We are Tribo Technologies Ltd, a company registered with Companies House in England and Wales under number 09834115 whose registered office is at Camburgh House, 27 New Dover Road, Canterbury, Kent, CT1 3DN, operating under the trading name ‘Bubble’ (“Bubble”/“we”/“us”/”our”). We control the ways your personal data are collected and the purposes for which your personal data are used by Bubble. Bubble is the “data controller” for the purposes of the UK Data Protection Act 1998 (as amended or replaced), the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and other applicable European data protection legislation (together the “Data Protection Legislation”).

Bubble provides mobile applications (the “App”) which enables parents or legal guardians of children (“Parents”) to arrange babysitters (“Sitters”) to look after those children (the “Services”).

We are committed to protecting and respecting your privacy. This is of paramount importance to us. By using and interacting with our App and the Services, you consent to us processing your personal data in accordance with this Bubble Privacy and Cookie Policy (the “Policy”).

This Policy explains:

• what information we may collect about you;
• how we may use the information we collect about you;
• whether we share your information with anyone else;
• the types of cookies we use and how you can reject these cookies;
• your choices regarding the personal information you provide to us;
• where we store your information; and
• how we keep your information secure.

WHEN DOES THIS POLICY APPLY

This Policy and our terms of use (“Terms of Use”) apply to your use of the App once you have downloaded a copy of it onto your mobile telephone or handheld device (“Device”). The Policy and the Terms of Use also apply to all of the Services we offer, including our App services and our Placement Services. For the avoidance of doubt, this policy applies to both Parents and Sitters, when using both the parent app “bubble – find a babysitter now” and the sitter app – “bubble for sitters”, as well as our website and other Services that we offer.

HERE IS THE INFORMATION WE MAY COLLECT ABOUT YOU

1. Information you voluntarily provide

• Information that you voluntarily provide on our App including when you download the App, register to receive the Services and create a profile. During the registration process, you will be asked to provide us with certain information about yourself and, if you are a Parent, your children. When creating your profile, you may provide us with information directly through the App or, with your consent, via your Facebook or other social media account.
• We may also ask you for information when you report a problem with our App or Services.
• If you contact us (by phone, email or through the App), we may keep a record of that correspondence.
• Information you provide when you choose to complete a survey or participate in a competition on the App
• If you provide a reference to bubble for a babysitter who is registering on the platform.
• If you use our Placement Services as either a Parent or a Nannt

The information you give includes your name, address, password, date of birth, number of children, any referral code, a photograph, credit card details, bank account details, telephone numbers and email address. It may also (with your consent) include details obtained from your social network, your Device contacts list and details of schools/nurseries/other community groups you have a connection with. For Sitters, it may include DBS details and Ofsted registration details (if applicable).

Please see the attached appendix for details of the categories of information that we may collect and process about you.

2. Information we collect about you and your Device

When you visit our App interact and with our Services, we (and other third party service providers) may use a variety of technologies that automatically or passively collect information about how our Services are accessed and used. These are listed in the appendix.

3. User-generated content

Any content that you create using our App (such as Sitter or Parent reviews) is stored on servers and some of that content is also cached locally on your device. Such content will be displayed on your profile. See our Terms of Use for further details. We will process your personal information for the purposes listed in this section given our legitimate interest in providing a safe, secure and transparent market platform for Users.

4. Third parties we work with

We work closely with third parties which provide technical and payment services. We work with advertising networks, analytics providers, social network providers, payment service providers and verification service providers and we may share information with them. Below is a non-exhaustive list of third parties we work with. We may work with third parties not listed below or stop working with the third parties listed below.

THIS IS WHAT WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU

We use the information you provide to us to:

• provide you with relevant information and enable you to use our App and Services including enabling payment by Parents to Sitters;
• ensure that content from our App is presented in the most effective manner for you and for your Device to achieve the most user-friendly navigation experience;
• provide you with relevant promotions, offers and discounts from time to time;
• carry out our obligations arising out of the Terms of Use such as enabling us to use the services of third party information verification providers; and
• notify you about changes to our App or Services.

MARKETING

We may:

• Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences and social media advertising through social media platforms such as Facebook or Google).
• Personalise, measure, and improve our advertising.
• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by bubble or its third party partners.

Please note, if your only interaction with the bubble app or service is to provide a reference for a babysitter as part of their onboarding process, then your information will not be used for any marketing purposes.

Otherwise, we will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our app or otherwise promote our products and services or the Bubble Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by Bubble. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

Please note that you may, at any time ask Bubble to cease processing your data for these direct marketing purposes by sending an e-mail to [email protected].

OUR USE OF AGGREGATED AND ANONYMISED INFORMATION

We may provide aggregate user statistics, demographic information and other usage data which does not identify you specifically with third parties. We may combine your data with those of other users of our App and share or provide this trend information in aggregated and anonymised form with third parties.

We may also use information collected from you and combine it with information provided by other users of our App and Services to help us improve the design and delivery of our software tools, increasing the effectiveness for all users.

THIS IS WHO WE SHARE YOUR INFORMATION WITH

We will only share information with other organisations where we have a lawful basis for doing so.

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and/or its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may disclose your personal information to third parties:

• if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
• to enforce or apply our Terms of Use and other agreements or to investigate potential breaches; or
• to protect the rights, property or safety of Bubble or our users.

SPECIAL CATEGORIES OF DATA

In the course of providing services to you, we may collect information that could reveal your racial or ethnic origin, sexual orientation, political opinions physical or mental health, religious or philosophical beliefs, trade union membership or genetic or biometric data. Such information is considered “special categories of data” under the GDPR and other data protection laws. We only collect this information where you have given your explicit consent or one of the other exemptions apply (e.g. it is necessary to comply with our legal obligations).

RETENTION OF DATA

Once your relationship with us ends, we will delete your personal data within 7 working days unless we consider there is a legal reason not to do so.

COOKIES, PIXELS, LOCAL STORAGE AND OTHER SIMILAR TECHNOLOGIES

Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small blocks of code on web pages that do things like allow another server to measure viewing of a Web page and often are used in connection with cookies. HTML5 Local Storage is a small database located inside your browser which web pages can use to store data to speed up their processing. We may use all three technologies from time to time, to help improve your user experience.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of our App. Cookies make the interaction between you and our App faster and easier. We use cookies to distinguish you from other users of the App and our Services. This helps us to provide you with a good experience when you use the App and also allows us to improve the App and Services. Cookies and things like local storage also help us authenticate you to deliver personalised content.

We have outlined below the individual cookies we use and why we use them:

Please refer to your Device’s help material to learn what controls you can use to remove or block cookies, or other similar technologies; or block or remove other data stored on your Device. Please remember that if you do this, it may affect your ability to use the App and/or the Services. As you use your Device, you will encounter third parties that make use of cookies and similar technologies. We are not responsible for those third parties or what they may place on your Device or in your browser.

TRANSFERRING YOUR INFORMATION INTERNATIONALLY

Bubble needs to transfer your information globally to be able to provide services to you. We want to make sure your information is stored and transferred in a way which is secure. We will therefore only transfer data outside for the European Economic Area (“EEA”) (i.e. the member states of the European Union, together with Norway, Ireland and Liechenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

• By way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws;
• By signing up to the EU-US Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the USA or any equivalent agreement in respect of other jurisdictions; or
• Transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
• Where it is necessary for the conclusion or performance of a contract between you and us or the implementation of pre-contractual measures taken at your request; or
• Where you have consented to the proposed transfer, after having been informed of the possible risks of such transfers.

KEEPING INFORMATION SECURE

All information you provide to us is stored on servers owned and operated by Microsoft, using its Microsoft Cloud Services (Azure), and Amazon, using its Amazon Web Services (AWS). More information on these providers are available at https://www.microsoft.com/en-us/TrustCenter/Security/AzureSecurity and https://aws.amazon.com/compliance/data-privacy-faq .

Payments are processed by Braintree (PayPal (Europe) S.à r.l. et Cie, S.C.A.) (“Braintree”) which uses encryption technology aligned to industry best practice. We store your bank account details to enable payments to be made. We encrypt such details whilst they are stored. When a payment needs to be made they are decrypted to enable that payment to be made. Card details are only ever stored and seen by Braintree other that some partial card details which we can see within Braintree’s dashboard.

Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. Please do not share a password with anyone.

Please remember that the transmission of information via the internet is not completely secure. We will do our best to protect your information, but we cannot guarantee the security of your data transmitted to the Apps or when you use our Services. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

HERE ARE YOUR RIGHTS

You have the following rights in relation to your information:

• Right to request a copy of your information. You can request a copy of your information which we hold (this is known as a subject access request).
• Right to correct any mistakes in your information. You can require us to correct any mistakes in your information which we hold.
• Right to request we stop processing your information. In certain circumstances, you may request that we cease processing your information.
• Right to request deletion of your information. You can ask us to erase your information (also known as the “right to be forgotten”) in certain circumstances.
• Right of data portability. You have the right to transfer your personal data between data controllers in certain circumstances.

If you would like to request any of the above, please contact us at [email protected] to make any such requests. We will comply with the Data Protection Legislation in responding to any such requests.

THIRD PARTY PROPERTIES ACCESSED FROM THE APP

Our App and Services may contain links to and from the online properties of advertisers and other third parties. If you follow a link to any of these online properties, please note that these online properties have their own privacy policies and that we cannot and do not accept any responsibility or liability for these policies or for any personal data that may be collected through these online properties. Please check these policies carefully before you click on any links and/or submit any personal data to these online properties.

CHANGE OF CONTROL

If the ownership of our business changes, we may transfer your information to the new owner so they can continue to operate the App and provide the Services. The new owner will be obliged to comply with this Policy.

CHANGES TO OUR POLICY

Any changes we may make to this Policy in the future will be posted on this page. Where it makes sense because the changes are material, we may notify you of the changes by e-mail or in another appropriate manner such as when you next start the App.

CONTACTING US IS EASY AND WE WANT TO HEAR FROM YOU

We really do welcome any questions, comments and requests you may have regarding this Policy. You can contact us by emailing us at [email protected].

APPENDIX: The Information that we process about you

Babysitters

Parents