Privacy Policy

Welcome to the Badanga Privacy Policy (“Policy”)! This explains how we collect, store, protect and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions of Use.

Whilst you’re enjoying the Badanga mobile application (including the desktop version) (“App”), our websites and microsites (such as badanga.app) or using our digital products and services (such as our competitions or surveys) (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other Badanga members including your friends and contacts (“Users”). We may also need to share your information sometimes.

Badanga is the Data Controller and is committed to protecting the rights of its users in line with the Data Protection Law, including the European General Data Protection Regulation 2016/679 (“GDPR”) and any other data protection and/or privacy legislation, regulation or guidance applicable to the Service.

In the present Privacy Policy, we use the terms "Badanga", "we", "us", and "our" to refer to Badanga Group. Badanga Group includes Promium Network Ltd (an English company under number 10366005, registered at the legal address: 321-323 High Road, Office 331, Romford, Essex, England, RM6 6AX) and Yako Ltd, registered in Bulgaria. "Service" includes any websites or applications that we manage, including this website and the Badanga mobile application. "You" or "your" refers to the users (data subjects) of our Service.

1. COLLECTION OF INFORMATION

Registration information

When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:

• Email address;
• Gender identity;
• Date of birth;
• Sexual preference;
• Photographs;
• Location.

You will also be required to create a password in connection with the registration of your Account. Once you register, you will be able to review and change this information at any time just by logging in to Badanga (other than your location, which, if you have given Badanga access to your location in your device settings, is automatically updated based on the location of your device) or contacting Badanga’s Customer Support Team. It is your responsibility to ensure that your account details are kept up to date.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!). Registration Information such as your sexual preference and name may be visible to other Users who view your profile page.

Profile Information

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ licence details and other sensitive information which is open to abuse and misuse on your profile.

When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on Badanga.

Profile Verification Information (Including Biometric Information)

For safety and security and to ensure you have the best possible user experience, we may require Users to verify their accounts. We want to make sure you are not a robot! And we also want to avoid fake Badanga accounts being created which can be used for malicious activities and cybercrime – they threaten the Badanga network and spoil things for everyone. This verification might be required by us for the prevention of fraud. You can also verify your photo on a voluntary basis (to add the blue “verified” badge to your profile).

If you choose to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. We do not add the verification photos to your profile. We retain the scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.

Purchases Information

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Badanga uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected Users can contact Badanga to contest the decision.

Geolocation Information

If you have given Badanga access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalise the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given Badanga access to your location services, but wish to turn them off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, Badanga
2. Android — settings, location, Badanga, permissions, location

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, and operating system, for a number of purposes, as set out here.

When you contact Customer Support

If you contact our Customer Support team via Feedback page, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 6 years after deletion of your account.

Cookies and similar technologies

When you visit our Sites or when you use our App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognise and remember you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.

2. USE OF YOUR INFORMATION

Our main goal is to ensure your experience on Badanga is an enjoyable one and in order to deliver it to you, we may use your Registration and other information to:

• offer you our services and features;
• contact you with information about the App (e.g. updates and new features);
• to personalise the App/Sites and the content we deliver to you;
• conduct research and analytics about how you use and interact with the App/Sites;
• resolve disputes, troubleshoot problems and enforce our Terms and Conditions of Use;
• investigate fraud, protect our legal rights, and to enforce our Terms and Conditions of Use;
• to send you information about the promotions and offers we have available - if you’ve signed up for our communications or otherwise told us it’s ok (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
• protect our Users and third parties from harm.

Moderation Practices

We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact Badanga to contest the decision.

If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.

Lawful Basis

Under EU and UK data protection laws, we are required to tell you our lawful basis for using your data and we have set this out in the table below. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

Purpose for which data is used	Data	Source	Legal basis
To provide you with the Badanga social networking service	Name, email address, date of birth, location (CCPA Categories A and B)	You provide your name, email address and date of birth to us. We obtain location data from the device that you use to access the service	Contractual necessity
To facilitate networking opportunities on the Badanga site	Optional information that you choose to provide in your profile, including through profile verification, which may include information about your sexual preferences, non-binary gender, photos, interests, etc. (CCPA Categories B, C, H, I, J)	You provide this information to us	Contractual necessity and our legitimate interests – it is in our legitimate interests to facilitate networking opportunities in the Badanga app. For special category/sensitive personal data, we rely on your explicit consent.
To verify your identity and prevent fraud and to ensure the safety and security of Users	Photo provided as part of profile verification (CCPA Category B and H)	You provide this information to us	Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard Users of the site
To send you marketing information about our events, offers and services	Name, email address (CCPA Categories A and B)	You provide this information to us	Consent or legitimate interests and in accordance with the laws applying to our marketing activities. We have a legitimate interest in promoting our business and products
To contact you in order to run surveys for research purposes and to obtain feedback, and to find out if you want to take part in marketing campaigns	Email address (CCPA Category B)	You provide this information to us	Legitimate interests – it is in our legitimate interests to carry out research so that we can further develop the app and improve the service
To enable Users to create and enhance their Badanga profile and log into the app via third party accounts	Data from Facebook and other third party accounts (see section 7 of this policy for more details) (CCPA Categories A, B, C, and H)	We obtain this information from Facebook or the providers of any other accounts you use to log in or connect with your Badanga account	Legitimate interests – it is in our legitimate interests to facilitate access to our services
To carry out research and analysis to help us improve the App	Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms, images and videos (CCPA Categories F and H)	You provide photos and videos to use. We obtain the log and usage information from the device that you use to access the service	Legitimate interests – it is in our interests to analyse the way in which Users are accessing and using our services so that we can further develop the App, implement security measures and improve the service
To respond to correspondence and queries that you submit to us, including social media queries	Email address, IP address, social media name, phone number (CCPA Categories B and F)	You provide your email address, social media name and phone number to us when you contact us and we obtain your IP address from the device that you use to contact us	Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems
To investigate and block Users for reported infringements of our Terms and Conditions of Use	Name and user registration details, profile information, content of messages and photographs; usage and device data such as IP address and IP session information (CCPA Categories A, B, C, F and H)	You provide your registration details, profile information, messages and photographs to us. We obtain the other information from the device that you use to access the service.	Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour to maintain the safety and integrity of our services.
To enable video and audio call functions and the sending of images and video	Video and audio call usage data, images and video (CCPA Categories F and H)	We obtain this information from the device you use to access the service	Legitimate interests - it is in our legitimate interest to provide these functionalities as part of the services.
To defend legal claims, protect legal rights and to protect people from harm	This could include any information that is relevant to the issue	This information may be obtained directly from you, from your device or from third parties, depending on the information involved	Legitimate interests – it is in our legitimate interests to protect our legal rights, defend legal claims and to protect our Users and third parties from harm

3. DISCLOSURE OF INFORMATION

Our policy is to not disclose your personal data, except in the limited circumstances described below:

Circumstances where data may be disclosed	Disclosed data
Service Providers - We engage certain trusted third parties to perform functions and provide services to us. We may share your personal data with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below	This could include all data, including all CCPA Categories listed above
Moderators - to monitor activity on the site/apps and approve content	Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, and H)
Law and Harm - As we mentioned in the Terms and Conditions of Use, we think it is very important that all Badanga members behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behaviour or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us.	This could include any personal data that Badanga holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above
Marketing Services Providers - To help us serve marketing and advertising on third party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below.	Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), age, gender and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App), hashed email address (for ‘custom audiences’ only) (CCPA Categories B, C, G, F and K)
Business Transfers - In the event that a Badanga Group entity or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data to a purchaser of all or part of the business or to an insolvency practitioner	This could include all personal data that Badanga holds about you, including all CCPA Categories listed above
Anti-Spam and Anti-Fraud - Your data may be shared with other Badanga Group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.	This could include email address, IP address and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F and D)
Aggregated Information - We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.

MORE INFORMATION ABOUT DISCLOSURES

Sharing your personal data with Service Providers

We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which Badanga shares User personal data vary depending on a variety of factors, such as which of our Apps and Sites a User engages with. For example, to provide our services to Badanga App Users, we typically use the following suppliers:

• Billing services - to allow customers to purchase paid features of our App (for example, Google Play)
• Social media providers - to allow customers to create/connect their Badanga account with their account(s) on such platforms (for example Facebook or Instagram)
• Growth marketing services - to allow us to market and advertise Badanga to potential customers (for example AppsFlyer and Facebook)

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

Sharing your personal data with Marketing Service Providers and Advertising Partners

We may partner with advertising publishers to place third party adverts on our App and Sites (‘Advertising Partners’). We also partner with providers of marketing services (such as Facebook for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:

• to exclude you from advertising campaigns aimed at finding new users, if you already have a Badanga account;
• to show Badanga adverts to users who have visited the Badanga App/Sites but haven’t yet created a Badanga account;
• to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers hold about you (also known as a Lookalike Audience); or
• to include you in a ‘custom audience’ that will receive Badanga advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).

We share a limited amount of your personal data with companies that help us with marketing and advertising, such as:

• the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer), know when an ad has been viewed or clicked on in the App or sites, and when an ad causes a “conversion” (for example downloading the app advertised to you))
• your estimated location (based on your IP address)
• age and gender
• data about your visit to our Sites or App and action taken on those (for example if you download our App or created an Account with our App)
• a hashed* version of your email address (to create ‘custom audiences’).

*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters - this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.

For more information about how we use cookies and other tracking technologies, including how you can set and manage your preferences with regards to such technologies, please see our Cookie Policy (section 10 of this Privacy Policy).

Some platforms require user consent before Badanga is permitted to use data gained through the platform for advertising purposes and where it is the case, Badanga will only use this data where the necessary consent has been obtained. Through your device’s security settings, you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

4. WHAT OTHERS MAY SEE ABOUT YOU

When using the Badanga App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users of the App and non-users of the App. We want our Users to be careful about posting information that may eventually be made public.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on Badanga may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of this information and making it public to other Users.

Your Badanga profile and other information you make available via the App, including certain information added to your profile through third party accounts (such as Facebook or Instagram – see section 7 of this Privacy Policy for more information about this) may be viewed and shared by Users with individuals who may or may not be Users of the App. For example, a User may recommend you as a match to his or her Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether such friend(s) is also a User of the App.

If you log in to or access the App through your Facebook account or another third-party account on a device which you share with others, remember to log out of the App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Badanga account.

5. OUR POLICY TOWARDS AGE

Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use the App.

Badanga does not knowingly collect any information about or market to children, minors or anyone under the age of majority. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their Profile information from Badanga. If we do delete a Profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

6. SECURITY

Badanga has implemented appropriate security measures to protect and prevent the loss, misuse, unauthorised access or disclosure and alteration of the information under our control, including your personal data. We use reasonable security measures to safeguard the confidentiality of your personal information. Our technical experts at Badanga work hard to ensure your secure use of our site.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
2. Please don’t share the password you use to access your Badanga Account with anyone else!
3. Change your password periodically.

7. LINKING OTHER ACCOUNTS TO BADANGA

Using your social media details to sign in to Badanga

When you sign in to our App using your Facebook account, you give permission to Facebook to share with us your name and profile picture. Unless you opt-out, you also give permission to Facebook to share with us your email address (if there is one associated with your Facebook account), date of birth, profile photos, gender, Page likes and current town/city.

If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email (you can choose to hide your email and Apple will create a random email address so your personal email can stay private). This email address will be linked to your Badanga account and will be used to retrieve your Badanga account.

We will then use this personal data to form your Badanga account. If you remove the Badanga app from your Facebook settings, or from your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your Badanga account using your Facebook or Apple ID (you must delete your Badanga account entirely for us to no longer have access to this data).

Linking social media accounts to your Badanga account

You may link your Badanga account with your Instagram or Facebook accounts. This allows you to share some information from those accounts directly to your Badanga account (for example, Instagram photos).

We only receive the limited information that Instagram/Facebook permits to be transferred (as detailed by Instagram/Facebook and agreed by you when you first connect your account from such platforms with your Badanga account).

If you no longer want to link your Badanga account to your Instagram or Facebook account, please visit the settings in your Instagram or Facebook account and follow the instructions to remove the Badanga app access permissions. Please note that any information already added to your Badanga account from those platforms will not be deleted unless you delete it within your Badanga account as well.

8. DATA RETENTION AND DELETION

We keep your personal information only as long as we need it for the legal basis relied upon (as set out in Section 2 above) and as permitted by applicable law. Please see “Profile Verification Information (Including Biometric Information)” in Section 1, above, to learn about our retention policy with respect to biometric information.

When you delete your Account or it is deactivated by us, we make sure it is no longer viewable on the App. For up to 90 days it is still possible to restore your Account if it was accidentally deleted or wrongfully deactivated. After 90 days, we begin the process of deleting your personal information from our systems, unless:

1. we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may need to be kept for tax and accounting purposes);
2. we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account).

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

9. CHANGES TO THIS POLICY

We may occasionally modify this Privacy Policy. When we do, we will let you know by changing the “last updated” date within this Privacy Policy, and your continued use of the Service shall indicate your agreement with the terms of the revised Privacy Policy.

10. COOKIES POLICY

In this Cookies Policy we explain the cookies which Badanga uses, the purposes for which cookies are used and how you can manage your preferences in relation to cookies.

What are COOKIES

We collect information by placing cookies on your computer or mobile phone. A cookie is a piece of text stored on your computer or mobile phone by your web browser. They are basically a tool that stores information about website visits, recognises you and your preferences each time you visit Badanga, and ensures site functionality enabling us to provide the services our members request.

When you visit the publicly available sections of Badanga, cookies which are necessary to make our application/site work (referred to as "strictly necessary" cookies) are placed on your device or mobile phone. We may use persistent tracking cookies (also known as local storage devices), mainly for security protection purposes, such as to prevent fishers, scammers and unauthorised login attempts.

You may set your browser and your mobile phone settings to block cookies and local storage devices, but if you do so, you may not be able to access the features that Badanga offers.

Why do we use COOKIES?

We use of cookies and local storage devices falls into the following categories:

• those that are strictly necessary to deliver the services and products you have requested. It is not possible to turn these cookies off because they are essential to enable us to provide the service that you have requested;
• cookies related to the performance of Badanga, such as analytics that help us determine how our site is performing and ensure a smooth and trouble-free experience for our members and visitors.

Below is a list to explain Badanga's cookie functions and why they're used.

1. Analytics and research: Badanga uses Google Analytics and Yandex Metrica to collect information about how visitors use the our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information about Google's privacy policy, please visit http://www.google.com/intl/en/policies/ and https://yandex.com/legal/confidential/?lang=en
2. Security and site integrity: We use cookies and other devices, such as CAPTCHAs, to help keep Badanga and our members safe and secure.We may use persistent cookies, which will help us to ensure we have identified the same device is logging in to the correct account. These types of cookies also help with our anti-spam measures and may help us to prevent phishers, scammers, unauthorised login attempts to your account and accessing any hacked accounts.
3. Performance: We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such as assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for Badanga services.

Our use of cookies and local storage devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. If you would like to know more about cookies, the following websites provide useful information:

• www.allaboutcookies.org
• www.youronlinechoices.eu

QUESTIONS

If you have questions about our Policy or how we collect and use personal data, drop us a line via Support page or send an email to our Data protection officer info@badanga.app.

This Privacy Policy was last updated on 01 January 2022.