Privacy Policy

Introduction

BUBBLE & BERRY LTD ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, including all associated pages, functionality, and services offered.

Please read this Privacy Policy carefully. By accessing and using this website, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our website.

1. What Data We Collect

We collect information in various ways, including information you voluntarily provide and information collected automatically through tracking technologies.

Information You Provide Directly

• Full name and contact information (email address, phone number)
• Postal address and business location details
• Investment amount range and preferred opportunity types
• Messages, enquiries, and communication content
• Any other information you voluntarily submit through forms

Information Collected Automatically

• IP address and browser type and version
• Device type, operating system, and unique device identifiers
• Pages visited, time spent on site, and navigation patterns
• Referring website and exit pages
• Cookies and tracking pixel events
• Conversion events (form submissions, button clicks, calls)

2. Cookie Categories and Usage

We use cookies to enhance functionality, measure performance, and deliver personalised advertising. Cookies are divided into three mandatory categories.

3. Marketing Cookies and Advertising Partners

Third-party vendors, including Google, use cookies to serve ads based on a user's previous visits to this website and other sites on the internet.

Remarketing

We may use remarketing services to advertise to previous visitors of our website. After visiting our site, you may see our ads on other websites, apps, or platforms you visit.

YouTube and Display Network

Advertisements may appear across Google services including YouTube, Gmail, and the Google Display Network.

Tracking Technologies Active on This Site

• First-party and third-party cookies
• Tracking pixels (Google Ads tag / gtag.js, Meta Pixel)
• Device identifiers (browser fingerprint, IP address)
• Conversion event tags

Advertising and Measurement

We use conversion tracking to understand which advertisements lead to actions on our website—such as form submissions, calls, or registrations. This allows us to measure campaign effectiveness and allocate budget appropriately. Conversion data may be shared with Google Ads and Meta.

Technologies in Use

• Google Ads (gtag.js / Google Tag Manager)
• Google Analytics 4
• Google Remarketing Tag
• Meta Pixel (Facebook and Instagram)

Opting Out of Personalised Advertising

You may opt out of personalised advertising at any time:

• Google Ads Settings
• Your Online Choices (EU)
• Network Advertising Initiative
• Digital Advertising Alliance

Opting out does not remove ads entirely—you will continue to see non-personalised advertisements.

4. Consent Requirements

Cookie Consent Banner

When you first visit our website, you will see a cookie consent banner offering three options: "Accept All," "Reject Non-Essential," and "Manage Preferences." You may dismiss this banner without accepting by selecting "Reject Non-Essential," which will activate only essential cookies.

Consent Statement

EEA and UK Users

Users in the European Economic Area and the United Kingdom receive this consent notice in compliance with the General Data Protection Regulation (GDPR) and UK GDPR. Marketing and analytics cookies are activated solely after explicit, informed, freely given consent under GDPR Article 6(1)(a). Consent is recorded with a timestamp and may be audited upon request.

Withdrawal of Consent

You may withdraw consent at any time by clicking "Manage cookie preferences" in the website footer, or by clearing cookies via your browser settings. Withdrawal does not affect processing that occurred while consent was valid.

5. Data Sharing with Advertising Partners

We share certain data with advertising partners for campaign delivery and measurement. Recipients and the data categories shared include:

Google LLC

Cookie identifiers, conversion events, anonymised behavioural data, and remarketing lists. Governed by Google's Privacy Policy.

Meta Platforms, Inc.

Pixel events, conversion data, and custom audiences. Governed by Meta's Data Policy.

6. Lead Forms and Contact Requests

When you submit a contact form, request information, or register as an investor, we collect the information you provide. This typically includes: full name, email address, phone number, and your message or enquiry.

Legal Basis

Consent (GDPR Art. 6.1.a) and, where a service relationship exists, performance of a contract (GDPR Art. 6.1.b).

Data Retention

Form submission data is retained for up to 2 years from the date of submission, unless a longer period is required by applicable law.

User Rights

You may request deletion of your data at any time by contacting us at the email address in this policy.

A link to this Privacy Policy appears adjacent to every submission button on this site. Submitting a form constitutes acknowledgment of this policy.

7. Google Services and Advertising

This website uses the following Google services:

Google Analytics 4

Collects anonymised usage data, device information, and behavioural signals. IP anonymisation is enabled. Data retention is set to 14 months. Users may opt out via the Google Analytics Opt-out Browser Add-on.

Google Ads Conversion Tracking

Records when a user completes a defined action (form submission, call, registration) after clicking one of our ads. This data is used solely for measuring ad campaign performance.

Google Remarketing

Allows us to show ads to previous visitors across Google's network. Remarketing lists are not created from sensitive data categories (health, finance, religion, sexual orientation).

Google Tag Manager

Deploys tracking tags on our behalf. No personal data is collected by GTM itself; it acts as a container for the tags listed above.

Google's advertising products are governed by Google's Advertising Policies.

8. Meta Advertising Services

This website uses the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram. The pixel may record:

• Page views and time on site
• Specific conversion events (form submissions, registrations)
• Custom audience membership for retargeting purposes

We do not use the Meta Pixel to collect sensitive personal data, nor to target users based on health status, financial situation, religion, political views, sexual orientation, or any other special-category attribute prohibited under Meta's advertising policies.

Meta acts as an independent data controller for data collected via its Pixel and processed within its own platform. Refer to Meta's Data Policy.

To manage your ad preferences on Meta platforms, visit Meta Ad Preferences.

9. Prohibited Content Disclosure

10. Landing Page Integrity Statement

The content of this website accurately represents the products and services advertised. No bait-and-switch practices are employed. The experience delivered to users arriving from paid advertisements is identical to the experience for all other visitors. Cloaking, automatic redirects, and content variation by traffic source are not used on this website.

11. Children's Privacy

This website is not directed at individuals under the age of 16. We do not knowingly collect personal data from minors. If we discover that data has been collected from a person under 16 without verifiable parental consent, we will delete it promptly. Contact us at the address in this policy if you believe we have received data from a minor.

12. International Data Transfers

Personal data collected through this website may be transferred to and processed in countries outside the European Economic Area, including the United States, where Google LLC and Meta Platforms, Inc. are based.

These transfers are conducted under Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for personal data. A copy of the applicable SCCs can be requested by contacting us directly.

13. Your Privacy Rights (GDPR Articles 15-22)

If you are located in the European Economic Area or the United Kingdom, you have the following rights:

• Access (Art. 15): Request a copy of data we hold about you
• Rectification (Art. 16): Correct inaccurate or incomplete data
• Erasure (Art. 17): Request deletion ("right to be forgotten")
• Restriction (Art. 18): Limit how we process your data
• Portability (Art. 20): Receive your data in a structured, machine-readable format
• Objection (Art. 21): Object to processing based on legitimate interest
• Withdraw Consent (Art. 7.3): Revoke consent at any time without penalty

To exercise any right, email us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with your local supervisory authority:

• EU users: EDPB
• UK users: ICO

14. Legal Basis for Processing

We process personal data under the following legal bases under GDPR Article 6:

• Consent (Art. 6.1.a): Analytics, marketing, and advertising cookies
• Contract Performance (Art. 6.1.b): Processing contact form data and investment enquiries
• Legitimate Interest (Art. 6.1.f): Security, fraud prevention, and website optimisation

15. Data Retention Periods

We retain personal data for the following periods:

• Contact Form Submissions: 2 years from submission date
• Analytics Data (GA4): 14 months
• Marketing Cookies (Google Ads): Up to 540 days
• Email Communications: Duration of relationship + 1 year
• Server Logs: 90 days
• Cookie Consent Records: 3 years (audit requirement)

16. Contact Information

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. Changes will be announced via a homepage banner at least 14 days before taking effect. Your continued use of the website after such notification constitutes your acceptance of the updated Privacy Policy.