Bullitt Mobile Limited designs, manufactures, markets and sells mobile devices under license from global brands. Bullitt Mobile Limited and our subsidiaries (“Bullitt”, “we”, “us”, “our”) know how important privacy is to our customers and end-users and we strive to be clear about how we collect, store and share your information with others through you using the kodakphones.com website (“Website”).
We gather and use certain information about individuals in order to provide products and services and to enable certain functions on this Website. We also collect information to better understand how visitors use this website and to present timely, relevant information for them.
This policy is updated from time to time. The latest version is published on this page.
This policy was updated on 8 May 2018
If you have any questions about the policy, please email firstname.lastname@example.org or write to: Data Protection Officer, Bullitt Mobile Limited, One Valpy, Valpy Street. Reading RG1 1AR.
* What information we collect
* How we use the information we collect
* The legal basis for processing your information
* Cookies and how we use them
* To whom we disclose your information
* How we keep your information secure
* How long we hold your information
* Your rights relating to your information
* Compliance and cooperation with regulatory authorities
*Links from our sites
- WHAT INFORMATION WE COLLECT
We may collect information to provide better services to all of our customers and end users. We may collect the following information:
- Your name and job title
- Your contact information including email address
- Demographic information, such as postcode, preferences and interests
- Website usage data
- Information relevant to client enquiries
- Information pertaining to special offers and surveys
- Email usage data
- Customer Enquiries data
- Webstore order data (in markets where we operate a webstore)
We collect information in the following ways:
Information you give us: Some services enable you to give us information directly. For example, a number of our services enable users to create accounts or profiles. In connection with these services, we may ask you to provide certain information about yourself to set up the account or profile.
Information we get from your use of our services: In addition to the information you provide us, we may collect information about the services that you use and how you use them. This information may be collected automatically through software on your device and other means. This information includes:
Device information: We may collect device specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number, IMEI number, IP Address).
Log information: When you use our services or view content, we may collect and store certain information in server logs. This includes: details of how you used our service, such as your search queries, any information stored in cookies.
Location information: When you use our services, we may collect, store and process anonymous information about your device’s location. Data can be collected by using various technologies to determine location, including IP address, GPS and other sensors that may, for example, provide Bullitt with information on nearby devices, Wi-Fi access points and mobile towers.
Unique application numbers: Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to a server when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
Local storage: Data may be collected and stored locally on your device (including personal information) using mechanisms such as browser web storage (including HTML 5) and application data caches.
Cookies and similar technologies: We use various technologies to collect and store information when you visit our Website for any service, and this may include using cookies or similar technologies to identify your browser or device.
Information we receive from other sources: We may receive information about you if you use any of the other services we provide. We are working closely with third parties (including, for example, business partners, payment and delivery services, advertising networks, search information providers) and may receive information about you from them.
Email information: when you register to receive marketing communications emails about news, offers and updates we will collect and store information about marketing permission, your email preferences and email usage including open and click activity. Your email preference information can be viewed by looking at MyPreferences which is in the footer of each marketing communications email.
Webstore order data: Your previous transactional history, including purchase data, voucher codes used, and shipping delivery information. For more information on Webstore visit Store Terms of Service
Customer Service data: Customer service ticket history, information about open Customer Support tickets, device information and contact preferences.
Any information we receive will only be provided if you have agreed with third parties that your data can be shared.
- HOW WE USE THE INFORMATION THAT WE COLLECT
Collecting this data helps us understand what you are looking for from us, enabling us to deliver improved products and services, and to make our marketing communications more relevant. Specifically, we may use the information we collect for a number of purposes.
INFORMATION YOU GIVE US:
- to register you or your device for a service;
- to provide a service or feature that you request, including to enable us to fulfil our obligations under any contract with you;
- to carry out obligations arising from any contract entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
- to notify you about changes to our service;
- to ensure that content from our Website is presented in the most effective manner for you and for your computer.
INFORMATION WE GET FROM YOUR USE OF OUR SERVICES:
- to provide customised content and make recommendations based on your past activities on our services;
- for advertising, such as providing customised advertisements and sponsored content and sending you promotional communications;
- for assessment and analysis of our market, customers, products, and services;
- to understand the way people, use our services so that we can improve them and develop new products and services;
- to provide maintenance services for your device;
- for the prevention or detection of fraud or crime;
- for business monitoring and internal record keeping;
- to conduct free prize draws, prize competitions or promotions, as permitted by law;
- to administer our Website and for internal operations such as troubleshooting, data analysis, research, statistical and survey purposes;
- to ensure that content from our Website is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service;
- to help keep our Website safe and secure;
- to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them;
- to comply with our legal obligations; and otherwise with your consent.
Information we receive from other sources:
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above.
- The legal basis for processing your information
Under GDPR, the main grounds that we rely upon in order to process your Information are the following:
- a) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your Information. We may also be obliged by law to disclose your Information to a regulatory body or law enforcement agency;
- b) Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your Information for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your Information protected. Our legitimate interests include responding to requests and enquiries from you or a third party, fulfilling sales, optimising our website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
- c) Consent – in some circumstances, we may ask for your consent to process your Information in a particular way
- Cookies and how we use them
What are Cookies
Cookies are small data files sent by the Website server to a web browser, processor memory or hard drive of your computer or mobile device and stored there. They can be used for a range of different purposes, such as customising a website, helping you navigate a website, improving your website experience, and storing that user’s preferences and login information.
- Analyse our web traffic using analytics package. Aggregated usage data helps us improve the Website, structure, design, content and function.
- Identify whether you are signed in to our Website. A cookie allows us to check whether you are signed in to the Website.
- Test content on our website. To ensure our users have a consistent experience on our Website.
- Store information about your preferences. The Website can then present you with information you will find more relevant and interesting.
- To recognise when you return to our Website. We may show you relevant content, or provide functionality you used previously.
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
Please note, however, that some services may be designed to work using cookies and that disabling cookies may affect your ability to use those services, or certain parts of them.
- TO WHOM DO WE DISCLOSE YOUR INFORMATION
We will not disclose your information to third parties for their own independent marketing or business purposes without your consent. However, we may disclose your information to the following entities:
Business partners and service providers: We may also share your information with trusted business partners and service providers, including wireless carriers. These entities may use your information to provide you with services you request and services provided as part of the device (such as preinstalled applications and software updates). Your information may also be used to make predictions about your interests and may also be used to provide you with promotional materials, advertisements and other materials that we feel may interest you. We may also disclose your information to trusted partners that provide services for or on behalf of us, such as companies that help us with sales and distribution, billing or that send emails on our behalf. These entities are not permitted to use your information for purposes other than providing services for us.
Advertisers and advertising networks: We may share your information with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We may also share your information with analytics and search engine providers that assist us in the improvement and optimisation of our Website.
Other parties when required by law or as necessary to protect our services: There may be instances when we disclose your information to other parties:
to comply with the law or respond to compulsory legal process (such as a search warrant or other court order);
to verify or enforce compliance with the policies governing our services; and
to protect the rights, property, or safety of Bullitt, or any of our respective subsidiaries, business partners, or customers.
Other parties in connection with corporate transactions: We may disclose your information to a third party as part of a merger or transfer, in the event that we sell or buy any assets, or in the event of a bankruptcy.
Your Choices: When you fill in a form or provide your details on our Website, you will see one or more tick boxes allowing you to:
- Opt-in to receive marketing communications from us by email, telephone, text message or post.
- Opt-in to receive marketing communications from our third party partners by email, telephone, text message or post.
- Opt-in to receive information about new products relating to your customer service enquiry
If you have agreed that we can use your information for marketing purposes, you can change your mind easily, via one of these methods:
- Sign in to our Website and change your opt-in setting.
- Send an email to email@example.com
- Write to us at Bullitt Mobile Limited, One Valpy, Valpy Street, Reading RG1 1AR
- Unsubscribe by clicking on the Unsubscribe link in the footer of marketing communication emails.
- Verbally requesting to be unsubscribed to a customer service agent
We will never distribute or sell your personal information to third parties unless we have your permission or the law requires us to.
Any personal information we hold about you is stored and process our data protection policy, in line with the General Data Protection Regulation.
- HOW WE KEEP YOUR INFORMATION SECURE
We have put in place reasonable physical and technical measures to safeguard the information we collect in connection with the services. However, please note that although we take reasonable steps to protect your information and use strict procedures and security features to try to prevent unauthorised access, no website, Internet transmission, computer system or wireless connection is completely secure.
INTERNATIONAL TRANSFER OF DATA
The data that we collect from you may be transferred to, stored at or otherwise processed in a destination outside the European Economic Area (“EEA”)
ACCESSING YOUR INFORMATION
You have the right to request details of Personal Data which we hold about you. We will comply with your request promptly and by no later than 14 days from receipt of any such request. If you would like to make any such request please write to us and send your request at our registered office to DPO, Bullitt Mobile Limited, One Valpy, Valpy Street, Reading, RG1 1AR, UK.
Please help us to ensure that the information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please write to us in the manner set out above. We will correct or update any information about you as soon as reasonably possible.
THIRD-PARTY LINKS AND PRODUCTS ON OUR SERVICES
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third parties for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms that we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution, and review the privacy statements applicable to the third-party websites and services you use. We may also make available to you certain products or services (such as software applications available on cellular phones) developed by third parties. Bullitt is not responsible for third-party products or services. Some of the content, advertising, and functionality on our services may be provided by third parties that are not affiliated with us.
- How long we hold your information
We will only retain your Information for as long as is necessary for the purpose or purposes for which we have collected it. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept. In certain circumstances, once we have deleted or anonymised your data, we may need to retain parts of it (for example, your email address), in order to comply with our obligations under GDPR or other legislation, or for fraud detection purposes.
- Your rights relating to your information.
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
- a) Right of Access. You have the right at any time to ask us for a copy of the Information about you that we hold, and to confirm the nature of the Information and how it is used. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
- b) Right of Correction or Completion. If Information we hold about you is not accurate, or is out of date or incomplete, and requires amendment or correction you have a right to have the data rectified, updated or completed. You can let us know by contacting us at the address or email address set out above.
- c) Right of Erasure. In certain circumstances, you have the right to request that Information we hold about you is erased e.g. if the Information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based on your consent and there are no other legal grounds on which we may process the Information.
- d) Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your Information by contacting us at the address or email address set out above. For example, if we are processing your Information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your Information for direct marketing purposes.
You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.
- e) Right of Data Portability. In certain instances, you have a right to receive any Information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that Information to you or directly to a third party organisation.
This right exists in respect of Information that:
- you have provided to us previously; and
- is processed by us using automated means.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to Information of others without their consent.
You can exercise any of the above rights by contacting us at the address or email address set out above. You can exercise your rights free of charge.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
- COMPLIANCE AND COOPERATION WITH REGULATORY AUTHORITIES