Effective Date: 25th May, 2018
Last Editorial Updated : Tuesday, 03. July 2018
What personal data we collect and why we collect it
Depending on the type of our business relationship and your usage of our services different types of data is collected. This document outlines bubble.kg’s Data Protection and Data Storage Policy and GDPR compliance. It describes which of your data is stored how long in order to provide which service and what we do to protect it.
Mailing List Subscribers
The bubble.kg mailing list server stores the email address of the list subscribers. It may, if known, store the full name of the subscriber and use it to address outgoing emails. This reduces the probability of our server emails to be considered spam by spam filters. We (humans) also use it to connect your email address to you at support requests, if you email does not reveal your name.
We do not share your email addresses with others, however subscribers choosing to actively use the list to post a message, reveal their email and all data within their email to the list subscribers and the public.
The mailing list server internally records transaction data between mail-servers for debugging purposes. This data may or may not hold the potential to reveal information about a user. This data is not used to analyze human behavior. Personal knowledge learned by a human technician during technical maintenance will neither be recorded nor shared.
To remove invalid email addresses and keep our mailing list clean, the mailing list server uses a technique called VERP mode (Variable envelope return path) to identify bouncing email addresses on some or all the emails distributed. This data is only used for bouncing emails to determine which submitted email address is failing and remove it from the list.
The mailing list server allows users to select only specific topics within their subscription. These preferences are recorded. This data is solely used by the software to filter the messages distributed. The data is not analyzed to gain insight about the user.
Beyond the above mentioned, we do not collect any site or personal data, and should we ever do so in the future, we will explicitly ask for your consent and explain what data we will collect.
We explicitly do not use any technique to analyze if you open or read an email.
Mailing List Archive
The mailing list server offers a public archive for some of its mailing lists, so users can reference and research previous posts (e.g. Archive for the international mailing list for Bishkek).
While this has measures implemented trying to prevent robots from scanning the archive for email addresses, robots may become ‘smart’ enough to circumvent that at some point. In this case the email address of people actively posting would be unintentionally revealed to email harvesters.
The archive is designed to revealed previous emails to humans, who are consulting the archive.
We manually consolidate the archive approximately once per year.
The maximum storage time for emails in the archive is:
- Standard Archive Time
- 24 month – consolidation to the last 12 month
Content Contributors
While using our Site, may be asked you to provide us with personally identifiable information that can be used to contact, identify you and meet contractual and fiscal obligations. Personally identifiable information may include, but is not limited to your name, email and billing address.
We use the information we collect about you in the following ways:
- To respond to any requests from you regarding sales and support.
- To contact you regarding any agreements or accepted terms that you may have with bubble.kg or one of its operational entities.
- To provide you with marketing emails, special offers, or newsletters.
- To find and prevent fraud.
- To carry out other purposes as disclosed to you through the Website, or found in terms or an agreement between you and bubble.kg, the owner or OsOO Heider Consulting.
- Process for other purposes for which we obtain your consent.
User Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar privacy policy is available online. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display and language choices. Login cookies and screen options cookies last for a month. If you log out of your account, the login cookies will be removed.
Additional cookies may be set by embedded analytics software.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
Analytics
Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.
We use Google Analytics and Yandex Metrica and other analytical tools to help us understand how our customers use the site.
Independently from this Privacy Statement and our use of data, we advice any user to use a browser plugin like Ghostery to generally monitor what websites are tracking and individually control what you want to allow each websites.
Google Analytics
You can read more about how Google uses your Personal Information in the Google Privacy Policy. You can also opt-out of Google Analytics by using their Google Analytics Opt-out Browser Add-on.
Yandex Metrica
You can read more about how Yandex uses your Personal Information in the Yandex Privacy Policy and their page about General Data Protection Regulation Compliance (GDPR).
You can also opt-out of Yandex Metrica by using their Yandex.Metrica opt-out add-on.
Webalizer
Bubble.kg uses Webalizer to analyze the web server log data to gain insight about the usage of the website and the clients used. The analysis is not connected to user profiles.
Automattic JetPack
We also use JetPack statistics to enhance site functionality and monitor the usage of bubble.kg. For this add-on also the Automattic Privacy Policy applies.
Data collected by the underlying software, CMS plugins and design themes
The bubble.kg web services are implemented using open source and commercially available content management software (CMS), CMS plugins and CMS design themes.
In respect to this software we are just users and only know about its function, what the software documentation reveals.
We will do our due diligence to monitor and document the data usage of this software. However there is no way for us to fully understand all functionality nor to guarantee for the employed softwares use of data.
We will document known functionality to the best of our knowledge, as in the paragraphs Analytics, Embedded content from other websites and Mailing List Subscribers.
Data collected by hosting and cloud providers
The technical infrastructure is outsourced to Kyrgyz hosting providers, which in turn may or may not rely on cloud services and other sub-providers who’s location and infrastructure and data usage is unknown to us.
Issue tracking system
We use an issue tracking system for internal communication between our team members and may therefore need to reference you, the customer, in order to provide contracted support services.
Who we share your data with
We do not and will never sell or transfer your data for reasons other than providing you with a better service on our own websites.
All third party services have their own privacy policies in accordance to European GDPR laws if they are subject to European regulation of have decided to comply voluntarily.
Our Sponsors and Advertisment partners do not receive any personal data or email addresses. Information distribution is handled by us.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website, we also store the personal information they provide in their user profile, including name and email. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on bubble.kg, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Changes to This Privacy Policy
We will constantly update this privacy policy to better describe the usage of your data and to reflect technical development. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice on the website or by sending you an email notification. Please review this privacy policy whenever you want to make sure you are informed about our information practices.
Previous Updates to this document
2018-06-04
Added storage period to mailing list archives and added procedure to regulary consolidate the archives to 12 month before the archive exceeds 24 month of emails.
2018-05-31
Improved Documentation on technical details, e.g. trackers.
2018-05-25
Initial Version