Privacy Policy

Last updated 25 May 2018

Banuba Limited, having its registered address at Office A, 16/F Heng Shan Centre 145 Queen’s Road East, Wan Chai, Hong Kong, reg. No. 2360577 (hereinafter – Banuba Limited), together with companies in the same corporate group, take your privacy very seriously. Please, read carefully this following document to find about our Privacy Policy. This Privacy Policy sets out our data processing practices and your options regarding the ways in which your personal information is used.

This Privacy Policy outlines how we manage the personal data we collect from your use of our services, applications or our website, through your interaction with us on social media or your other dealings with us. When doing that we act in accordance to the principles contained in data protection regulations, including The General Data Protection Regulation (GDPR) (EU) 2016/679. The Company’s contact with regards to any queries about Data protection will be the Legal Department which can be contacted through email on:

Terms and Definitions

The following terms used in this Privacy Policy shall have the following definitions:

2. Consent

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

Tracking 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.

Clients consent to the collection, processing, storage and use of personal information by the Company as outlined below when accepting the Company’s Privacy Policy. Potential clients will be prompted to consent to the same by accepting this Privacy Policy through means that would allow us to trace and record that such consent has been properly given in the first place.

With regards to our collection and processing of your personal data you have the right to:

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:

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 does not sell, license, lease or otherwise disclose your personal information to third parties, except as described in this Privacy Policy.

We may disclose personal information if: (a) it is requested by any judicial, non-judicial state or supranational authority required by any applicable laws, regulation, edict, local acts; (b) it is shared under Section 3 of this Privacy Policy; (c) it is necessary for national security, law enforcement, or other issues of public importance that disclosure of information is necessary. We may also disclose personal information to companies within Our corporate group of companies

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:

# Name Location Access Purpose
1 Facebook Marketing Management Marketing automation
2 Appsflyer EU Marketing Management Marketing automation
3 Amplitude United States Marketing Management Marketing automation
Product analytics
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
8 Amazon S3 Ireland Developers Storage
9 Amazon EC2 Ireland Developers Compute
10 Amazon lambda Ireland Developers Compute
11 Amazon DynamoDB Ireland Developers Database
12 Redshift Developers Database
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.

6. Storage

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.

7. Privacy Policy Updates

Banuba may update this Privacy Policy from time to time. In the event the Company materially changes this Policy including how it collects, processes or uses your personal information, You will be notified by means of the publication of the updated Privacy Policy on our website

Banuba encourages you to periodically review this Privacy Policy so that you are always aware of what information the Company collects, how it uses it and to whom it may disclose it, in accordance with the provisions of this Privacy Policy.

If you have any complaints in relation to the areas discussed above please forward your complaint to the Legal department of The responsible person is the Head of Legal. You can reach his department by email: