Privacy Notice for website users, customers and suppliers

Welcome to Bango.net Limited's privacy notice for website users, customers and suppliers.

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. This privacy notice aims to give you information on how Bango collects and processes your personal information. It applies to individuals whose data we process in our capacity as a controller (within the meaning of UK data protection laws). This includes:

our account management contacts (e.g. individuals working for the customer organizations that we supply services to and the service providers that we source services from); and
individual users of our website, including when you sign up for our newsletter(s).

Please note that our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Alternatively, for more information about when and how Bango uses personal information in its capacity as a processor acting on behalf of another party that uses our services (e.g. telecommunications providers), please refer to https://bango.ai/about/privacy-policy.

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, use, store and transfer different kinds of personal data about you:

Identity and contact details such as your name, title, telephone number and relevant addresses including email address.
Usage and technical data about how you use our website including data about your browsing actions and patterns.
Marketing and communications data, including your preferences in receiving marketing from us and our nominated third parties, and your communication preferences.

Bango also collects, uses and shares aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Bango does not collect any special categories of personal data about you (this includes 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). We do not collect any information about criminal convictions and offences.

How is your personal data collected?

Bango uses different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data such as contact and identity data by filling in forms or by corresponding with us by email, phone, messaging or otherwise.
Customer/Supplier. If you work for one of our customer organizations or service providers, they may share contact and identity data with us.
Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties such as technical data from analytics providers such as Google and identity/contact data from publicly available sources such as Companies House.

How does Bango use your personal data?

Lawful Basis

Bango will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:

It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We need to comply with a legal obligation.

Here’s some more detail:

Legitimate Interest means Bango’s interest in conducting and managing its business, to enable us to give you the best products and service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purpose and lawful basis

We have set out below, in a table format, a description of all the ways we plan to use your personal data (our purpose/activity), and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To liaise with our account management contacts for the purpose of providing our products/services to customer organizations and procuring services from our service providers.	Necessary for our legitimate interests (to run our business, perform our contracts with customer organizations, exercise our rights under our contracts with service providers etc.)
To manage our relationship with you, which may include notifying you about changes to our terms or privacy notice and/or asking you to leave a review or take a survey	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable participation in a prize draw or competition or completion of a survey	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you or the organization that you work for	Necessary for our legitimate interests (to develop our products/services and grow our business)

Where Bango needs to collect your personal data for the purposes set out above (for example, to enter into or fulfil a contract with you or the organization that you work for), if you fail to provide that data when requested, Bango may not be able to perform the contract Bango has or are trying to enter into with you or the organization that you work for (for example, to provide the services that you wish to purchase) or we may not be able to otherwise assist you (for example, responding to a request or query that you submit to us).

Bango will only use your personal data for the purposes for which Bango collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing and opting out

Bango strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other communications relating to the provision of Bango products or services we provide to you or your organization.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://bango.ai/about/cookies.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

Internal Third Parties
- Other companies in the Bango Group who are based United Kingdom, United States of America, European Union, and Japan.
External Third Parties
- Service providers based in the United Kingdom and the European Union who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We share your personal data within the Bango Group. This will involve transferring your data outside the UK.

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
We will 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 out of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

Exercising your rights

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Protection Authority

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this privacy notices and informing us of changes to your personal data

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

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Contacting us

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

Full name of legal entity: Bango.net Limited

ICO Registration number: ZB110113

Email address: dataprivacy@bango.com

Postal address: Botanic House, 100 Hills Road, Cambridge, Cambridgeshire, England, CB2 1PH