Privacy Policy - EU
BUBTY PRIVACY POLICY EU
Bubty B.V. (hereinafter referred to as "Bubty " or "us" or "we") values your privacy and cares about the way in which your personal information is treated.
This Privacy Policy was last updated on 11 December 2023. We may unilaterally change or update this Privacy Policy by amending this page, so make sure you check this page from time to time. If there are substantive adjustments made to this Privacy Policy, a clear notification will be made available on our website.
In this Privacy Policy we explain:
what personal information we collect about you
how we obtain your personal information
how we use your personal information
on what basis we use your personal information
how long we keep your personal information
who we share your personal information with
how we protect your personal information
which countries we transfer your personal information to
your rights regarding your personal information
Please click on the relevant heading below for more information on each of these areas.
what personal information we collect about you
We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our legal or other services or as a result of your relationship with one or more of our staff and clients.
The personal information that we process includes:
Basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person
Contact information, such as your postal address, email address and phone number(s)
Professional information, including your photograph, from LinkedIn or the website of the organisation you work for
Financial information, such as payment-related information
Technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically, collected through cookies and other tracking technologies
Information you provide to us for the purposes of attending meetings and events, including access and dietary requirements
Identification, background and financial verification information provided by you or collected as part of our business acceptance and ongoing monitoring processes
Personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data
Any other information relating to you which you may provide to us
How we obtain your personal information
We collect information directly from you as part of our business acceptance processes and about you and others as necessary in the course of providing legal service
We collect your personal information while monitoring and analysing our technology tools and services, including our website, email and other communications sent to and from Bubty
We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or registering on one of our digital platforms, applications or training courses
We may collect or receive information about you from other sources, such as keeping the contact details and professional information we already hold for you accurate and up to date using publically available sources, including LinkedIn, or collecting information from third party sources as part of our business acceptance procedures
How we use your personal information
Bubty collects and processes personal information about you in a number of ways, including through your use of our website and in the provision or promotion of services by us. We use that information:
To provide and improve this website, including auditing and monitoring its use, and ensure content is provided in the most effective way for you and the devices you are using
To provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients, and to monitor compliance with our policies and standards
To manage access to our premises and for security purposes
To provide information requested by you
To promote our services, including sending business updates
To manage and administer our business and our relationship with you and our clients
To better understand our clients’ or potential clients’ services and marketing requirements and our own business and to develop our services and offerings
For professional networking purposes
To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims, complying with our legal obligations, preventing crime or fraud and protecting the rights of third parties
For the purposes of recruitment
On what basis we use your personal information
Under EU and UK data protection law, the use of personal data must be justified under one of a number of legal grounds. The principal legal grounds that justify our use of your personal data are:
To perform a contract, such as engaging with an individual to provide legal or other services
For the establishment, exercise or defence of legal claims or proceedings
To comply with our legal and regulatory obligations
For legitimate business purposes. Please see ‘How we use your personal information’ for more detail
Consent, where your consent is required by law
How long we keep your personal information
Your personal information will be retained in accordance with our global data retention policy which categorises all of the information held by Bubty and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and Bubty’s business purposes.
Who we share your personal information with
We are an international business and any information that you provide to us may be shared with and processed by any entity in the worldwide network of Bubty. We may also share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
Our professional advisers and auditors
Our insurers and insurance brokers
IT and other service providers engaged in the course of the services we provide to clients and with their prior consent, such as barristers, local counsel and technology service providers like data room and case management services
Third parties or selected partners that we work with such as suppliers (such as hosting providers, customer service and e-marketing), customers (e.g. business customers/employers) and other partners, depending on your location and the services you use
Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to new Bubty entities or to third parties through which the business Bubty will be carried out.
Bubty may use social media sites such as Facebook, LinkedIn and Twitter. If you use these services, you should review their privacy policy for more information on how they deal with your personal information.
How we protect your personal information
We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
This includes the use of data loss protection tools in order to protect Bubty our employees, clients and suppliers, from cyber threats and the loss of sensitive information.
We apply internationally recognised security standards in respect of your personal information
Which countries we transfer your personal information to
In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this privacy policy. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. Please see ‘Who we share your personal information with’ for more detail on how the information may be shared.
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. EU standard contractual clauses are in place between all Bubty entities that share and process personal data. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.
Please contact us using the details at the end of this privacy notice if you would like to see a copy of the safeguards applied to the export of your personal data.
Your rights regarding your personal information
The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for data subjects.
You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. You may also have the right to lodge a complaint in relation to Bubty’s processing of your personal information with a local supervisory authority.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘How we use your personal information’) or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information.
Cookies and Similar Technologies
When using our online services, we collect data through cookies and similar technologies (eg, web beacons, tags and device identifiers). Cookies are text files placed on a device to collect and analyze standard internet log information and information about visitor behavior. This information is used to evaluate visitor behavior on the website and to compile statistical reports on online activities. We register your interaction with our online platforms in order to improve our content and services. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that this may affect the functionality of the website. The following functional and analytical cookies may be placed via the website without your prior consent:
More information about cookies can be found on www.allaboutcookies.org
Questions and complaints
If you have any questions about how we use your personal data, you can contact our customer service support@bubty.com
You can also contact our Data Protection Officer (DPO) via this email address. If you feel that a problem has not been adequately addressed, you also have the right to file a complaint with the Dutch Data Protection Authority.
Bubty B.V.
Spaarneplein 2
2515 VK The Hague
Netherlands
info@bubty.com
