Privacy Policy GifYou

Last updated 20 January 2020

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, together with companies in the same corporate group, take your privacy seriously. Please, read carefully this Privacy Policy as it sets out our data processing practices with respect to your data collected via Banuba App.

This Privacy Policy is an integral part of Our Terms and Conditions and refers to Banuba Apps, incl. GIFYOU and other Apps operated by Banuba Limited, hereinafter – the “App/ Apps/ Banuba App/ Banuba Apps”. All definitions used in this Privacy Policy (if not explicitly mentioned herein) shall have the same meaning as provided in Our Terms and Conditions.

“Advertising ID” means Apple Identifier for Advertisers (“IDFA”). These are unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.

“Device identifier”means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.

“IP address” or “Internet Protocol Address” mean addresses assigned to computers connected to the Internet. Those addresses can be “dynamic” which means they change each time the computer connects to the Internet, or they can be “static” which means that they are fixed. When a computer requests a web page or other content on the Internet, it sends its IP address to the computer hosting that content asking the server to return the content to its IP address. Without the address, the server would not know where to send the content. 

“Your (personal) data” in this Privacy Policy shall mean any data regarding You or users of the App, which identifies or allows to identify You.

1. ACCEPTANCE OF THIS PRIVACY POLICY

2. INFORMATION COLLECTED

2.1 Information We Collect
To use our App You need to enable Your camera. However, all images taken by your mobile phone camera shall be processed solely on your device and shall not be sent to our servers, i.e. we do not have access to such images (we will not collect, share or store them). We will ask for Your separate permissions to enable Your camera. If You change Your mind, You will be able to revoke the given permission any time afterwards by changing settings on Your Device or by e-mailing your request to [email protected]. However, please note that rejecting or switching off this permission might negatively affect the use of our Apps or even effect its full functionality.

Provider Provider’s Data Policy
Facebook Analytics https://www.facebook.com/policy.php
Amplitude https://amplitude.com/privacy
Appsflyer https://www.appsflyer.com/privacy-policy/

To see the list of open source licenses used please follow the link.

The lists of Providers and open source licenses used may be amended from time to time, please refer to this Privacy Policy to obtain up-to-date information.

3. BASES FOR PROCESSING

3.1. The legal bases that we rely upon when processing your personal data are as follows: 

We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. 

These legitimate interests are: (a) to ensure effective administration and management of your relationship with us; (b) to understand how you use our Services and how we can improve the customers usage experience; (c) understand and respond to your feedback; (d) to prevent, detect, or investigate unauthorized use of our Services; (e) ensure we comply with law and our policies; (f) anti-fraud reasons; and (g) manage any disputes and accidents and take legal or other professional advice.

3.2. 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 will lose its full functionality.

4. PURPOSES OF PROCESSING

4.1. We will process data collected under this Privacy Policy for the purposes of: 

4.1.1. Personal data mentioned in Clause 2.2.2 shall be processed by Our Providers for the purposes of:

Please refer to the Privacy Policies of each Provider available at the respective web sites.

4.2. In case you voluntarily provide us with any additional personal data, we shall process these data solely for the purposes for which they were provided to us and for no longer they are needed to fulfil such purposes.

4.3. We limit access to data we hold about you to employees who we believe reasonably need to come into contact with that information to provide Services to you or in order to fulfil their official duties. These employees are bound by confidentiality obligations and may be subject to liability, if they fail to meet these obligations. We will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this Privacy Policy.

4.4. Information collected under Clause 2.2.2. will be used for automated decision making, as our Providers perform their advertising and analytics services based on automated analysis of your browsing behavior. As a consequence of automated decision making: 

4.5. You can always limit collection of Your data used for targeting by managing your mobile devices:

On Your iPhone, iPad, or iPod touch:

Note: If you clear your cache, you’ll lose your opt-out setting.

5. SHARING OF DATA

5.1. We cannot provide all Services by ourselves. We must, therefore, share collected information with third parties for the purposes as described in section 4 of this Policy. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it. 

Your information may become available for the following categories of recipients: 

5.2. We may also share your data when it is required by law and/or any regulatory authority. In such circumstances, we will expressly inform the recipient of the confidential nature of the data shared. 

5.3. Our third-party providers with whom we share your data or which directly collect such data via integration with Banuba App may be located in non-EEA countries, where data protection and privacy regulations may be different from your home country and offer even lower level of protection. You acknowledge such transfer and processing of your data out of EEA to the countries where data protection and privacy regulations may be different from your home country and offer even lower level of protection. To safeguard your interests when transferring your personal data out of EEA, we will conclude with all out-of-EEA recipients standard data protection clauses adopted by the European Commission or our supervisory authority.

5.4. All third parties with which We share your data only get the minimum amount of data that are reasonably required in order for them to provide their service to us and therefore to you. The use of the shared information by such third parties is strictly limited to the purposes of processing outlined in Section 4 and is not permitted for any other purpose. All third parties with which we share your data are required to protect such data in accordance with all relevant laws and regulations and in a manner similar to the way we protect the same. 

5.5. We will not share your data with third parties which are considered as not being able to provide its clients and potential client with the required level of protection.

6. YOUR RIGHTS

6.1. We respect the privacy rights of our users, and to the extent required by applicable law, will make reasonable commercial efforts to allow you to access, correct, object to the processing of, delete or port any of your personal data, provided that we are able to properly verify your identity and link it to any personal data in our possession. With respect to your personal data we process (if any) you have the right: 

Please contact us via [email protected] to execute any of the rights as stated above.

7. PROTECTING CHILDREN’S PRIVACY

7.1. We do not knowingly collect or process personal data from or with respect to children under the age of 17, and you must be 17 years of age or older in order to use Services.

7.2. If you are a parent or legal guardian and believe that your child under the age of 17 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will promptly act to remove your child’s data from our database, cease the use of such data and inform any other party we suspect to have access to such data to do the same.

8. PERIOD OF PROCESSING

8.1. Records of email, IP addresses and device ID are retained for as long as we need to deliver services to you unless we have a bases to further process your data as described in the Section 3 of this Policy. 

8.2. If you request erasure of your data or you deleted our Apps from your device or you unsubscribed from our marketing communications we erase your data from our servers and request our providers to do the same within 30 days upon your request.  

8.3. With respect to non-personal data We are not limited by any particular retention period.

9. PRIVACY POLICY UPDATES

9.1. We shall update this Privacy Policy from time to time. In the event we materially change this Privacy Policy including how We collect, process or use Your personal data, you will receive the respective notification via Banuba App. 

9.2. Any changes to this Privacy Policy with respect to processing of your personal data shall be subject to your prior consent, unless they are required under applicable law.

9.3. Unless otherwise required by law, any changes to this Privacy Policy with respect to processing of your non-personal data and changes with respect to processing of your personal data shall become effective immediately upon their posting in the App.

9.4. In case you continue to use Banuba App after you have received the notification about the changes we presume that you have read the new Privacy Policy and accept all the introduced changes.

9.5. It is your responsibility to periodically review this Privacy Policy to be aware of the current changes (as we will notify you only about the material changes).

9.6. If you do not accept Privacy Policy following an amendment, do not start or continue to use Banuba App.

10. QUESTIONS AND COMPLAINTS

10.1. If you have any requests concerning your personal information or any queries with regard to this Privacy Policy or if you consider that our collection, usage, disclosure and/or storage of your personal information violate any applicable data protection laws we are bound by, please feel free to contact us via [email protected]. We will consider your requests within reasonable time and provide you with an answer.