Access to Personal Information
Bling UniverCity provides Customers and Employees with reasonable access to the Personal Information maintained about them. We also provide a reasonable opportunity, as required by applicable law, to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances or as otherwise permitted by the Safe Harbor principles. To obtain access to Personal Information, Customers may contact Bling UniverCity as specified in the “How to Contact Us” section of this Policy. Employees should submit requests for access to their Personal Information to their local Human Resources representative.
Bling UniverCity maintains reasonable administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Bling UniverCity takes reasonable steps to ensure that Personal Information the company collects is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current. We depend on our Customers and Employees to update and correct their Personal Information whenever necessary.
Enforcement and Oversight
Bling UniverCity has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. We conduct an annual self-assessment of our practices with respect to Personal Information to verify that representations we make about our Personal Information privacy practices are true and that related privacy policies have been implemented as represented.
Customers and Employees may file a complaint with Bling UniverCity in connection with the processing of their Personal Information under the Safe Harbor principles. We will also cooperate with the following dispute resolution bodies to address individual’s complaints regarding privacy issues: (i) for Customer complaints, we cooperate with the American Arbitration Association in accordance with its applicable commercial rules; (ii) for complaints concerning our handling of Employee Personal Information, we cooperate with the relevant EU data protection authorities. We will take steps to remedy any issues arising out of a failure to comply with the Safe Harbor principles. Please contact us as specified below to address any complaints regarding our Personal Information practices.
Any complaints or disputes by EU citizens about privacy that cannot be resolved directly with Bling Univercity, will be resolved through the EU Safe Harbor Dispute Resolution Procedure by the American Arbitration Association at 1633 Broadway, 10th Floor, New York, NY 10019-6708.
For more information about Safe Harbor, please visit: www.export.gov/safeharbor
Bling UniverCity’s mobile app was built on top of functionality referenced as Gimbal. In using the app, you agree to Gimbal collecting, using and storing information as described below.
End-user Location fixes – latitude / longitude coordinates, accuracy estimate and time stamp. Sourced from native OS location APIs. Location collection occurs periodically, based on significant location change events as reported by the native OS.
Information about the end-user device (e.g., make, model, OS, and other similar information). But not phone number or UDID. The version of the Gimbal software.
Information that end-users may enter in Bling UniverCity’s app that is passed to Gimbal. Such as designating a private place (e.g., “my favorite store”).
Gimbal monitors end-user location to create place events (“at” or “left”). These events are used to notify Bling UniverCity’s app when the end-user has arrived at or left places designated (based on user preference.) Gimbal generates a list of the location clusters (identified by lat/longs) that the end-user visits frequently.
Location fixes that do not generate place events are not stored. The single location fix that does generate a place event is stored on the client, along with the corresponding place event. The set of generated PPOIs are stored on the client.
Place events and the location fix that caused the event are stored on the Gimbal servers. The set of generated PPOIs are stored on Gimbal servers. Gimbal Servers are located in the United States. All data transmission is sent encrypted via SSL.
Gimbal stores information on the client for up to sixty days, at which point it is overwritten on a rolling basis. Gimbal stores information on Gimbal managed servers for up to one year, at which point it is overwritten on a rolling basis.
We do not share personal information with others, except as follows:
We may share personal information with agents, service providers, vendors, contractors, or affiliates who (i) are bound to data privacy and security terms and conditions at least as restrictive as those in the Agreement and (ii) process the data only on our behalf for the purposes set forth above. We may also share personal information as required by law or in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer personal information in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business.
How to Contact Us
Writing to: Bling UniverCity
Attention: Privacy Officer