Privacy Policy

Privacy Policy

Last updated 09 June 2022

Banuba (Cyprus) Limited, having its registered address at 6 Ioanni Stylianou, Floor: 2^nd, Flat/Office: 202, Nicosia, 2003, Cyprus, reg. No. 377250, 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 Video Editor application.

This Privacy Policy refers to Banuba Video Editor application, hereinafter – the “App/ VE App”.

“IP address” means 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, which identifies or allows to identify You.

“Advertising ID” means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). 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.

“User ID” means a unique identifier assigned to each user when the individual installs and launches VE App.

1. ACCEPTANCE OF THIS PRIVACY POLICY

1.1. By using VE App You express acceptance of this Privacy Policy, as such Policy may be amended from time to time. Each time You use VE App, You agree to Our collection, use, storage, transfer and disclosure of the information that You provide as described in this Policy.

1.2. If You do not agree to be bound by this Privacy Policy then, please, do not use VE App. The current version of this Privacy Policy shall be always available at https://banubafilters.com/privacy-policy-ve.

2. PERSONAL DATA COLLECTED

2.1. When You use Our Services to enable functioning of VE App We shall automatically collect from You and/or Your device certain data:

2.1.1. Device IP address. We collect device IP address for security (We store that data to protect against cyberattacks), as well as to know Your geographic location to stay aware of legislation applicable to You, so we could follow its requirements;

2.1.2. User ID. We process User ID to see the number of unique VE App users.

2.2. VE App functionality is based on video processing and face detection. In order to use Our VE App We need it to process videos taken by Your device camera. However, all videos taken by Your mobile phone camera are processed solely on Your device and are not sent to Our servers, i.e. We do not have access to such videos (We will not collect, share or store them).

2.3. VE App algorithms used within processing of Your videos are not able to identify a specific person and, therefore, generally cannot be considered as collecting biometric information. However, in case the applicable law stipulates that videos captured by the camera or face geometry generated by VE App are considered as biometric identifiers, biometric information or similar legal category, hereby You express Your informed written consent on their processing as described in this Policy.

2.4. In case We start collecting other categories of Your personal data, We shall first explain why We collect it and ask for Your express consent for such collection and further processing.

3. INFORMATION COLLECTED BY THIRD-PARTY PROVIDERS

3.1. For the purposes of attribution and tracking the performance of Our advertising campaigns and VE App, including their effectiveness, usage, installations and downloads, We engage analytics third party providers (hereinafter – Providers), currently the following Providers are being engaged:

To see the list of open source licenses used in VE App please follow the links:
Android licenses: https://github.com/Banuba/ve-sdk-android-integration-sample/blob/main/mddocs/3rd_party_licences.md 
iOS licenses: https://github.com/Banuba/ve-sdk-ios-integration-sample/blob/main/mdDocs/3rd_party_licences.md

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.

3.2. The Providers collect the following information about users of the devices: 

3.2.1. Facebook SDK:

3.2.1.1. Explicit events - information from events that We explicitly configure our VE App to send, along with any additional parameters provided;

3.2.1.2. Automatically logged events - basic interactions in VE App (e.g. app installs, app launches) and system events (e.g. SDK loading, SDK performance) that are collected automatically;

3.2.1.3. Facebook app ID - a unique identifier provided by Facebook to reference the Our VE App;

3.2.1.4. Mobile advertiser ID - the iOS IDFA or Android Advertising ID;

3.2.1.5. Metadata from the request - the mobile OS type and version, the SDK version, app name, app version, the device opt-out setting, the user agent string and the client IP address. It also collects the following device related metrics: time zone, device OS, device model, carrier, screen size, processor cores, total disk space, remaining disk space.

3.2.2. Adjust:

3.2.2.1. Hashed IP address;

3.2.2.2. Mobile identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID or similar mobile identifiers;

3.2.2.3. Installation and first opening of VE App on Your mobile device;

3.2.2.4. Your interactions within VE App (e.g. in-app purchases, registration);

3.2.2.5. Information regarding which advertisements You have seen or clicked on.

3.3. Such information is collected directly by Providers and subsequently shared with Us. The Providers may use this information for targeted advertising, i.e. for showing the most relevant ads to You across Internet network.

3.4. If You do not wish Your data to be processed for advertising and analytical purposes You may opt out as described in Clause 5.4.1 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.

3.5. Besides statistics data collected by the Providers, the data on how You are using the App will be accessible for Us. These data will not be personalized or linked to device You are using. These data are needed to enable proper operation of the VE App, in particular to identify and fix the problems You are facing when using the VE App.

4. BASES FOR PROCESSING

4.1. The legal bases that We rely upon when processing Your personal data are as follows:

4.1.1. Processing of Your data, mentioned in Clause 2.2 and 2.3, is based on performance of a contract and specifically required for the provision of Services to You.

4.1.2. Processing of Your personal data as described in Clauses 2.1.1. (collecting of device IP address), 2.1.2 (collecting of User ID), is in Our legitimate interests. These legitimate interests are:

4.1.2.1. to ensure effective administration and management of Your relationship with Us;

4.1.2.2. to understand how You use Our Services and how We can improve the customers usage experience;

4.1.2.3. understand and respond to Your feedback;

4.1.2.4. to prevent, detect, or investigate unauthorised use of Our Services;

4.1.2.5. ensure We comply with law and our policies; and

4.1.2.6. manage any disputes and accidents and take legal or other professional advice.

4.1.3. We pay special attention to Your data protection rights making sure that Your data protection rights are not overridden by Our legitimate interests.

4.1.4. We will ask for Your separate permissions to use Your camera, microphone and gallery. If You change Your mind regarding 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 will negatively affect the use of VE App as VE App will lose its full functionality.

5. PURPOSES OF PROCESSING

5.1. We will process data collected under this Privacy Policy for the following purposes: 

5.1.1. delivering the Services to You (including, maintaining and monitoring the proper operation of VE App, fixing any problems in its operation, administering VE App, including troubleshooting, dealing with Your enquiries, complaints and requests);

5.1.2. ensuring and protecting the safety and security of VE App, protecting Our Intellectual Property Rights and other rights;

5.1.3. conducting statistical and analytical surveys and researches, in particular for improving the Services and Your user experience;

5.1.4. attribution and tracking the performance of Our advertising campaigns and VE App, including their effectiveness, usage, installations and downloads.

5.2. In case You voluntarily provide us with any additional personal data, We shall process these data solely for the purposes for which it were provided to Us and for no longer it is needed to fulfil such purposes.

5.3. 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.

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

5.4.1. On Your iPhone, iPad, or iPod touch: * Go to Settings > Privacy > Tracking > Turn off the option “Allow Apps to Request to Track”.

5.4.2. 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. Note: If You clear Your cache, You’ll lose Your opt-out setting.

5.4.3. Once You have turned off personalization, Google will no longer use Your information to personalise Your ads. Ads can still be targeted with info like Your general location or the content of the website You are visiting.

6. SHARING OF DATA

6.1. We cannot provide all Services by Ourselves. We must, therefore, share collected information with third parties for the purposes as described in section 5 of this Policy. We also reserve the right to disclose Your information (including personally identifiable information):

6.1.1. when We are legally required to do so;

6.1.2. in an anonymous and aggregated manner, meaning You could not be personally identified from it.

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

6.2.1. the companies being in the same corporate group with Us;

6.2.2. data storage, networking and security providers;

6.2.3. advertising and analytics third party providers;

6.2.4. providers assisting Us with a client support;

6.2.5. any other providers assisting us with delivering and improving the Services.

6.3. Our third-party providers with whom We share Your data or which directly collect such data via integration with VE 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.

6.4. 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 services 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 5 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.

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

7. YOUR RIGHTS

7.1. 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 processed (if any) You have the right:
7.1.1. to obtain from Us the information regarding Our processing of Your personal data;

7.1.2. to obtain from Us without undue delay the rectification of inaccurate personal data concerning You;

7.1.3. to obtain from Us the erasure of Your personal data (Your “right to be forgotten”);

7.1.4. to restrict Our processing of Your personal data, when it is permitted under applicable law;

7.1.5. 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;

7.1.6. to withdraw Your consent, where We are relying on consent to process Your personal data;

7.1.7. to lodge a complaint against Us with a supervisory authority for GDPR purposes;

7.1.8. to object processing of Your personal data where We are processing Your personal data based on Our legitimate interests (as set out above). If You ask Us to stop processing Your personal data on this base, We will stop processing Your personal data unless We can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws.

8. PROTECTING CHILDREN’S PRIVACY

8.1. We do not knowingly collect or process personal data from or with respect to children under the age of 13, and You must be 13 years of age or older in order to use Services and/or VE App.

8.2. If You are a parent or legal guardian and believe that Your child under the age of 13 has submitted his or her personal data or other data without Your consent, permission, or authorisation – 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.

9. PERIOD OF PROCESSING

9.1. IP addresses and User IDs 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 4 of this Policy.

9.2. If You request erasure of Your data or You deleted VE App from Your device, We erase Your data from Our servers and request Our providers to do the same within 30 days upon Your request.

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

10. PRIVACY POLICY UPDATES

10.1. 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 VE App.

10.2. Any changes to this Privacy Policy with respect to processing of Your personal data shall be subject to Your prior consent, unless they are not required under applicable law.

10.3. 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 VE App.

10.4. In case You continue to use VE 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.

10.5. 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).

10.6. If You do not accept Privacy Policy following changes, do not start or continue using VE App.

11. QUESTIONS AND COMPLAINTS

11.1. If You consider that our 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 a response.