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Last Updated: February 19, 2024
This Privacy Notice explains the practices, collection, use, and sharing of information by Bluebulb Financials (“we”, “us”, “our”).
Unless otherwise stated, this Privacy Notice describes and governs the information collection, use, and sharing practices of Bluebulb Financials with respect to your use of our website (https://bluebulbfinancials.com/) and the services (“Services”) we provide and/or host on our servers or via our represented staff. Before you use or submit any information through or in connection with the Services, carefully review this Privacy Notice. By using any part of the Services, you understand that your information will be collected, used, and disclosed as outlined in this Privacy Notice.
If you do not agree to this Privacy Notice, please do not use our Services.
Bluebulb Financials has designed this Notice to be consistent with the international best standards as follows:
Reader-friendly and in a comprehensive manner;
Data collection, storage, and processing simplified as much as possible to enhance security, ensure consistency, and make the practices easy for users to understand;
Data practices meet the reasonable expectations of users.
We collect your Personal Information for the purposes provided in this Privacy Notice and our Terms of Service, which may include your name, physical address, email address, bank details, and bank verification number. We collect your information in multiple ways, such as when you provide information directly to us; when we passively collect information from you, such as from your browser or device; and from third parties.
We will collect any information you provide to us. We may collect information from you in a variety of ways, such as when you:
Transact with us;
Send and receive money;
Contact us or provide feedback;
Subscribe to our mailing lists or newsletter(s).
This information may include but is not limited to your name, email address, phone number, mailing address, payment information, and your geographic location.
Device/Usage Information
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze:
Device information such as IP addresses, location information (by country and city), unique device identifiers, IMEI and TCP/IP address, browser types, browser language, operating system, mobile device carrier information;
Information related to the ways in which you interact with the Services, such as referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Cookies and Other Tracking Technologies
We also collect data about your use of the Services through the use of Internet server logs and online tracking technologies, such as cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to:
Recognize your device such as phone, tablet, computer;
Store your preferences and settings;
Understand the web pages of the Services you have visited and the referral sites that have led you to our Services;
Enhance your user experience by delivering content specific to your inferred interests;
Perform searches and analytics; and
Assist with security administrative functions.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. We may also use tracking technologies in our license buttons and/or icons that you can embed on other sites/services to track the website addresses where they are embedded, gauge user interaction with them, and determine the number of unique viewers of them. If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as whether you open our message, click on any links or banners our email contains, or otherwise interact with what we send. This data allows us to gauge the effectiveness of our communications and marketing campaigns. As we adopt additional technologies, we may also gather additional information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
For more information about how we use cookies, please read our Cookie Notice.
To the extent permitted by law and for the purposes of our Services, we may also collect information from third parties, including public sources, social media platforms, and marketing and market research firms. Depending on the source, this information collected from third parties could include name, contact information, demographic information, information about an individual’s employer, information to verify identity or trustworthiness, and information for other fraud or safety protection purposes.
We may use the information we collect from and about you to:
Fulfill the purposes for which you provided it.
Provide and improve the Services, including to develop new features or services, take steps to secure the Services, and for technical and customer support.
Make sales, accept payments, or process transactions; send you information about your interaction or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed.
Process and respond to your inquiries or to request your feedback.
Conduct analytics, research, and reporting, including to synthesize and derive insights from your use of our Services.
Comply with the law and protect the safety, rights, property, or security of Bluebulb Financials, the Services, our users, and the general public.
Enforce our Terms of Use, including to investigate potential violations thereof.
Please note that we may combine information that we collect from you and about you (including automatically collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Privacy Notice.
We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes.
Service Providers: We may disclose your information with third parties who perform services on our behalf, including without limitation, website developers, internet service providers, marketing personnel, customer support agents, data storage operators, data analysts, and legal service providers.
Legal Compliance and Protection: We may disclose your information if required to do so by law or on a good faith belief that such disclosure is permitted by this Privacy Notice or reasonably necessary or appropriate for any of the following reasons:
(a) To comply with legal process;
(b) To enforce or apply our Terms of Use and this Privacy Notice, or other contracts with you, including investigation of potential violations thereof;
(c) Enforce our Code of Conduct and policies contained and incorporated therein;
(d) To respond to your requests for customer service; and/or
(e) To protect the rights, property, or personal safety of Bluebulb Financials, our agents and affiliates, our users, and the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
Business Transfers: As we continue to develop our business, we may engage in certain business transactions, such as the transfer or sale of our assets. In such transactions (including in contemplation of such transactions, e.g., due diligence), your information may be disclosed. If any of our assets are sold or transferred to a third party, customer information (including your name, phone number, and email address) would likely be part of the transferred business assets.
Affiliated Companies: We may disclose your information with current or future affiliated companies.
Consent: We may disclose your information based on your consent to do so.
Aggregate/De-identified Information: We may disclose de-identified and/or aggregated data for any purpose to third parties, including advertisers, promotional partners, and/or others.
The laws in certain jurisdictions require companies such as ours to inform you about the legal ground they (We) rely on to use or disclose information that can be directly linked to or used to identify you. To the extent those laws apply, our legal grounds for processing such information are:
To Honor Our Contractual Commitments to You: Much of our processing of information is to meet our contractual obligations to provide services to our users.
Legitimate Interests: In many cases, we handle information on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. These include:
(a) Customer service
(b) Marketing, advertising, and fundraising
(c) Protecting our users, personnel, and property
(d) Managing user transactions
(e) Organizing and running events and programs
(f) Analyzing and improving our business
(g) Managing legal issues
We may also process information for the same legitimate interests of our users and business partners.
Legal Compliance: We may need to use and disclose information in certain ways to comply with our legal obligations.
Consent: Where required by law, and in some other cases where legally permissible, we handle information on the basis of consent. Where we handle your information on the basis of consent, you have the right to withdraw your consent in accordance with applicable law.
We may use third-party web analytics services (such as Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies and Other Tracking Technologies” section above will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive to our Site, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the official Google Analytics Opt-out Browser Add-on.
7.1 Bluebulb Financials may transfer Personal Information that we maintain about you to recipients outside the country in which the Personal Information was originally collected. The data protection regulations of these countries may be different from those of your country. Where Personal Information is to be transferred to a country outside Nigeria, Bluebulb Financials shall put adequate measures in place to ensure the security of such Personal Information. Transfer of Personal Information out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation and other applicable regulations. Bluebulb Financials will therefore only transfer Personal Information out of Nigeria on one of the following conditions:
The transfer is necessary for the performance of a contract between Bluebulb Financials and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request.
The transfer is necessary to conclude a contract between Bluebulb Financials and a third party in the interest of the Data Subject.
The consent of the Data Subject has been obtained.
The transfer is necessary for reasons of public interest.
The transfer is for the establishment, exercise, or defense of legal claims.
The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.
Bluebulb Financials will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.
Please note that you are not obliged to share your Personal Information with Us. But if you refuse to share the Personal Information we require from you for the purpose of providing our Services, we will not be able to provide our Services to you. To use your information as described above, we rely on the following legal bases:
Provide the Services to You: We process your information to perform the contract (Terms and Conditions of Service) that you have with us.
Legitimate Interests: We use your information for legitimate business interests when permitted by law. For example, we analyze users’ behavior on the Services to improve them, for direct marketing, and for administrative use, fraud detection, and other legal purposes.
Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us using the contact information provided at the end of this Privacy Notice.
Performance of a Contract: The processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.
Legal Compliance: Processing is necessary for compliance with a legal obligation to which Bluebulb Financials is subject.
Vital Interest: Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.
Public Interest and Mandate: Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Bluebulb Financials.
For the purpose of this Privacy Notice, consent means any freely given, specific, informed, and unambiguous indication of the Data Subject's wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.
Individuals who have their Personal Information held by Bluebulb Financials are entitled to exercise the rights below and may contact us accordingly:
Right to request for and access their Personal Information collected and stored. Where data is held electronically in a structured form, such as in a database, the Data Subject has a right to receive that data in a common electronic format.
Right to information on their personal information collected and stored.
Right to objection or request for restriction.
Right to object to automated decision-making.
Right to request rectification and modification of Personal Information which Bluebulb Financials keeps.
Right to request deletion of their data.
Right to request the movement of data from Bluebulb Financials to a third party; this is the right to the portability of data.
Right to object to, and to request that Bluebulb Financials restricts the processing of their information.
Your request will be reviewed by Bluebulb Financials Data Protection Officer (DPO) or Compliance Officer and carried out except as restricted by law or Bluebulb Financials’s statutory obligations. You may decline to provide your Personal Information when it is requested by Bluebulb Financials, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us.
You have various rights with respect to the collection and use of your information through the Services. Those choices are as follows:
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