Website Privacy Notice

Summary of key points

• Visit statistics. On the home page and the pages for specialists we count visits with PostHog; the data is stored in the EU, in Frankfurt. Without your consent the script stores nothing in your browser, and visitors are told apart only by a hash that changes every day. If your device's time zone is in the EU or the EEA, we count nothing without your consent. Learn more.
• Session recording happens only on the pages for specialists and only after you choose 'Дозволити' (Allow). Form fields and your contact details are hidden in recordings.
• Your choice. 'Ні, дякую' (No, thanks) keeps only counting without cookies; 'Не рахувати мене взагалі' (Don't count me at all) turns statistics off completely. You can change your choice at any time: 'Налаштування статистики' (statistics settings) at the bottom of the home page or 'Статистика' (statistics) at the bottom of the pages for specialists.
• An enquiry is used to reply to you. We do not combine statistics or recordings with enquiries, contacts or accounts. Learn more.
• Work contacts. We collect work contact details that centres and specialists have published for clients themselves, in order to offer them Bulbee. Write to us and we will not contact you again. Learn more.
• We do not sell data, show advertising or use advertising pixels.

Table of contents

1. What information we process
2. Visit statistics and session recording
3. Enquiries from specialists and centres
4. Work contacts from public sources
5. Legal bases
6. Who receives the information
7. International transfers
8. How long we keep the information
9. Your rights
10. Children
11. Changes to this Notice
12. How to contact us

1. What information we process

• Visit statistics for the home page and the pages for specialists and, with your consent, session recordings on the pages for specialists (section 2).
• Enquiries from the 'Мені цікаво' form (section 3).
• Work contacts of centres and specialists from public sources, and the history of our contact with them (section 4).
• Letters you write to us and our replies.

The pages of our notices, Terms, account deletion and 'Питання й підтримка' (questions and support) have no scripts and store nothing in your browser. Our server keeps no log of visits with IP addresses.

2. Visit statistics and session recording

Statistics show how many people visit the website, where they come from, which sections they view and where they stop. This is how we make the pages clearer. We use PostHog for this. The PostHog script and the data go through our own server, at https://bulbee.org/ingest. The server passes them to PostHog without the cookies of bulbee.org and keeps nothing of them.

Without your consent

If you have not answered the question about recording or chose 'Ні, дякую' (No, thanks), the script stores nothing in your browser: no cookie and no identifier. It sends:

• the address and title of the page, the page you came from, and campaign tags in the address (utm);
• the device type, operating system, browser and its version, screen and window size, browser language and time zone;
• page views, scroll depth, clicks on buttons and links together with their text, the positions of clicks and scrolling for heatmaps, the sections of the page you reached, and the mere fact that an enquiry was sent, without its content.

To count visitors, PostHog computes on its server a hash of the IP address, the browser details, the website address and a secret value that changes every day and is then deleted. This hash tells visitors apart only within one day: the next day we cannot recognise you, and the IP address cannot be recovered from the hash. PostHog does not store IP addresses or derive a location from them.

EU and EEA. If your device's time zone is in an EU or EEA country, or your browser does not show it, the PostHog script does not load and sends nothing without your consent.

If you chose 'Дозволити' (Allow)

• PostHog stores a random identifier and the session state in your browser (localStorage). This is how we see repeat visits. It sets no cookies.
• On the pages for specialists PostHog records the session: what was displayed on the page, mouse movements, clicks, taps, scrolling and window size. Form fields, the text you type and the contact details shown after an enquiry is sent are hidden in the recording. The recording does not capture sound, the camera, other tabs or other apps. The home page is never recorded.
• Before discarding the IP address, PostHog may derive an approximate location from it: country, region and city.

'Не рахувати мене взагалі' (Don't count me at all) and browser signals

If you chose 'Не рахувати мене взагалі', the PostHog script does not load and sends nothing. We do the same if your browser sends a Global Privacy Control or Do Not Track signal, until you choose 'Дозволити' yourself.

Your choice

Your choice and its date are kept in your browser (localStorage, the entry bulbee-stats). Twelve months after you consent we will ask again. You can change your choice at any time: 'Налаштування статистики' at the bottom of the home page or 'Статистика' at the bottom of the pages for specialists. If you withdraw consent, recording stops and the PostHog identifier is removed from your browser. Clearing the website's data in your browser also resets your choice.

What we do not do

We do not combine statistics or recordings with your enquiry, work contacts or app account, and we do not use them to make decisions about an individual. There is no advertising and there are no advertising pixels on the website. The old web account on bulbee.org no longer loads the Meta pixel or Google Analytics.

3. Enquiries from specialists and centres

In the 'Мені цікаво' form you leave an email address or a phone number (one is enough) and, if you wish, your name, the name of your centre or organisation and the type of your practice. We keep them together with the date of the enquiry, its status and the team's notes.

• Why: to reply to your request and discuss how Bulbee can help in your work.
• Who sees it: Bulbee administrators only. The team receives an email about a new enquiry with a link to it, without your contact details.
• IP address: not stored. To protect the form from spam, the server keeps for up to a day a marker computed from the IP address and a secret key.
• Work contacts: if your email address is already among the work contacts (section 4), we see the enquiry next to that card.
• How long: until the conversation is completed and 12 months after that. To delete an enquiry sooner, write to support@bulbee.org. If you delete your Bulbee app account, we also delete enquiries with its email address.

Please do not include children's data in an enquiry.

4. Work contacts from public sources

We look for centres and specialists who work with children in Ukrainian, in order to offer them Bulbee for their work.

• Sources: websites of centres and practices, professional directories and catalogues, and professional pages where a centre or a specialist publishes contact details for clients themselves. We do not buy contact lists and do not take contact details from closed groups or private correspondence.
• What we keep: the name of the centre or the specialist, the city or region, the field of work, languages, work contact channels (email, phone, website, messenger), the address of the source and the date we read it, and the team's status and notes about our contact.
• Why: to write or call with an offer to try Bulbee, to understand how many centres and specialists work in Ukrainian, and to know whom we have already contacted and who asked us not to.
• Who sees it: Bulbee administrators only.
• Opting out: reply to our letter or write to support@bulbee.org, and we will not contact you again. So that a later search does not bring your contact details back, we mark the card 'Не звертатися' (do not contact). We can also delete it completely, but then a later search may find your contact details again.
• How long: while the contact is needed for the offer. We delete a card without a conversation no later than 12 months after we last contacted you or checked the source.

5. Legal bases

We rely on the UK GDPR and the UK rules on cookies and similar technologies (PECR):

• Statistics without cookies: our legitimate interest in understanding how people use the website and improving it. PECR allows such statistics without consent if people are told about them and can opt out simply; 'Не рахувати мене взагалі' is there for that.
• The identifier in your browser and session recording: your consent. You can withdraw it at any time.
• Keeping your choice in your browser is needed to carry out the choice itself.
• Enquiries: your request, which we answer before a possible contract, and our legitimate interest in replying.
• Work contacts: our legitimate interest in offering Bulbee to professionals who have published their work contact details for enquiries themselves. We have weighed it against your interests: the information is work-related and public, the contact concerns your work, and one letter is enough to opt out.
• Correspondence: our legitimate interest in replying to letters and remembering what we agreed.

6. Who receives the information

We do not sell personal information or share it for advertising. The information is received only by those who process it on our behalf:

• PostHog Inc.: visit statistics and session recordings. The data is stored in the EU: PostHog EU Cloud in Frankfurt (Germany).
• DigitalOcean: our server in London (United Kingdom), where enquiries and work contacts are kept; encrypted backup copies may be stored in Frankfurt (Germany).
• Email services that carry our correspondence with you.

7. International transfers

Our server is in the United Kingdom and the PostHog data is in the EU; the United Kingdom recognises data protection in the EU as adequate. PostHog Inc. is a US company. If its staff access the data from outside the EU, they do so on the basis of the European Commission's Standard Contractual Clauses and the UK Addendum to them, provided for in the data processing agreement with PostHog.

8. How long we keep the information

• Statistics events: 12 months; PostHog deletes older events at its monthly cleanup.
• Session recordings: 30 days.
• The PostHog identifier in your browser: while your consent lasts, but no longer than 12 months, or until you clear the website's data.
• Your choice in your browser: until you change it or clear the website's data; we ask for consent again after 12 months.
• Enquiries: until the conversation is completed and 12 months after that.
• Work contacts: as described in section 4.
• Letters: until the matter is resolved and 12 months after that.

9. Your rights

You have the right to get a copy of your information, to have it corrected or deleted, to restrict its processing, to object to it and to withdraw consent. You can object at any time to the use of your work contact details for offers, and then we stop without conditions. Write to support@bulbee.org. A session recording does not carry your name: to help us find the recording of your visit, tell us the day and the approximate time of the visit.

We will reply within one month. If you are not satisfied with our reply, you can complain to the UK Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint, telephone 0303 123 1113. In the EEA you can contact the data protection authority of your country, and in Ukraine the Ukrainian Parliament Commissioner for Human Rights: ombudsman.gov.ua.

10. Children

The website is meant for adults: parents, specialists and centres. We do not knowingly collect children's data through the website. The demo account shows only fictional children.

11. Changes to this Notice

A new version has a new date at the top. If a change concerns statistics based on your consent, we will ask for consent again.

12. How to contact us

Write to us at support@bulbee.org or by post:

DEEP THOUGHT SOLUTIONS LIMITED, registered in England and Wales, company number 14299488

Unit 2 Pondtail Farm, Coolham Road, West Grinstead

Horsham, West Sussex RH13 8LN

England