Privacy Policy - Bulbah

 

Bulbah takes privacy very seriously, and therefore has set up this privacy policy to inform you of your rights. Please be cognizant of the fact that your information travels through third parties as a part of its services, and that Bulbah will abide by local regulations as required by law, which may require disclosure of certain information.

Information Bulbah Collects: Bulbah collects some information, both personally identifiable and non-personally identifiable, according to the following criteria.

 

Information You Provide Bulbah: Bulbah collects email addresses, first name, last name& phone number.  We may also collect information that you provide on a volunteer basis, such as when you fill out forms for its advertisers, participate in its activities or provide it with information via website submission.

 

Information Bulbah Collects from visitors to our Publishers’ Sites: Bulbah may also retain information which is in its nature non-personally identifiable; where Bulbah gathers it through your use of the services such as your device type, browser type, screen resolution, operating system, system preferences, the pages you viewed, the content you submitted and other information it collects through your use of the services. Bulbah and its publishers may also place a cookie on your device. A cookie is a small text file which allows Bulbah and its publishers to better know your preferences.

 

Information Bulbah Receives from Third Parties: Bulbah may also retain information it received and/or procured from third parties, such as its service providers, ad networks and marketing agencies, which all relate to your preferences and your use of the services. Bulbah uses third party services to provide us with aggregated, non-personally identifiable, information.

 

How Does Bulbah Use The Information? In the case of personal information we gather, we only use this internally, which means it is only disclosed to our employees and subcontractors who are under strict confidentiality obligations. We share aggregated, non-personally identifiable information with our publishers, content providers, networks and advertisers. Moreover, in the unlikely event that we receive an order from an authorized legal authority to provide them with information, we will comply.

 

How to Review Your Information: If you wish to review the information Bulbah has about you, please contact us at info@bulbah.com, If you provide sufficient evidence about your identity, you may ask Bulbah to delete your information.

 

If you feel your Privacy Was Violated: you can always contact our privacy officer at info@Bulbah.com. Our privacy officer shall inspect the complaint and answer you within a reasonable time, and no later than 14 days. These complaints shall also be presented, anonymously, in our yearly privacy reports. Please note that as our service evolves we may change this privacy policy at any time.

 

GDPR Compliance

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1. Definitions

“Applicable Data Protection Law” means any and all applicable privacy and data protection laws (including, where applicable, EU Data Protection Law) as may be amended or superseded from time to time; and “EU Data Protection Law” means (i) prior to 25 May 2018, the EU Data Protection Directive (Directive 95/46/EC); (ii) on and after 25 May 2018, the EU General Data Protection Regulation (Regulation 2016/679); (iii) the EU e-Privacy Directive (Directive 2002/58/EC); and (iv) any national data protection laws made under or pursuant to (i), (ii) or (iii).​

2. Data Protection

2.1 In this Clause 2, the expressions “controller”, “processor”, “personal data”, “processing” (and “process”) shall have the meanings given in Applicable Data Protection Law.

2.2 The Parties acknowledge that Publisher will disclose or make available certain data about visitors to the Publisher Properties (which may include personal data) (“Data”) to Advertisers for the purpose of selling Advertising and to improve ad targeting across the Publisher Properties (the “Permitted Purpose”).

2.3 Publisher is a controller of the Data it discloses or makes available to Advertisers, and Advertisers will process the Data as a separate and independent controller for the Permitted Purpose. In no event will the Publisher and Advertiser process the Data jointly as joint controllers.

2.4 Publisher and Advertisers shall be individually and separately responsible for complying with the obligations that apply to it as a controller under Applicable Data Protection Law. Without limitation to the foregoing, each Publisher and Advertisers shall maintain a publicly-accessible privacy policy on its website that satisfies the transparency disclosure requirements of Applicable Data Protection Law.

2.5 Publisher shall implement appropriate technical and organizational measures to protect the Data (i) from accidental or unlawful destruction, and (ii) loss, alteration, unauthorized disclosure of, or access to the Data (a “Security Incident”). In the event that Publisher suffers a confirmed Security Incident that impacts the Data, it shall notify Advertisers without undue delay and cooperate in good faith with the Advertisers to agree and action such measures as may be necessary to mitigate or remedy the effects of the Security Incident.

2.6 Publishers and Advertisers may appoint third party processors to process Data for the Permitted Purpose, provided that such processors: (a) agree in writing to process Data in accordance with the requirements of Applicable Data Protection Law; (b) implement appropriate technical and organizational security measures to protect the Data against a Security Incident; and (c) otherwise provide sufficient guarantees that they will process the Data in a manner that will meet the requirements of Applicable Data Protection Law. Publisher accepts responsibility for any breach of this Clause 2 that is caused by an act, error or omission of a processor it has appointed.

2.7 Publishers and Advertisers uses cookies and similar tracking technologies (such as mobile device identifiers and digital fingerprinting) to provide advertising Services (“Cookies”). Publisher shall ensure that appropriate notice and consent mechanisms as may be required by Applicable Data Protection Law are displayed upon Publisher Properties from which the Data are collected or made available so that Advertisers can serve Cookies lawfully through such Publisher Properties. In particular, Publisher Properties will have an active, publicly stated privacy policy that contains the following language (or similar):
“We use third-party advertising companies to serve ads when you visit our Web site. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about companies, click here.(http://www.networkadvertising.org/managing/opt_out.asp).”

2.8 Publisher must inform Advertisers if any Publisher Properties are directed towards children under the age of sixteen. In such event, Publisher acknowledges that Advertisers may elect not to sell Advertising on such child-directed Publisher Properties.

2.9 Bulbah, as an independent broker between Publisher and Advertiser, is neither controller nor processor, and as such, can assume no responsibility for Publisher’s nor Advertiser’s responsibilities under this Addendum. While Bulbah will recommend and implement possible CMP solutions, it is the Publisher’s responsibility to ensure proper coverage of their responsibilities under the EU Data Protection Law.

2.10 This Clause 2 shall survive termination or expiry of the Agreement. Upon termination or expiry of the Agreement each Party may continue to process the Data under its control provided that such processing complies with the requirements of this Clause 1 and Applicable Data Protection Law.

3. Miscellaneous

3.1 This Amendment may be executed: (a) simultaneously in one or more counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument; and (b) by facsimile (or PDF) and such facsimile (or PDF) execution will have the same force and effect as an original document with original signatures.

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Privacy Policy © 2020 Bulbah LLC