Audiences Privacy Policy

Bango.net Limited (“Bango”) is committed to protecting the privacy and security of personal information, whether in its capacity as a controller of that personal information or as a processor acting on behalf of another party. Bango complies with all applicable data protection laws including the UK Data Protection Act 2018 and the UK GDPR.

Bango is a controller of personal information when it is responsible for determining the purposes and the means of the processing of that personal information. Bango is a processor acting on behalf of another party when it is acting under the instructions of the other party and that other party is responsible for determining the purposes and the means of the processing of that personal information.

For more information about when and how Bango collects and uses personal information as a controller, please refer to https://bango.ai/about/privacy-notice

This Audiences Privacy Policy describes Bango’s role as a processor of personal information collected from individuals (the “End User” or “you”) that make a purchase using the account they have with their telecommunications or other payment provider.

Bango receives your personal information from your telecommunications or other payment provider (the “Carrier”) and/or from the vendor from whom you are making a purchase (e.g. a mobile app games developer) (“Vendor”) and uses that personal information for the creation of Bango Audiences, acting on behalf of the Carrier and /or Vendor (“Providers”).

Bango Audiences is a data analysis service that Bango supplies to Providers to facilitate targeted advertising through online and mobile advertising platforms including but not limited to Facebook, Instagram, TikTok, Snapchat and Google(“Advertising Platform”). From your perspective, the data collated as part of Bango Audiences, when combined with the data held by an Advertising Platform that you use, helps the Advertising Platform to show you products and services that you may be interested in, based on your purchase history.

What personal information does Bango collect?

Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Bango may collect and use the following personal information about you as part of providing Bango Audiences to the Providers:

Bango receives this information in a pseudonymized form (for example, a hashed MSISDN) from Providers. Pseudonymized information is personal data that is altered, modified or changed in such a manner that the personal data can no longer be attributed to a specific individual without the use of additional information.

Bango cannot identify you as an individual because we do not have access to the additional information that would enable us to do so. However, the Providers, who are the controllers of your personal information, do have the ability to identify you. Equally, when Bango shares your personal information (on behalf of the Providers) with an Advertising Platform, that Advertising Platform is also able to identify you by combining the information that they receive from Bango with information that they already have about you if you are a user of their platform (e.g. if you have a Facebook, Instagram, TikTok, Snapchat or Google account).

Bango does not collect or receive any special categories of personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

How is your personal information collected?

Bango receives your personal information from Providers on the basis described above.

To find out about how your personal information is collected by the Providers that you use, please refer to their privacy notices.

How does Bango use your personal information?

Bango only uses personal information when the law allows us to. Bango uses your personal information under the instructions of the Provider (including their specified purpose) and in accordance with Bango’s agreement with that Provider for the provision of our Bango Audiences services to them.

Your Provider is required to have a purpose and lawful basis for sharing your personal information with us to receive our Bango Audience services. Broadly speaking, your Provider’s purpose in this context will relate to marketing and communications and its lawful basis is likely to be its legitimate interests in refining their marketing strategy and facilitating target advertising. However, this is determined by your Provider so, for more information about this, please refer to your Provider’s privacy notice.

Disclosures of your personal data

Bango discloses your personal information (in pseudonymized form as part of Bango Audiences) to advertisers that carry out advertising through the Advertising Platforms. As described above, the Advertising Platforms that you use will combine the information provided by Bango with personal information that they already hold about you and this helps them to advertise the developer’s products and/or services that are relevant to you.

For more information, please refer to the privacy notices of the Advertising Platforms that you use (e.g. Facebook, Instagram, TikTok and Snapchat).

Opting out

You can ask your Provider and any relevant Advertising Platforms to stop sending you marketing messages at any time by accessing your account with them and/or by following the opt-out links on any marketing message sent to you. For further details, please refer to the privacy notices of the relevant Provider and/or Advertising Platforms.

International transfers

Bango will, where relevant, transfer your personal information outside of the UK when information is shared with other companies in the Bango group (for example, our company in the United States, Bango Inc.) and with any developers and Advertising Platforms that are based outside of the UK (for example, Facebook, Instagram TikTok, Snapchat).

Where we transfer your personal data outside of the UK, we use specific contracts which ensure that your personal information is given the same protection it has in the UK. For further details and a copy of the relevant contracts, see the ICO’s webpage on the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Bango (and its staff and contractors) will only process your personal information on the instructions of your Provider and Bango is (and its staff and contractors are) subject to a duty of confidentiality.

We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

Bango will only keep your personal information for as long as we have an agreement with your Provider to supply our Bango Audiences service to them. Bango will delete your personal information on the expiry or termination of its agreement with your Provider (except to the extent that it is required by law to retain any such information).

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. This may include the rights set out below.

If you have any questions about these rights, please contact your Provider in the first instance, noting that that Bango only holds pseudonymized data about you. That said, Bango is very happy to help where it can – to contact us, please use the details specified below in the “Contacting Bango" section.

Your rights may include the right to:

Data Protection Authority

You also have the right to make a complaint at any time to the UK supervisory authority for data protection issues. This is the Information Commissioner's Office (ICO) whose details can be accessed via the ICO website at https://ico.org.uk/global/contact-us/

Changes to this privacy policy

We may update this privacy policy from time to time. You will always be able to find our up-to-date privacy policy on our website. Alternatively, you can contact us using the details provided below.

Contacting us

Bango has appointed a data protection officer (DPO) who is responsible for overseeing Bango’s data protection activities. If you have any questions about this End User Privacy Policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below.

Email: dataprivacy@bango.com