1 INTRODUCTION TO OUR SERVICES
Through our Services, Bluenumber empowers you to take control of your data pursuant to the GDPR. More generally, data subject control their own personal information on our Services, and we will not share their personal information with a third party unless consent is given.
Bluenumber itself may analyse and draw conclusions about any user’s personal or other information. In addition, we may share aggregated and/or deidentified data with third parties. Aggregated data is information that Bluenumber generates from individualized information but subsequently maintains and uses in a form that combines information about numerous individuals so that no individual can be identified. Examples include the number of users who live in a certain city, with specific gender and age group. De-identified information is information (including individualized information) from which Bluenumber has removed any data that personally identifies an individual. We may disclose aggregated or de-identified data derived from information about you to any third party. By registering for or using our Services you consent to the collection, use, and sharing of such aggregated and/or de-identified information as Bluenumber deems appropriate.
Our internal data protection resource is based in Kuala Lumpur, Malaysia. If you have any questions or concerns about Bluenumber’s policies or practices regarding Personal Data please email to firstname.lastname@example.org.
3 COLLECTION OF PERSONAL DATA
3.1. INFORMATION YOU VOLUNTARILY PROVIDE TO US
We collect personal information when you provide your Personal Data in order to be assigned our global unique identifier, the bluenumber (B#), or if you sign up to become a registered user of our Sites including our products and services operated by Bluenumber.
Personal Data collected by Bluenumber as part of our registration process, may include your first and last name, email address, business or home address, phone number and any other information we require to provide a service you requested or to support your use of our products or services.
If you communicate or correspond with us by email or other forms of communication, we may collect the information you provide to us as part of those communications. For example, if you correspond with us through email, we may collect and store the email address you use to send the applicable correspondence and use it to respond to your inquiry, notify you of any publications or other services or keep a record of your complaint or enquiries.
This information is used to communicate with you, to design content and activities that we believe would be of interest to you. Bluenumber shall ensure this use of information will not violate any applicable laws or regulations in providing you access to Bluenumber’s products and services.
If you wish to opt-out of receiving these communications from us, please follow the instructions contained in an applicable communication you receive from us or submit a request to Info@bluenumber.org.
3.2. INFORMATION WE AUTOMATICALLY COLLECT FROM YOU
Bluenumber automatically collects your information when you use our Sites or Services. For example, if you access our Sites through a computer or mobile application, we will automatically collect information including but not limited to your browser type and version, computer and connection information, IP address, location of your mobile device and standard web log information pursuant to our Cookies Policy [insert hyperlink].
If you choose not to share your location details some or all of the features and functions of our Sites or Services may be affected. For instructions on changing the relevant settings, please contact your service provider or device manufacturer. Note that this information that we automatically collect from you is used to enhance the performance of our Sites.
Information that may be collected by cookies or tracking technology when you use our Sites may include, without limitation:
- the pages you visit within our Sites;
the date and time of your visit to our Sites;
- the amount of time you spend using our Sites;
- other general demographic trends; the Internet Protocol (IP) address used to connect your computer to the Internet; and/or
- your computer and connection information (browser type and version, operating system and platform).
The collected information is to enhance our Sites’ performance and end user experience. You can set your browser to reject cookies or to notify you when you are sent a cookie. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.
In addition, to find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
3.3. INFORMATION WE RECEIVED FROM THIRD PARTIES
We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, certification bodies, business partners, third-party technological service providers such as supplier management systems as well as sensors, Bluetooth devices and near field communication technologies, joint marketing partners, social media platforms, people with whom you are connected on social media platforms, and other third parties.
2.4. INFORMATION COLLECTED BY THIRD PARTIES THROUGH THIRD-PARTY LINKS AND CONTENT
4 USE, SHARING AND RETENTION OF PERSONAL INFORMATION
4.1. HOW WE USE YOUR INFORMATION
Bluenumber uses personal information for the purposes described at the time of collection:
- to provide B# holder benefits and other services to you, including order processing, processing of certification or membership applications or registering you for any Bluenumber-related event or programmes, and to report to others about whether you are a B# holder or not;
- to provide you with information about the Services that you request from us;
- to provide you with information about Bluenumber, as permitted by law, our Services or other services in which we believe you may be interested;
- If you are a member or registered user, we may email you about Services that we believe may be of interest to you. If you wish to opt-out of receiving these emails from us, please follow the instructions contained in an applicable email you receive from us, which will allow you to opt-out of receiving these types of email communications from us;
- to offer you our Services;
- to protect our rights or property, or the security or integrity of our Services;
- to verify your identity (including age) when you are dealing with us to determine your eligibility for any of our products and services;
- to comply with any applicable law, regulation, legal process or governmental request;
- to answer your queries and requests;
- to tailor your experience at our Sites, to compile and display content and information that we think you might be interested in, and to provide you with content according to these preferences. Bluenumber may also use this information to help us understand our members’ needs and interests, to better tailor our Services to meet your needs; or
- for any other purpose disclosed to you in connection with our Services.
4.2. HOW WE SHARE YOUR INFORMATION WITH THIRD PARTIES
- Third-Party Service Providers. We may share your information with vendors or third parties who deliver or provide services or otherwise act on behalf of or at the direction of Bluenumber. These third parties may include, for example, our third-party technology providers, including our mobile application vendors, technology partners and third-party event hosts for conference registrants, sponsors, co-sponsors and exhibitors. These third-party service providers will only have access to the information needed to perform these limited functions on our behalf and at the same time, bound by confidentiality obligation set forth in an agreement between both parties.
- Newsletters. Bluenumber uses e-mail service providers to collect contact information, distribute our newsletter, and track actions you take that assist us in measuring the performance of our Sites and newsletters. At any time, you may be removed from our newsletters by clicking on the unsubscribe button provided in each e-mail.
- Bluenumber Events. If you are an event attendee, speaker or sponsor, some of your information may be included in the event roster, which will be publicly disclosed, and may also be shared with third-party event sponsors and exhibitors. Further, by registering and attending a Bluenumber event, you agree irrevocably, with no compensation to you, that Bluenumber or any third party who is acting on Bluenumber’s behalf may create images, videos and/or sound recordings of you (“the Works”) at the event for marketing purposes. This grant of rights in the Works also includes the rights to adapt, reproduce, distribute, perform, and make available to the public, broadcast, retransmit or sublicense the Works to Bluenumber’s affiliates. This grant of rights in the Works also includes all current and future media and is not restricted to time or territory.
- Response to Subpoenas, Court Orders, Government Requests or to Protect Rights and to Comply with Our Policies. To the extent permitted by law, we will disclose your information to government authorities or third parties if:
- required to do so by law or regulation, or in response to a subpoena or court order or any other enforceable governmental request or order;
- we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or
- we believe that you have abused our Sites by using them to attack other systems or to gain unauthorised access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable laws.
- Aggregate Information. We may share your information with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.
Where we do share your Personal Data with third parties, Bluenumber takes steps to ensure that they use appropriate safeguards to protect your Personal Data.
5 TRANSFERRING YOUR PERSONAL DATA INTERNATIONALLY
Bluenumber has its operations in different countries including the United States (US) and European Economic Area (“EEA”). As such, the data that we collect from you may be transferred to, and process at, a destination outside the US or EEA. By submitting your Personal Data, you agree to this transfer or processing. If this data is not processed and transferred, Bluenumber will not be able to execute a contract with you or you will not have access to any or all of the benefits and features associated with our Services.
6 LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (FOR EEA CUSTOMERS ONLY)
If you reside within the EEA, our processing of your personal information will be legitimised as follows:
- Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1)(a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.
- If the processing of your personal data is necessary for the performance of a contract between you and Bluenumber or for taking any pre-contractual steps upon your request, such processing will be based on the Article 6(1)(b) of the GDPR. If this data is not processed, Bluenumber will not be able to execute the contract with you.
- Where the processing is necessary for us to comply with a legal obligation, we will process your information on the basis of Article 6(1)(c) of the GDPR, such as when complying with the requirements of the employment law.
- And where the processing is necessary for the purposes of Bluenumber’s legitimate interests, such processing will be made in accordance with Article 6(1)(f) of the GDPR, to, for example, detect fraud.
7 ACCESS AND CONTROL OF YOUR PERSONAL DATA
If you wish to confirm that Bluenumber is processing your Personal Data, or to have access to the Personal Data Bluenumber may have about you, or have other questions, please contact us at Info@bluenumber.org.
If your data was collected or processed, you have the following rights, subject to exceptions or requirements under current laws, including the GDPR:
- To request information about the purpose of the processing, the categories of personal data concerned, who else outside Bluenumber might have received the data from Bluenumber, what the source of the information was (if you did not provide it directly to Bluenumber), where the personal data is stored and how long it will be stored.
- To correct (rectify) the record of your personal data maintained by Bluenumber if it is inaccurate.
- To erase that data or cease processing it, subject to certain exceptions. You may also ask Bluenumber for your personal data to be supplemented or updated, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons.
- To withdraw your consent for the processing of personal data or the further processing of personal data by Bluenumber at any time. You may also request that Bluenumber cease using your data for direct marketing purposes.
In many countries (including US and EEA countries), you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Bluenumber processes your personal data. When technically feasible, Bluenumber will, at your request, provide your Personal Data to you or transmit it directly to another controller. You have the right to receive your Personal Data in a structured and standard format.
In general, reasonable access to your personal data will be provided at no cost to B# holders, upon request made to Bluenumber via Info@bluenumber.org. Nevertheless, repeated requests to access your personal data may incur additional charges as administration fee, as provided in Art.15 of the EU GDPR policy https://gdpr-info.eu/art-15-gdpr/. If access cannot be provided within a reasonable time frame, Bluenumber will provide you with a date when the information will be provided. If for some reason access is denied, Bluenumber will provide an explanation as to why access has been denied.
7.1. Security of Your Information
Bluenumber uses reasonable physical, technical and administrative measures to safeguard personal information you provide through our Sites or in connection with Bluenumber’s products and services. Please be aware that no data transmission over the Internet can be guaranteed to be completely secure. As a result, Bluenumber cannot guarantee or warrant the security of any information you transmit on or through our Sites and you do so at your own risk.
7.2. Data Storage and Retention
Your Personal Data is stored by Bluenumber on the secure cloud services Bluenumber engages. Bluenumber retains data for the duration of a business relationship with our client and otherwise as required under applicable law. Personal data will be kept for no longer than is necessary for the purposes for which your Personal Data are processed. We will retain your Personal Data as long as you are a B# holder or user of Bluenumber Services so that we can provide these Services to you.
If you are located in the EEA, at the moment your B# is removed or you withdraw your consent for the processing of your personal information, all of your Personal Data that has been received and stored will be erased unless we are required to retain this Personal Data by law or to comply with our regulatory obligations. In such a case, we will only keep this Personal Data for as long as necessary. For more information on where and how long your Personal Data is stored, and for more information on your rights of erasure and portability, please contact us at Info@bluenumber.org.
8 SPECIAL INFORMATION (FOR CALIFORNIA RESIDENTS)
If you want to opt-out of Bluenumber from sharing your information with third parties for their own marketing purposes, you can opt out by contacting Info@bluenumber.org.
Upon receipt, verification and confirmation of your opt-out request, Bluenumber will process the request and you will receive an email confirming that you have opted-out and that Bluenumber has stopped using or collecting your personal data as well as deleted it, if the data is no longer required by law.
Section 1798.83 of the California Civil Code requires selected businesses to disclose policies relating to the sharing of certain categories of your information with third parties. If you reside in California and have provided your information to Bluenumber, you may request information about our disclosures of certain categories of information to third parties for direct marketing purposes. Such requests must be submitted to us at Info@bluenumber.org.
9 HOW TO CONTACT BLUENUMBER TO MODIFY YOUR INFORMATION OR PREFERENCES
To help us keep your Personal Data up to date, or to request access to the Personal Data Bluenumber maintains about you, please email us at Info@bluenumber.org.
Bluenumber is not directed to children under the age of 16. Bluenumber does not knowingly collect personally identifiable data from persons under the age of 16 pursuant to the GDPR. If you are a parent of a child under 16, and you believe that your child has provided us with his or her information, please contact us at Info@bluenumber.org.