Privacy Policy

Last updated: Aug 28, 2023

Adapted from the Basecamp open-source policies / CC BY 4.0

The privacy of your data is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data.

This policy applies to all products and services built, delivered and maintained by Bilby Limited, a Hong Kong registered company with company registry number 2867719 and any subsidiary thereof ("Bilby"). This policy applies to our handling of information about site visitors, prospective customers, and customers and authorised users (in relation to their procurement of the services and management of their relationship with Bilby). We refer collectively to these categories of individuals as "you" throughout this policy.

However, this policy does not cover information about a customer’s end users that Bilby receives from a customer, or otherwise processes on a customer’s behalf, in connection with the services provided by Bilby to the customer pursuant to an applicable services agreement (including the content of messages of customer end users ("End User Communications")). Bilby processes End User Communications under the instructions of the relevant customer, which is the "data controller" or "business" (or occupies a similar role as defined in applicable privacy laws), as described in the applicable services agreement between such customer and Bilby. Bilby’s obligations with respect to such information are defined in such Software as a Service Agreement. If you are a customer’s end user and you have questions about how your information is collected and processed through the services, please contact the organisation who has provided your information to us for more information. If you are a California resident, please click here to see our California Notice at Collection, which includes additional disclosures as required by California law.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity and access

When you sign up for a Bilby product or service, we may ask for identifying information such as your name, email address, phone number and company name. That’s so you can personalise your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. We will sometimes send you our newsletter and other updates. We sometimes also give you the option to add a profile picture that displays in our products. We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

If you sign up for a paid Bilby product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit Bilby servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for the service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.

Product interactions

We store on our servers the content that you upload or receive or maintain in your Bilby product accounts. This is so you can use our products as intended. We keep this content as long as your account is active. If you delete your account, we’ll delete the content within 60 days.

General Geolocation data

For most of our products, we log the full IP address used to sign up a product account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active and for a period of up to 60 days thereafter.

Website interactions

We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active and for a period of up to 60 days thereafter. The web analytics we use are described further in the Advertising and Cookies section.

Advertising and Cookies

We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics. A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off.

In the future, Bilby may run ads on various third-party platforms such as Google, Facebook, and LinkedIn. Users who click on one of our ads will be sent to the Bilby marketing site. Where permissible under law, we may load an ad-company script on their browsers that sets a third-party cookie and sends information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form.

Voluntary correspondence

When you email Bilby with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future. We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

When we access or disclose your information:

To provide products or services you’ve requested.

We use some third-party subprocessors to help run our applications and provide the Services to you.

We also use third-party processors for other business functions such as managing newsletter subscriptions, sending customer surveys, and providing our company websites.
We may disclose your information at your direction if you integrate a third-party service into your use of our products. No Bilby human looks at your content except for limited purposes for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see "When required under applicable law" below).

Aggregated and de-identified data.

We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.

  • Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. It is Bilby’s policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.
  • If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information. Finally, if Bilby is acquired by or merges with another company — we don’t plan on that, but if it happens — we’ll notify you before any of your personal information is transferred or becomes subject to a different privacy policy.

Your rights with respect to your information

At Bilby, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:

  • Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Request Correction. You have the right to request correction of your personal information.
  • Right to Erasure / "To Be Forgotten". This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfilment of some data deletion requests may prevent you from using Bilby services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account. To make use of this policy, please email admin**@bilby.ai**
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
  • Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
  • Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
  • Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.

Data retention We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.

When transferring personal data from the EU

The European Data Protection Board (EDPB) has issued guidance that personal data transferred out of the EU must be treated with the same level of protection that is granted under EU privacy law. UK law provides similar safeguards for UK user data that is transferred out of the UK. Accordingly, Bilby has adopted a data processing addendum with Standard Contractual Clauses to help ensure this protection.
There are also a few ad hoc cases where EU personal data may be transferred to the U.S. in connection with Bilby operations, for instance, if an EU user signs up for our newsletter or participates in one of our surveys or buys swag from our company online store. Such transfers are only occasional and data is transferred under the Article 49(1)(b) derogation under GDPR and the UK version of GDPR.

Changes and questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at admin**@bilby.ai** and we’ll be happy to try to answer them!