1. The introduction

This Privacy Policy (hereinafter referred to as the “Policy”), is intended to provide information to visitors and users of https://bubbles.marketing/ (hereinafter referred to as the “Website”) regarding the information required by articles 13-14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the “GDPR”).

This information includes, but is not limited to, the following:

• The types of personal data collected when using the Website;
• The purposes and legal bases for collecting this data;
• The recipients with whom this data may be shared;
• The duration for which this data will be retained;
• Your rights with respect to the processing of your data.

The Policy may be revised, amended, or updated for a variety of reasons, including changes in applicable laws, changes in our business practices, or for any other reason we deem necessary. If you are a registered user, we will notify you of any changes by sending an email to the address you provided during registration on the Website. If you do not have an account on the Website and/or we do not have your email address to communicate changes to this Policy, it is your responsibility to review this Policy each time you access the Website. Your continued use of the Website will be considered as your acceptance of the revised Policy.

2. Collected data

Automatically collected data. When you use the Website, the following data are collected from you by automated means.

2.1 By Google Services. When you use the Website, the following data are collected from you by Google Services:

a) The data collected by Google Analytics:

• The total time you spend on the Website;
• The time you spend on each page and in what order those pages were visited;
• What internal links were clicked (based on the URL of the next pageview);
• Your IP address and user agent string;
• Initial page inspection that analytics.js performs when creating a new tracker object is used to determine your geographic location, what browser and operating system are being used, your device`s screen size, whether flash or java is installed, and the referring site.

The information collected by Google Analytics is generated to Google`s server in the USA and stored there. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on follow this link: https://tools.google.com/dlpage/gaoptout?hl=en.

b) The data collected by Google reCAPTHCA. In case of Google reCAPTCHA, Google collects the data about your input in order to distinguish whether an input is made by a human or by a robot or with the use of any other form of automated means.

c) The data collected by Google Tag Manager. Google Tag Manager is a tool made by Google that allows us to integrate and manage tags (snippets of code) into the Website. Google Tag Manager collects the following data:

• Aggregated data about tag firing.

If you want to find out more about how Google processes your data, please, follow Google`s Privacy Policy https://policies.google.com/privacy.

2.2 By Cloudflare. We use the Services provided by Cloudflare. These Services collect the following data:

• Your IP address;
• System configuration information;
• Other information about traffic to and from the Website.

If you want to find out more about how Cloudflare processes your data, please, follow Cloudflare`s Privacy Policy https://www.cloudflare.com/privacypolicy/. The data you voluntarily provide us.

2.3 When you use the Website and our Services, you may voluntarily provide us with the data concerning you:

a) Contact data. When you contact us via the interface of the Website or via available contact details, you hereby provide us with the following data:

• Your name;
• Your e-mail address;
• Your phone number;
• The subject of your message;
• Your message which may also include your personal data.

We may also collect information on whether you have provided your consent to receive our newsletter regarding the Company’s new products, services, and updates.

b) Account data. When you create and use an account on the Website, you hereby provide us with the following data:

• Your name;
• Your username;
• Your e-mail address;
• Your password (in hashed form);
• Personal data you submit in your account.

c) Payment data. When payments are made for the services offered by the Website, we process data pertaining to such payments. This information encompasses, but is not limited to:

• Information about the payer;
• Information about the payment instrument used by the payer;
• The information about transactions for the services of the Company (including all the data necessary to identify the transactions).

3. The purposes and legal grounds for the collection of your personal data

3.1 To administer the Website and our facilities. We use automatically collected data for the following purposes:

• To administer the Website;
• To protect the Website from DDoS attacks and other cyberattacks;
• To protect the Website from any illegal, unlawful activity, fraud, and abuse;
• To diagnose any problems with the Website and the Server which makes the Website available;
• To provide you with the Website tailored for your device, language, and opted preferences;
• To load balance to the Server which makes the Website available.

The legal basis for processing your personal data is in accordance with Article 6(1)(f) of the GDPR. This provision specifies that the processing of personal data is necessary for the purposes of the legitimate interests pursued by the Company and the third party. The aforementioned purposes, namely, the collection and processing of your personal data, are legitimate interests of the Company.

3.2 To conduct research and analysis. We use your contact data, automatically collected data, and account data for the following purposes:

• To conduct research and analysis on how the Website is used by its users and visitors, and, having known this information, to develop and enhance the Website;
• To conduct so-called “A/B tests” (to find out more A/B tests please follow https://en.wikipedia.org/wiki/A/B_testing);
• To test new features on the Website.

The legal basis for processing: Article 6(1)(f) of the GDPR – the processing is necessary for the purposes of the legitimate interests pursued the Company and the third party. The abovementioned purposes are the legitimate interests of the Company.

3.3 We use your account data to create an account on the Website and provide you with the Company’s Services, and use your payment data to confirm that you have paid for the services. The legal basis for processing is Article 6(1)(b) of the GDPR, as it is necessary for the performance of a contract or to take steps before entering into a contract.

3.4 To process your payments. This processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract, in accordance with Article 6(1)(b) of the GDPR.

3.5 To contact you. We use your contact data in order to contact you when the situation may require. The legal bases for processing: If you are interested in entering into the business relationships with us: Article 6(1)(b) of the GDPR: the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. If you a natural person that is interested in any form of business relationships with us, we need to process your personal data in order to apply pre-contractual measures or in order to enter into a contract with you. If you make data subject`s requests or your request contain another legal issue: Article 6(1)(с) of the GDPR: the processing is necessary for compliance with a legal obligation to which the Company is subject. To send you Company`s Newsletter: Article 6(1)(a) of the GDPR: your consent to the processing of your data for this purpose. If you ask a general question about us and our products/services: Article 6(1)(f) of the GDPR: the processing is necessary for the purposes of the legitimate interests pursued the Company and the third party.

3.6 To comply with applicable legislation. We may use your data in order to comply with the legal obligations to which the Company is subject. The legal basis for this processing: Article 6(1)(с) of the GDPR: the processing is necessary for compliance with a legal obligation to which the Company is subject.

3.7 We may utilize the data we have about you for the purpose of establishing, exercising, or defending legal claims. The legal basis for such processing is Article 6(1)(f) of the GDPR, as the Company and third parties have legitimate interests in pursuing such actions. The establishment, exercise, and defense of legal claims are deemed as legitimate interests of the Company.

4. Data retention period

4.1 The automatically collected data will be retained for a period of twenty-six (26) months from the date of your last visit to the Website.

4.2 Contact data, if you have not entered into any business relationships with us, will be kept for as long as necessary for the particular purpose of the communication.

4.3 If you have used our Services, we will store your data for as long as you have an account on the Website and an additional five (5) years after the deletion of your account, as permitted by Aarticle 18 of the Law of the Republic of Kazakhstan.

5. Recipients of your data

5.1 The maintenance and operation of the Website and Services involve a considerable staff consisting of our employees, affiliates, contractors, and sub-contractors. As a result, your data may be disclosed to this category of recipients. It should be noted that all such transfers are subject to appropriate contractual arrangements, which obligate these recipients to handle your data in strict compliance with this Policy and within the confines of a confidentiality and professional secrecy regime.

5.2 The server hosting the Website and Services is owned by a third-party hosting provider. As such, your data will be shared with this hosting provider in an encrypted format. This implies that only authorized personnel within the Company will have access to your data, as they are the only ones who possess the decryption keys.

5.3 In the event of a legal obligation to disclose your data to public authorities of our jurisdiction, which may include, but is not limited to, courts, police, and financial investigation units, the Company will comply with this obligation and make the necessary disclosure.

5.4 When making payments for our Services, your transaction will be processed by a third-party payment services provider, bank, or financial institution. As a result, your data will be shared with these entities.

5.5 As previously mentioned, the Company utilizes the services of Google LLC, located at Amphitheatre Parkway, Mountain View, CA 94043, USA, and Cloudflare, Inc., located at 101 Townsend St, San Francisco, CA 94107 USA.

6. Your rights under this Policy

6.1 As a data subject, you have the right to exercise several rights by contacting us via email at hello@bubbles.marketing, including the right to withdraw consent under Article 6(1)(a) of the GDPR, the right of access to confirm whether your data is being processed, the right to rectify inaccurate data, and the right to erasure. The right to erasure will be applied if your personal data is no longer necessary for the purposes for which it was collected, you withdraw your consent, or if processing your data is unlawful.

7. Third-party links

This Website may contain the links to the Websites which are owned and operated by third parties. For example, when you make payment for the services of the Website: in this case, you will be redirected to the payment provider operated by third party. These Websites are outside our control and we bear no liability for the result of your visit to these Websites. We recommend you to visit “Privacy Policy” or “Data Policy” or another privacy document on any of these third-parties` services before submitting any information to the latter.