Privacy Policy

Privacy Policy

This Privacy Policy (“Privacy Policy”) constitute a legally binding agreement between you, whether personally or on behalf of a company (you) and Programus LTD. This policy explains how Programus LTD, located at No,591 London Road, Cheam, Sutton, Surrey, SM3 9AG and registered in England and Wales  and bubltown (“bubltown” "we" or “us” or “our”) which  supports white label mobile applications and any websites we have now or in the future that reference these Terms of Use (collectively, "Site"), uses your information and applies to all who use our websites and platforms – including mobile applications, touch technologies, electronic services, social networking sites, interactive features, online services or any of our described online activities we own or control (collectively, the “Service”). For terms that govern the use of the Service, please review the Service’s Terms of Use. 

bubltown and our Affiliates collect, control, process, and use information about you (which we call “personal data”). bubltown is the operator of the marketplace. It provides platforms where our affiliated and other unaffiliated third-party sellers (collectively “Sellers”) can list offers, products, vouchers, deals, goods, travel, and other offerings. 

By using the Service, you acknowledge you have read the terms of, please do not provide us with your information or interact with the Service. this Privacy Policy. If you do not want your information handled as described in this Privacy Policy 

We may modify this Privacy Policy at any time. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on the Service prior to the change becoming effective. You can determine when this Privacy Policy was last revised by referring to the "Effective Date” above. 

You understand that your continued use of the Site after we send a notice about our changes to the Privacy Policy means that the collection, control, processing, and use of your personal data is subject to the updated Privacy Policy. If you object to any changes, you may modify your account settings or close your account as described below. 

This Privacy Policy is organized as follows: 

1. Types of Information we Collect

We may collect the following categories of personal information from and about you: 

• Identifiers: such as your name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.
• Demographic information: such as your age, birthdate, and gender.
• Commercial information: such as information that enables us to determine lifestyle, interests, and activities, including purchasing tendencies and order history (such as the vouchers you purchase and redeem); areas of interest; information collected through your interactions with social networks; information about persons for whom you have purchased vouchers as gifts or who have bought bubltown vouchers as gifts for you; and information about friends who refer you or whom you have referred.
• Location information: such as information related to your state/province, city, or neighbourhood and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Service.
• Financial information: such as information collected from you as needed to process payments for products or services that you buy, or as provided by you to administer your participation in optional services and programs, such as your payment card number, expiration date, and card verification number. All payment data is securely stored in our system
• Internet and network activity information: such as information about your browsing behaviour, search history, and interactions with websites and advertisements, including data from cookies. 
• Inferences regarding preferences and other characteristics: such as our assessment of the types of products or services you may have an interest in.

We may also collect information regarding your geo-location, and push notifications when you use our apps. If you use our Apps, we may also collect the following information: 

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Push Notifications. We may request to send you to push notifications regarding your account or the mobile application. If you wish to opt-out of receiving these types of communications, you may turn them off in your device’s settings.

2. How bubltown collects information

We may collect personal information about you from a variety of sources, including: 

From you: We collect information that you submit to us. For example, when you use the Service; make a purchase; register to receive information, products, or services available through the Service; or interact with us in other ways. We will collect any information you voluntarily provide, and we may also request optional information to support your use of the Service. We also collect any information that you voluntarily enter into any postings, comments, or forums within the Service. If you send an e-mail or a SMS to us, we will collect your phone number and e-mail address and the full content of your e-mail or SMS, including attached files and other information you choose to provide to us.  

From your device: When you use the Service, we may collect information about the devices you use to access the Service, including the hardware model, operating system and version, Internet Protocol (“IP”) address, and other unique device identifiers, mobile network information, and information about the device’s interaction with our Service. We also collect information about how you use our Service, including your access times, browser types, and language. This type of data enables us to understand how often individuals use parts of the Service so we can analyse and improve it. To collect this information, we use cookies and web beacons, and other similar technologies. To learn more about how we automatically receive and record information when you interact with the Service, please review our Cookies Policy. Note that this Privacy Policy covers only how we use information collected via cookies; it does not cover the use of such information by third parties. 

Location information: We may collect diverse types of information about your location, including general information, such as the city, state, and/or zip code associated with your IP Address, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Service. We may use such location information to customize the Service, including advertising that is presented to you. In order to do this, your location information may be passed along to our affiliates, agents, vendors, or advertisers. You may be able to disallow our use of certain location data through your device or browser settings, for example, by disabling “Location” services for the application in iOS privacy settings. 

Social media networks and other third parties: We may obtain information about you or your use of the Service from third-party sources, such as our vendors, like web-hosting providers, analytics providers, or advertisers. You may give us permission to access your information from services offered by third parties, including social media networks. The information we obtain from third-party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies, so be sure to check those policies and adjust your settings to meet your preferences. When you access the Service through social media networks and other third-party platforms, you authorize bubltown to collect, store and use such information and content per this Privacy Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy. 

3. How bubltown uses information

We may use information collected as described in this Privacy Policy to: 

• Operate, maintain, and improve the Service and other programs, features, and functionality related to the Service,
• Provide you with interest-based ads, push notifications, communications, and offers for products and services from us and our business partners, including based on your precise geolocation,
• Facilitate and fulfil orders – for example, for vouchers and other goods and services, including tracking redemption,
• Process and confirm bookings with our partners,
• Process your payments,
• Evaluate your eligibility for certain types of offers, products, or services that may be of interest to you, and analyse advertising effectiveness,
• Answer your questions and respond to your requests,
• Perform analytics and conduct customer research,
• Communicate and provide additional information that may be of interest to you about bubltown and our business partners, sometimes by combining your information with information we obtain from other sources,
• Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of our business partners.
• Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our business partners.
• Manage our everyday business needs, such as administration of the Service, forum management, fulfilment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Use, or to comply with the English law,
• Allow you to apply for a job, post a video, or sign up for special offers from merchants, our business partners, or other companies,
• Verify your requests made pursuant to this Privacy Policy,
• Enhance other information we have about you to help us better understand you and determine your interests,
• Use your data as described in our Card Linked Deals program, if you consented to participate in such program; and

We also may use information collected as described in this Privacy Policy with your consent or as otherwise required or permitted by the laws of England and jurisdiction of the English Courts. 

bubltown uses your geolocation, including your precise geolocation, consistent with this Privacy Policy as described in Section 2 above to deliver location-based offers, products or services that may be of interest to you. 

If you make purchases without creating a password, we link these purchases to your email address and create a secure account in our system. If you create a password at a later date, you will be able to view past purchases made with that email address. 

If you use any features on the Service to send information about a product or service to another person, we will also collect the personal information of that other person to the extent disclosed by you and may contact them using the information you provided us. 

4. When and why bubltown discloses information

We may share your personal information as follows: 

• as required to comply with the law or legal obligations, such as to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions.
• in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and accordance with the laws of England and jurisdiction of the English Courts, and other countries where we operate.
• with our vendors who perform a variety of services and functions for us, such as data storage, order fulfilment, transmitting emails, and managing digital content. We may share your information with such vendors subject to confidentiality obligations consistent with this Privacy Policy and on the condition that the service providers use your information only on our behalf and pursuant to our instructions,
• in the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of our assets (as described below in Section 10),
• to combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of legal proceedings affecting bubltown,
• with our affiliates and subsidiaries who may only use the personal information for the purposes described in this Privacy Policy,
• if the information has been aggregated, de-identified, or otherwise does not identify you personally; and
• otherwise with your consent.

We may disclose your personal information to the following categories of third parties: 

• bubltown Entities – means organisation possessing separate and distinct legal rights, such as an individual, partnership, or corporation. An entity can, among other things, own property, engage in business, enter contracts, pay taxes, sue, and be sued.
• Merchants - means a person or organisation who deals in goods of the kind or otherwise by his occupation holds himself out as having knowledge or skill peculiar to the practices or goods involved in the transaction or to whom such knowledge or skill may be attributed by his employment of an agent or broker or other intermediary who by his occupation holds himself out as having such knowledge or skill.
• Co-marketers – means and refers to a marketing strategy where brands or organizations partner together to expand their reach
• Distributors – means a party that purchases goods from a supplier and distributes them in the territory he was granted the contractual right to distribute such goods.
• Resellers – means a type of channel partner that acts as an intermediary between companies that make, distribute, or provide IT products or services and end customers
• Advertising Networks - means a mediator between publishers and advertisers, to curate a large repository of ad inventory from publishers and sell it to advertisers
• Payment Services Providers – means and refers to a third-party company that provides payment services to businesses that accept online payment methods.
• Internet Service Providers – means a company that provides individuals and organizations access to the internet and other related services.
• Data Analytics Providers – means entities that submit the individual, educational, academic, training, employment, social service, health, and other information used to create the data system.
• Operating Systems and Platforms – means the platform consists of an operating system, and the hardware. The hardware consists of the microprocessor, main storage, data bus and attached I/O devices
• Social Networks – means the use of internet-based social media platforms to stay connected with friends, family, or peers.
• Government or Law Enforcement Entities - means any federal, state, local or foreign law enforcement authority or other governmental investigative authority or the enforcement unit of any securities or commodities ex- change or other self-regulatory entity.
• Fraud Protection and Prevention Providers - means taking steps to prevent online fraud.
• Delivery Services Providers - means a third-party service provider who we contract to deliver goods to you.
• Service Providers - means an employee, officer or director of the Company or an Affiliate, or a consultant or adviser currently providing services to the Company or an Affiliate.

We may disclose the following categories of personal information for our own business and operational purposes: 

• Identifiers
• Demographics
• Commercial information
• Location information
• Financial information
• Internet and network activity information; and
• Inferences regarding preferences or characteristics.

We may disclose certain personal information in exchange for services, insights, or other valuable considerations. These disclosures may involve: 

• Identifiers
• Demographics
• Commercial information
• Location information
• Financial information (not including payment card numbers)
• Internet and network activity information; and
• Inferences regarding preferences or characteristics.

5. Security of personal information

bubltown has implemented an information security program that contains administrative, technical, and physical controls that are designed to reasonably safeguard personal information. For example, we use industry-standard encryption technology to secure financial account information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at support@bubltown.co.uk. 

6. Your rights regarding personal information

You have certain rights with regard to your personal information: 

• You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information for business purposes.
• You have the right to update your personal information
• You have the right to request a portable copy of your personal information.
• You have the right to request that bubltown delete your personal information, subject to certain exceptions allowed under applicable law.
• You have the right to opt-out of certain disclosures of your personal information for valuable consideration. You can exercise this right through our “Do Not Sell My Personal Information” protocol.
• You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.

If you request a correction to your personal information but we do not make that correction, you have the right to request that we take attach to your personal information a statement that a correction was sought but not made. 

Whilst we will typically comply with any request for you to exercise your data subject rights, there may be limited instances where, to the extent required or permitted by applicable laws, we will not immediately comply with such requests. 

You may exercise these rights through the bubltown Data Privacy Portal or by sending an email to support@bubltown.co.uk. We may take reasonable steps to verify your identity prior to responding to your requests.  

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: 

http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm 

If you have questions or comments about your privacy rights, you may email us at support@bubltown.co.uk. 

Account Information 

If you would at any time like to review or change the information in your account or terminate your account, you can: 

• Log into your account settings and update your user account. 
• Contact us using the contact information provided. 

In addition to the above rights, you can update or remove financial account information. You can also deactivate your bubltown account. 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with legal requirements. 

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt out, you may: 

• Note your preferences when you register an account with the site. 
• Access your account settings and update preferences. 
• Contact us using the contact information provided. 

7. Your Choices

We think that you benefit from a more personalised experience when we know more about you and what you like. However, you can limit the information you provide to bubltown, and you can limit the communications that bubltown sends to you. In particular: 

• Commercial Emails: You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send or by logging into your account and adjusting your email preferences. Please note that even if you unsubscribe from commercial email messages, we may still email you non-commercial emails related to your account and your transactions on the Service. You may update your subscription preferences at any time.
• Cookies and Other Technologies: You may manage how your browser handles Cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt out of being targeted by certain ad-service companies and bubltown-served ads online by using the National Advertising Initiative’s Opt-Out Tool or the Digital Advertising Alliance’s (DAA) About Ads Opt-Out Tool. For more information review our Cookies Policy.

Currently, we do not alter our data collection and use practices in response to Do Not Track signals. 

Most web browsers, as well as some mobile operating systems and applications, include a Do-Not-Track ("DNT") feature or setting that you can use to signal your privacy preference not to have data about your online browsing activities monitored and collected. There is no uniform technology standard for recognising and implementing DNT signals. As a result, we currently do not respond to DNT browser signals or any other mechanism that communicates your preference not to be tracked online. 

If an online tracking standard is adopted that we must follow in the future, we will notify you in a revised version of this privacy policy. 

We use internet and network activity information and device data to directly serve you interest-based ads on third-party websites and mobile applications. Interest-based ads served directly by bubltown on third-party sites will display the Ad Choices icon. If you prefer not to receive interest-based ads from bubltown on third-party sites, you can click on the Ad Choices icon in the ad, which will direct you to the Your bubltown Ad Choices page where you can opt-out of receiving interest-based ads served by bubltown. 

• Device Data: You may manage how your mobile device and mobile browser share certain device data with bubltown, as well as how your mobile browser handles cookies by adjusting the privacy and security settings on your mobile device. Please refer to the instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
• When you first visit or use the Service, we may request permission to collect and use your device’s precise geolocation. You can opt not to permit the collection of this information, or permit it only when using the mobile app, but it may limit certain functions or features of the Service. You can control how and whether we collect your precise geolocation information through your device’s settings.
• Emails from Business Partners: If you wish to opt out of receiving offers directly from our business partners, you can follow the opt-out instructions in the emails they send you.

8. Social Community Areas

The Service may be accessible through or contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products, and merchants, and submit media content. Prior to posting in these areas, please read our Terms of Use carefully. All the information you post may be accessible to anyone with Internet access, and any personal information you include in your posting may be read, collected, and used by others. We recommend that you do not post any personal information in the social community areas. 

9. Privacy Practices of Third Parties

This Privacy Policy only addresses the use and disclosure of information by bubltown through your interaction with the Service. Other websites that may be accessible through links from the Service and our co-branded websites may have their own Privacy Policy and personal information collection, use, and disclosure practices. Our business partners may also have their own Privacy Policy. We encourage you to familiarize yourself with the Privacy Policy provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion. 

10. Business Transfers and Corporate Changes

bubltown reserves the right to disclose, transfer, or license any and all information related to the Service, including personal information: 

• to a subsequent owner, co-owner, or operator of the Service or any portion or operation related to part of Service; or
• in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

11. Notices to Residents of Countries outside the United Kingdom

This Service is intended only for users in the United Kingdom. If you live outside the United Kingdom, your information will be handled in accordance with the International Privacy Policy. By using the Service or giving us your personal information, you are directly transferring your personal information to us in the United Kingdom. You agree and consent to our collection, transfer, and processing of your personal information in accordance with this Privacy Policy. You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use the Service or provide us with personal information. Regardless of where we transfer your information, we still protect your information in the manner described in this Privacy Policy. 

12. Children's Privacy

The Service is a general audience site not directed at children under the age of 18.  

By using bubltown, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised through the Service. 

Further detail please contact support@bubltown.co.uk. 

Review, update, or delete the data collected 

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request a review, update, or delete your personal information, please email us at support@bubltown.co.uk.We will respond to your request within 30 days. 

13. Updates to this Policy

Policies are updated as needed to remain in compliance with applicable laws. 

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 

14. Contact Us

Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can reach us online at support@bubltown.co.uk and contact our Data Protection Officer (DPO) by email, or you can reach us via postal mail at the following address: 

Shantha Ruban 

Programus LTD 

No,591 London Road,  

Cheam, Sutton, Surrey, 

SM3 9AG, England Wales 

Cookie Policy

Last updated: 02nd August 2022 

The Cookies Policies constitute a legally binding agreement between you, whether personally or on behalf of a company (you), Programus Limited and bubltown Technology Group LTD. 

This Cookie Policy explains how we uses cookies and similar technologies to recognise you when you visit our websites at  https://www.bubltown.com and https://bubltown.co.uk  (“Websites “). It explains what these technologies are and why we use them, as well as your rights to control our use of them. 

In some cases, we may use cookies to collect personal information, or that it becomes personal information if we combine it with other information. 

1. What are Cookies?

Cookies are unique identifiers, usually made up of small bits of text or code. Cookies are usually stored on your device or in your web browser and they send certain information back to the party who served the cookie. When we say cookies, we are actually referring to a broader range of technologies than just cookies, including web beacons, clear gifs, pixels, and other similar technologies. When we say first-party cookies we mean cookies that are served by bubltown. When we say third-party cookies, we mean cookies that are served by non-bubltown parties. 

Cookies set by the website owner (in this case https://www.bubltown.com and https://bubltown.co.uk )called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. 

2. How are Cookies Used?

Cookies are used in order to better understand how applications and websites work and to optimize online and mobile experiences. Cookies do this by allowing the party serving the cookie to analyse a websites or mobile app’s performance, to remember user preferences, to recognize whether a computer or device (and probably its user) has visited a website previously, and to serve personalized advertisements. We may collect this information across browsers or devices, but the interest-based advertising cookie is not associated with and does not contain Personal Information. 

The specific types of first- and third-party cookies served through our websites and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit) 

3. What Kind of Cookies are Used on the Site?

Our Site primarily uses the following four types of cookies: 

1. Operationally Necessary Cookies

These cookies are essential for the operation of our Site. They make it possible for you to browse and use our Site. If you disable these cookies, the Site will not function correctly. 

2. Performance Cookies

These cookies gather information about how visitors use the Site and monitor Site performance. For example, performance cookies tell us which pages are popular, monitor traffic to our Site and compile anonymous analytic information. Third-party vendors may collect this information on bubltown’s behalf in order to perform data analytics services for bubltown. Performance cookies can also be used to identify and remedy operational problems with the Site. 

3. Functionality Cookies

These cookies are used to recognize and remember your preferences. For example, functionality cookies may use information, such as your location, to make sure that you arrive at a version of our Site that is specific to your city or region. 

4. Advertising Cookies

We use first party and allow third-party cookies on our Site in order to deliver interest-based advertising content on third-party websites and applications. We, and third-party ad servers, use cookies to understand your interest in the advertisements and content delivered to you, as well as to serve you with more relevant ads based on your activities on our Site. For example, cookies used for advertising could record information about whether you have clicked on certain content or advertisements on our Site or other websites or placed an item on our Site in your shopping cart. You can learn more about interest-based ads served by bubltown and others in our Privacy Policy. 

5.Shopping basket cookies 

Cookies are used to ensure that you can add items to your basket and complete orders. 

For some tickets we also use a third-party payment provider on our checkout page to process payment. This provider uses cookies as part of processing payment. 

6. Analytics cookies

Every time someone visits our website, software provided by another organisation generates an anonymous analytics cookie. These cookies can tell us whether or not you have visited the site before. Your browser will tell us if you have these cookies and, if you don't, we generate new ones.  This allows us to track how many individual users we have, and how often they visit the site. We cannot use these cookies to identify individuals. We use them to gather statistics, for example, the number of visits to a page, in order to improve the website. 

7. Affiliate cookies 

We sometimes advertise our website on third party websites. Cookies from these websites are used to determine whether you arrived on our website. 

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information,  

please visit  http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. 

The collection of your Personal Information by third parties is not governed by this Cookie Policy or our Privacy Policy. Please consult the privacy policies of those third parties to determine how they collect and use your personal information. Many third-party advertisers and some web browsers and mobile devices allow you to opt-out of third-party advertising.  

4. How can I opt-out of Cookies?

You may be able to opt out of the placement of certain cookies by configuring your browser settings or opting out directly with the party that operates and controls the cookie. Please check your browser settings for more information. 

5. Essential Website Cookies

These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas. 

6. Are there cookies in emails?

Our e-mails contain cookies that track whether you open our e-mails and whether you click any links within them. The cookies used in our e-mails to monitor these behaviours are unique to each e-mail and are not stored on your computer or mobile device. 

7. Further Information

If you have any questions about our use of cookies or other technologies, please email us at support@bubltown.co.uk or by post to: 

bubltown TECHNOLOGY GROUP LIMITED 

2a Woodcote Avenue, Wallington, Surrey, SM6 0QS 

United Kingdom