Privacy Policy

Version March 2025 (Version 3)

Important Information and Who We Are

BLUEDESK LIMITED is the controller and is responsible for your personal data (collectively referred to as “Company““we““us“, or “our“ in this policy).

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. This version was last updated in March 2025. It may change, and if it does, these changes will be posted on this page and will be shared with users via emails and in-app notifications to review and accept.

The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you as follows:

Our platform handles two types of information:

Platform Usage Information

This data helps us understand how our system is being used and includes:

Identity Data

Like Full name and username.

We collect the full name and username to create and manage your account and to use in the login process.

Identity data are retained as long as the account is active.

Contact Data

Like email address and phone number.

We collect the email address to create and manage your account, verify the account via email, and use it to reset the password upon user request.

We collect the phone number to verify the account via SMS. Note that the account needs only one of these contact data to be verified.

Contact data are retained as long as the account is active.

Transaction Data

We only save the transaction ID to get its status from the payment gateway.

Device Data

BrandModelAndroid versionBuild numberDevice ID

Device ID: Android Advertising ID, device serial number (if applicable). We collect the Android Advertising ID for analytics and troubleshooting, and the device serial number for unique device identification in bug reporting.

We don’t collect the device serial number.

Location Data

With user permission, we collect precise GPS coordinates for the start and end locations during interviews. Location data is stored for the duration of the interview or survey response.

The user can access and see these locations via the web interface and can delete them upon deleting the interview record.

Marketing and Communications Data

To manage communication channels and ensure effective delivery of information, we keep records about the following communication data: emails sentpush notifications deliveredSMS messages sent.

We also record users’ marketing preferences, such as opt-in and opt-out statuses.

These data are retained as long as the user is active.

Financial Data

We don’t save any financial data.

Usage Data

Troubleshooting: In internal test versions of the mobile app, we collect usage data for troubleshooting and debugging. This data includes feature usage, screen interactions, and crash logs. The resulting log is only shared manually by the user.

Users participating in internal testing are invited via a clear message, to which they can join or decline.

Mobile users can opt out of usage data collection by selecting the option to “Leave the program“ in Google Play.

In production versions of the app, we do not collect usage data.

Audit Logs

We maintain audit logs within our secure Microsoft SQL Server database to track user actions on the web system for security, compliance, troubleshooting, and to facilitate the undoing of unintended actions.

These logs track the following specific actions, including the user that made the change: project creation timestampsurvey update detailsuser deletion record, and other create, update, and delete events.

These logs track actions related to main objects and features in the system, such as projects, surveys, interviews, data views, and user accounts.

Audit logs are retained for 3 months and are protected by Microsoft SQL Server’s Transparent Data Encryption feature. Access is restricted to authorized personnel only.

Audit logs can fall under usage data. We comply with all relevant legal requirements regarding audit logging.

Error Logging

To facilitate troubleshooting and improve the stability of our mobile app and web system, we use third-party error logging tools:

  • InstaBug (Mobile App): InstaBug automatically collects error logs, including device information (model, OS version), app version, stack traces, and the name of the function leading to the error. This data helps us identify and fix bugs. You can review InstaBug’s privacy policy here. Data collected by InstaBug is retained for the amount mentioned in their privacy policy.
  • Sentry (Web System): Sentry automatically collects error logs, including browser information, operating system, stack traces, and user actions leading to the error. This data is used to diagnose and resolve technical issues. You can review Sentry’s privacy policy here. Data collected by Sentry is retained for the amount mentioned in their privacy policy.

Users cannot directly opt out of error logging, as it is essential for maintaining system stability. However, we ensure that error logs are used solely for troubleshooting and are protected according to the privacy policies of InstaBug and Sentry.

Respondent Data

The information collected through your surveys is entirely controlled by you. As the survey creator, you determine what data is collected and how it is used. Our system securely stores this respondent data as a data processor, following your instructions. You are responsible for complying with all applicable privacy laws regarding the data you collect.

Content Data

ImagesAudiosVideos, and normal document files (pdfdocx, etc.).

The user can create a form/survey that contains media content questions, in which the enumerator can select files, shoot images, or record audios and videos.

These content files are kept as long as the interview data are used and retained.

Voice Recording Data

The user who is designing the survey might enable a flag for background voice recording during the interview for quality assurance purposes.

The mobile app shows a clear message to get explicit user consent to record voice conversations during the interviews, showing a clear icon to indicate when the background voice recording is on.

These recordings are content data and are stored locally on the device with encryption, then transferred with encryption to the server, and stored on our encrypted servers without sharing them with any third party.

The user can access, view, and delete these recordings by logging in to the web interface using their same credentials.

The background voice recordings are kept as long as the interview data are used and retained.

Voice recordings will be deleted with the deletion of the interview or the project.

Voice recordings might happen in the background. The user can stop the background recording by ending, stopping, or pausing the data collection section (the interview).

Location Data

We provide the ability to include location questions (pointline, and area) within the survey design, which allows users to select or provide location data within survey forms.

Location data is retained for the duration of the interview and can be accessed, changed, and deleted via the web interface.

Aggregated Data

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

Data Under Our Control

Data under our control includes registration data (e.g., email, organization name, organization website, country, business sector, and domain) and site visitor data (e.g., website analytics). This data is used in aggregated ways to monitor usage and growth of Bluedesk Limited. Personal information from registered users is used to provide services to registered users and communicate with them about our services. Registered users can view, edit, and delete their personal information stored in their profile, unregister from communication emails, or delete their account.

What Type of Data Do We Control and Process?

This data privacy policy distinguishes between data that is controlled by Bluedesk Limited and data that is processed by Bluedesk Limited.

Data Controller

We are a data controller of very limited data about account holders and site visitors (i.e., we determine the purposes, conditions, and means of the processing of personal data). Bluedesk Limited collects web page analytics from unregistered and registered users of its web page using Google Analytics – pages visited, clicks, browser used, language choice, country of origin, and so on. For registered users, Bluedesk Limited collects the following as part of the registration process:

  • Email
  • Organization name
  • Organization website
  • Country
  • Business sector
  • Domain

This information is stored in the user’s profile along with their preferences.

Data Processor

We act as a data processor for data collected by account holders (i.e., we process data on behalf of a data controller). Once a registered user creates a project, Bluedesk Limited stores the information related to the survey and data collected by the account holder. This includes data submitted by participants completing surveys designed by registered users and can include personal information.

International Transfers

We may share your personal data with organizations. This will involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules“. For further details, see European Commission: Binding corporate rules.

Many of our external third parties are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Mobile App Permissions

Here is a list of the permissions needed in our mobile app and their uses. Users can control or revoke these permissions through their device settings:

  1. android.permission.INTERNET – Allows the app to access the internet to communicate with our servers and download data.
  2. android.permission.ACCESS_NETWORK_STATE – Allows the app to check the internet connectivity status, and it is used for this purpose.
  3. android.permission.RECORD_AUDIO – Grants permission to record audio from the microphone to answer audio questions in the survey. This is only done with explicit user consent. The audio recording might occur in the background, as explained in another section of this document.
  4. android.permission.MODIFY_AUDIO_SETTINGS – Allows the app to modify audio settings, such as volume and routing, to answer audio questions in the survey. This is only done with explicit user consent.
  5. Manifest.permission.CAPTURE_AUDIO_OUTPUT – Allows capturing system audio output to answer audio questions in the survey. This is only done with explicit user consent.
  6. com.google.android.gms.permission.AD_ID – Grants access to the Google Advertising ID for ad tracking. Users can limit ad tracking through their Google account settings.
  7. android.permission.READ_EXTERNAL_STORAGE – Allows the app to read files from external storage (deprecated in newer Android versions) to read the application files. Note that this is only used in old Android versions (before Android 13 (API level 33)).
  8. android.permission.WRITE_EXTERNAL_STORAGE – Grants permission to write files to external storage (deprecated in newer Android versions) to write the application files related to the media and files questions to the external storage. Note that this is only used in old Android versions (before Android 13 (API level 33)).

    The application files mentioned in the above two permissions are the images, videos, audios, and office files that are collected during the user-designed survey.

  9. android.hardware.camera (uses-feature) – Declares that the app requires a camera to function, allowing the user to take pictures during the survey process.
  10. android.permission.FLASHLIGHT – Enables the app to control the flashlight to be used in taking pictures while answering image questions in any user-designed survey.
  11. android.permission.ACCESS_FINE_LOCATION – Allows the app to access precise (GPS-based) location data to be used in the location questions in any user-designed survey. The location can also be used to record the start and end locations of interviews with the user’s explicit consent.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Mobile App Security Measures

  • A secret key will be generated on each mobile upon installing the App.
  • The secret key will be saved locally in the app’s secured storage within the mobile device and will not be shared.
  • Data and files will be encrypted using the AES Algorithm with this secret key.
  • The secret key will be encrypted using the RSA Algorithm.

Data Transfer Security Measures

  • Transferred data (interviews’ answers, interviews’ related files) are encrypted using the AES algorithm with a secret key that is encrypted using the RSA algorithm.
  • Requests are sent using POST.
  • We only use the HTTPS protocol.

Database Security Measures

  • We depend on Microsoft SQL Server’s Transparent Data Encryption (TDE) feature.
  • Access to the database is also protected by strong authentication and authorization mechanisms.

Additional Security Measures

We implement robust security measures to protect your personal data from unauthorized access, use, or disclosure. These measures include:

  • Firewalls and intrusion detection systems to monitor and protect our network.
  • Regular security audits and vulnerability assessments to identify and address potential weaknesses.
  • Employee security training to ensure awareness of best practices.
  • Data minimization principles to limit the collection of unnecessary data.
  • Strict access control lists to restrict access to sensitive data.
  • We regularly update our systems and software to patch security vulnerabilities.

Data Retention

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting, or other requirements.

Third Party Links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies. We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data.

Third Party Integrations

We integrate our system with the following third-party services to enhance functionality and provide a better user experience:

Communication

  • Twilio: We use Twilio for sending SMS messages. When you use SMS verification or receive SMS notifications, your phone number and message content are transmitted to Twilio. You can review Twilio’s privacy policy here. Data retention: up to 13 months by default.
  • Azure Communication Services: We use Azure Communication Services for sending emails. When you use email verification or receive a reset password email, your email address and the sent emails data are transmitted to Azure. You can review Azure Communication Services’ privacy policy here. Data collected by Azure Communication Services is retained for the amount mentioned in their privacy policy.

Error Logging

  • InstaBug (Mobile App): InstaBug automatically collects error logs, including device information (model, OS version), app version, stack traces, and the name of the function leading to the error. This data helps us identify and fix bugs. You can review InstaBug’s privacy policy here. Data collected by InstaBug is retained for the amount mentioned in their privacy policy.
  • Sentry (Web System): Sentry automatically collects error logs, including browser information, operating system, stack traces, and user actions leading to the error. This data is used to diagnose and resolve technical issues. You can review Sentry’s privacy policy here. Data collected by Sentry is retained for the amount mentioned in their privacy policy.

Maps

  • Google Maps APIs: We use Google Maps APIs to display maps and provide location-based services. When you use these features, your location data and map usage data are transmitted to Google. You can review Google’s privacy policy here. Data retention: Google’s data retention policy is here.

Data Quality

  • ChatGPT (OpenAI): We use ChatGPT to analyze survey responses. When survey responses are submitted, the text of the responses is transmitted to OpenAI. OpenAI processes the data to analyze data profiling, basic patterns and anomalies, identify inconsistencies like duplications or contradictions, and enhance the survey design. You can review OpenAI’s privacy policy here. Data retention: 30 days. We do not use user data to train the ChatGPT model.

Users cannot opt out of the data sent to these third parties, as they are essential for the functionality of the application.

Children Privacy Section

Our system is not intended for children.

GDPR Compliance

We are committed to protecting your personal data and respecting your rights under the General Data Protection Regulation (GDPR). This section outlines how we comply with GDPR principles and your rights as a data subject.

Legal Basis for Processing

We process your personal data based on one or more of the following legal bases:

  • Consent: Where you have given us explicit consent to process your data for a specific purpose (e.g., troubleshooting and debugging).
  • Contractual Necessity: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering a contract.
  • Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject.
  • Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party), provided your rights and interests do not override those interests. We ensure that our legitimate interests are balanced against your rights.

Your GDPR Rights

Under the GDPR, you have the following rights:

  • Right to Access: You have the right to request access to the personal data we hold about you.
  • Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
  • Right to Erasure (“Right to be Forgotten“): You have the right to request that we delete your personal data under certain circumstances.
  • Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data under certain circumstances.
  • Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
  • Right to Object: You have the right to object to the processing of your personal data under certain circumstances, including direct marketing.
  • Right to Withdraw Consent: Where we rely on your consent to process your data, you have the right to withdraw that consent at any time.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority.

Exercising Your Rights

To exercise any of your GDPR rights, please contact us using the contact details provided in the “Contact Us“ section of this privacy policy. We will respond to your request within the timeframes specified by the GDPR.

Data Transfers Outside the EEA

If we transfer your personal data outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place to protect your data, such as:

  • Adequacy decisions by the European Commission.
  • Standard Contractual Clauses approved by the European Commission.

Contact Us

If you are uncertain about our data privacy policy or have requests with regards to general compliance, including GDPR rights, please contact us at [email protected].