BingoEspresso

Privacy Policy


The privacy policy here entails how we, at AVRA MEDIA LIMTED use,store and secure your information as you interact with our website, http://bingoespresso.com and the other ways where we collect or obtain the information from you. This privacy policy is effective from 21st May 2018.

CONTENTS

  • Summary
  • Details About Us
  • Information Collected By Your Visit
  • Information We Obtain When You Contact Us
  • Information About Various Interactions On Site
  • Automated Decision-Making And Profiling Systems
  • Information Gathered Through Third Parties
  • Transparency And Utility Of Your Information
  • Duration Of Retaining Your Information
  • Security Of Your Information
  • Your Information Shared Outside The European Economic Area
  • Your Information And Your Rights Related To your Information
  • You Can Object The Processing Of Your Information For Certain Purposes
  • We Do Not Knowingly Or Intentionally Collect Your Sensitive Personal Information
  • Updating And Amending Our Privacy Policy Regularly
  • Below 18 Privacy Policy
  • Compliance With Copyright Laws

SUMMARY

This section gives you a very general overview on how we gather, use and store information about you.


Data controller: AVRA MEDIA LIMITED (webmaster@bingoespresso.com)

How do we collect the data about you?

  1. When we obtain it from you
  2. When you use our website and
  3. From Third parties

We collect information such as; name, e-mail, contact details, IP Address, website browsing behaviour and your geographic location (based on your IP address).

Why do we use your information? for management purposes as per our legal rights and obligations.

When do we disclose your information to third parties?

  1. Only the required information is disclosed when it is important for the business
  2. When service providers need it
  3. To execute any contracts we have entered with you
  4. When required by law or to enforce our legal rights.

Do we have sell your information to other parties? Generally no, however, if there is sale or purchase of the business we may consider the same.

Duration of retaining your information: We retain your information for only as long as it is necessary, barring the legal obligations that we may have to fulfil. For example, maintaining records for tax purposes or to execute any contract we have with you.

Methods we use to secure your information: We secure your information by taking necessary organizational and technical measures such as; storing your data on secure servers and encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology

Sharing your information outside European Economic Area: We may share your information outside the European Economic Area only after taking appropriate measures that ensures the safety of your information.

Do we use automated decision making and profiling? No, we do not make use of automated decision making and profiling.

What are your rights regarding your information?

  1. Right to access your information and remain informed about its usage
  2. Right to get your information corrected or updated
  3. Right to get your information deleted
  4. Right to deny the use of your information
  5. Right to receive your information in PDF format
  6. Right to question the use of your information
  7. Right to take back your consent for using your information
  8. Right to approach a superior authority

Protection of your sensitive personal information:

We do not collect, use, store or share your personal sensitive information. We suggest you not to give out your personal sensitive information to us and we are obligated to respect your right to privacy.

DETAILS ABOUT US

Our data controller is AVRA MEDIA LIMITED and the company registration number is 6917615. The data controller can be contacted via e-mail at webmaster@bingoespresso.com.

AVRA MEDIA LIMITED is the data protection officer for the data controller.You can contact the data protection officer at via e-mail at webmaster@bingoespresso.com.

Should you have any further queries about the privacy policy, you can contact the data controller.

INFORMATION COLLECTED BY YOUR VISIT

In accordance with legal norms and regulations related to disclosure and additional use of your information, we collect, share and use your information when you visit our website.

Details of our web server log

We use webfaction as our server to host our website Bingoespresso.com (https://web581.webfaction.com). The website server records your IP address that you use to access and interact with our website. We also gather other information such as pages accessed, information requested, the URL you use, your browser and its version and your operating system.

Website server log information for IT security reasons

Our provider collects and stores servers logs that ensures a secure network and IT security so that the server and the website remains free of technical glitches. Our security measures include; analyzing log files to help identify and prevent unauthorized access to our network and strict surveillance on unusual or suspicious activity.

  • Legality of processing: in compliance with Article 6(1)(c) of the GDPR(General Data Protection Regulation)
  • Legal obligation: we have a legal obligation to take appropriate technical and organizational measures ensuring security that is appropriate to the potential risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
  • Legal requirement for processing: by adhering to (Article 6(1)(f) of the General Data Protection Regulation).
  • Legal interest(s): we and our third party hosting provider strictly follow all the legal norms with respect to using your information.

Web server log to analyse, improve and update our website

The information is analyzed to scrutinize how our website users interact with our website and its features. For example, we consider the number of visits we receive, the time and date of the visit,the operating system, browser used for our analysis.

Once the analysis is done, we use it to improve and update our website. For example, the information gathered may be used to change certain features, content, structure of our website and individual pages to make our website more user-friendly.

  • Legality for processing: in compliance with Article 6(1)(c) of the GDPR(General Data Protection Regulation)
  • Legal interest(s): improving our website for our users and getting to know our users' preferences so our website can have high functionality and utility.

INFORMATION WE OBTAIN WHEN YOU CONTACT US

n accordance with legal norms and regulations related to disclosure and additional use of your information, we collect, share and use your information when you contact our website.

Email

When you contact us via e-mail on the e-mail address mentioned on our website, we collect your e-mail Id and other information such as your name, contact number, and the information present in the signature block in your email.

  • Legality of processing: in compliance with (Article 6(1)(f) of the General Data Protection Regulation).
  • Legal interest(s): prompt responses to enquiry and messages we receive and keeping the track of the correspondence.
  • Legal requirement for processing: by adhering to (Article 6(1)(f) of the General Data Protection Regulation).
  • Why is it necessary to perform a contract? When we receive your message that relates to us providing you with goods or services or complying with your request to provide you with goods and services (for example, if you seek more details about the goods and services, we will process your information in order to do so).

Sharing and storing your information

Our third party email providers are Netcore and Sendy . To know more about our third party email providers' privacy policy you can visit https://sendy.co/privacy-policy and https://netcore.in/privacy-policy/

Sendy uses Amazon Web Server which is based in Ireland and Netcore is a company based out of India. The databases will be stored and transferred outside the European Economic Area on our third party email provider's servers in different countries. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Contact form

Our contact form contains mandatory questions such as; name, e-mail address and IP address and unless you fill out all the details in the contact form, you will not be able to submit it. As you fill out the form, we collect the aforementioned details about you.

  • Legality of processing: in compliance with (Article 6(1)(f) of the General Data Protection Regulation).
  • Legal interest(s): to receive and store the information of the respondents
  • Legal requirement for processing: by adhering to (Article 6(1)(f) of the General Data Protection Regulation).
  • Why is it necessary to perform a contract: When we receive your message that relates to us providing you with goods or services or complying with your request to provide you with goods and services (for example, if you seek more details about the goods and services, we will process your information in order to do so).

Sharing and storing your information

When we receive information about you through our contact forms, the databases will be stored and transferred outside the European Economic Area on our third party email provider's servers in different countries. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

INFORMATION ABOUT VARIOUS INTERACTIONS ON SITE

In accordance with legal norms and regulations related to disclosure and additional use of your information, we collect, share and use your information when you interact with our website.

E-Newsletter

We collect your name and e-mail ID when you opt-in to receive our E-newsletter to get an update about our offers and promotions.

  • Legal requirement for processing: by adhering to (Article 6(1)(f) of the General Data Protection Regulation).
  • Your authorization: we need your consent to send you our E-Newsletter.

Sharing and storing your information

When we receive information about you through your interaction with our website, the databases will be stored and transferred outside the European Economic Area on our third party email provider's servers in different countries. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Web beacons technology in e-mails

We use small graphic files in our e-mails known as web beacons to evaluate the engagement levels of our e-mails that we receive by assessing delivery rates, open rates and click through rates.

To know more about out third party email provider and their use of web beacons, please see their privacy policy which is available here: https://sendy.co/privacy-policy

Profiling

Any form automated processing of your information to asses, analyse or predict your personal aspects such as: personal preferences, performance at work, heath, location, interests, economic situation or interests is known as profiling.

How we use profiling for web analytics

We use Google analytics for our web analytics services. It is used to collect your information such as your location that is based on your IP address and your behaviour when you interact with our website in anyway.

  • Why do we use profiling? to improve our website and to make it as user friendly as possible by collecting your information such as your location that is based on your IP address when you interact with our website in anyway.
  • Legality of processing: in compliance with (Article 6(1)(f) of the General Data Protection Regulation).
  • Legal interest(s) : Enhancing the user experience by making the website as user friendly as possible.

How we make use profiling in marketing emails

We use web beacons, which are small graphic files to evaluate who opens our mails and what action do they take thereafter.

  • Reason to use profiling : by evaluating the engagement level on our e-mails we can improve the functionality of our website
  • Importance and possible outcome: we can asses the open rates and click through rates through small graphic files called as web beacons
  • Your right to object or question: Contact us via email (webmaster@bingoespresso.com).
  • Legality of processing: in compliance with (Article 6(1)(f) of the General Data Protection Regulation).
  • Legal interest(s) : Improving our communications based on user interest.

Revealing and using your information for other purposes

In compliance with the legal and regulatory norms, we will disclose your information under the following circumstances.

Sharing your information with service providers

The following are our third party service providers and as an essential part of the business activity, we are required to share your information with the provider mentioned below.

  1. Email provider(s): Netcore and sendy
  2. SMS provider: Mobivate
  3. Hosting provider: Webfaction
  4. Push Notifications provider(s): Push Engage Notifications

The intention to share the details about our service providers is to improve the user experience.

We do not disclose every detail of our service providers, publicly. Therefore, should you wish to know more about our service providers, you can reach out to us at www.bingoespresso.com.

  • Legality of processing: in compliance with (Article 6(1)(f) of the General Data Protection Regulation).
  • Legal interest(s): we share your information only to the extent necessary to run our business effectively and efficiently
  • Legal grounds for processing: in accordance with (Article 6(1)(b) of the General Data Protection Regulation) prior to entering a contract with you
  • Why is it necessary to perform a contract? Sharing your information with the third party providers enables to deliver the services you have requested for before entering into a contract with you.

Sharing your information with other third parties

The third parties we are referring to are our Accountants, Business Partners and Independent Contractors. Detailed information about the third parties is given below.

Accountants

We are obligated to share your information with our accountants for tax purposes. For Filing tax returns and to prepare our end of the year accounts, we share the invoices that are issued or received.

Our accountants are located in The United Kingdom and India.

Business partners

Our business partners are the businesses from whom we buy or sell the goods and services that are corresponding to ours. We share the information with our business partners to provide you with the services that you have requested for and these services are provided by our business partners either independently or/and in connection with us.

Independent contractors

Intermittently, we tie up with independent contracts to carry out a certain business activity. In this case, we share the your information with the independent contractors only to the extent necessary.

Sharing your information within our business consortium and for administrative purposes that includes client, customer and employee information.

  • Legality of processing: in compliance with (Article 6(1)(f) of the General Data Protection Regulation).
  • Legal interest(s): to enhance the functionality of our business.

Revealing and using your information for legal reasons

We have a strict surveillance over criminal or suspicious activities. However, if we sense a potential crime, for instance, if a cyber crime is committed or we receive threats, we need to approach a higher authority, such as the police.

Rest assured, the information will be disclosed only if you are directly or indirectly involved or if you get affected by such an incident in any way.

  • Legal interest(s) : preventing and reporting crime or any suspected criminal activity

Using your information in connection with legal requirements

To comply with the legal obligations that we are subjected to, we will use and disclose your information. For example, if there is a need to report a cyber crime or a fraud to the national crime agency.

  • Legality of processing: in compliance with (Article 6(1)(f) of the General Data Protection Regulation).
  • Legal obligation(s): legal obligations to share information which form a part of the laws of England and Wales or if they have been integrated into the United Kingdom's legal framework
  • Legal requirement for processing: in accordance with (Article 6(1)(b) of the General Data Protection Regulation) prior to entering a contract with you.
  • Legal interest(s) : legal obligations that a are part of the laws of another land and have not been integrated into the United Kingdom's legal framework, we have a legal interest in complying with these obligations.

DURATION OF RETAINING YOUR INFORMATION

We have mentioned both, the specific period for retaining your information and where it is not possible to give out the exact duration of retaining your information, we have set a criteria to determine the retention period.

Retention periods

Interaction or enquiry: when you interact with us or send out a query to us either via e-mail or a contact form, we retain your information as long as we resolve your queries.

E-newsletter: we gather your information when you opt-in to receive our E-newsletter and retain it until u choose to unsubscribe from our E-newsletters.

How are retention periods determined?

When we cannot determine the duration of your retention period, we use the following criteria:

  1. reasons(s) to use of your information for both now and in the future (for instance, if it is necessary to store a particular information in order perform our obligations under a contract with you or to contact you in the future).
  2. if there is any legal obligation to continue to process your information.
  3. importance your information if we have any legal requirement to continue to process your information.
  4. any industry practices that are agreed upon unanimously or by a majority on an ideal duration for retaining the information.
  5. the degree of risks, cost incurred and liability we may face if we continue to hold the information.
  6. The difficulty level involved in proving the safety and security of your information with us.
  7. Any other circumstances relating to the aforementioned criteria.

Measures we take to secure your information

We make conscious efforts in taking appropriate technical and organizational measures to secure your data and protect it from any kinds of uncertainties. Our measures include:

  1. sharing and providing access to your information only to the extent necessary in accordance with legal norms and regulations.
  2. Collecting and storing your data on secure servers only.
  3. Authenticating, verifying or in some cases, denying any individual who requests for your information.
  4. The information you give us is always encrypted on SSL (Secure Socket Layers) software.

Sharing the information to us online

Considering the vulnerabilities of the internet, the onus of the repercussions as you share your information via email or by any other means such as; harm to reputation, damages, loss of profits, or liabilities lies completely on you. We cannot in any way be held responsible for the aforementioned uncertainties.

YOUR INFORMATION SHARED OUTSIDE THE EUROPEAN ECONOMIC AREA

Your information will be stored and shared outside the European Economic Area (EEA) under the circumstances given below.If we have to comply with legal obligations that we are subject to, we will also share your information outside the EEA or to an international organisation.

E-Newsletter

Your information obtained when you opt-in to receive our E-Newsletters is shared outside the EEA and is stored on our third party mailing list provider's servers.

Country of storage: India and Ireland. These countries are not subject to an adequacy decision by the European Commission.

Safeguard(s) used: You can see the GDPR Compliance Policy here: https://netcore.in/privacy-policy/ and https://aws.amazon.com/compliance/gdpr-center/

Push Notifications

Your information obtained when you opt-in for push notifications is shared outside the EEA and is stored on our third party mailing list provider's servers.

  • Country of storage: India. This country is not subject to an adequacy decision by the European Commission.
  • Safeguard(s) used: You can see the GDPR Compliance Policy here: https://www.pushengage.com/gdpr

YOUR INFORMATION AND YOUR RIGHTS RELATED TO YOUR INFORMATION

  1. Right to access to your information.
  2. Right request the deletion or updating of your information.
  3. Right to object us from using of your information.
  4. Right to receive information in portable or PDF format and the right to transfer your information to another data controller (including a third party data controller).
  5. Right to question the processing of your information for certain purposes (to know more, refer the section below entitled Your right to object to the processing of your information for certain purposes).
  6. Right to deny us the permission to use of your information at any time when we rely on your consent to use or process that information. However, even if you withdraw your consent, it will not affect the legality of our use and processing of your information on the basis of your consent if you do not withdraw your consent and inform us about the same abruptly.
  7. In accordance with Article 77 of the General Data Protection Regulation, you a have the right to approach a superior authority, in particular in the Member State of your perpetual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
  8. In UK, the supervisory authority is the Information Commissioner's Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Additional information on your rights related your personal data

The rights mentioned above gives only an overview and may be subject to certain limitations. To know more about rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO's website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can read the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation available here :

http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf, to get further information regarding your rights and the limitations that may apply.

Verification of your identity

Once we obtain the information about you, we tend to verify and authenticate the same.

To process a specific information, we may verify your identity in your specific circumstances if and when you make such a request.

Your right to question or object to the processing of your information for certain reasons

Here are the following rights in relation to your information,that you may exercise by writing to us at support@bingoespresso.com

  1. Right to deny us from using or processing your information to carry out a task in the public interest or for our legitimate interests, including ‘profiling'.
  2. Right to deny us from using or processing your information for direct marketing purposes which also includes any profiling we engage in related to direct marketing
  3. You have the right to object to us using or processing your information for direct marketing purposes by either unsubscribing from our e-mail or by unsubscribing to our Push Notifications or both. Details are explained here: https://www.pushengage.com/blog/how-to-unsubscribe-from-chrome-push-notifications-in-3-easy-steps/

Know about the safekeeping of your sensitive personal information

Information about an individuals that gives out their personal details such as; religious or philosophical beliefs, genetic information,racial or ethnic origin, biometric information that helps in identifying an individual, information concerning health or information concerning a natural person's sex life or sexual orientation.

We do not do not sensitive personal information, neither knowingly nor intentionally and we suggest you not to submit your personal information of any kind to us.

In case you willingly or intentionally share your sensitive personal information with us, it is deemed that you have permitted us to process your personal sensitive information Article 9(2)(a) of the General Data Protection Regulation and we will eventually, process your personal sensitive information to delete it.

  1. Right to deny us from using or processing your information to carry out a task in the public interest or for our legitimate interests, including ‘profiling'.
  2. Right to deny us from using or processing your information for direct marketing purposes which also includes any profiling we engage in related to direct marketing
  3. You have the right to object to us using or processing your information for direct marketing purposes by either unsubscribing from our e-mail or by unsubscribing to our Push Notifications or both. Details are explained here: https://www.pushengage.com/blog/how-to-unsubscribe-from-chrome-push-notifications-in-3-easy-steps/

Updating our privacy policy

Our privacy policies are updated and amended regularly.

Negligible changes to privacy policy

Should there be any minor changes to our privacy policy, we will update our privacy policy and give out the date from which the privacy policy will be effective at the beginning of it. The processing of your information will happen in accordance with the practices set out in the new version of privacy policy from the date it comes to effect on.

Notable changes to our Privacy Policy

If any major changes happen in the privacy policy, you will certainly be informed either via e-mail or through a notification on our website.

We will give out detailed information about the change and the reason for such a change before we put your information to use for the new purpose.

If needed, we will request for your permission before using your information for a purpose that is not same as the purpose which we originally collected your information for.

BELOW 18 PRIVACY POLICY

We strictly comply with the Children's Online Privacy Protection Act of 1998 (COPPA). COPPA and its regulations intend to protect the privacy and safeguard the children using the internet. We do not intentionally collect information of individuals below the age of 18. The website does not intend collect any kind of information from individuals who are under the age of 18.

It is, however, possible for us to obtain information from individuals below the age of 18 by way of fraud or pretence of a third party. As soon as we come across this situation, we will take the necessary measures such as; obtaining appropriate parental consent to use that information and/or deleting the information from our servers. We would appreciate if you would like to notify us about the information give out to us by the individuals under the age of us. Please write to us at webmaster@bingoespresso.com regarding the same.

Copyright, credit and logo

This privacy policy is drafted in compliance with the General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) as per the guidelines given in GDPR Privacy Policy.

2018 © Bingo Espresso by AVRA Media Ltd All Rights Reserved. All logos and creatives placed on the website are owned by AVRA Media Ltd.