We take your privacy and data security very seriously. Our commitment to you in short is:
- We will process all your data and information with industry-leading security tools so it is safe.
- We will not sell or give away your information for any reason.
- We will only use your data for the purposes you give us permission to.
What information we collect about you
Account and Profile Information:
Bulb asks for and collects information necessary to perform the functions of the application. We collect username, email address and password for authentication and customer care purposes, and we collect name and address for payment purposes. You also have the option of uploading a photo and writing a description for your profile.
Content you provide:
You have the ability to post content to your bulb profile including any personal information you choose to share. You have the ability to set your privacy settings for any and all content you upload, including images, audio, video, documents and links.
Information provided to support:
bulb provides a ticketing system through Zendesk to provide customer support. Your email address may be collected. You may also provide details about your support issue and may be asked by our personnel to provide contact information to resolve your concern.
We collect payment information to provide our higher level of account access including Name, address and credit card information. The payment information is collected through our secure payment processing service (Stripe) which is PCI, and GDPR compliant.
Personally Identifiable Information:
Common forms of personally identifiable information include the student’s name, the name of the student’s parent or other family members, the address of the student or student’s family, a personal identifier, such as the student’s social security number, student number, or biometric record, or other indirect identifiers, such as the student’s date of birth, place of birth, and mother’s maiden name. (Source: US Dept. of Education)
bulb collects some data that is considered personally identifiable, including your name and email address, and in some cases a student ID as provided by a school district or organization. We also collect indirectly identifiable information such as school name, teacher name, and class information as provided by the school district or organization. Any personally identifiable information is collected to directly provide bulb’s service to you.
Information we automatically collect
We collect information about your device and internet connection including device type, screen size, browser and operating system. We collect these through our analytics service in aggregate to evaluate how our service is being used. We also collect general location information through your IP address to approximate your location to provide services.
Cookies and tracking software:
Our public website (before login) may collect information to promote bulb to teachers and administrators. Cookies are used for login and session data. We do not use trackers other than basic site analytics in our app to assess usage and performance of the website. We may also collect general location information for geographical purposes, but we don’t track in a way that would allow us to identify a street address.
Information we receive from other sources
Third party services linked to your account:
We receive information from third party sources that you or your administrator make available to us. For example, if you are using Google or Microsoft to sign in to your account, we are provided basic info like your name and email address as permitted by your Google or Microsoft account settings.
How we use the information we collect
To provide bulb Services to you:
We use the information you provide to authenticate you, to personalize your bulb account, to provide customer support and to process operations for you. We provide you access to bulb features and functionality based on your account status, and provide appropriate interactions with other bulb users based on your preferences or administrator settings.
For Analytics and Usage purposes:
We gather certain information to use to understand how account holders interact with the Service. In some cases, we make decisions about new features or improvements to make to bulb based on usage patterns of account holders.
We use the contact information we gather from you or from linked services to process customer support requests, account-related information, or to communicate about changes and updates to the Service. For example we send out email notifications to you regarding account renewals and payments processed. Depending on your settings, you may receive notifications in app or via email for activities that occur in your account.
For customer support:
We use information you provide to help resolve your support requests, analyze data logs, and to improve your interaction with the Service.
For safety and security:
We use your information to verify your account, detect any areas of suspected fraudulent activity or examine violations of our policies.
For protecting our legitimate business interests and rights:
Where required by law, or as necessary to protect our rights and the rights of others, we may use information about you in connection with legal directives, compliance issues, audits or requests by law enforcement.
For promotional purposes:
With your consent, we may include information about you in testimonials, features and promotions of bulb on our site and in social media.
Our Lawful Basis for Processing Data
If you are a person in the European Economic Area (EEA), we collect and process information only where we have a legal basis to do so.
- Consent: We only use information under your consent to provide you with access to the Service, to provide functionality to perform tasks, to provide customer support, and to process account and payment information.
- Under Contract: If your organization has entered into a contract with bulb to provide you with the Service, we will use the information that they provide for the same functions listed above. This may include a pre-contractual agreement to provide demo or test accounts.
- Legal Obligation: If we need to process your information to satisfy legal requests.
If you have given your consent for us to process your data, you can change your mind at any time by contacting us at firstname.lastname@example.org. If your organization (for example, your school) provided a legitimate interest for us to process your data, you have the right to object to that use, however that may mean you will lose access to the Service.
How we share information we collect
Bulb is a digital portfolio, and by nature, information in the portfolio is meant to be shared. We share the information about you and what you provide in the following ways. We do not share information about you in any way related to advertising through third parties.
Sharing with other service users
Collaborators and user interaction:
The content you create can be shared with other service users to whom you give permission (within limits an administrator may set). This information may include your profile information, content on your pages and comments shared with other service users. For example, in a group you may have the ability to share comments with other users, and your display name and profile image will be shown in that context. Keep in mind that pages you make publicly available may be indexed by search engines and made available in search results.
Sharing with Third Parties
bulb works with third-party service providers to provide website and application development, hosting, backup, storage, maintenance, payment processing, image and video processing, authentication, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures consistent with our policies designed to protect your information.
Links to third-party sites:
We allow you to share your public portfolio pages through third-party sites who may then have access to content you permit. For example, you may use our social shaaring tools (if allowed by your administrator) to publish pages to Facebook, Twitter, Google+ or LinkedIn. The content you share to those sites are subject to the privacy policies of the site you share to.
From time to time, we may share your content, only with your prior permission, for purposes of providing testimonials and use cases of our services.
Law Enforcement and Enforcement of our rights:
We may transfer any information collected during a sale, merger or acquisition of our services, and will do so in a way consistent with our principles protecting your privacy. In that event, we will contact you by email or make announcements through the service to inform you of the process, and what options and rights you have, including your right to not send information forward.
How we store information we collect
Storage and Security:
Bulb is constructed to keep your data secure. We take every measure possible to ensure that your data is secure at all points of transfer and storage in our system. We use data hosting systems based in the U.S. to store data. Any transfers of data from outside the U.S. are handled according to our Services’ usage of data storage providers. Although it is impossible to ensure 100% security of data due to the complexity of the internet, we employ the best safeguards available to us to prevent compromise. In the very unlikely event that data is compromised, we will respond to the appropriate authorities in a timely way to inform you and resolve any associated issues.
How long we keep data:
Your Rights Regarding Access and Control of Your Information
You have the right to confirmation whether we process your personal data and, where we do, access to the personal data, together with details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Our Services give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account and search for content containing information about you using key word searches. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content. Providing the rights and security of others are not affected, we will provide you a copy of your personal data within 30 days of your request. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. To request this information, please contact us at email@example.com.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. We will retain personal information that we store and process on behalf of our subscribers for as long as needed to provide the Services to our subscribers. We will retain and use this personal information as necessary as long as you are a subscriber, to comply with our legal obligations, resolve disputes, and enforce our agreements.
You have the right to the erasure of your personal data in a timely manner. The circumstances for erasure include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for exercising rights in legal claims.
You have the right to restrict the processing of your personal data in some circumstances. For example, if you contest the accuracy of the personal data, or you believe processing is unlawful but you oppose erasure.
You have the right to object to processing of your personal data. If you make an objection, we will stop processing the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data. We do not use any data for direct marketing purposes (including profiling for direct marketing purposes). If you make an objection, we will cease to process your personal data for any purpose.
You have the right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance. Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create in your portfolio.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time, however it will not affect the processing that has already taken place.
You may exercise any of your rights in relation to your personal data by contacting us at firstname.lastname@example.org.
Children’s Personal Information
Bulb only processes information for children under the age of 13 when we have verified parental consent or when an organization acting as an agent on behalf of a parent provides consent. For example, a school will provide student information as part of a contract where they have received parental consent. If you have reason to believe that we have obtained student information for someone under the age of 13 without proper consent, please contact us at email@example.com and we will rectify the situation in a reasonable manner.
Certain personal data, such as Student personal data provided to us by an Organization, is subject to FERPA. We comply with requirements imposed on service providers by FERPA when processing such personal data at the instruction of an Organization. To see the requirements imposed on service providers, please review Responsibilities of Third-Party Service Providers under FERPA.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by bulb to a third party for the third party’s direct marketing purposes. To make such a request, please contact us as indicated below.
400 E. Simpson St. Suite 230
Lafayette, CO. 80026
Effective Date: Sep 2019 (clarified what personally identifiable information is collected.)