Privacy Policy Slimy

Updated July 25, 2021

This privacy policy describes the way of use of your personal data in connection with your use of the app (“App”), a mobile application, and the services, features, or content Banuba Limited (“we”, “our”) offers in such App. 

This Privacy Policy is an integral part of the Terms and Conditions and all definitions have the same meaning as in the respective Terms and Conditions. Please, do not use the App if You do not agree to be bound by this Privacy Policy.

1. LEGITIMATE INTEREST

Our legitimate interest is to improve the performance of our App by processing of your personal data by ways prescribed in this Privacy Policy and provide you with information and services you request. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests.

The legitimate interest construed:

1) to ensure effective administration and management of your relationship with us; 

2) to understand how you use our App and how we can improve the customers usage experience; 

3) understand and respond to your feedback; 

4) to prevent, detect, or investigate unauthorized use of our App;

5) ensure we comply with law and our policies; and manage any disputes and accidents and take legal or other professional advice.

For the purposes of this Privacy Policy legitimate interest may include contractual necessity which covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you, 

AND

Legal obligation, which covers information that is processed by us to comply with a legal obligation.

We will ask for your separate permissions to use your camera when you use the App, 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 Apps, which will lose their full functionality.

1. INFORMATION COLLECTED

We do not collect any information, identifying you including your name, e-mail, phone number, advertising ID (“Personal Data”).

You may at any time voluntarily provide us with any Personal Data for particular circumstances by giving your express consent for collection and processing (when communicating with support team, leaving feedback in the App and any other means of communication). In such case, we will not associate collected Personal Data with other data about you.

1. THIRD-PARTY PROVIDERS 

Using the App, you may be able to use or get access to Third-Party Providers open-source licenses. In such event, the following Third-Party Providers may collect your Personal Data:

Your IP address, device ID, advertising IDs and location data are only Personal Data which may be collected by Third-Party Providers. Such information collected directly by Providers and will not be shared with us. Any collected by Third-Party Providers Personal Data is based on our legitimate interest and tested on case-by- case basis.

The Third-Party Provider is entitled to combine this type of your Personal Data with other Personal Data in their procession to use it for targeted advertising. The information concerning your usage of the App is also subject to Third-Party Providers collection to identify and fix the problems in the App. This information is not personalized or linked to your device. 

Some Third-Party Providers may generate a specific identifier for statistics and usage data that is specific to each App to control operation of the App. This identifier does not allow us to identify a specific user, but allows us to identify that a certain type of App use event belongs to one user.

Other Personal Data about your devices do not permitting direct association with you may be also collected by Third-Party Providers.

Third-Party Providers also collect information about your online-activity over time and across other Third-Party websites. Third-Party Providers do not respond to DNT (Do Not Track) signals, provided you ability to exercise your right to Personal Data collection. 

1. DATA PROCESSING PURPOSES

Your Personal Information or Data collected under this Privacy Policy shall be used by us for the purposes of delivering the services to you (including, maintaining and monitoring the proper operation of the App, fixing any problems in its operation); ensuring and protecting the safety and security of the App, protecting our Intellectual Property Rights and other rights; conducting statistical and analytical surveys and researches, in particular for improving the services and your user experience; displaying advertisement, i.e. showing the most relevant ads to you across Internet network; attribution and tracking the performance of our advertising campaigns and applications, including their effectiveness, usage, installations and downloads.

Your Personal Data collected by Third-Party Providers shall be processed by such Providers for the purposes of:

• attribution and tracking the performance of our advertising campaigns and applications, including their effectiveness, usage, installations and downloads;
• targeted advertising, i.e. for showing the most relevant ads to users of the devices across Internet network.

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

Our employees are bound by confidentiality obligations when we hold your Personal Data 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 may be subject to liability, if they fail to meet confidentiality obligations. We will take all steps reasonably necessary to ensure that your Personal Data are treated securely and in accordance with this Privacy Policy. 

Data collected shall be accessed via AdMob by certain ad technology providers who are allowed to serve and measure ads in the European Economic Area (EEA), to support ad delivery, ad measurement, and other functions. All ad technology providers provided Google with information about their compliance with the GDPR. 

Data collected under Section 2 shall be used for automated decision making, as Providers perform their advertising and analytics services based on automated analysis of your browsing behaviour. As a consequence of automated decision making you will receive advertisements throughout the Internet which the system considers the most relevant to you.

You can at any time limit collection of your Personal Information or Data used for targeting by managing your mobile devices by following ways if you do not want to be subject to automated decision making: 

On Your iPhone, iPad, or iPod touch:

• Go to Settings > Privacy > Advertising.
• Turn on Limit Ad Tracking.

On Your Android:

• Open your device's Settings app > Google, or open the Google Settings app (differs depending on your device).
• Under “Services,” select Ads.
• Turn on “Opt out of Ads Personalization” by moving the switch to the right until it turns blue.

If you clear your cache, you'll lose your opt-out setting.

Once you've turned off personalization, Google will no longer use your info to personalize your ads. Ads can still be targeted with info like your general location or the content of the website you’re visiting.

4.YOUR RIGHTS

We provide you with the following choices concerning your Personal Data we process: 

1. to access and control your Personal Data, i.e. to obtain from us your Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another controller without any obstacle on our side;
2. to opt-out targeted advertising. If you do not wish your data to be processed for receiving a personalized advertising and analytical purposes you may opt out or if applicable simply turning off the switcher in the Settings menu in the App or you may send your request via [email protected]. We will erase your personal data and request our providers to do the same within 30 days upon your request.
3. to obtain from us without undue delay the rectification of inaccurate Personal Data concerning you;
4. to erasure your Personal Data as ‘right to be forgotten’;
5. to restrict our processing of your Personal Information and Data, when it is permitted under applicable law.

5. PERSONAL DATA SHARING

As we do not collect, store or process your Personal Data in any other manner, we do not share it with other parties. However, information collected by Third-Party Providers when this is needed for the purposes of processing may become available for the following categories of recipients:

1. the companies being in the same corporate group with us;
2. data storage, networking and security providers;
3. advertising and analytics third party providers (upon your consent only).
4. providers assisting us with client support;
5. any other providers assisting us with delivering and improving the services for you.

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

NOTE: Third-Party Providers which directly collect such data via integration with the 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 and give your consent to 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 to the countries which do not provide an adequate level of data protection, we will use standard data protection clauses adopted by the European Commission or our supervisory authority.

Third parties with which we may share your data only get the minimum amount of data that are reasonably required in order to provide them 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 and is not permitted for any other purpose. All the 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.

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

6. PROCESSING PERIOD 

All e-mail records, contained your Personal Data retained for no longer they are needed for the purposes for which you provided them to us, unless we need to further process your Personal Data as described above in this Policy. If you request erasure of your data 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. We are not limited by any particular retention period with regard to your non-personal data and/or information.

7. PRIVACY POLICY UPDATES PERIOD

We may update this Privacy Policy from time to time. Changes to this Privacy Policy with respect to processing of your Personal Data is subject to your prior express consent, unless they are required under applicable law or do not negatively affect your rights under this Privacy Policy.

Unless otherwise required by law, any changes to this Privacy Policy with respect to processing of your non-personal data and/or information and changes with respect to processing of your Personal Data, not requiring your prior consent under Section 8, shall become effective immediately upon their posting in the App.

8. CHILDREN’S PRIVACY

We do not knowingly collect or solicit Personal Information from anyone under the age of 16.  

If you are under 16, please do not attempt to get the App or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please let us know.

9. QUESTIONS AND COMPLAINTS

Any requests with regard to your Personal Data or any queries with regard to this Privacy Policy shall be delivered via [email protected].

If You consider that collection, usage, disclosure and/or storage of your Personal Data violate any applicable data protection laws we are bound by, please refer your complaints to [email protected]. We will consider them within reasonable time and provide you with an answer.

10. FOR CALIFORNIA RESIDENTS

Beginning January 1, 2020, if you are a resident of California, you will have additional rights under the California Consumer Privacy Act (the “CCPA”) with respect to your Personal Data, as outlined below.

1. Erasure. You may request that we delete the Personal Data that we have collected from you. We will also direct all our service providers to do the same. However, we may not be required to delete your Personal Data under certain circumstances indicated below. 

Please note that we have the right not to delete your Personal Data upon your request if it is necessary for us to maintain this information in order to:

(1) Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.

(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

(3) Debug to identify and repair errors that impair existing intended functionality.

(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.

(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.

(8) Comply with a legal obligation.

(9) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

If you request that we delete your Personal Data, you may no longer be able to use the Services.

2. Access. You may, not more than twice in a twelve-month period, request more information about the Personal Data we hold about you and request a copy of such Personal Data.

3. Disclosure. In any time, but not more than twice in a 12-months period, You are allowed to send a verifiable request to disclose the following:

(1) The categories of personal information we have collected about You.

(2) The categories of sources from which the personal information is collected.

(3) The business or commercial purpose for collecting or selling personal information.

(4) The categories of third parties with whom we share Your personal information.

(5) The specific pieces of personal information we have collected about You.

(6) The categories of personal information that we disclosed about You for a business purpose or the fact that we did not disclose it.

(7) The category or categories of Your personal information we have sold, or the fact that we have not sold your personal information.

For this purpose we will identify by categories Your personal information that we disclosed for a business purpose in the preceding 12 months, and will provide the categories of third parties to whom Your personal information was disclosed for a business purpose in the preceding 12 months. In case we did not disclose Your personal information in the preceding 12 months, we will inform You about it.

Not later than 45 days after we receive your request, we will deliver this information by mail or electronically in a portable and, to the extent technically feasible, in a readily useable format that allows You to transmit this information to another entity without hindrance. The time period for the response mentioned above may be extended for up to 90 additional days where necessary due to complexity and number of requests. If your request is manifestly unfounded or excessive (in particular because of repetitive character), we may either charge a reasonable fee or refuse to act on the request. In this case you will be additionally notified.

Please note that we shall keep only the information collected about you during the last 12 months. Previously collected information may be deleted.

4. Communication. For the purposes to execute your rights under this Sections please address Your verifiable requests at our email: [email protected]. 

You can also address your requests via our website contact form available at: http://banubafilters.com/

Before we satisfy your request, we may ask you to verify your personality in order to avoid any abuse of rights and to associate the information provided by you in the request with the information previously collected about you. 

Verifiable request means the request containing your name and Advertising ID. We need your ID since we do not store the information allowing us to identify You. After we receive your ID, we will be able to identify You within our environment and satisfy your request. This information will be used strictly for the purpose of to satisfy your request. 

In case You do not know your Advertising ID, see the instruction below.

Instruction. 

How to determine your Advertising ID.

iOS: At present, the advertising ID on iOS devices is hidden from users by default but can be retrieved with third-party apps. In order to find your Apple IDFA, a third party tool is required. There is a wide selection of apps in the App Store. We suggest using this app (https://itunes.apple.com/us/app/myidfa/id1099872451?mt=8) 

For Android: To find your Android Advertising Identifier, open the Google Settings app on your Android device and click on “Ads.” Your Advertising Identifier will be listed at the bottom of the screen.

Please note that we do not have a toll-free number for your requests. We are allowed not to have it under Section 1798.130.(a)(1)(A) of California Civil Code.

5. Non-discrimination. The execution of any of your rights under this Section will not affect the scale and quality of services we are providing to You. We shall not discriminate you upon this condition by any means including, but not limited to, by:

(1) Denying goods or services to you.

(2) Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.

(3) Providing a different level or quality of goods or services to you.

(4) Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

6. Violation. In case You believe that your rights under CCPA have been violated, please send to us the written notice identifying the specific provisions of the CCPA allegedly violated. 

If we fail to cure the violation during the period of 30 days after the notice was received, You can file the case before the court.

7. Updating.

 This Section shall be updated not less than once upon 12 months.