Introduction
Bubble Teach has always been designed with these two convictions in mind, even before the European General Data Protection Regulation (GDPR) came into effect, which has had the merit of generalizing these good practices.
The GDPR came into effect on May 25, 2018. This new legislation pursues three objectives:
- to standardize legislation within the European Union,
- to hold companies accountable for their management of personal data,
- and to strengthen the protection offered to individuals regarding their data.
Therefore, we have updated our privacy policy.
1. Nature of personal data collected
According to the CNIL, « Personal data means any information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identification number or to one or more elements specific to them. »
If information or a combination of information can identify an individual, alone or by cross-referencing, it is considered personal data.
For example, a name, first name, address, phone number, but also an IP address, a photo are considered personal data because they allow you to be identified, either directly or indirectly.
Data you provide to us directly
By its very nature, the Bubble Teach application collects personal data, which are mostly provided to us directly by you.
On your account
- Name, First Name
- Phone number
Similarly, shopping lists, events in the agenda, tasks, etc., do not constitute private data as they do not allow you to be identified directly or indirectly.
On each learner
- First Name
- Email address
- Phone number
Aside from the email address which is necessary for processing, none of this information is mandatory.
Interactions with technical support
- Name and first name
- Email address
- Email exchanges
Data we collect automatically
As you navigate our site and/or mobile applications, we collect data to track and improve your experience as well as the security of our service.
Thus, we store in data log files and a data warehouse, information such as a unique identifier via cookies, the connection date, the IP address of connection, the source platform (e.g.: site, mobile site or applications), the country of connection, the type of device, or when a mobile application crashes on a smartphone.
Personal data collected through cookies
Only the Bubble Teach.com site uses cookies, web beacons, unique identifiers, and other similar methods to collect information about:
- the different pages viewed;
- clicked links;
- other actions performed during the use of our site through the content of our advertising or emails.
Personal data collected through social networks
With your permission, some social networks may give us access to certain personal data they have stored. These data may be collected during your registration/login on our site via Facebook connect.
2. Processing of personal data
According to the CNIL, it involves « Any operation, or set of operations, performed on such data, regardless of the process used (collection, recording, organization, storage, adaptation, modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, alignment or interconnection, blocking, erasure, or destruction, ...) »
The collection, transfer, or storage of your personal data are considered processing under the GDPR.
According to the CNIL, « The controller of personal data processing is, unless explicitly designated by legislative or regulatory provisions related to this processing, the person, public authority, service, or organization that determines its purposes and means. In practice and generally, it is the legal entity represented by its legal representative. »
By logging in and entering your data on the Bubble Teach application, the data controller is therefore:
The company arNuméral
2 avenue Galilée
86360 Chasseneuil Du Poitou
support.bubble-teach@arnumeral.fr
We also work with subcontractors for certain operations (subscription payment), and as such, they must have access to certain information, but only those that we transfer to them.
Your data is used for different purposes. You will find the detailed list below:
Advertising
In the free version of Bubble Teach, we may use your information for advertising purposes, including displaying advertisements for our site when you browse the Web or on the application itself. We may use this data to send you information related to our business activities, such as promotional offers or targeted newsletters. Your information may also be used to evaluate our advertising performance.
In the Premium version of Bubble Teach we no longer use your data for advertising purposes and you have the option to disable all email communications on your member profile.
Payment
Your payment information is not retained by Bubble Teach and is directly transmitted to the payment service provider you have chosen (Stripe, ApplePay). This information is necessary for the payment of the order or for your refunds. We remind you that by using one of our payment service providers, their data protection provisions apply.
Surveys
The information you provide during surveys we conduct allows us, with your consent, to conduct studies to improve our services and offers.
Technical management
The information you provide allows us to ensure the proper technical management of our site and mobile applications, particularly through internal technical operations, bug resolution, data analysis, testing, etc. We also use them in the context of developing our services, and the constant improvement and optimization of our site and mobile applications.
We also inform you that we share your anonymized personal data with third parties, notably for marketing purposes.
When you log in to our website, we automatically have access to certain information, such as your connection IP address, the number of times you visited our website, the number of times you logged in to the application or the website.
This data is collected in accordance with the law, and not for statistical or commercial purposes.
Cookies
The term "cookies" refers to all trackers placed and/or read on a user's terminal connecting to the internet. It can be any type of terminal (smartphone, computer, laptop, tablet). Some trackers allow for the analysis of user navigation. The cookies collected on the Bubble Teach.com site are solely intended to enable or facilitate the functioning of the site. They are not used for commercial purposes.
3. Retention period of personal data
Data necessary for the Bubble Teach service
We will retain your data related to your Bubble Teach account as long as it is not deleted.
A Bubble Teach account is automatically deleted when it has not been used for more than 6 months.
The owner of the Bubble Teach account can delete all personal data (as defined by GDPR) from the account at any time by using the "Delete" function on the member profile or by requesting it at support.bubble-teach@arnumeral.fr. The disconnection of all users will be immediate. The deletion will be effective after a period of 2 working days. After this period, the deletion will be final and it will no longer be possible to request its cancellation.
Each Bubble Teach user can delete personal data (as defined by GDPR) belonging to them on their member profile by clicking on the "Delete" button of the said profile. The user's disconnection will be immediate on all devices where they would be logged in. The deletion will be effective after a period of 2 working days. After this period, the deletion will be final and it will no longer be possible to request its cancellation.
Data not accessible to the application
All data that is not accessible within the Bubble Teach application is never retained beyond the strictly necessary duration for your use of the Bubble Teach service, and for managing our relationship with you. This includes exchanges with the Bubble Teach support service.
Data from social networks
When a Bubble Teach account is deleted, data associated with social networks such as Facebook, Twitter, Instagram, Messenger, Google Play, AppleStore, etc. is not deleted. It is the user's responsibility to refer to the deletion procedures of each of these companies to know the steps to follow.
Banking and financial data
We draw your attention to the fact that some of your information, such as those concerning your payment, cannot be deleted, notably for accounting reasons.
Legal data
Some data will be retained as part of our legal and regulatory obligations.
4. Transfer of personal data
The new regulation also gives you the right, upon request, to have your personal data transferred to a third-party organization.
You can make the request by email or mail to our customer service, always justifying your identity at support.bubble-teach@arnumeral.fr and/or Bubble Teach Company, 2 Avenue Galillée, 86360 Chasseneuil du Poitou - FRANCE. Due to their nature, transfer by paper support is not feasible. The data will then be made available to you via a link allowing you to download your data.
5. Confidentiality of personal data
We are committed to keeping your data under the strictest security conditions and not disclosing it to anyone without your express consent.
However, we are required to transmit some of your data to subcontractors for certain operations, notably the management of your payments (bank and accountant).
When you take out a subscription, it is a purchase, and we must necessarily call on a banking institution to validate the payment transaction. Our bank is Crédit Coopératif and our payment system is Stripe or ApplePay. They, therefore, hold all the necessary data for your identification and the validation of your payment. Bubble Teach holds no banking information about you.
We also transmit data concerning the amount of subscriptions and the payment method to our accountant.
6. Security of your personal data
The activity of your account on Bubble Teach concerns only its members and is confidential: no indexing by a search engine. In short, no one knows that you - and especially your children - are there. There is no public profile notion on Bubble Teach.
The data you enter into Bubble Teach and that circulates on the Net is also encrypted: this means that apart from you and those you have authorized, no one can read the messages or see the photos of your children.
The data as well as the application and the site are hosted by the company Online.net, a subsidiary of the Iliad group on servers located in France, and no information about you is transferred outside the EU.
Regularly, your data is backed up from your mobile device (smartphone or tablet) to our servers. Similarly, when you log out, we save all your data on the servers and erase them from your mobile device to restore them to you the next time you log in.
This means that if you lose your smartphone, your data will be safe and we will return it to you on the device you use at your next login.
On our servers, we take all necessary precautions to ensure the security of your data and, in particular, to prevent them from being altered, damaged, or accessed by unauthorized third parties.
7. Consent
Before collecting your data, we ensure full acceptance of the following elements:
- Our General Terms of Use (GTU),
- This Privacy Policy.
Acceptance of the GTU and this Privacy Policy is a prerequisite for creating any account on the Bubble Teach application.
If you no longer agree with these elements, you can delete your account at any time.
8. Transparency on our mechanisms
We are committed to processing your data with the greatest transparency. When we implement new mechanisms, or when we need to transmit your contact information to a third party, we are committed to informing you as soon as possible.