1. Introduction

1.1. Blipply AB (“Blipply”, “we”, “us” or “our”) values how the information and data you provide to us is collected, used and shared. Blipply is a data controller for the purposes of this Privacy Policy (“Policy”). This means that we determine what we do with the information we collect from you and how we look after it. Blipply is dedicated to respecting and protecting your privacy in compliance with the applicable laws, regulations and obligations on data use and privacy.

1.2. This Privacy Policy describes what information we may collect about you; how we use and share your information; how we protect it; and what choices you have about how that information is used and shared.

2. Scope of Application

2.1. This Policy applies to the processing of personal information of all employees, suppliers, customers, job applicants, former employees, partners, consultants, and all other third parties.

2.2. As used in this Policy, ‘Personal Data’ includes information that can be used to identify a natural individual.

2.3. For employees, this Policy will form part of your contract of employment and should be read together with the contract. For non-employees, this Policy will form part of the terms and conditions of your engagement or appointment or partnership or otherwise.

3. Who is responsible for this Policy?

3.1. Blipply and its affiliated entities are responsible for the processing of your Personal Data as described in this Privacy Policy.

4. Collection of Personal Data

4.1. Blipply may collect and use the following types of Personal Data about you:

4.1.1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. Information contained in identification documents such as passport or national identification card. Academic and professional qualifications, skills, experience and employment history, including start and end dates, with previous employers and with Blipply.

4.1.2. Contact Details includes physical address, email address and telephone numbers.

4.1.3. Financial Data includes bank account and payment card details. Payment and remuneration details such as pay slips, and other income earning information, such as payment summaries from your employer, statements from banks and financial institutions, employment termination payment summaries, receipts for work-related expenses, entitlement to benefits such as medical, pensions and/or insurance cover.

4.1.4. Sensitive Personal Data such as information relating to your health condition, race, ethnic region, religion, sexual orientation or gender for purposes of ensuring diversity and equality of employment opportunities;

4.1.5. Information collected from the use of Blipply’s apps, equipment or your personal equipment, (where you have given us access).

4.1.6. Government-issued identification numbers such as personal identification number (PIN).

4.1.7. Criminal record data and checks.

4.2. We may obtain your Personal Data either directly from you or someone else (such as a credit reference agency, former employer, or reference) or it could be created by us. It could be provided or created during your engagement or appointment for suppliers, customers, partners and third- parties; or during the recruitment process or the course of your employment or even after your termination for employees.

4.3. You might be required to provide Personal Data relating to other individuals to us about your spouse, dependents or other family members for insurance purposes or as part of your emergency contacts list. This is particularly relevant to employees.

4.4. Blipply may collect and process sensitive personal data about you as part of financial application obligations and for the following reasons:

4.4.1. For purposes of ensuring diversity and equality of financial opportunities;

4.5. Where we do collect and process such sensitive personal data, Blipply has adopted appropriate technical safeguards such as encrypted traffic, firewalls, anti – virus software, encryption, multi factor authentication, demilitarised zones (DMZ) and access controlsto protect your sensitive personal data.

5. Processing of your Personal Data

5.1. We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we will use your Personal Data. Please contact us if you require details about the specific legal grounds we are relying on to process your Personal Data where more than one ground has been set out in the table below.

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

5.2.1. Where we need to perform the contract we are about to enter into or have entered into with you.

5.2.2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

5.2.3. Where we need to comply with a legal obligation.

5.3. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

6. Your Rights as a Data Subject

6.1. You may exercise the rights of a data subject available to you under the applicable laws, regulations and obligations on data use and privacyin relation to your Personal Data. This includes the right to:

6.1.1. Be informed of the use of your Personal Data;

6.1.2. Success your Personal Data held by Blipply;

6.1.3. Object to processing of part of or all your Personal Data;

6.1.4. Request for the erasure of your Personal Data;

6.1.5. Request for the correction of your Personal Data where it is incomplete, inaccurate or outdated;

6.1.6. Request the restriction of processing of your Personal Data;

6.1.7. Withdraw your consent where the processing of your Personal Data is based on consent.

6.2. If you wish to exercise any of the rights set out above, please contact Blipply or Blipply’s Data Protection Officer.

6.3. To realise any of the above requests, we may need to request specific information from you to help us confirm your identity as a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it.

6.4. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights set out above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances and we will notify you of the reasons for declining to comply with your requests.

7. Retention of your Personal Data

7.1. Blipply will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for collection including for the purposes of satisfying any legal, regulatory, tax, application, accounting or reporting requirements.

7.2. Blipply may retain your personal data for a longer period if:-

7.2.1. It is required or authorised by law;

7.2.2. It is reasonably necessary for a lawful purpose including instance where you have lodged a complaint or if Blipply reasonably believes that there is a prospect of litigation in respect to our relationship with you;

7.2.3. And authorised or consented by you.

7.3. After the expiry of the applicable retention period, we will delete, erase, anonymise or pseudonymise any information we hold about you.

8. Disclosure of your Personal Data

8.1. We may share and disclose your Personal Data in accordance with applicable data protection laws with:-

8.1.1. Third parties where this supports the administration of your engagement and/or financial application;

8.1.2. Emergency service providers where an emergency arises and it is necessary for your rescue, health and safety including your approximate location; and

8.1.3. Law-enforcement agencies, regulatory authorities, courts or other public authorities in response to a demand issued with the appropriate lawful mandate and where the form and scope of the demand is compliant with the law.

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

9. International Transfers

9.1. From time to time Blipply may transfer your Personal Data to other jurisdictions . In the event of such a transfer, we will ensure that this is done in accordance with the applicable data protection laws including on the basis of contractual measures or other legal transfer mechanisms permitted under the applicable data protection laws. We shall ensure that appropriate safeguards or adequate measures are in place prior to the transfer of your Personal Data.

9.2. Please contact us if you require more information on the specific mechanism used by Blipply when transferring your Personal Data to other jurisdictions.

10. Data Security

10.1. Blipply takes your privacy seriously and has therefore put in place processes, policies, security controls, tools and other adequate technical and operational measures to protect your Personal Data from accidental or unlawful destruction, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

10.2. Where Blipply engages third parties to process Personal Data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of the data.

11. Complaints

If you have any complaints or queries in connection with this Privacy Policy or our Personal Data handling practices, please contact support@blipply.com.

12. Breach of this Policy

12.1. If you are aware of potential security incident or breach of Personal Data, please report it to support@blipply.com.

13. Amendments to this Policy

13.1. Blipply reserves the right to amend or modify this Policy at any time. In the event Blipply amends this Policy, Blipply will provide appropriate notice to you and avail an updated copy of the Policy.

13.2. This Policy was last updated on 25 september 2024.