A Bubble Company Ltd (Trading As:  Bubble Food)

PRIVACY POLICY

 

1. OUR APPROACH TO THE PROTECTION OF YOUR PRIVACY

• We pay close attention to the protection of all personal data you provide to us in the course of our cooperation.
• You may decide which data you provide to us and how detailed they should be – while using our online services, it is up to you whether you provide us only with the minimum necessary information or tell us more about you so you can access all the benefits connected with our services.
• We only require the data we need to provide our services and process them for purposes stated below. We do not give your information to anyone who is not entitled to process it.
• As a business entity we cooperate with various trustful partners who provide important services to us, such as technology and infrastructure, data storage, data backup and so on. These partners may have access to your data, but only within the scope of the service they provide to us. See below for more information.

 

2. A BUBBLE COMPANY LTD AS A CONTROLLER OF YOUR PERSONAL DATA

• The controller is responsible for the lawfulness of the processing of your personal data - it is the person or an entity who determines for what purpose and by what means your data will be processed and protected. The controller also handles any of your privacy issues and helps you exercise your rights.
• The controller of your personal data processed in connection with using the app Bubble Food on Sinch is:
  • A Bubble Company Ltd, Company Registered Number: 3716261, registered office 333 Medlar Street, London SE5 0JU,
  • Website: www.bubblefood.com
  • E-mail: admin@bubblefood.com
  • Phone number: 02077032653

 

3. THE SCOPE OF THE PROCESSING OF PERSONAL DATA

• The scope of your personal data we process depends on which services you decide to use and what settings you apply on them. Your data is processed by us in the following situations:
• 01: When you browse our website bubblefood.onsinch.com
  • Purpose of processing: Customization of the website to your needs and collecting visitors’ data for improvement of our services.
  • Legal basis for processing: Our legitimate interests in shaping our professional online identity and your consent to the collection of cookies (you can change your cookie settings at any time in your browser - for more information please refer to section "Cookies settings").
  • Processed data: Cookies, data about the use of our website (e.g. device data, browser, time of access).
  • Duration of processing: So-called Session Cookies are processed only while the browser is in use (i.e. until the browser is closed). Processing of so-called Persistent Cookies (long-term) lasts until the expiration date specified in their code, this period shall not exceed 12 months.
• 02: When you contact us via form or e-mail
  • Purpose of processing: Communication with the public and handling your inquiries or requests.
  • Legal basis for processing: Your consent by sending a message, our legitimate interests in developing good public relations.
  • Processed data: E-mail or other personal data voluntarily included in your message.
  • Duration of processing: Usually for the duration of our communication, the archiving of the communication related to the enforcement of claims and requests for a maximum of 3 years from the end of the communication.
• 03: When you sign up for Bubble Food on Sinch app
  • Purpose of processing:  Setting up and maintaining your user account, enabling to perform work tasks (assignment of work) and their scheduling and organisation. Bubble Food on Sinch app allows us to offer you specific job opportunities and allows you to register for specific jobs, track your work history including your job evaluations and reports that can help you reach a higher hourly wage.
  • Legal basis for processing: Performance of the contract concluded between you and us.
  • Processed data: name, surname, maiden name, residential address & postcode, date of birth, place of birth, nationality, passport number, passport date of issue, visa number and date of expiry, national insurance number, bank name, bank sort code, bank account number, emergency contact (name, phone number and relationship), height, languages spoken
  • Duration of processing: Until the termination of the user account.
• 04: When you use Bubble Food on Sinch app and enter information about yourself
  • Purpose of processing: Maintaining your user account, work-related data evidence, adjusting work conditions to your needs, evaluating your eligibility for scheduled tasks.
  • Legal basis for processing: Performance of the contract, performance of the obligations of A Bubble Company Ltd as an employer.
  • Processed data: availability details
  • When using Bubble Food on Sinch app, you can decide what information you provide to us. If such provision is mandatory (e.g. for the purpose of drafting an employment contract), you will be informed respectively in the app. Otherwise you can decide whether or not you provide us with the information by entering them into the app – some information may help us improve our mutual cooperation and provide you with personalised benefits (e.g. the “Attributes” bookmark in your profile).
  • Duration of processing: Until the termination of the user account. However, if stipulated by law (e.g. employment documentation) or if it is necessary for the protection of our claims and interests, we are entitled to process certain personal data even after the termination of the user account.
• 05: When you work for us as a Worker
  • Purpose of processing: Performance of the obligations between employer and employee. After your successful registration, we will conclude an employment-related contract which will serve as a basis for our future cooperation in accordance with labour law.
  • Legal basis for processing: Performance of the contract and performance of legal obligations of A Bubble Food as an employer.
  • Processed data: first name, surname, contact details, photos, availability, hours worked.
  • Duration of processing: The duration of the processing is imposed differently by UK law.
• 06: When you attend our events
  • Purpose of processing: Organization of events, communication related to events, reporting in connection with the event for the PR purposes.
  • Legal basis for processing: Performance of the contract (under which you take part on the event), our legitimate interests in developing our online identity and informing about our activities / your consent.
  • Processed data: First name, surname, contact details, photos, hours worked, availability.
  • Duration of processing: We process your personal data related to participation in the event for 3 years from the end of the event. Where consent is a legal reason for processing, we process data until the consent is withdrawn.
• 07: When you subscribe to e-mail newsletters
  • Purpose of processing: Sending e-mail newsletters with information about Bubble Food to your e-mail.
  • Legal basis for processing: Your consent.
  • Processed data: E-mail address.
  • Duration of processing: Until the consent withdrawal.

 

4. VOLUNTARY PROVISION OF PERSONAL DATA

• The provision of your personal data for our services is voluntary. This means that it is exclusively at your discretion whether you provide us with your data.
• However, please note that the provision of your personal data is in some cases necessary for certain services to be successfully performed or received by you. For instance, we are unable to conclude the worker-related contract with you and sign you up for work tasks unless you provide us with the data we must process as an employer. Similarly, we are unable to set up and maintain a user account for you unless you provide the necessary information when registering. The voluntary element is still represented by your decision whether to use our services or whether to establish cooperation with us or not.

 

5. LEGAL BASIS FOR OUR PROCESSING

• The processing of your personal data is lawful only if at least one of the so-called lawful bases for processing under the General Data Protection Regulation (known as GDPR) is applicable. We identified the following legal bases:
  • Performance of the contract
    • This applies to the processing of your personal data in connection with maintaining a user account in the Bubble Food on Sinch app, assignment of work under an agreement to complete a job or other contract, arrangement of your participation in events or other activities based on a contract to which you are a party.
  • Performance of legal obligations by A Bubble Company Ltd
    • This basis applies where the obligation to process certain personal data is imposed on A Bubble Company Ltd directly by law or other binding legislation - for instance, Employment Law etc. It applies especially to the situations when A Bubble Company Ltd acts as an employer or an accounting unit.
  • Legitimate interests of the controller
    • For instance, we take legitimate interests in collecting data about the online traffic and usage of our online services for quality improvements, utilizing data for our branding campaign (such as reporting from our events, etc.) or keeping certain data for the purpose of the enforcement of claims, including claims made by a third-party entities.
  • Consent of the data subject
    • Your consent is necessary in situations where none of the above-mentioned legal basis applies. If we want to use your personal data for self-promotion, we need your consent. Similarly, if we want to send you our e-mail newsletters, we need your consent.
    • You can easily withdraw the consent you previously gave to us – in such a case send an email to admin@bubblefood.com  and inform us you take the consent back.

 

6. THE PROCESSORS

• We are not alone in what we do. We use services of third parties (our partners) to help us function properly and provide professional and reliable services. These are mainly partners providing technical background to our services or specialized services that we find necessary to outsource.
• These processors may have access to your personal data if legal conditions are met. This applies in situations where the provision of your data is necessary for the performance of the obligations we agreed on. The processing of data by the processors shall only occur to the minimum necessary extent in relation to the purpose for which the data is provided.
• We use services of the following processors:
  • Sinch, s.r.o., reg. no.: 242 74 330, registered office Zdiměřická 1427/9, 149 00 Prague 4, The Czech Republic – the provider of Bubble Food on Sinch app where work is assigned and shifts are selected;
• Other processors of your personal data may also be our clients who upload events and request staff in the app - they can see a limited amount of personal information – i.e. the information necessary for organizing the event or obtaining security permissions.
• A Bubble Company Ltd does not transfer personal data to a third country (i.e. outside the EU).

 

7. YOUR RIGHTS AND HOW TO EXERCISE THEM

• In relation to your personal data you may exercise the following rights:
  • Right of access to personal data – the right to obtain information about the processing carried out by the controller;
  • Right to a correction of inaccurate data (right to rectification) – you can correct the data directly in the app;
  • Right to erasure of your personal data from our databases (right to be forgotten) in case the data is no longer necessary for the purpose for which it has been collected.
  • Right to restriction of processing, e.g. the right to require that we temporarily process data only by deposition.
  • The right to data portability, i.e. the transfer of data to another controller, if possible.
  • The right to object at any time to processing of personal data based on our legitimate interests as described above.
  • The right to revoke your consent to processing of personal data where the consent is the legal basis of such processing without any sanction – the consent can be revoked either by unchecking the respective box in the app or by sending an e-mail to the address specified below.
• You can mail your request to exercise a privacy-related right to admin@bubblefood.com or you can send us a letter addressed to our seat (see Article 2). Please note that the requests shall be made in writing.
• It is important that we know who exercises the right and what exactly is requested - we may therefore require verification of your credentials to ensure we can further process the request. We do not want any unauthorised person to get the data or to delete them on your behalf.
• We believe that we can quickly resolve any questions or requests to your satisfaction. However, you have the right to submit a complaint against our processing with the respective supervisory authority – A Bubble Company Ltd.

 

8. COOKIES SETTINGS

• Cookies, as described above, are tiny data files stored at your computer which carry the data related to your online preferences and use of our online services. They allow our website to load faster or load in a way which is suitable for your browser, etc. We process cookies based on your consent, which you grant through your browser settings. If you do not want our website to store and use cookies, you can disable it with a few clicks.
• To change your browser's cookie settings, visit the following links:
  • Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
  • IE: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
  • Microsoft Edge: https://support.microsoft.com/en-us/help/4027947/microsoft-edge-delete-cookies
  • Mozilla Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy/cookies
  • Opera: https://help.opera.com/en/latest/web-preferences/

 

9. EFFECT OF THIS POLICY

• In the future, we may adapt this privacy policy to any potential new data processing activities. We will notify you about any substantial changes but even so, we recommend checking back from time to time for updated versions of this policy.
• This policy becomes effective on 1.10.2021