Privacy Policy

Last updated: 26 July 2023

Banuba Limited, incorporated and registered in Hong Kong with company number 2360577 whose registered office is at Office A, 16/F Heng Shan Centre 145 Queen’s Road East, Wan Chai, Hong Kong (“Banuba”), 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 the Personal Data collected via Banuba Developer Portal (“Portal”).


  • “Personal Data” means information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, gender, genetic, mental, economic, cultural, social, political and sexual orientation identity of that natural person

  • “Process” or “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • “Device identifier” means device type, device operating system and its version, user-agent, internet service provider, browser and its version, language, location or other technical data available from a device.

  • *“IP address” means addresses assigned to computers connected to the Internet. 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.


1.1. By using the Portal, you express acceptance of this Privacy Policy, as such Policy may be amended from time to time. Each time you visit and (or) use the Portal, you give your explicit consent to our processing of your Personal Data as described in this Privacy Policy.

1.2. If you do not agree to be bound by this Privacy Policy, then please do not use the Portal.

1.3. The current version of this Privacy Policy shall be available at [Privacy Policy].


2.1. During the usage of the Portal, we process certain Personal Data for the purposes specified below:

Purpose of the processing Data processed Legal basis for the processing
Registration in the portal
  • E-mail address
  • First and last name
  • Username
Your consent
Using the Portal’s functionality (posting, adding, writing, and evaluating the content shared here)
  • IP address
  • Device identifier
Performance of a contract (ToS)
* without providing this data you will not be able to use this functionality of the Portal

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

2.3. In case you voluntarily provide us with any additional Personal Data, we shall process this data
solely for the purposes for which it was provided to us and for no longer it is needed to fulfill such purposes.

2.4. We limit access to the Personal Data we hold to employees who we believe reasonably need to come into contact with that data 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 fulfil these obligations. We will take all steps reasonably necessary to ensure that the Personal Data is treated securely and in accordance with this Privacy Policy.


3.1. We do not sell, trade, or otherwise transfer to outside parties your Personal Data. This does not include trusted third parties who assist us in operating the Portal, conducting our business, or servicing you, so long as those parties agree to keep the Personal Data confidential. We also reserve the right to disclose the Personal Data:

3.1.1. when we are legally required to do so;

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

3.2. The Personal Data may become available for the following categories of recipients:

3.2.1. companies being in the same corporate group with us;

3.2.2. data storage, networking and security providers;

3.2.3. advertising and analytics third party providers;

3.2.4. providers assisting us with client support;

3.2.5. any other providers assisting us in connection with the Portal.

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

3.4. All third parties with which we share the Personal Data only get the minimum amount of data that is reasonably required for them to provide their services to us and therefore to you. The use of the shared data by such third parties is strictly limited to the purposes of processing outlined in Section 2 herein and is not permitted for any other purpose. All third parties with which we share the Personal Data are required to protect such data in accordance with all relevant laws and regulations and in a manner similar to ours.

3.5. We will not share the 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.


4.1. We respect your privacy rights, and to the extent required by applicable law, we will make reasonable commercial efforts to allow you to exercise your privacy rights.

4.2. With respect to the Personal Data processed, you have the following rights:

Your Right Explanation
Right of access You may obtain from us information about what data concerning you is kept by us and receive a copy of it.
Right to rectification You may obtain from us without undue delay the rectification of your Personal Data that you believe is inaccurate or outdated.
Right to erasure (‘right to be forgotten’) You may obtain from us without undue delay the erasure of your Personal Data. * Please note that we can retain your Personal Data if necessary to comply with our legal obligations or resolve disputes
Right to restriction of processing You may obtain from us restriction of processing of your Personal Data, when it is permitted under applicable law.
Right to data portability You may obtain from us your Personal Data in a structured, commonly used and machine-readable format and transmit those data to another controller without any obstacle on our side. Please note that this right only applies to data that we process based on your consent or a contract, or when the processing is carried out by automated means
Right to be informed You have the right to be provided with clear and easy-to-understand information about how we use your Personal Data.
Right to object You may object to the processing of your Personal Data where we are processing your Personal Data based on our legitimate interests. If you ask us to stop processing your Personal Data on this basis, we will stop processing your Personal Data, unless we can demonstrate compelling grounds as to why the processing should continue in accordance with applicable data protection laws.
Right to withdraw consent You may withdraw your consent at any time, where we are relying on your consent to process your Personal Data.
Right to complain to a supervisory authority You may contact the relevant data protection authority to complain about our data protection and privacy practices.


5.1. We do not knowingly process any Personal Data from or with respect to children under the age of 13, and you must be 13 years of age or older to use the Portal.

5.2. 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 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.


6.1. We store the Personal Data for a period needed to fulfill the purposes indicated in Section 2 herein. In certain cases, we may store the Personal Data for a longer period if needed to comply with our legal obligations, to resolve disputes, establish and defend legal claims.

6.2. If you request erasure of your Personal Data, we will erase your Personal Data from our servers within 30 calendar days following your request.

6.3. With respect to non-personal data, we are not limited by any particular retention period.


7.1. We may update this Privacy Policy from time to time to keep it in conformity with the relevant data protection legislation.

7.2. In the event we materially change this Privacy Policy, you will receive the respective notification via the Portal.