Privacy policy and terms of service (short version)

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Bubl Cloud privacy policy and terms of service

Bubl B.V. in the Netherlands provides our services and is responsible for your information when you use Bubl Cloud.

Bubl Cloud never shares, uses or has access to your information. We simply can't. All the information you store in your Bubl is end-to-end encrypted. We have no access to your personal information because we believe your information is yours. Only you decide who you share your data with. We have a privacy policy and terms of service. Our privacy policy explains what information we collect, or better what we don't collect and how we do this. Our terms of service describe our agreement with you to use our service.

Some companies start with the terms of service. We don't. Your information is so important to us that we first want to explain how we use and protect your data. Privacy policy We believe that everyone should be able to understand our privacy policy. We have nothing to hide. We therefore use a simple question and answer format to explain everything.

Bubl Cloud privacy policy

How does Bubl Cloud protect your information?

All data is stored in a personal encrypted data vault, which we call Bubl. When using that data, the data doesn't leave the Bubl, instead Bubl Cloud sends the service to the data. We call this: "the reverse data model".
Services that run within your Bubl need to ask you for permission to process data stored in your Bubl. Only when you grant a service this permission can it access this data.

What do we see as personal information?

We simply see all your information as personal information because we believe your information is yours and you should be able to decide what to do with it.

What information do we collect?

Personal information

Your personal information is stored in your own Bubl. We do not have access to your Bubl in any way.

Account information

When you register with your email address we store a hash of this email address as metadata on our servers. This allows us to forward you to your own personal Bubl when you login again. This is a one way hash, meaning that we cannot reverse it back to your plain text email address.
Because we do not store any other information about you on our servers, outside the information you stored in your own encrypted personal Bubl, this email hash can never be linked to any other personal information.

Support

When you contact us for support we store the information you share with us for this support question until we resolve the issue. As soon as we resolve the issue we delete all personal information and we only keep the anonymous technical information regarding the problem. You can always ask us to remove your personal information at any time before we solve the issue. This may result potentially in us not being able to solve your support question completely.

What about the information I provide with services on the Bubl store?

In general the information provided to services stays within the Bubl environment, but in the exceptional circumstances that the data is required to leave the Bubl this will only happen in the case you granted the access. Data shared outside of the Bubl environment falls under the privacy statement and terms of service of the service provider the information was shared with.

Am I allowed to (re-)share the information I receive without the sender's consent?

No, of course not.
We strongly believe that people should have control over their own information. The Bubl ecosystem is designed to always respect your wishes regarding your information and always ask for your approval.

Do I keep control over the information I share with another Bubl Cloud service for-ever?

Yes and no.

Yes because the Bubl platform is designed with the philosophy not to share your information. The service is sent to the data. All your data is stored in your own personal Bubl. When a service uses your information it does not have to leave your personal Bubl.
When you install or use a service, a service has to tell you what information is shared with whom. If this does not suit you, you can decide not to use that service. Sharing data outside your Bubl is always limited and your Bubl monitors and prevents sharing your information with other parties.

No, under special circumstances the service provider will need to share or grant access to your data outside of your Bubl. This can for example happen when for legal reasons a service provider needs to keep access to your information. Think of medical information or financial information. In those cases the access will stay effective for the maximum amount of time stated by law. After the period ends the access will be revoked automatically. When you provide the access we will always highlight these circumstances.

What would we do if a government asks us for your information?

To meet any applicable law, regulation, legal process or enforceable governmental request, Bubl Cloud may be asked to share your data. But because all your information is end-to-end encrypted there simply is no useful information to give. This also makes it unlikely to ever receive such a request.

What third party services do we use and what information do they collect?

We use third party services for the Bubl Cloud and our service. Below is a list of third party services we use and a link to their corresponding privacy policies.

In addition if you Bubl Cloud url outside the use of the Bubl Cloud platform, in a third party service, their terms and Privacy Policies govern your use of those services.

We use the following third party services:

  • Leaseweb. Find their privacy policy here.
  • All our servers are hosted by our hosting provider, Leaseweb.
  • Cloudflare. Find their privacy policy here.
  • We use Cloudflare for DNS load balancing. No traffic is routed through cloudflare.

How long do we keep your information?

We keep your information until you decide to delete it.
The exception is that in some cases data needs to be kept for legal reasons after the deletion request. For example in the case of medical information. In those cases the data will stay stored for the maximum amount of time stated by law. After the period ends the information will be removed automatically.

Do we adhere to the EU GDPR laws and regulations?

Of course we do. We are based in The Netherlands, which is part of the European Union (EU). We do not only follow these laws and regulations, but our platform is specifically designed to follow the philosophy behind GDPR, meaning you are always in control of your own information.

How did we implement the right to be forgotten?

In the settings screen of your Bubl there is a 'remove my Bubl' button. When you press this button all your information and your Bubl are completely removed from our servers. Therefore, be careful as this can not be undone. It can take up to 90 days before your encrypted data is removed from our backups.

The exception is that in some cases data needs to be kept for legal reasons after the deletion request. For example in the case of medical information. In those cases the data will stay stored for the maximum amount of time stated by law. After the period ends the information will be removed automatically.

At which locations do we store your data?

All data is currently replicated over three locations in The Netherlands, Germany and the United Kingdom (UK). In the future we may add new locations in different countries and on request.

When do we ask for your information?

Because we don't have access to your information, we need to specifically ask for it when we need it.
In the following situations we might need to ask for your information.

  • To enforce applicable terms, including investigation of potential violations.
  • To detect, prevent, or otherwise address fraud, security, or technical issues.
  • To protect against harm to the rights, property, or safety of Bubl Cloud, our users, or the public as required or permitted by law. For example when someone is being mean to you (abuse).

What should you do if you have a question or complaint about this privacy policy?

If you have a question or comment about this privacy policy you can contact us at privacy@bubl.cloud.

If you have a complaint, you have the right to file a complaint with the national supervisory authority responsible for the protection of personal data. For the Netherlands, this is the Dutch Data Protection Authority. You can contact them at https://autoriteitpersoonsgegevens.nl/en This is in accordance with EU privacy laws and regulations.

When can we change this privacy policy?

We make updates and changes to this privacy policy on a regular basis. You can always visit our website to see the latest version.

Do we sell your personal information?

No and again no. We do not have access to your information, so for us there is nothing worthwhile to sell.

We do allow services that ask you to sell your personal information to a third party. Of course you will always need to explicitly give permission and the proceeds of this transaction go directly to you. We built this feature because we believe that your data is yours and you want to earn money with it, you can.

Can your personal information be used for advertising?

We do not have access to your information so Bubl Cloud cannot send your data to an advertising company outside your Bubl.
Some services that run within your Bubl, including ours, may use (personalized) advertising. This works completely inside your Bubl and your data never leaves or is shared with someone else.

What is the contact information of Bubl B.V.?

Bubl B.V., registered at the chamber of commerce in Amsterdam, The Netherlands, registration number: 72372370 contact@bublcloud.com

General terms and conditions

  1. 1 Our terms of service

    Bubl B.V. in the Netherlands provides our services and is solely responsible for your information when you use Bubl Cloud. You agree to our terms of service ("terms") by installing or using our apps, services, or website (together, "services"). Our terms cover the entire agreement between you and Bubl Cloud regarding our services. If you do not agree with our terms, you should stop using our services.

  2. 2 Minimum age

    You must be at least 16 years old to use our services. The minimum age to use our services without parental approval may be higher in your country of residence.

  3. 3 Privacy policy

    When you agree to our terms of service you automatically agree to our privacy policy.

  4. 4 Terms of service

    1. 4.1 Account registration
      By signing-up for our services you automatically agree to our terms of service.
    2. 4.2 Software
      In order to enable new features and enhanced functionality, you consent to downloading and installing updates to our services. You also consent to let us send you notifications via Bubl Cloud from time to time, as necessary to provide our services to you.
    3. 4.3 Fees and taxes
      You are responsible for data and mobile carrier fees and taxes associated with the devices on which you use our services.
    4. 4.4 Permitted and acceptable use
      You agree to use our services only for legal, authorized, and acceptable purposes. You will not use (or assist others in using) our services in ways that:
      a) violate or infringe the rights of Bubl Cloud, our users, or others, including privacy, publicity, intellectual property, or other proprietary rights;
      b) involve sending illegal or impermissible communications.
    5. 4.5 Harm to Bubl Cloud
      You must not (or assist others to) access, use, modify, distribute, transfer, or exploit our services in unauthorized manners, or in ways that harm Bubl Cloud, our services, or systems. For example you must not:
      a) gain or try to gain unauthorized access to our services or systems;
      b) disrupt the integrity or performance of our services;
      c) create accounts for our services through unauthorized or automated means;
      d) collect information about our users in any unauthorized manner;
      e) sell, rent, or charge for our services.
    6. 4.6 Keeping your account secure
      Bubl Cloud embraces privacy by design and does not have the ability to access your information. You are responsible for keeping your Bubl Cloud account safe and secure. If you lose access to your Bubl, you lose access to your data. You are also responsible for the security of the devices you use for Bubl cloud.
    7. 4.7 Third-party services
      Our services may allow you to access, use, or interact with third-party websites, apps, content, and other products and services. When you use third-party services, their terms and privacy policies govern your use of those services.
    8. 4.8 Personal rights
      You own the information you submit through our services.
    9. 4.9 Intellectual property rights of Bubl Cloud
      We own all copyrights, trademarks, domains, logos, trade dress, trade secrets, patents, and other intellectual property rights associated with our services. You may not use our copyrights, trademarks, domains, logos, trade dress, patents, and other intellectual property rights unless you have our written permission.
    10. 4.10 Locations
      We have the right to provide or transfer our services and transfer or store data at any location in the world, without notification or prior consent, that is not subject to trade sanctions. Except when there is an additional agreement to host your Bubl and/or Bubl Cloud services at a specific location.
    11. 4.11 Reporting copyright, trademark, or other intellectual property infringement
      To report copyright, trademark, or other intellectual property infringement, please contact legal@bubl.cloud
    12. 4.12 Licences
      Bubl Cloud grants you a limited, revocable, non-exclusive, and non-transferable license to use our services in accordance with these terms.
    13. 4.13 Interruptions
      Our services may be interrupted, including for maintenance, upgrades, or network or equipment failures. We may discontinue some or all of our services, including certain features and the support for certain devices and platforms, at any time.

  5. 5 Disclaimers and Limitations

    1. 5.1 Disclaimers
      YOU USE OUR SERVICES AT YOUR OWN RISK AND SUBJECT TO THE FOLLOWING DISCLAIMERS. WE PROVIDE OUR SERVICES ON AN "AS IS" BASIS WITHOUT ANY EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, AND FREEDOM FROM COMPUTER VIRUS OR OTHER HARMFUL CODE. BUBL CLOUD DOES NOT WARRANT THAT ANY INFORMATION PROVIDED BY US IS ACCURATE, COMPLETE, OR USEFUL, THAT OUR SERVICES WILL BE OPERATIONAL, ERROR-FREE, SECURE, OR SAFE, OR THAT OUR SERVICES WILL FUNCTION WITHOUT DISRUPTIONS, DELAYS, OR IMPERFECTIONS. WE DO NOT CONTROL, AND ARE NOT RESPONSIBLE FOR, CONTROLLING HOW OR WHEN OUR USERS USE OUR SERVICES. WE ARE NOT RESPONSIBLE FOR THE ACTIONS OR INFORMATION (INCLUDING CONTENT) OF OUR USERS OR OTHER THIRD PARTIES. YOU RELEASE US, AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, PARTNERS, AND AGENTS (TOGETHER, "BUBL CLOUD PARTIES") FROM ANY CLAIM, COMPLAINT, CAUSE OF ACTION, CONTROVERSY, OR DISPUTE (TOGETHER, "CLAIM") AND DAMAGES, KNOWN AND UNKNOWN, RELATING TO, ARISING OUT OF, OR IN ANY WAY CONNECTED WITH ANY SUCH CLAIM YOU HAVE AGAINST ANY THIRD PARTIES.
    2. 5.2 Limitation of liability
      BUBL B.V. WILL NOT BE LIABLE TO YOU FOR ANY LOST PROFITS OR CONSEQUENTIAL, SPECIAL, PUNITIVE, INDIRECT, OR INCIDENTAL DAMAGES RELATING TO, ARISING OUT OF, OR IN ANY WAY IN CONNECTION WITH OUR TERMS, US, OR OUR SERVICES, EVEN IF BUBL B.V. HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. OUR AGGREGATE LIABILITY RELATING TO, ARISING OUT OF, OR IN ANY WAY IN CONNECTION WITH OUR TERMS, US, OR OUR SERVICES WILL NOT EXCEED ONE EURO CENT (€0.01). THE FOREGOING DISCLAIMER OF CERTAIN DAMAGES AND LIMITATION OF LIABILITY WILL APPLY TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW. THE LAWS OF SOME STATES OR JURISDICTIONS MAY NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, SO SOME OR ALL OF THE EXCLUSIONS AND LIMITATIONS SET FORTH ABOVE MAY NOT APPLY TO YOU. NOTWITHSTANDING ANYTHING TO THE CONTRARY IN OUR TERMS, IN SUCH CASES, THE LIABILITY OF THE BUBL CLOUD PARTIES WILL BE LIMITED TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

  6. 6 Disputes

    Dutch law governs our terms, as well as any disputes, whether in court or arbitration, which might arise between Bubl Cloud and you, without regard to conflict of law provisions. You agree to resolve any claim arising out of our terms, us, or our services. The competent court is a court in Amsterdam, the Netherlands.

  7. 7 Ending terms of service

    1. 7.1 You ending these terms
      You can end these terms with Bubl Cloud at any time by deleting your Bubl in the settings and discontinuing use of our services.
    2. 7.2 We revoke your access
      We may modify, suspend, or terminate your access to or use of our services, or delete your account anytime for any reason, such as if you violate the letter or spirit of our terms or create harm, risk, or possible legal exposure for Bubl Cloud.
      If we disable your account for a violation of our terms of service, you will not create another account without our permission.
    3. 7.3 Provisions surviving termination
      The following provisions will survive termination of your relationship with Bubl Cloud: "Our terms of service (1)", "Licenses (4.12)", "Interruptions (4.13)", "Disclaimers (5.1)", "Limitation of Liability (5.2)", "Disputes (6)", "Ending terms of service (7)", "Trade sanctions and using services in different countries (8)", "Updates to our terms of service (9)", "Failing to enforce our terms of service (10)".

  8. 8 Trade sanctions and using services in different countries

    You will comply with all applicable export control and trade sanctions laws. Our services are not intended for distribution to or use in any country where such distribution or use would violate local law or would subject us to any regulations in another country. We reserve the right to limit our services in any country.

  9. 9 Updates to our terms of service

    Bubl Cloud may update the terms of service from time to time. When we update our terms, we will update the "Last Modified" date associated with the updated terms. Your continued use of our services confirms your acceptance of our updated terms and supersedes any prior terms. You will comply with all applicable export control and trade sanctions laws. Our terms cover the entire agreement between you and Bubl Cloud regarding our services. If you do not agree with our terms, you should stop using our services.

  10. 10 Failing to enforce our terms of service

    When we fail to enforce any of our terms of service, that does not mean we waive the right to enforce them. If any provision of the terms is deemed unlawful, void, or unenforceable, that provision shall be deemed severable from our terms and shall not affect the enforceability of the remaining provisions.

  11. 11 Questions

    If you have a question or comment about these terms of service you can contact us at contact@bubl.cloud

  12. 12 Contact information

    Bubl B.V., registered at the Netherlands Chamber of Commerce in Amsterdam, The Netherlands, registration number: 72372370 contact@bubl.cloud