DataPrivacy


Statement About DrukBees Privacy
DrukBees E-Commerce and DrukBees Courier is a firm, registered in Bhutan (hereinafter referred to as “we”, “us” or “our”). You can use our services (hereinafter such search functionality is referenced as “DrukBeesl” or “service”).
This Statement describes:
1. What Data do We Collect About You?
2. How do We Use Your Data?
3. How Long do We Store Your Data?
4. How do We Share Your Data?
5. What are Your Rights and Options?
6. How to Contact Us?
7. How do We Update this Statement?
1 What Data do We Collect About You?

As part of the DrukBees, we shall collect and use your personal data only for the purposes stated in this Statement. Personal data refers to any information that enables us to identify you as a user.

We may collect and process the following publicly accessible information:
As part of providing DrukBees we may collect and index information about you from publicly accessible sources. The content being indexed may include sensitive information about you.
You have the right to request delisting of a search result when it comes up against a search on your name in accordance with Section 5.6. As part of such request we shall collect and process information such as your full legal name, contact information, identification documentation, delisting URLs, delisting reasons, search name subject to delisting request.
We shall collect and process the following data of DrukBees users:
Account information: such as your account identifier, age, photo, nickname, country code and access token if you have connected your DrukBees ID to Search.
Device information: such as screen size and time zone.
Network information: such as IP-address (we only use IP-address for preventing ads click fraud)
Service usage information: such as ads clicks, search queries, search keywords (derived from the search query), search intent (derived from search query), search channel name (e.g. “news”) and ID, duration of the search, query ID (unique ID assigned for each of your search query), index ID (order of presented search results), search language and region and clicked URLs.
2 How do We Use Your Data?
Collection and Indexing of Publicly Accessible Information

As part of providing DrukBees, which serves the interest of DrukBees users to search and receive information, we may collect information about you from publicly accessible sources. DrukBees may index, for example, your name from an online newspaper as part of indexing the content of the newspaper and make it visible in search results to other people using DrukBees and searching with your name. The content being indexed may include sensitive information about you.

Handling Delisting Requests

If you request for delisting of a search result, we will use the personal information that you supply on the delisting form and any personal information you may submit in further correspondence for the purposes of processing your request and meeting our legal obligations.

Processing of DrukBees Users’ Information

To fulfill the contractual obligations in relation to DrukBees Browser, Search and DrukBees ID, we will use and process your personal data. This data is processed for customer relationship management, support provision and communication, customer complaint handling, maintenance, software and system updates, user identification as well as for problem diagnosis and fixing. The above mentioned processing of your personal data is based on your contract with us.

In addition, we use DrukBees users’ personal data for the following purposes based on legitimate interest pursued by us:

Search functionality

To enable the search functionality we need to process the following data: your language, region, device screen size, time zone, search query and a query ID. When you conduct a search, we never link or associate the search query to you as a specific user. The search queries (the terms you have used for the search) are collected and stored using random identifiers, such as “ab7221ca3d9f4a43a425ce1e5b85c13”, which are created unique for each search query by DrukBees.

We use your language, region, time zone and device’s screen size to tailor the search results presented to you.

We may derive your search intent from the search keywords identified from your search query to predict the intent of your search. For example, if you search with a film title, we may predict that you are searching for videos. In that case we would preference videos in the search results presented to you. The different intent categories used for such prediction include “human”, “location”, “music”, “animal”, “plant”, “video” and “video artist”. Such intentions are never linked to you as a specific user, but linked to a query specific random identifier to preserve your privacy in Search.

By analyzing search keywords, we may predict your search intention and provide specific Search features regarding topics of you interests such as apps, weather, flights, hotels, sport results and translator. For example, if you do a search with a specific name of a sports team or league, we may prompt relevant sports results to you. Also, if you, for example, do different searches with city names (e.g. “from Madrid to Rome”, “hotels in Rome” or “weather in Rome”), we may prompt relevant information regarding available flights, hotels and weather by analyzing your search query. Such features may be provided in co-operation with our partners. We never share any data with such third party partners, which could be associated or linked to you as a specific user (e.g. we may share general factors, such as, city, time and language information to enable the features).

Search suggestions

We analyze keywords derived from users’ search queries to calculate top keywords used by our users. Such analysis is done on an aggregated basis and we do not link or associate the keywords to you as a specific user. Such processing enables us to provide you search recommendations and real-time search suggestions as well as hot content (e.g. trending news and personalities). In practice, we calculate which search keywords are most common and which, for example, news and persons receive search hits the most. The following data is used for such functionalities: search keywords and respective user count, search language and region. The keywords are collected and stored without any identifiers or other data that could be linked or associated with you.

For “Recommended searches” we may derive your search intent from the search keywords identified from your search query to predict the intent of your search. For example, if you search with a film title, we may predict that you are searching for videos. In that case we would provide you “recommended searches” with a preference to videos. The different intent categories used for such prediction include “human”, “location”, “music”, “animal”, “plant”, “video” and “video artist”. Such intentions are never linked to you as a specific user.

We use your language, region, time zone and device’s screen size to tailor the search results presented to you.

We also use your language, region, time zone and device’s screen size to tailor the suggestions presented to you.

Service Improvement

In order to improve the quality of our search service (e.g. improve our search algorithms), we will store the URLs of the search results you have clicked. In practice we analyze the kind of queries our users make and the search results that they choose to follow up. We do not link or associate the URLs to you as a specific user. The URLs are collected and stored without any identifier or other data that could be linked or associated with you.

User Statistics

We generate general statistics and business insight based on Search users’ data (e.g. to know how many Search users are there in total, etc.). Such analysis of our users, which is always conducted on aggregated basis, enables us to understand our users and to improve the quality and user experience of our current and future services and offerings.

The following data is used for such statistical purposes: channel name (such as “news”), channel ID (such as “10”), duration of the search, ID of the search index and search result page, search language, returned URL list, clicked URLs and search region. The data is collected and stored without any identifier or other data that could be linked or associated with you.

Ads

We may use your search query to provide contextual ads based on automatically identified keywords from your query. This enables us to show you ads that are relevant to you. For example, if your search query includes “hotel” we may show you ads relating to hotels.

In addition, we collect your ads clicks and views information to handle our business with our ads partners. We only share aggregated summary data with our partners.

We never link or associate the search query or any subsequent clicks to you as a specific user. The search queries and any subsequent clicks are collected and stored using random identifiers, such as “ab7221ca3d9f4a43a425ce1e5b85c13”, which are created unique for each search query and subsequent delivery of ads.

Security and Fraud Prevention

In relation to ads clicks, we collect your IP-address in order to detect possible fraud (e.g. an attacker using automatic software to click systematically on an advertisement) and to safeguard our ads partners from being unfairly charged. We also use log information, which may include search queries, for security purposes to provide you with secure and reliable services.

3 How Long do We Store Your Data?

We will retain your personal data for no longer than is necessary for the purposes defined in this Statement.

DrukBees Users

We will process your data for the duration of the customer relationship. All search queries, which are collected with an identifier or any comparable data, will be erased within six (6) months from the collection of the data.

In addition we shall retain:

Personal data processed for customer relationship management such as data subject requests, complaints and customer interaction records up to six (6) years from the last interaction.
Personal data processed for contract management purposes up to three (3) years after your DrukBees ID has been deleted.
Backups and app logs, which are processed for fraud prevention, including for ads click fraud, and for ensuring the security of your data and services, for up to twelve (12) months from the date they were created. The data is stored for twelve (12) months to ensure the effectiveness of our anti-fraud and security measures. Our logs may contain information about search queries, but they are not stored with any unique identifiers or other comparable data, which would allow correlation of stored search queries.

Once the retention period expires, we will delete or anonymize your personal data, unless otherwise required by applicable laws and regulations.

We shall collect and process the following data of DrukBees users:
Account information: such as your account identifier, age, photo, nickname, country code and access token if you have connected your DrukBees ID to Search. We use age information from DrukBees ID account to automatically enable the Safe-Search functionality with the aim of blocking inappropriate content from children.
Device information: such as screen size and time zone.
Network information: such as IP-address (we only use IP-address for preventing ads click fraud)
Service usage information: such as ads clicks, search queries, search keywords (derived from the search query), search intent (derived from search query), search channel name (e.g. “news”) and ID, duration of the search, query ID (unique ID assigned for each of your search query), index ID (order of presented search results), search language and region and clicked URLs.
Search result delisting requesters

If you make a search result delisting request, we may store the request and the interaction records up to six (6) years from the closing of your removal request. We will erase any copies of identification documents you have provided to us within a month of closing your removal request except as otherwise required by applicable laws and regulations.

4 How do We Share Your Data?

We will collect and index publicly available information to servers located in Bhutan.

DrukBees users

We share your data in the following ways:

Our third party vendors, who provide us with IT (including cloud-based) services and business support as well as customer care services, may need to process your information. All such third parties are operating under contract and acting on behalf of us. Our IT vendors may also process your data from Bhutan Only.
When required in response to a legal process or request from a competent authority based on an applicable law or in connection with legal proceeding or process.
When required as part of merger, acquisition, sale of assets (such as service agreements) or transition of service to a DrukBees group entity or other company.

When the transferring and disclosing your data outside the EU/EEA, where the local law may not provide the same level of protection as in the EU/EEA, we shall comply with applicable legal requirements for providing adequate safeguards by incorporating the EU Commission standard data protection model clauses to such transfers. If you want to obtain a copy of the actual signed standard data protection model clauses, please contact us.

Search result delisting requesters

In addition to the above mentioned, when you request delisting of search results, we may share the details of the request with third parties providing us with legal or other professional support as to handling the requests. We may also need to share details of your request with data protection authorities, if they require these details to investigate or review a decision that we have made (e.g. if you have chosen to contact authority about our decision).

5 What are Your Rights and Options?

You have the following data subject rights and choices regarding your personal data.

5.1 Access your data

As DrukBees user you can request information and a copy of personal data that we have collected and stored about you in relation to Search by contacting us.

5.2 Port your data

As DrukBees user you can request your personal data, which you have provided to us in relation to Search, to be ported to you in a commonly used machine readable format by contacting us.

5.3 Erase your data

As DrukBees user you may at any time:

Object to the processing of your data, as detailed in Section 5.4. If your objection is valid, and we no longer have legal basis to continue processing your data, we will erase the relevant data within your effective objection.
Request delisting of a search result, as detailed in Section 5.6. If your request is valid, we will remove the requested search results coming up against a search on your name.
Contact us if you think the processing of your personal data is unlawful and your data should be erased.

We shall erase or anonymize your personal data without undue delay in accordance with the retention periods detailed in Section 3.

5.4 Object to processing

If you want to object to the processing of your data, please contact us.

When making the request, please specify the scope of the request.c

For requests concerning delisting of a search result, please see Section 5.6.

5.5 Restrict processing

If you want to restrict the processing of your personal data, please contact us. As a DrukBees user you have the right to restrict the processing of your date in the following cases:

Your data is unlawfully processed but you do not want to erase it.
You have a legal claim that you need to establish, exercise and defend, and you requested us to keep your data when we would not keep it otherwise.
You have contested the accuracy of your personal data and the accuracy of your data is pending our verification.
Your request for objection is pending our verification.

When submitting the request, please specify the scope and the basis of the request. We will contact you to verify your identity in order to proceed with your request.

5.6 Delist search results

You have the right to request delisting of a search result when it comes up against a search on your name. When we assess the request we will balance your privacy rights with the interest of the general public in having access to the information as well as the right of others to distribute the information. You can file a request and find more information about the assessment criteria here.

6 How to Contact Us?

You can find advice on how to exercise your data subject’s rights in Section 5. If you have any questions on your rights as a data subject or the processing of your personal data by us or if you want to contact our Data Protection Officer, please contact us

Our headquarters’ address: DrukBees, Norlha Building, Dooebum Lam, 11001, Thimphu, Bhutan.

If you believe that we are not processing your personal data in accordance with this Statement or the applicable data protection laws, you can lodge a complaint with your data protection authority, or the Data Protection Officer in Ireland.

7 How do We Update this Statement?

We encourage you to regularly check for the latest version of this Statement in the app settings as we may change it in due course. In the event of material changes to this Statement, we will inform you of such changes by an appropriate method, such as a notification dialogue box, push message, email, and so on, depending on the nature of the change.

Latest update: August 2020.

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