Privacy Notice 

 

Scope

Bubty BV (“Bubty”, “we”, “us”, “our”) offers the possibility for employers to manage their contingent workforce in one centralized place through the bubty.com SaaS (“the B2B Service”). This privacy notice (this “Notice”) is addressed to residents of the United States and outlines how any information that directly or indirectly identifies you (your “Personal Information”) will be processed by us in relation to the B2B Service. Please note that Bubty acts as a service provider to our corporate clients (“Corporate Client(s)”) and your Personal Information is processed by us at their discretion. If you need additional information about the processing of your Personal Information not outlined in this Notice, please contact the Corporate Client who has asked you to create an account with us. As our company is established in the European Union, the General Data Protection Regulation of the European Union also applies to our Personal Information processing activities, as described in our GDPR Privacy Statement which this Notice supplements.

 

What Personal Information is Processed?

We generally receive Personal Information about you either directly from you or when a Corporate Client provides it to us. This typically includes but is not necessarily limited to:

• Identifiers:
  1. first and last name;
  2. email address;
  3. tax identification number.

 

• Personal Information described in the California Customer Records statute:
  1. phone number;
  2. home address and country of residence;
  3. information typically seen on an invoice, such as bank account number (IBAN), VAT registration number, tax identification number and other similar mandatory state registrations, where applicable.

 

• Internet activity information:
  1. logs about work performance and other data produced and recorded within the B2B Service as a result of using the services as intended over a period of time.

 

• Visual information:
  1. photographs.

 

• Professional or employment-related information:
  1. role within the organization of the Corporate Client, employment history, education, professional skills, equipment used, work location preferences, professional social media accounts, professional/personal website, project portfolio, language proficiency;
  2. information relating to the provision of services by you to a Corporate Client, such as hourly rate, payout details (e.g., amount and currency) and history;
  3. attachments, such as CVs/resumes, documents from the onboarding flow (e.g., NDA), compliance reports – and all information contained therein.

 

• Other Personal Information not listed under the categories above:
  1. free-text information (e.g., notes and your bio);
  2. any other data provided as (or within) an attachment or free-form text at either your or Corporate Client’s discretion.

 

How is Your Personal Information Used?

We only use your Personal Information for the purposes for which it was provided to us by either you or a Corporate Client, and on limited occasions and where applicable, to comply with our legal obligations. This includes:

• Safety, security and dispute resolution. We use your Personal Information to ensure the security, integrity and protection of our products, services and customers. For example, we may process your data to detect and prevent fraud, theft and other misuse of our services. Where appropriate, we may use your data in the context of dispute resolution, to enforce the agreement with our Corporate Clients, to enforce our rights against third parties, or to defend ourselves against claims or allegations of third parties.
• Legal requirements. We may process your information to comply with legal obligations, e.g., to keep records or to comply with legitimate requests from competent authorities (e.g., police/courts).
• Maintenance, development and incident management. If you experience problems with, for example, creating an account or editing your account, we may need to process Personal Information, such as name and relationship ID, to solve the problem in question. We also process your Personal Information for some internal operational processes, for example when we transfer customer data to a new database.
• Execution of general business processes, internal management and management reporting. In order to carry out our business activities, we use Personal Information for general business processes. For example, we process your data for archiving purposes, management reports, audits and other administrative purposes.

 

Who do we share your Personal Information with?

We may share your Personal Information with third parties we use as suppliers, more specifically those providing the following types of services:

• platform services and hosting;
• managing contacts and sending messages;
• business register information queries;
• infrastructure monitoring;
• web-based CRM;
• web analytics;
• payment services.

 

Where is your Personal Information processed?

For hosting and maintenance purposes, your Personal Information is stored in both the European Union and the United States. Please note that Bubty BV is a legal entity established in the Netherlands and your Personal Information is mainly processed by our staff employed by said company at our head office in the Netherlands which means that even if your Personal Information is stored in the United States, it may be accessed from (and thus transferred to) the European Union.

 

How long do we keep your Personal Information?

We only keep Personal Information for as long as it is necessary for the purposes for which our Corporate Clients have instructed us to collect and/or store it, and/or as long as required by law, where applicable.

 

Access and management of your Personal Information

You can view most of your Personal Information we store about you directly via your personal account. If you cannot view, correct or delete certain Personal Information yourself, want a copy of your Personal Information, or want to submit any other data rights request, you should directly contact the Corporate Client who has asked you to create an account with us.

 

Contacts

Bubty BV

Spaarneplein 2

2515 VK The Hague

Netherlands

[email protected]

Last updated: 30 March 2023