Bullitt Satellite Messenger Privacy Notice
The Bullitt Satellite Messenger service (the Service), provided via the Bullitt Satellite Messenger app (the App), is a trading name of Bullitt Group Services Limited (BGSL). BGSL is the Data Controller in respect of personal information used in the connection and use of the Service. If you have any questions or concerns in relation to this Privacy Notice you can contact our Data Protection Officer at dpo@bullitt-group.com or write to us at FAO: The Data Protection Officer, Bullitt Satellite Messenger, One Valpy, Valpy Street, Reading Berkshire RG1 1AR.
At Bullitt Satellite Messenger, we are committed to the operation of fair and transparent processing in relation to the collection and use of personal information. In this Privacy Notice, we explain how we will collect and use your personal information. This Privacy Notice should be read alongside Bullitt Satellite Messenger service and Bullitt Messenger app Terms of Use (the Contract) which can be found at www.bullitt.com/legal/terms-of-use
Summary
What we usually collect | When and how we collect it | Why we collect it, and our main legal basis | How long we will normally hold it for |
Personal Information | When you open an Account, and after that it will be updated for the duration of time you are using our Service. | To identify you and provide our service to you under the Contract. After the Contract has ended we have a Legitimate Interest in retaining the information to improve the Services and protect our business interests. | While your Account is active and for up to 6 years after your Account has been closed. We may keep information for longer where necessary in connection with our right to establish, commence or defend any Legal actions, or are subject to a mandatory request from a law enforcement agency. |
Usage information | We collect this while you are using any of the Services available via the App. | We have a Legitimate Interest in collecting this information to manage, improve, and provide our Services to you. | While your account is active and for up to 6 years after your account has been closed. We may keep information for longer where necessary in connection with our right to establish, commence or defend any Legal actions, or are subject to a mandatory request from a law enforcement agency. |
Message content data | We collect, but do not have routine access to, content of messages sent and received when using the App. | Message content data is retained and processed for a very limited time only to ensure that a message has been sent and received. Message content may be reviewed in circumstances where the SOS Services are being used. For those purposes, we need to do this in order to perform our obligations under the Contract. In some jurisdictions, we may be subject to a Legal obligation to share message content with law enforcement agencies, | For a very limited time to ensure adequate opportunity for a message to be sent or received and whilst the SOS Services are being performed. This may be extended for as long as is necessary when we are subject to a Legal obligation to retain the data. |
Location data | This data may be collected when you use the SOS Service, when you use the Tracking Service, or when you elect to share your location via the messenger Services we provide. | Processing of this data is essential for delivering these Services in accordance with the terms of the Contract we have entered into with you. In some jurisdictions, we may be subject to a Legal obligation to share location data with law enforcement agencies, | For a limited time after the requirements under the Contract have been performed. This may be extended for as long as is necessary when we are subject to a Legal obligation to retain the data. |
Appropriate detail on a physical or mental condition you have told us about | We collect this when you notify us of such a condition. | We will seek your Consent to enable us to supply additional services that may assist with your condition if you are a vulnerable customer or because there is a medical condition relevant to provision of the Services (including the SOS Services). | While your account is active or when you tell us you wish to withdraw Consent (whichever occurs first). |
Financial and billing information | When you request to become a subscriber to a paid-for Service, and after that the information will be updated for the duration of time you are using the paid-for Service. | To monitor, process and record your payments under the Contract. After your contract with us has, ended we have a Legitimate Interest in retaining the information to improve the services and protect our business interests. | While your account is active, and for up to 6 years after your account has been closed. We may keep information for longer where necessary in connection with our right to establish, commence or defend any Legal actions. |
We rely on different legal bases to process your personal information. In the section below, we have set out what each of these mean, to help you to understand the different legal bases when you see them written in bold throughout this Privacy Notice.
Consent – you have given us your express consent to process your personal information (usually by voluntarily providing the information to us), you can withdraw your consent at any time.
Contract – we are processing your personal information in order to carry out our contractual obligations under the Contract.
Legal – we are processing your personal information in order to comply with any regulatory government or legal requirements.
Legitimate Interest – we have a legitimate business interest in processing your personal information, this may include, fraud prevention, protection of our business, managing and improving the Services.
What information we may collect and how we use it
Keeping in touch with you
How we look after your information
Your rights
Therefore, if you are in the EEA or the UK:
Changes to the Privacy Information Notice
Users of the Service in the EEA (GDPR compliance)
Linked service providers
Digital River: [URL]
Focuspoint International: https://www.focuspointintl.com/privacy-policy/#:~:text=We%20do%20not%20sell%2C%20lease,as%20required%20by%20applicable%20law.