Privacy policy

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Last updated January 2022

At Bramble, we respect your privacy and are committed to protecting your personal data.

Welcome to Bramble’s privacy policy. In this policy, we explain what personal data we collect and for what purpose, how we look after your personal data, and how you can exercise the legal rights that exist to protect you.

This privacy policy applies to all of the services offered by Bramble. We do not collect any special categories of personal data about you, nor do we collect any information about criminal convictions and offences.

Bramble Technologies Limited of Unit 211, The Lightbox 111 Power Road, London, United Kingdom, W4 5PY (“Bramble”, "we", "us" or "our" in this privacy policy) is the data controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO by email at data@bramble.io.

We are registered with the Information Commissioners’ Office under reference number ZA837668.

Our website may contain links to and from third party websites, portals and applications. If you follow a link to any of these, please note that we do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Information we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We will collect and process the following data about you:

Profile information, such as name, email address, date of birth, profile picture and user ID/room URL;
Account information, such as purchase activity, searches made on myBramble and sessions rewatched on myBramble;
Technical information, such as devices, browsers, IP addresses and operating system; and
Live session information, such as participant names and email addresses, time and date of live sessions, notebook/whiteboard activity, uploaded content, audio and video recordings of live sessions.

We may also collect, use and share aggregated data, such as statistical or demographic data. Aggregated data cannot be used to reveal your identity and is not considered personal data. For example, we may aggregate your usage data (information about how you use our website, products and services) to calculate the percentage of users accessing a specific feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, provide you with Bramble services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case.

We use different methods to collect data from and about you including through:

Things you create or provide to us. When you create a Bramble account, youprovide us with personal information that includes your name and email address. We will use this email address to send you relevant information, which you may opt out of at any time. You can also add payment information to your Bramble account. When you use Bramble for live sessions, you provide us with live session information as described above.
Information we collect automatically. As you interact with our website, we automatically collect technical data about your equipment, browsing actions and patterns such as internet protocol (IP) address, login information, browser type and version, browser plug-in types and versions, operating system and platform; information about your visit, including URLs, clickstream to, through and from our website (including date and time), Bramble usage and purchase history, search terms made, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call us. We collect this personal data by using cookies, server logs and other similar technologies.
Information we receive from other sources. We may receive personal data about you from various third parties such as schools and organisations using Bramble. This data may be subject to our data processing addendum.

Why Bramble collects data

We will only use your data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where you have given your consent.
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) but only where these are not overridden by your own fundamental rights and interests.
Where we need to comply with a legal obligation.

We use the information we collect from all our services for the purposes set out in the table below. We have also identified the lawful bases that we rely on and our legitimate interests where appropriate. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you want to know more about the specific legal grounds we are relying on to process your personal data.

Purpose	Data	Lawful basis
Provide our services We use your information to deliver our services, such as processing the interactions you have on live sessions in order to provide you with a valuable revision resource.	Email address; name; date of birth; profile picture; user ID/room URL; Bramble purchase activity; searches made on myBramble; devices; browsers; IP addresses; operating system; live session participant email addresses; time and date of live sessions; audio of live sessions.	Consent Performance of a contract with you Necessary for our legitimate interests (to provide and maintain innovative products and features that enable users to express themselves, communicate, discover and engage with information relevant to learning and education, and use tools and features that promote learning and education)
Maintain & improve service We use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues that you report to us. We also use your information to make improvements to our services — for example, understanding the location and duration of sessions helps us develop and improve features.	Date of birth; Bramble purchase activity; searches made on myBramble; sessions watched on myBramble; devices; browsers; IP addresses; operating system; time and date of live sessions; audio of live sessions; webcam data from live sessions.	Consent Performance of a contract with you Necessary for our legitimate interests (to maintain the integrity of our services, to understand how customers use our products and services, for running our business, for administration and IT services, for network security)
Develop new services We use the information we collect in existing services to help us develop new ones. For example, understanding how people use the shared whiteboard, will help us design and launch new services.	Date of birth; Bramble purchase activity; searches made on myBramble; sessions watched on myBramble; devices; browsers; IP addresses; operating system; time and date of live sessions; audio of live sessions; webcam data from live sessions.	Consent Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our growth strategy)
For personalised services We use the information we collect to customise our services for you, including providing recommendations, personalised content, and customised search results.	Email address; name; date of birth; profile picture; Bramble purchase activity; searches made on myBramble; sessions watched on myBramble; devices; browsers; IP addresses; operating system; time and date of live sessions; audio of live sessions; webcam data from live sessions.	Consent Necessary for our legitimate interests (to provide and maintain personalised products and features that enable users to express themselves, communicate, discover and engage with information relevant to learning and education, and use personalised tools and features that promote learning and education)
Measure performance We use data for analytics and measurement to understand how our services are used. For example, we analyse data about your visits and interactions to our site to do things like optimise product design.	Date of birth; Bramble purchase activity; searches made on myBramble; sessions watched on myBramble; devices; browsers; IP addresses; operating system; time and date of live sessions; audio of live sessions; webcam data from live sessions.	Consent Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Communicate with you We use the information we collect, like your email address, to interact with you directly. For example, we may let you know about upcoming changes or improvements to our services. And if you contact us, we’ll keep a record of your request in order to help solve any issues you might be facing.	Email address; name; live session participant email addresses.	Consent Performance of a contract with you Necessary for our legitimate interests (to provide non-marketing communications for product or customer service-related issues, to promote our products and services)
Protect Bramble and users We use information to help improve the safety and reliability of our services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Bramble, our users, or the public.	Email address; name; date of birth; profile picture; searches made on myBramble; sessions watched on myBramble; devices; browsers; IP addresses; operating system; live session participant email addresses; time and date of live sessions; audio of live sessions; webcam data from live sessions.	Necessary for our legitimate interests (to prevent and address fraud, unauthorised use of Bramble, violations of our terms of use; to keep Bramble products free of harmful or inappropriate content; to protect Bramble (including our rights, property or products), our users or others, including as part of investigations or regulatory inquiries; and to protect the safety of children, including to prevent exploitation or other harms to which such individuals may be particularly vulnerable) Necessary to comply with a legal obligation
Conduct research activity We use information we collect to conduct research. This research provides insights in to how people teach and learn. It is used to further understanding and develop products.	Date of birth; Bramble purchase activity; searches made on myBramble; sessions watched on myBramble; devices; browsers; IP addresses; operating system; time and date of live sessions; audio of live sessions; webcam data from live sessions.	Consent Necessary for our legitimate interests (to further the state of the art or academic understanding on important issues that impact education in a positive way)

We may use your personal data to form a view on what we think may be of interest to you and provide you with personalised recommendations.

Bramble uses cookies to distinguish you from other users. This helps us to provide you with a positive user experience and allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our cookie policy.

Sharing your information

We may share your personal data for the purposes set out in the table above with the following parties:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Selected third parties including agencies, business partners, suppliers and subcontractors for the performance of any contract we enter into with you; analytics that assist us in the improvement and optimisation of our website;
Specific third parties such as schools and organisations that you study at or work with.
Third parties to whom we may sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may also share your data if we are under a duty to disclose it in order to comply with any legal obligation; in order to enforce or apply our terms of use and other agreements; and to protect the rights, property, or safety of Bramble, our customers, and the public.

Keeping your information secure

All information you provide to us is stored on our secure servers in the UK and Europe. All payment transactions will be encrypted.

We have put in place appropriate security measures to prevent your personal data from being lost, used or accessed in unauthorised ways, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have procedures to deal with personal data breaches and will notify you and applicable regulators of breaches as legally required.

Retaining your information

Your data is retained until you remove it from your Bramble account. We may need to retain some data for longer periods of time when required for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.

When you remove data, we follow a removal process to make sure that your data is safely removed from our servers or retained only in anonymised form. We try to ensure that our services protect information from accidental or malicious removal. Because of this, there may be delays between when you remove something and when copies are removed from our active and backup systems.

Your rights

You have rights under data protection laws in relation to your personal data. Requests to exercise those rights can be made at any time to data@bramble.io.

You can contact us to exercise your right to request access to, update, remove, and restrict the processing of your information. In some circumstances, you also have the right to object to the processing of your information or export your information to another service.

There is no charge to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively we may refuse to comply with such requests.

We may need to request specific information from you to help us confirm your identity. This is a security measure to prevent unauthorised requests. We may also ask for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it can take longer than a month if your request is complex or you have made a number of requests. We will let you know if this is the case.

Changes to this policy

We update our privacy policy from time to time. Any changes we make will be posted on this page and, where appropriate, notified to you by email. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.