Last updated 25 May 2018
Terms and Definitions
- “You” and “Your” relates to you, the user of Banuba mobile Apps;
- “We”, “Our” and “Us” relates to Banuba Limited and the companies in the same corporate group;
- “Banuba mobile Apps” – mean Banuba App and other Apps developed by Banuba Limited.
- “Banuba App” – means Banuba mobile app which enables people to create photos and videos using filters and video effects;
- “Services” – services of Banuba App.
- “information” – both personal and non-personal information.
Whenever we collect and process your personal data we do this as a data controller and with your explicit consent and for legitimate purposes. Within the categories of internal, external, social and tracking data, the Company collects the following personal data:
2.1 Internet Protocol Address
2.1.1 Category of personal data
2.1.2 What information falls under this category
IP-address, device id, browsing behaviour, location
2.1.3 Purpose of processing or legal basis
The purpose for acquiring and tracking this data is mainly for analytics and advertisement reasons. The Company is dealing with analytical, back end and ad providers that use the IP-Address and Device ID to detect potential needs. In order for the Company to provide a state of the art and customised client experience it is necessary for marketing and development to use this data with regards to your preferences.
2.1.4 Source of the data
The data is retrieved during the use of the application
2.1.5 Existence of automated decision making or profiling
Based on browsing behaviour analytical and back end providers can help us to improve the application and ad providers can send you tips and related advertisement.
2.1.6 Statutory obligation or Contractual requirement. Consequence of not providing the data by the client
Analytical, back end and ad providers will be disabled. Relevant advertisement with regards to your preferable instruments and tips with regards to your browsing behaviour will not be customised.
With regards to our collection and processing of your personal data you have the right to:
- unconditionally withdraw your consent to the collection, processing, storage and use of personal information by the Company. The client is also allowed to partially give consent to specific collection, processing and storage of personal data. At the time of giving consent you will be given several options to specify your consent.
- Erasure of personal details for non-active clients.
- Rectify your personal details on your request.
- Object to processing after giving the Company consent to collect, process and store your personal data. If you want to make use of any of the above rights please contact our compliance department and send question related to any of the above rights at: email@example.com
3. Collection & Usage of Personal Information
We will not rent, sell, or share Your personal information with any third-parties, except as specifically described herein.
We will use personal information collected via Banuba App for the purposes of:
- providing and personalising the Services, monitoring usage of Banuba App;
- helping Us create, develop, operate, deliver, protect, promote and improve Our products, Services, content and advertising, to deliver personalized experiences and for loss prevention purposes. For example, so that Our Services work well for You, We offer tools that apply filters and video effects, that fit the contours of Your face, that modify the size and shape of facial features such as Your nose or eyes, or that follow facial movements in videos. In order to enable these Services, We use the information We have to distinguish patterns of shape and form that compose a digital image of a still or moving face. For the purposes of developing and improving Our products and Services, We may also make photo or video records of Your using the Services;
- dealing with Your enquiries and requests;
- analysing the video effects that are selected and how people share images or videos, such as from Banuba App to third-party services, or conducting surveys and researches, producing reports and statistics on the usage of Banuba App, testing features in development, and analysing the information We have to evaluate and improve products and Services, develop new products or features, and conduct audits and troubleshooting activities;
- sharing information with financial institutions, relevant authorities and/or any person or entity that has the legal right to such information, as well as verifying Your identity, if We suspect that You have engaged or attempted to engage in fraudulent, unlawful, dishonest or improper activity while using the Services;
- detecting and resolving any fraud or security concerns arising out of or relating to the Services;
- being compliant with any valid legal process, governmental request, or applicable law, rule, or regulation, preventing unlawful, dishonest or improper activity;
- sharing information with Our legal advisors and insurers in case of legal disputes and claims;
- sharing information with third party service providers to the extent that it is reasonably necessary to perform, improve, promote, protect or maintain the Services. For example, We may use third-party analytics tools to help Us measure use of Our Services, or We may use vendors that provide infrastructure services to help Us provide and maintain the Services.
- sending You messages about faults and service issues, keeping You up to date with news about Our software and products that You have purchased and/or other Banuba products and related information. For these purposes We may engage third party providers (e.g. those providing push notification services) and share the information collected via Banuba App with them.
We will ask for Your separate permissions to use Your camera and microphone, as well as for sending push notifications to You. If You change Your mind re permissions granted, You will be able to revoke them at any time afterwards by changing settings on Your Device. However, please note that rejecting or switching off these permissions shall negatively affect the use of Banuba App: Banuba App shall lose its full functionality.
4. Protection of Personal Information
Any personal information provided by you to Banuba will be treated as confidential and shared only within the Company and its affiliates and will only be disclosed to a third party taking in account the principle of data minimisation (only the necessary info) or under any regulatory or legal proceedings. In case such disclosure is required to be made by law and/or any regulatory authority, it will be made on a ‘need-to-know’ basis, unless otherwise instructed by the law and/or regulatory authority. Under such circumstances, Banuba will expressly inform the third party of the confidential nature of the information. See the list of third parties in section 5.
5. Affiliates, Partners and Non-Affiliated Third Parties
Banuba may share information with its affiliates, partners, including those located inside and outside the European Economic Area (EEA), in the event such information is reasonably required by such affiliate to provide the services to you. In case any information is provided to affiliates inside or outside the EEA, the Company will do so in full compliance with the applicable EU-wide data protection regulations.
The personal data is shared with the following affiliates/partners:
|1||Marketing Management||Marketing automation|
|2||Appsflyer||EU||Marketing Management||Marketing automation|
|3||Amplitude||United States||Marketing Management||Marketing automation
|4||Pinpoint AWS||Ireland||Marketing Management||Marketing automation|
|5||iTunesconnect||United States||Management Developers||App store|
|6||Google Play||United States||Management Developers||App store|
|7||Amazon Cloudwatch||Ireland||Developers||Management Tools|
|13||Amazon VPC||Ireland||Developers||Networking & Content Delivery|
|14||Amazon CloudFront||Ireland||Developers||Networking & Content Delivery|
|15||Amazon Route 53||Ireland||Developers||Networking & Content Delivery|
|16||Amazon API Gateway||Ireland||Developers||Networking & Content Deliver|
|17||Amazon CloudTrail||Ireland||Developers||Management Tools|
|18||Amazon Trusted Advisor||Ireland||Developers||Management Tools|
|19||Amazon Cognito||Ireland||Developers||Security, Identity & Complience|
All the mentioned partners only get the minimum amount of personal data in order for them to provide their service to our company and therefore to you.
In addition, Banuba may engage third parties to carry out certain internal functions such as, client satisfaction surveys or other data collection activities. The use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. All third parties with which Banuba shares personal information are required to protect such personal information in accordance with all relevant laws & regulations and in a manner similar to the way the Company protects the same. Banuba will not share personal information with third parties which are considered as not being able to provide its clients and potential clients with the required level of protection.
Banuba will not engage any business introducers and no information will be passed by the Company to such entities.
The collected data will be permanently destroyed when the initial purpose for collecting or obtaining such information has been satisfied.
We will retain Your personal information for a reasonable period necessary to fulfil the purposes for collecting it or as long as applicable law requires.
If you have any complaints in relation to the areas discussed above please forward your complaint to the Legal department of Banuba.com. The responsible person is the Head of Legal. You can reach his department by email: firstname.lastname@example.org