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We may collect, use, store and transfer different kinds of personal data about you which we have grouped together and defined below:
- Personal Information (Identity Data) - any information that can identify you as a person i.e. name, date of birth, gender
- Contact Information - including billing address, delivery address, email addresses and telephone numbers
- Financial Data - including bank account and payment card details
- Transactional Data - including details about payment to and from you and other details of services you have purchased from us
- Profile Data (on VelaCRM) - including username, historical payments, preferences, feedback and survey responses
- Marketing and Communications Data - your preferences in receiving marketing from us and your communication preferences
- Device Information (Technical Data and Usage Data) - Information on how users interact with a website i.e. analytics of site activity
We do not collect any Special Categories of Personal Data (unless you offer this information) about you (this includes details about your race, ethnicity, religious or political beliefs or sexual orientation). Nor do we collect any information about criminal convictions and offences.
We are committed to maintaining the trust of our clients. We want you to know that Otaara Limited (which includes the brand BankBulb) is not in the business of selling email lists to other companies. However, for your records we provide more detailed information below on when and why we collect your personal information, how we use it, the limited conditions under which we may disclose it to others and how we keep it secure.
1.1 Otaara Limited (which includes the brand BankBulb), (Otaara, BankBulb, we/us/our) are committed to safeguarding the privacy of our customers and users (you/your) who visit our websites (www.bankbulb.com; www.otaara.com). This privacy statement (the Privacy Statement) sets out our personal information collection and sharing practices for our website and is intended to inform you of the ways in which our website collects personal information, the uses of that personal information and the ways in which we will share any personal information you choose to provide to us.
1.2 Further notices highlighting certain uses we wish to make of your personal information together with the ability to opt in or out of selected uses may also be provided when we collect personal information from you.
1.3 Our website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.
1.4 This Privacy Statement covers the following areas:
(a) What personal information about you we collect
(b) How we use your personal information
(c) How we protect your personal information
(d) Contacting us & your rights to prevent marketing and to access and update your personal information
(e) Our Cookies Policy
2 Information we collect about you
2.1 We will collect and process all or some of the following personal information about you:
(a) Information you provide to us ► personal information that you provide to us, such as when using the contact form or any subscription forms on our website, including your name, email address, and other contact details. [If you choose to apply for a job at Otaara and submit a job application via our careers page we will collect information that you submit via our careers site.] Please refer to the terms and conditions on our careers site for information on how we process this information].
(b) Our correspondence ► if you contact us, we will typically keep a record of that correspondence;
(c) Survey information ► if we ask you to complete surveys that we use for research purposes, we shall collect the information provided in the completed survey;
(d) Website and communication usage ► details of your visits to the website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
3 How we use your personal information
3.1 In this section, we set out the purposes for which we use personal information that we collect via our website and, in compliance with our obligations under European law, identify the “legal grounds” on which we rely to process the information.
3.2 Please note that, in addition to the disclosures we have identified below, in some circumstances we will also disclose personal information to service providers, contractors, agents and affiliates of Otaara that perform activities described in this notice on our behalf.
(a) To communicate effectively with you and conduct our business ► to conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us, which in some circumstances may include passing your data to third parties such as agents or contractors or to our advisors (e.g. legal, financial, business or other advisors).
(b) To provide you with marketing materials ► to provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own and our selected business partners’ products and services to you by post, email, SMS, phone and fax and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in paragraph 5.1 below.
(c) For research and development purposes ► to analyze your personal information in order to better understand your and our other clients’ services and marketing requirements and to better understand our business and develop our products and services.
(d) To monitor certain activities ► to monitor queries and transactions to ensure service quality, compliance with procedures and to combat
(e) To inform you of changes ► to notify you about changes to our services and
(f) To ensure website content is relevant ► to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers.
(g) To reorganize or make changes to our business ► if we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organization, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. We may also need to transfer your personal information to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.
(h) Memberships ► If you have purchased and set up a company membership on BankBulb, we will keep your details and may need to contact you so that we can fulfil the service that your company or you have paid for. This information includes email addresses of individuals who have been appointed page admins, employee names and email addresses as well as company decision makers involved in choosing to sign up with BankBulb.
(i) In connection with legal or regulatory obligations ► We process your personal information to comply with our regulatory requirements or as part of dialogue with our regulators as applicable which may include disclosing your personal information to third parties, the court service, regulators and/or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
4 Transmission, storage and security of your personal information
4.1 Payment information
Registration forms that include credit cards numbers are destroyed after performance of the corresponding obligation.
Online payment is secured: SSL protocol.
4.2 No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
4.3 All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
4.4 We will retain your personal information for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal information for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information is retained) or securely destroyed in accordance with our internal retention policy.
5 Your rights and contacting us
5.1 You have the right to ask us not to process your personal information for marketing purposes. You can exercise the right at any time by clicking the “unsubscribe” option on any electronic marketing communication sent to you or by contacting us at email@example.com.
5.2 We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us.
5.3 If you have any questions in relation to this Privacy Statement, please contact firstname.lastname@example.org.
Rights of California Residents
5.4 Under California’s “Shine the Light” law, Site visitors who are California residents may request and obtain a notice once a year about the personal information the Company shared with other businesses for their own direct marketing purposes. Such a notice will include a list of the categories of personal information that was shared (if any) and the names and addresses of all third parties with which the personal information was shared (if any). The notice will cover the preceding calendar year. To obtain such a notice, please contact us as described below. In addition, under this law you are entitled to be advised how our Site handles “do not track” browser signals. Because there currently is not an industry or legal standard for recognizing or honouring DNT signals, we do not honour Do Not Track requests at this time
6 Cookies policy
7 Changes to our Privacy Statement and/or Cookies Policy
7.2 This Privacy Statement was last updated on 4 January 2020.