information you provide to us is stored on our or those of our data processing partners’ secure servers. Where you have chosen a password that enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
RETAINING YOUR INFORMATION
- Bubbleology is obligated under the DPA 1998 to retain certain personal data about you for a period of 6 years. In order to not hold your information for longer than is strictly required we will assess the necessity of holding any of your personal data for more than 6 years after the termination of our business relationship.
YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights: You have the right to:Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team via firstname.lastname@example.org.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via email@example.com.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Bubbleology is under certain obligations to retain certain data for a minimum of 6 years (see above). Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.
Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. Bubbleology is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide the Bubbleology Services and it is likely we will have to terminate your account.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Bubbleology Services). In this case, we may have to cancel your use of the Bubbleology Services but we will notify you if this is the case at the time.
Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team via firstname.lastname@example.org.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Bubbleology Services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Bubbleology Services). In this case, we may have to cancel your use of the Bubbleology Services but we will notify you if this is the case at the time.
- Take a look at some helpful guidance on the ICO website which can be found here: ico.org.uk; and