NOTICE REGARDING PROCESSING OF PERSONAL DATA – BUBLAR GROUP AB (publ)
Version 1.1 | Updated: 2017-11-02
WE CARE ABOUT YOUR PRIVACY
Hello! This is where we, Bublar Group AB (publ) ("Bublar", "us", "we", "our"), describe how we
process the personal data that you provide to us when accessing or using our applications (each an
"App") and or our website www.bublar.com (the "Site")
(together the "Services").
We care about your privacy. We have therefore implemented appropriate technical and
organizational measures to protect your personal data when accessing and using our
Services. Bublar is the data controller for the processing of your personal data.
available at: http://legal.bublar.com/tos. Please read these carefully.
WHICH CATEGORIES OF PERSONAL DATA DO WE PROCESS AND WHY?
Access and use of the App
In order to access and use our App(s) you may need to create a user account or,
alternatively, login through a Facebook account using Facebook Connect. In connection with
creating a user account we collect your e-mail address. If you choose to login using your
Facebook account, we collect the information that you allow Facebook through your privacy
settings to disclose to us. This normally includes your Facebook username, name, e-mail
address, gender, locale, currency, timezone, picture and your list of friends.
When using the App, we may collect further information that you provide to us and which
relate to the use of the App as such, including your mobile device's geographic position at a
specific time, virtual items associated with your user profile and other content that you upload
using the App, e.g. photographs and text. Moreover, if you make an in-app purchase in the
App, we will collect purchase, transaction and payment information relating to your in-app
purchase. Additionally, we may process technical information regarding your mobile device,
e.g. device ID, operating system, version of our App(s) and similar.
We process the personal data that you provide to us when accessing and using the App in
order to give you access to the App, provide you with features in the App and to
administrate your user profile, in-app purchases and the Services. The processing of your
personal data is necessary for the performance of the contractual agreement between you
To the extent that you have disclosed personal data of somebody else in connection with
using a App, you are obligated to inform and, where necessary, obtain the individual's
consent regarding our processing of the individual's personal data in accordance with this
Use of the Site
We may also process personal data that you voluntarily provide to us via our Site when using
contact forms or subscribing to newsletters, e.g. your name and e-mail address. The
processing of your personal data is necessary in order to fulfill our legitimate interest of
responding to your request.
Additionally, we collect visitor statistics, including IP-addresses, on our Site. We process the
personal data collected in order to satisfy our legitimate interest of understanding how our Site
is used and to develop and improve our Site.
When making a purchase on the Site you may need to provide further information, such as
debit or credit card information. The provision of personal data in this regard is necessary in
order for us to carry out the transaction. We use third party payment providers in order to
process payments via the Site. The payment providers are data controllers for their own
processing of your personal data in order to process payments. If you would like further
information on how the payment providers process your personal data we recommend that
you read their data privacy notices. Our processing of your personal data in this regard is
necessary for the performance of the contractual agreement between you and us.
Communications with you
We may use your e-mail address in order to communicate with you regarding the App(s)
that your user profile is associated with, e.g. in order to inform you of updates and other
changes to an App, new features and in-app events. The processing of your personal data
for these purposes above is necessary in order to satisfy our legitimate interest of keeping in
contact with you regarding the App(s) that your profile is associated with.
Additionally, based on your consent, we may process your e-mail address to send direct
marketing information to you relating to us, our App(s) and Services. You have the right to at
any time to oppose to our processing of your personal data for direct marketing purposes and
de-register from future communications from us, please see contact details below.
We may also process the personal data that you provide to us in connection with accessing
and using our App(s) and in your interactions with us for statistical purposes. The
processing of your personal data is based on our legitimate interest of aggregating statistics in
order to understand how our App(s) are used and to develop and improve our App(s).
Development, testing and improvement of our Services
We may, where necessary, use the personal data that you provide to us, e.g. user name,
geographic position, photographs, social connections made in the App(s) in order to
develop, test and improve our App(s) and Services. We process your personal data in order
to satisfy our legitimate interest of continuously improving our App(s) and Services.
FOR HOW LONG IS YOUR PERSONAL DATA RETAINED?
We retain your personal data for as long as necessary in order to provide the Services. Your
personal data will thus, as a starting point, be stored until you decide to delete your user
account. However, if you have not logged into the App during a period of 12 months, we will
send you an e-mail to the e-mail address that you have registered requesting that you confirm
whether you wish to continue to access and use the App. If you do not respond to this
request within 3 months thereafter your user account and profile associated with the App will
be deleted, meaning that it will no longer be possible to log into App using your user
Any content, which does not include your personal data, that you have uploaded to or created
in the App will be stored until further notice, unless you request that we delete the content.
Your personal data may be retained for such additional period that is necessary if we are
required by law to retain the information, or in order to establish, defend or exercise legal
claims. When your personal data is no longer necessary for these purposes, we will securely
delete the data.
TRANSFER OF YOUR PERSONAL DATA OUTSIDE THE EU/EEA
We use Amazon Web Services (AWS) in order store content used by our App(s). Given that
Amazon Web Services, Inc. is established in the U.S. and has datacenters in several regions
around the globe, your personal data may in connection with the use of our App(s) be
transferred outside the EU/EEA to countries which do not have the same level of protection for
personal data as countries within the EU/EEA. In order to ensure that your personal data is
adequately protected, we ensure that there are appropriate safeguards in place by way of data
transfer agreements which include standard data protection clauses adopted by the EU
Commission. As of 25 May 2018 you have the right to receive a copy of the clauses by
contacting us on the contact details below.
HOW IS MY PERSONAL DATA SHARED?
Upon your request and based on your consent, we may share your personal data on social
networks, e.g. if you wish to post an achievement made in an App to your social networks.
Application Distribution Service Providers
In connection with in-app purchases, we need to disclose certain information to the application
distribution service provider (e.g. Apple or Google) in order to process the purchase. The
personal data is necessary for the performance of the contractual agreement between you
and us and thus in order for us to fulfill your in-app purchase request. The application
distribution service providers are data controllers for their own processing of your personal
We may, as outlined above, disclose your personal data to third party payment providers if
you choose to make a purchase via our Site.
We may disclose aggregated statistics to business partners of how our Services are used.
This allows us to create experiences and events together with our business partners in our
App(s) and on our Site. We only disclose personal data to business partners with your prior
given consent in which case we inform you which categories of personal data and for which
purpose(s) that we ask to disclose.
For the purposes outlined above, we may also disclose your personal data to companies
within the Bublar group. The disclosure to the group companies is based on the same legal
basis as the processing as such.
Other Third Parties
Finally, we may process and disclose the personal data that you have provided to other third
parties than outlined above in order to fulfill our legitimate interest of complying with applicable
law and regulations and lawful regulatory requests or relevant orders from competent courts
and public authorities and to establish, exercise and defend legal claims.
Additionally, we may disclose your personal data to third parties in case of a merger or a
transfer of assets in order to fulfill our legitimate interest of carrying out such merger or transfer
You have the right to request access to the personal data that we store about you. Some
information is directly available in your profile in the App. You also have the right to request
that incorrect or incomplete personal data is corrected.
Furthermore, you have the right, to the extent our processing is based on your consent, to at
any time revoke your consent to our processing of your personal data. If you revoke your consent,
we still have a right to continue to process the personal data that we already have collected
based on your previous consent.
Should you have any issues regarding the processing of your personal data, you have the
right to lodge a complaint with the Data Inspection Board.
As of 25 May 2018, you also have, to the extent applicable data protection laws provide, a
right to erasure of personal data, restriction of processing, to object to certain processing and
to data portability.
HOW WILL WE NOTIFY YOU OF CHANGES TO THIS NOTICE?
If we make any changes to this information, we will notify you on the Site, by a message in the
App(s) that your user profile is associated with and or by sending you an e-mail to the e-mail
address that you have registered for your user account.
If you have any questions or concerns about our processing of personal data, please contact
us on using the following contact details.
Bublar Group AB (publ), 559019-7462
Skeppargatan 8 BV, SE-114 52 Stockholm, Sweden
+46 (0)8 559 251 20