Privacy Policy 

DATA PROTECTION POLICY
This Data Protection Policy (“Policy”) sets out the basis upon which Bull Speed Ahead Pte. Ltd.
(hereafter referred to as “MBAbull”, “we”, “us” or “our”) may collect, use, disclose, or otherwise
process personal data of users on our Website, mbabull.com and/or mbabullshit.com (the “Website”)
and mobile app (the “App”) (hereafter referred to as “user”, “you” or “your”) in accordance with the
Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under
our control, including personal data in the possession of organisations which we have engaged to
collect, use, disclose or process personal data for our purposes.
APPLICATION OF THIS POLICY
1. This Policy applies to all individuals and entities with whom we have a business relationship,
including customers and members who utilize our Services (collectively referred to as
“customer” or “you”). All references to “business relationships” within this Policy include
transactions, communications, and any interactions related to the provision or receipt of
goods, services, or information.
PROTECTION OF CHILDREN’S DATA
2. Our Services are intended for users who have attained the age of majority where they reside
(18 years or older in most jurisdictions). We do not knowingly collect personal information
from persons under the age of 13 in the United States, or under the age of 16 in the European
Union.
DEFINITION OF PERSONAL DATA
3. As used in this Policy, “personal data” means data, whether true or not, about users who can
be identified: (a) from that data; or (b) from that data and other information to which we have
or are likely to have access.
PERSONAL DATA COLLECTED THROUGH YOUR USE OF OUR SERVICES
4. We collect personal data you provide directly to us, such as
(a) When you register for an account with our Service;
(b) When you create a subscription for our Services;
(c) When you provide responses to a survey or quiz;
(d) When you join or enroll in an event through our Services;
(e) When you order services or products from, or through our Service;
(f) When you sign up for any newsletters or other materials through our Services;
(g) When you provide information to us through a third-party application, service or
Website;
(h) When you communicate with us or request information about us or our products or
Services, whether via email or other means;
(i) When you participate in any of our marketing initiatives, including, contests, events,
or promotions; and
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(j) When you participate in forums, reviews or provide or post user generated content or
other submissions.
5. We also automatically collect information via the Website or App through the use of various
technologies, including, but not limited to Cookies and Web Beacons. We may collect your IP
address, browsing behavior and device IDs. This information is used by us in order to enable
us to better understand how our Services are being used by visitors and allows us to administer
and customize the Services to improve your overall experience.
6. This personal data may include, without limitation: name, date of birth, e-mail address,
physical address, country, phone number, photograph, credit card or other method of
payment information, or any other personal information you choose to provide.
PERSONAL DATA COLLECTED FROM OTHER SOURCES
7. We may also receive your personal data from other sources and combine that with information
we collect through our Services. For example, if you choose to link, create, or log in to your
MBAbull account with a social media service, e.g. LinkedIn, Facebook or Twitter, or a payment
provider, e.g. Apple Pay or Google Pay, or if you engage with a separate App or Website that
uses our API, or whose API we use, we may receive information about you or your connections
from that Site or App.
8. This includes, without limitation, profile information, profile picture, gender, user name, user
ID associated with your social media account, age range, language, country, friends list, and
any other information you permit the social network to share with third parties. The data we
receive is solely dependent upon your own privacy settings with the social network.
PERSONAL DATA THIRD PARTIES PROVIDE
9. We may collect personal data about you from sources other than you, such as from social
media websites (i.e., Facebook, LinkedIn, Twitter or others), blogs, analytics providers,
business affiliates and partners and other users.
10. This includes, without limitation, identity data, contact data, marketing and communications
data, behavioral data, technical data and content data.
MISCELLANEOUS DATA COLLECTED
11. We may also collect the following miscellaneous data while you use any of our Services:
(a) AGGREGATED DATA: We may collect, use and share Aggregated Data such as statistical
or demographic data for any purpose. Aggregated Data is de-identified or anonymized
and does not constitute Personal Data for the purposes of the GDPR as this data does
not directly or indirectly reveal your identity. If we ever combine Aggregated Data with
your Personal Data so that it can directly or indirectly identify you, we treat the
combined data as PII which will only be used in accordance with this policy.
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(b) DEVICE INFORMATION: When you use our Services through your computer, mobile
phone or other device, we may collect information regarding and related to your
device, such as hardware models and IDs, device type, operating system version, the
request type, the content of your request and basic usage information about your use
of our Services, such as date and time. In addition, we may collect information
regarding application-level events and associate that with your account to provide
customer service. We may also collect and store information locally on your device
using mechanisms such as browser web storage and application data caches.
(c) LOCATION INFORMATION: When you use the Services we may collect your precise
location data. We may also derive your location from your IP address.
(d) CALL AND SMS DATA: In connection with providing Service, we may receive call data,
including the date and time of the call or SMS message, the parties phone numbers,
and the content of the SMS message. You consent to the receipt, collection and
storage of this information.
(e) AGGREGATED DATA: We use one or more third party payment processing gateway to
collect, store and process payment information. MBAbull does not store this
information on our Website or servers. Your use of the third-party payment processing
gateway to process your payments is subject to their terms and condition of use and
their own privacy policy.
CONSENT, USE AND DISCLOSURE OF PERSONAL DATA
12. We will seek your consent before collecting, using, or disclosing your personal data, except
where such actions are permitted or required without consent under the Personal Data
Protection Act (PDPA) or other applicable laws.
(a) Your consent is provided when you knowingly and voluntarily provide personal data
during our business interactions after, or via a third party who has been duly
authorized by you to disclose your personal data to us (your “authorized
representative”), after
(i) you (or your authorized representative) have been notified of the purposes for
which the data is collected; and
(ii) you (or your authorized representative) have provided written consent to the
collection and usage of your personal data for those purposes. This written consent
may be given by checking an online checkbox indicating your agreement to provide
personal data.
(b) We will seek your consent before collecting any additional personal data or before
using your personal data for a new purpose that has not been previously notified to
you, unless such actions are permitted or required by law.
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13. If you are a customer/member, your personal data will be collected and used by us for the
following purposes and we may disclose your personal data to third parties where necessary
for the following purposes:
(a) Provide you with our Services and customer support including, but not limited to,
fulfilling purchase orders, processing returns and refunds, confirming emails related
to our products and services, setting reminders and responding to requests for
information and transactions.
(b) Track your purchase history and to contact you for account and promotional purposes.
(c) Contact you and provide you with important notices.
(d) Analyze, improve and manage our Services and operations
(e) Attempt to resolve problems and disputes, and engage in other legal and security
matters.
(f) Detect and prevent fraud.
(g) Enforce our Terms of Service and any terms and conditions of any agreements
(h) Send you communications we think will be of interest to you, including information
about products, services, promotions, news, and events of MBAbull and other
companies, where permissible and according to local applicable laws.
(i) Display advertising, including advertising that is targeted to you or other users based
on your location, interests, as well as your activities on our Services.
(j) Verify your identity and prevent impersonation, spam or other unauthorized or illegal
activity including, without limitation, infringement of intellectual property rights of
third parties as well as chargeback fraud and refund fraud.
(k) We may transfer the information described in this policy to, and process and store it
in, the United States and other countries, some of which may have less protective data
protection laws than the region in which you reside. Where this is the case, we will
take appropriate measures to protect your personal information in accordance with
this Privacy Policy.
14. The purposes listed in the above clauses may continue to apply even in situations where your
relationship with us (for example, pursuant to a contract) has been terminated or altered in
any way, for a reasonable period indicated in our retention policy (including, where applicable,
a period to enable us to enforce our rights under any contract with you).
WITHDRAWING CONSENT
15. The consent that you provide for the collection, use and disclosure of your personal data will
remain valid until such time it is being withdrawn by you in writing. You may withdraw consent
and request us to stop using and/or disclosing your personal data for any or all of the purposes
listed above by submitting a written request either through the contact form at our website or
via email to our Data Protection Officer at the contact details provided below.
16. Upon receipt of your written request to withdraw your consent, we may require reasonable
time (depending on the complexity of the request and its impact on our relationship with you)
for your request to be processed and for us to notify you of the consequences of us acceding
to the same, including any legal consequences which may affect your rights and liabilities to
us.
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17. We shall provide you with a written confirmation stating that we no longer possess any of your
personal data.
18. Where applicable, we shall also instruct all third parties to whom your personal data has been
disclosed in connection with the Services rendered under this Agreement, to either return the
personal data to us or delete it. We will ensure that these third parties comply with the return
or deletion request and will provide confirmation of the same upon your request.
19. Whilst we respect your decision to withdraw your consent, please note that depending on the
nature and extent of your request, we may not be in a position to process your request (as the
case may be). We shall, in such circumstances, notify you before completing the processing of
your request (as outlined above). Should you decide to cancel your withdrawal of consent,
please inform us in writing in the manner described in clause 8 above.
20. Please note that withdrawing consent does not affect our right to continue to collect, use and
disclose personal data where such collection, use and disclose without consent is permitted
or required under applicable laws.
PROMOTIONAL INFORMATION OPT OUT
21. You may opt out of receiving promotional messages from us at any time by following the
instructions in those messages sent to you or by contacting us at any time using the Contact
Us information at the end of this Privacy Policy. If you opt out, we may still send you nonpromotional communications, such as those about your account, about Services you have
requested, or our ongoing business relations.
ACCESS TO AND CORRECTION OF PERSONAL DATA
22. If you wish to make
(a) an access request for access to a copy of the personal data which we hold about you or
information about the ways in which we use or disclose your personal data, or
(b) a correction request to correct or update any of your personal data which we hold,
you may submit a written request either through the contact form at our website or via email
to our Data Protection Officer at the contact details provided below.
23. We will respond to your access request as soon as reasonably possible. If we are unable to
provide you with any personal data or to make a correction requested by you, we shall
generally inform you of the reasons why we are unable to do so (except where we are not
required to do so under the PDPA).
24. Please note that depending on the request that is being made, we will only need to provide
you with access to the personal data contained in the documents requested, and not to the
entire documents themselves. In those cases, it may be appropriate for us to simply provide
you with confirmation of the personal data that our organisation has on record, if the record
of your personal data forms a negligible part of the document.
CORRECTION OF ACCOUNT INFORMATION
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25. You may correct your account information at any time by logging into your online account. If
you wish to cancel your account, please submit a written request either through the contact
form at our website or via email to our Data Protection Officer at the contact details provided
below. Please note that we may retain certain information about you for reactivation purposes
and as required by law, or for legitimate business purposes to the extent permitted by law. For
instance, if you have a standing credit or debit on your account, or if we believe you have
committed fraud or violated our Terms of Service, we may seek to resolve the issue before
deleting your information.
ERASURE OR DELETION OF PERSONAL DATA
26. In certain circumstances, you have the right to request that personal information we hold
about you is deleted. If we cannot delete the information you want, we will let you know and
explain why. To request information deletion, you may submit a written request either through
the contact form at our website or via email to our Data Protection Officer at the contact
details provided below.
OBJECTION OR RESTRICTION TO PROCESS PERSONAL DATA
27. In certain circumstances, you have the right to object to our processing of your personal data.
For example, you have the right to object to use of your personal information for direct
marketing purposes. Similarly, you have the right to object to use of your personal data if we
are processing your information on the basis of our legitimate interests and there are no
compelling legitimate grounds for our processing which supersede your rights and interests.
You may also have the right to restrict our use of your personal information, such as in
circumstances where you have challenged the accuracy of the information and during the
period where we are verifying its accuracy. To object to or restrict processing, please submit a
written request either through the contact form at our website or via email to our Data
Protection Officer at the contact details provided below.
DATA PORTABILITY OR TRANSFER OF PERSONAL DATA
28. You have the right to be provided with a copy of the information we maintain about you in a
structured, machine-readable and commonly used format. To receive a copy of the
information we maintain about you please submit a written request either through the contact
form at our website or via email to our Data Protection Officer at the contact details provided
below.
PROTECTION OF PERSONAL DATA
29. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying,
modification, disposal or similar risks, we have introduced commercially reasonable technical
and administrative security measures to reduce the risks of loss, misuse, unauthorized access,
disclosure and alteration. Some of the safeguards we use are firewalls, anti-malware and
password protections.
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30. You should be aware, however, that no method of transmission over the Internet or method
of electronic storage is completely secure. While security cannot be guaranteed, we strive to
protect the security of your information and are constantly reviewing and enhancing our
information security measures.
ACCURACY OF PERSONAL DATA
31. We generally rely on personal data provided by you (or your authorised representative). In
order to ensure that your personal data is current, complete and accurate, please update us if
there are changes to your personal data by submitting a written request either through the
contact form at our website or via email to our Data Protection Officer at the contact details
provided below.
RETENTION OF PERSONAL DATA
32. We may retain your personal data for as long as your account is active or as needed to provide
you Services. Following termination or deactivation of your account, we will retain information
for at least 1 year and may retain the information for as long as needed for our business and
legal purposes. We will only retain your Personal Data for so long as we reasonably need to
unless a longer retention period is required to fulfil the purposes for which they were collected,
or as required or permitted by applicable laws.
33. We will cease to retain your personal data, or remove the means by which the data can be
associated with you, as soon as it is reasonable to assume that such retention no longer serves
the purposes for which the personal data were collected, and are no longer necessary for legal
or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
34. In order to provide our products and services to you, we may send and store your personal
information outside of the country where you reside or are located, including to the United
States. Accordingly, if you reside or are located outside of the United States, your personal
information may be transferred outside of the country where you reside or are located,
including countries that may not, or do not, provide the same level of protection for your
personal information. We are committed to protecting the privacy and confidentiality of
personal information when it is transferred.
35. If you reside or are located within the European Economic Area and such transfers occur, we
take appropriate steps to provide the same level of protection for the processing carried out
in any such countries as you would have within the European Economic Area to the extent
feasible under applicable law.
36. By using and accessing our products and services, users who reside or are located in countries
outside of the United States agree and consent to the transfer to and processing of personal
information on servers located outside of the country where they reside, and assume the risk
that the protection of such information may be different and may be less protective than those
required under the laws of their residence or location.
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SHARING OF PERSONAL DATA WITH THIRD PARTIES
37. We do not sell, share, or disclose your personal data to any third parties for their marketing or
other independent purposes, unless required by law or with your prior consent. All personal
data collected is used solely for the purposes outlined in this policy or as necessary to provide
our Services. In circumstances where sharing is mandated by regulatory requirements, you will
be notified accordingly.
DATA BREACH NOTIFICATION
38. In the event of a data breach involving your personal data, we shall notify you and the relevant
authorities as required by law, within three calendar days of becoming aware of the breach.
The notification will include details of the breach, the type of data that was compromised, the
likely consequences of the breach, and the measures we have taken or will take to address the
breach.
DATA PROTECTION OFFICER
39. You may contact our Data Protection Officer if you have any enquiries or feedback on our
personal data protection policies and procedures; or if you wish to make any request, with the
following contact details:
Name: DIANECIA EDREWS SIVANUS
Phone: +65 31578897
Email: dpo20240906@bullspeedahead.com
EFFECT OF POLICY AND CHANGES TO POLICY
40. This Policy applies in conjunction with any other policies, notices, contractual clauses and
consent clauses that apply in relation to the collection, use and disclosure of your personal
data by us.
41. We may revise this Policy from time to time without any prior notice. You may determine if
any such revision has taken place by referring to the date on which this Notice was last updated.
Your continued use of our services, products, and participation in our business activities,
including procurement, sales, and collaborative projects, constitutes your acknowledgment
and acceptance of such changes.
Effective date: 23 OCT 2024

Furthermore, for international visitors we strive to follow comprehensive privacy practices such as those laid out but EU GDPR, California, and others. Note we are NOT located in the EU or California and believe we are NOT subject to EU GDPR nor California nor do we guarantee visitors that we are EU GDPR or California compliant. HOWEVER, we nevertheless attempt to follow EU GDPR and California regulations as a “best practices” guideline, as detailed below.

 

 

 

We at Bull Speed Ahead Pte. Ltd. respect the privacy of your personal information and, as such, make every effort to ensure your information is protected and remains private. As the owner and operator of mbabull.com (the “Website”) and/or mbabullshit.com and any mobile application that we may make available to you now or in the future (the “App”), hereafter referred to in this Privacy Policy as “MBAbull”, “MBAbullshit,” “us”, “our” or “we”, we have provided this Privacy Policy to explain how we collect, use, share and protect information about the users of our Website and mobile App (hereafter referred to as “user”, “you” or “your”).  For the purposes of this Agreement and our Terms of Service, any use of the terms “MBAbull”, “MBAbullshit,” “us”, “our” or “we” includes Bull Speed Ahead Pte. Ltd., without limitation. We will not use or share your personal information with anyone except as described in this Privacy Policy.

 

This Privacy Policy will inform you about the types of personal data we collect, the purposes for which we use the data, the ways in which the data is handled and your rights with regard to your personal data. Furthermore, this Privacy Policy is intended to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR”) and the laws implementing GDPR.

For the purpose of this Privacy Policy the Data Controller of personal data is Bull Speed Ahead Pte. Ltd. and our contact details are set out in the Contact section at the end of this Privacy Policy. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

 

For purposes of this Privacy Policy, “Your Information” or “Personal Data” means information about you, which may be of a confidential or sensitive nature and may include personally identifiable information (“PII”) and/or financial information. PII means individually identifiable information that would allow us to determine the actual identity of a specific living person, while sensitive data may include information, comments, content and other information that you voluntarily provide.

 

MBAbull collects information about you when you use our Website or App to access our services, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. The term Services includes, collectively, streaming instructional videos, downloadable ebooks, articles, tutorials, Website content, products, various applications, widgets, email notifications and other mediums, or portions of such mediums, through which you have accessed this Privacy Policy.

 

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site and in the App. Those changes will go into effect on the “Last updated” date shown at the end of this Privacy Policy. By continuing to use the Site or Services, you consent to the revised Privacy Policy. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.

 

BY ACCESSING OR USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, MANIPULATION, STORAGE, DISCLOSURE AND OTHER USES OF YOUR INFORMATION (COLLECTIVELY, “USE OF YOUR INFORMATION”) AS DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS OF SERVICE FOR MBABULL WHICH MAY BE ACCESSED HERE https://mbabull.com/bull/terms-conditions/ . IF YOU DO NOT AGREE WITH OR CONSENT TO THIS PRIVACY POLICY AND OUR TERMS OF SERVICE YOU MAY NOT ACCESS OR USE OUR SERVICES.

 

 

  1. Children’s Privacy

Our Services are intended for users who have attained the age of majority where they reside (18 years of age or older in most jurisdictions). Furthermore, we do not knowingly collect personally identifiable information (PII) from persons under the age of 13 in the United States (“U.S.”), or under the age of 16 in the European Union (“EU”), the “Protected Age”. If you are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.

 

  1. Information Provided Directly By You

We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, order a subscription to our Services, complete a MBAbull form, survey, quiz or application, contact customer support, make a purchase, join or enroll for an event, newsletter or otherwise communicate with us in any manner. This information may include, without limitation: name, date of birth, e-mail address, physical address, phone number, photograph, credit card or other method of payment information, or any other personal information you choose to provide.

 

  1. Information Collected Through Your Use of Our Services

The following are situations in which you may provide Your Information to us:

  1. When you fill out forms or fields through our Services;
  2. When you register for an account with our Service;
  3. When you create a subscription for our Services;
  4. When you provide responses to a survey or quiz;
  5. When you join or enroll in an event through our Services;
  6. When you order services or products from, or through our Service;
  7. When you sign up for any newsletters or other materials through our Services;
  8. When you provide information to us through a third-party application, service or Website;
  9. When you communicate with us or request information about us or our products or Services, whether via email or other means;
  10. When you participate in any of our marketing initiatives, including, contests, events, or promotions; and
  11. When you participate in forums, reviews or provide or post user generated content or other submissions.

We also automatically collect information via the Website or App through the use of various technologies, including, but not limited to Cookies and Web Beacons (explained below). We may collect your IP address, browsing behavior and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.

 

  1. Cookies, Log Files and Anonymous Identifiers
    1. When you visit our Services, we may send one or more Cookies – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website browsing equipment for record keeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. Cookies allow the Sites to remember important information that will make your use of the site more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Sites regardless of whether you are logged in to your account or not.
    2. Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Site.
    3. Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).
    4. When we use session Cookies to track the total number of visitors to our Site, this is done on an anonymous aggregate basis (as Cookies do not in themselves carry any personal data).
    5. We may also employ Cookies so that we remember your computer when it is used to return to the Site to help customize your MBAbull web experience. We may associate personal information with a Cookie file in those instances.
    6. We use Cookies to help us know that you are logged on, provide you with features based on your preferences, understand when you are interacting with our Services, and compile other information regarding use of our Services.
    7. Third parties with whom we partner to provide certain features on our Site or to display advertising based upon your Web browsing activity use Cookies to collect and store information.
    8. Our Website may use remarketing services, to serve ads on our behalf across the internet on third party websites to previous visitors to our Sites. It could mean that we advertise to previous visitors who haven’t completed a task on our site. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network and/or Facebook Pixel or other similar services. Third-party vendors, including but not limited to Google, use Cookies to serve ads based on your past visits to our Website. Any data collected will be used in accordance with our own privacy policy, as well as the Third-party’s privacy policies. To learn more, or to opt-out of receiving advertisements tailored to your interests by our third parties, visit the Network Advertising Initiative at networkadvertising.org/choices.
    9. MBAbull may use third-party services such as Google Analytics and similar services to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including Cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager here https://adssettings.google.com/authenticated?hl=en. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on here https://tools.google.com/dlpage/gaoptout.
    10. You can control the use of Cookies at the individual browser level. Use the options in your web browser if you do not wish to receive a Cookie or if you wish to set your browser to notify you when you receive a Cookie. You can easily delete and manage any Cookies that have been installed in the Cookie folder of your browser by following the instructions provided by your particular browser manufacturer. Consult the documentation that your particular browser manufacturer provides. You may also consult your mobile device documentation for information on how to disable Cookies on your mobile device. If you reject Cookies, you may still use our Website or App, but your ability to use some features or areas of our Service may be limited.
    11. MBAbull cannot control the use of Cookies by third parties (or the resulting information), and use of third party Cookies is not covered by this policy.
    12. We automatically collect information about how you interact with our Services, preferences expressed, and settings chosen and store it in Log Files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or App/Site functionality, and to document your consent to receiving products, services or communications from us or our partners. In addition to using this information to improve our Services and your MBABull experience, we use it to enforce the terms of this Agreement including, without limitation, sharing of usernames and passwords, unauthorized downloads of content, copyright and other intellectual property right infringement, etc. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as PII for purposes of this Privacy Policy.
    13. When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your account is collected using these Web Beacons.

 

  1. Information Collected From Other Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your MBAbull account with a social media service, e.g. LinkedIn, Facebook or Twitter, or a payment provider, e.g. Apple Pay or Google Pay, or if you engage with a separate App or Website that uses our API, or whose API we use, we may receive information about you or your connections from that Site or App. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your own privacy settings with the social network.

 

  1. Information Third Parties Provide

We may collect information about you from sources other than you, such as from social media websites (i.e., Facebook, LinkedIn, Twitter or others), blogs, analytics providers, business affiliates and partners and other users. This includes, without limitation, identity data, contact data, marketing and communications data, behavioral data, technical data and content data.

 

  1. Aggregated Data

We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. If we ever combine Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as PII which will only be used in accordance with this Privacy Policy.

 

  1. Device Information

When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.

 

  1. Location Information

When you use the Services we may collect your precise location data. We may also derive your location from your IP address.

  1. Call and SMS Data

In connection with providing Service, we may receive call data, including the date and time of the call or SMS message, the parties phone numbers, and the content of the SMS message. You consent to the receipt, collection and storage of this information.

 

  1. Protective Measures We Use

We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Although we take measures to secure your information, we do not promise, and you should not expect, that your personal information, or searches, or other information will always remain secure. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

 

  1. Payment Information

MBAbull uses one or more third party payment processing gateway to collect, store and process payment information. MBAbull does not store this information on our Website or servers. Your use of the third party payment processing gateway to process your payments is subject to their terms and condition of use and their own privacy policy.

 

  1. The Legal Basis For Collection and Processing Your Personal Information

The legal basis upon which we rely for the collection and processing of your Personal Information under the GDPR are the following:

  1. When signing up to use our Services, you have given us explicit consent allowing MBAbull to provide you with our Services and generally to process your information in accordance with this Privacy Policy; and to the transfer of your personal data to other jurisdictions including, without limitation, the United States;
  2. It is necessary for entering into, or performing, the obligations of a contract between you and MBAbull, including, without limitation, the Terms of Service agreement which may be accessed by you here https://mbabull.com/bull/terms-conditions/and any subscription for our Services that you order;
  3. It is necessary registering you as a user, managing your account and profile, and authenticating you when you log in.
  4. It is necessary for our legitimate interests in the proper administration of our website and business; analyzing the use of the website and our Services; assuring the security of our website and Services; maintaining back-ups of our databases; and communicating with you;
  5. To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support.
  6. To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages.
  7. To send promotional communications that may be of specific interest to you.
  8. It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you;
  9. It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a regulatory agency.

 

  1. How We Use Information We Collect

Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. MBAbull will not rent, sell, lease or barter your Personal Information to anyone without your affirmative authorization.

We will use this information in order to:

  1. Provide users with our Services and customer support including, but not limited to, fulfilling purchase orders, processing returns and refunds, confirming emails related to our products and services, setting reminders and responding to requests for information and transactions.
  2. Track your purchase history and to contact you for account and promotional purposes.
  3. Contact you and provide you with important notices.
  4. Analyze, improve and manage our Services and operations.
  5. Attempt to resolve problems and disputes, and engage in other legal and security matters.
  6. Detect and prevent fraud.
  7. Enforce our Terms of Service and any terms and conditions of any agreements for our

Additionally, we may use the information we collect about you to:

  1. Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of MBAbull and other companies, where permissible and according to local applicable laws.
  2. Display advertising, including advertising that is targeted to you or other users based on your location, interests, as well as your activities on our Services.
  3. Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties as well as chargeback fraud and refund fraud.
  4. We may transfer the information described in this Privacy Policy to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Privacy Policy.

 

  1. How We Share Information We Collect
    1. We may share the information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:
      1. With third party Service Providers to enable them to provide the Services you request;
      2. With companies that perform services for us, such as fulfilling orders;
  • With the general public if you submit content in a public forum, such as your reviews, comments or other features of our Services that are viewable by the general public;
  1. With third parties with whom you choose to let us share information, for example other users and other websites or apps that integrate with our API or Services, or those with an API or Service with which we integrate.
  2. With MBAbull subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes;
  3. With affiliated entities that provide payment processing services on our behalf;
  • With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
  1. With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our user agreements, Terms of Service, or policies, or to protect the rights, property, or safety of MBAbull or others;
  2. With third parties, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company. In this event, you release us of any liability for damages resulting from the intentional or negligent acts of the third party regarding Your Information;
  3. If we otherwise notify you and you consent to the sharing; and
  • In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any personal information.
  1. We may disclose Your Information:
    1. To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
    2. To our third-party vendors and service providers so that they may provide support for our internal and business operations, including for the processing of payments, handling of data processing, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and our Services maintenance and security. These companies are authorized to use Your Information only as necessary to provide these services to us and are contractually obligated to keep Your Information confidential;
  • To third parties when you engage in certain activities through our Services that are sponsored by them, such as purchasing products or services offered by a third party, electing to receive information or communications from a third party, or electing to participate in contests, sweepstakes, games or other programs sponsored, in whole or in part, by a third party. When we disclose Your Information to these third parties, Your Information will become subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of Your Information;
  1. As required by law or ordered by a court, regulatory, or administrative agency;
  2. As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;
  3. If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency;
  • To enforce our Terms of Service, this Privacy Policy, and any other applicable agreements and policies;
  • To enforce or protect our legal rights.

 

  1. Sharing Information With Law Enforcement
  2. MBAbull is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If MBAbull receives a request for user account information from a government agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency.
  3. Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer Communications or Records), MBAbull may disclose user account information to law enforcement, without a subpoena, court order, or search warrant, in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone. MBAbull will not release more information than it prudently believes is necessary to prevent harm in an emergency situation.

 

  1. Social Media Sharing
  2. Our Services may now or in the future integrate with social sharing features and other related tools which let you share actions you take on our Services with other Apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
  3. Any information or content that you voluntarily disclose for posting publicly to a social sharing service becomes available to the public, as controlled by any applicable privacy settings that you set with the social sharing service. Once you have shared User Content or made it public, that User Content may be re-shared by others. If you remove information that you posted to the social sharing service, copies may still remain viewable in cached and archived pages, or if other users or third parties, using the social sharing service, have re-shared, copied or saved that User Content.

 

  1. User Content and Public Sharing

If you share User Content or post a comment or message that contains personally identifiable information to a page on our Services that is accessible to the public, third parties may use that information, or share it with other parties. As a result, you may receive unsolicited messages from other parties. Such User Content, comments or messages is not subject to this Privacy Policy and you share this information at your own risk. You will need to contact MBAbull in the event that you wish to have this personally identifiable information removed from our Service.

 

  1. Analytic Services Provided By Others

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use Cookies, Web Beacons, software development kits (SDKs), and other technologies to identify your device when you visit our Site and use our Services, as well as when you visit other online sites and services.

 

  1. Links to Third-Party Websites
  2. Our Services, as well as the email messages sent with respect to our Services, may contain links or access to websites operated by third parties that are beyond our control. Links or access to third parties from our Services are not an endorsement by us of such third parties, or their websites, applications, products, services, or practices. We are not responsible for the privacy policy, terms and conditions, practices or the content of such third parties. These third-parties may send their own Cookies to you and independently collect data.
  3. If you visit or access a third-party Website, application or other property that is linked or accessed from our Services, we encourage you to read any privacy policies and terms and conditions of that third party before providing any personally identifiable information. If you have a question about the terms and conditions, privacy policy, practices or contents of a third party, please contact the third party directly.

 

  1. Do Not Track Settings

Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting Cookies, as browsers with a “do not track” feature enabled may still accept Cookies. There is currently no industry standard for how companies should respond to “do not track” signals, although one may develop in the future. We do not respond to “do not track” signals at this time; if we do so in the future, we will describe how in this Privacy Policy.

 

  1. International Privacy Practices

In order to provide our products and services to you, we may send and store your personal information outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including countries that may not, or do not, provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our products and services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and assume the risk that the protection of such information may be different and may be less protective than those required under the laws of their residence or location.

 

  1. Account Information

You may correct your account information at any time by logging into your online account. If you wish to cancel your account, please email us at support(at)mbabull.com Please note that we may retain certain information about you for reactivation purposes and as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debit on your account, or if we believe you have committed fraud or violated our Terms of Service, we may seek to resolve the issue before deleting your information.

 

  1. Promotional Information Opt Out

You may opt out of receiving promotional messages from us at any time by following the instructions in those messages sent to you or by contacting us at any time using the Contact Us information at the end of this Privacy Policy. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.

 

  1. Your Access and Rights to Your Personal Information Under the GDPR

Pursuant to the General Data Protection Regulation (GDPR) You have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

  1. Right to Access Your Personal Data. You have the right to access information held about you for the purpose of viewing and in certain cases updating or deleting such information. Furthermore, if you prefer that MBAbull does not share certain information as described in this Privacy Policy, you can direct MBAbull not to share that information. We will comply with an individual’s requests regarding access, correction, sharing and/or deletion of the personal data we store in accordance with applicable law. To make changes to your account affecting your personal information contact us at the email address in our Contact section below. For any deletion, non-sharing or update request, we will make the changes as soon as practicable, however this information may stay in our backup files. If we cannot make the changes you want, we will let you know and explain why.
  2. Right of Correction or Completion of Your Personal Data. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.
  3. Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request information deletion please contact us at the email address in our Contact section below.
  4. Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.
  5. Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable and commonly used format. To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.
  6. Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at the email address in our Contact section below.

 

  1. Our Information Retention Policy

Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 1 year and may retain the information for as long as needed for our business and legal purposes. We will only retain your Personal Data for so long as we reasonably need to unless a longer retention period is required by law (for example for regulatory purposes).

 

  1. California Privacy Rights

This section has been provided to comply with the California Consumer Privacy Act of 2018 as amended (the “CCPA”), and applies solely to residents of the State of California; it is designed to supplement the information provided elsewhere in this Privacy Policy. Please read the entire Privacy Policy, including sections cross referenced herein, in conjunction with the following terms.

 

MBAbull will not rent, sell, lease or barter your Personal Information to anyone without your affirmative authorization.

 

  1. Information We Collect. We collect information that identifies directly or indirectly, with a particular person or a device (“personal information”). Below is a list of the categories of personal information we may have collected about California residents in the past 12 months:
  2. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  3. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
  • Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  1. Geolocation data. Physical location or movements.
  2. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  3. Direct Collection. We collect information directly from you when you fill out forms or fields through our Service; register for an account; order products or services from, or through our Service; provide responses to a survey or questionnaire; join or enroll in an event through our Service; sign up for any newsletters or other materials; provide information to us through a third-party application, service or website; communicate with us or request information about us, or our products or Service, whether via email or other means; and participate in any of our marketing initiatives.
  4. Indirect Collection. We may Collect Information Indirectly from you through the use of various technologies, including, but not limited to Cookies, Pixel Tags, Web Beacons, Google Analytics or other analytics plugins and third-party payment service providers.
  5. Our Use of Personal Information.

Please refer to Section 14 of this Privacy Policy.

  1. How We Share Personal Information.

Please refer to Section 15 a. of this Privacy Policy.

Below is a list of the categories of personal information that we may have shared in the preceding 12 months:              

  •  
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • Internet or other similar network activity.
  • Geolocation data.
  • Inferences drawn from other personal information.
  1. Disclosures of Personal Information.

Please refer to Section 15 b. of this Privacy Policy.

Below is a list of the categories of personal information that we may have disclosed in the preceding 12 months:

  •  
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • Internet or other similar network activity.
  • Geolocation data.
  • Inferences drawn from other personal information.
  1. California Residents Under the Age of 16. We do not sell the Personal Information of California residents under 16 years of age without affirmative authorization.

 

                                INDIVIDUAL RIGHTS AND CHOICES FOR CALIFORNIA RESIDENTS

 

  1. Right to Access Specific Information and to Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  1. The categories of personal information we collected about you.
  2. The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  1. The categories of third parties with whom we share that personal information.
  2. The categories of personal information that each recipient received.
  3. The specific pieces of personal information we collected about you.
  4. Right to Request Deletion

You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete your personal information from our records.

  1. Exercising Your Rights to Access, Data Portability, and Deletion

To exercise the access, data portability, and deletion rights discussed herein, you must submit a verifiable consumer request to us using the How to Contact Us information at the end of this Privacy Policy. Only you, or a person you have designated in writing as your authorized agent (“Authorized Agent”), may make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must (a) describe your request in adequate detail, and (b) include sufficient information that allows us to verify that you are the person associated with the personal information we collected.

  1. Non-Discrimination

We will not discriminate against you because you exercise any of the rights provided by the California Consumer Privacy Act.

  1. Do Not Sell My Personal Information; Opt Out

The CCPA requires businesses to provide a web page where consumers can opt out of the ”sale” of their Personal Information. The link to our Do Not Sell My Personal Information web form is here.  Furthermore, you may opt out of receiving promotional messages from us at any time by following the instructions in those messages sent to you including emails, or by contacting us at any time using the How to Contact Us information at the end of this Privacy Policy. In doing so, you elect not to receive correspondence from us or have your personal information shared with other entities for their marketing purposes. If you opt out, we may still send you non-promotional communications, such as those about your account, about services you have requested, or our ongoing business relations.

  1. Other California Privacy Rights
  2. Shine The Light Law. California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the information in the How to Contact Us section at the end of this Privacy Policy.
  3. Do Not Track. Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. We do not take any action in response to this signal.

 

  1. Contact Us

If you have any questions or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.

 

MBAbull

Contact name: Data Protection Officer

Email: support(at)mbabull.com

Live Chat: Available on homepage

Our office address:

Bull Speed Ahead Pte. Ltd.

#05-03 Plus, 20 Cecil Street, Singapore 049705

 

Last updated: February 21, 2020