Effective date: November 10, 2021
In this Policy “Banafo”, “we” or “us” refers to Banafo EOOD, a company duly registered under the laws of Bulgaria, with a registered address at 11 Gen. Ivan Kolev Str., fl. 1, 1407 Sofia, Bulgaria. Banafo entity acts as the processor or controller of your personal data, as explained in more detail in the PERSONAL INFORMATION WE COLLECT section below
1. PERSONAL INFORMATION WE COLLECT
“User Personal Information” is any information about one of our Users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. User Personal Information does not include aggregated, non-personally-identifying information that does not identify a User or cannot otherwise be reasonably linked or associated with them. Such aggregated, non-personallyidentifying information may be used for research purposes and to analyze, improve and optimize our Website and Services.Information you actively provide to us when you use our Services:
Usage information – when using the Services or access our Website, you may provide to us audio or video conversation recording, notes, call duration, contact lists, comments, responses to surveys, or requests for feedback. When you use 2 Banafo for recording conversations, you are solely responsible for ensuring that you comply with all applicable local regulations. This might mean that you need to inform every User and obtain their consent prior to the recording. You should also make sure that all the personal data in the contact lists you share with Banafo is obtained in a compliant manner and in accordance with all applicable laws. You might also share personal data with us if you use Banafo’s transcription and voice analytics services, either by uploading a conversation recording or through using our voice recording functionality. Based on your account settings and the permissions you grant us, we may use your conversation to train and improve the machine learning models that power our Services.
We maintain records of the conversation metadata, such as, but not limited to, time, duration, telephone number, as well as information, derived from the conversation and other details for all Users.
When you use our Services, we may collect certain information about your device, such as its Internet Protocol (“IP”) address, web browser or client application information and operating system, application version. Banafo needs to process this data to guarantee the functionality and security of the Website. We also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make decisions about future development focus. You may be able to change your browser or device preferences to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.
When you subscribe to a paid plan, you will be able to choose which one of our payment processing partners should handle the transfer. We won’t ask you to share any payment information directly with us.
If you choose to invite other Users to Banafo, or refer us to them, you share with us their email address and contact information. Before you do so, please make sure you have all the necessary permissions to provide us with this information.
If you provide a conversation recording, it may contain the Personal Information of third parties. Please make sure you have all the necessary permissions before you do so.
2. PERSONAL INFORMATION WE DO NOT COLLECT
We do not intentionally collect, and we ask that you not send or disclose to us any “Sensitive Personal Information,” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, biometrics or genetic characteristics, data concerning health status or sexual orientation, criminal background, or union membership. If you choose to send or disclose any Sensitive Personal Information to us (such as when you share your screen or place a telephone call using the Service), you are responsible for complying with any regulatory controls regarding that data.
3. HOW BANAFO USES YOUR PERSONAL INFORMATION
We may use your information for the following purposes:
To provide you with our Services
To set up your account – we use the registration information you provide us with, the personal data we receive from third-party services, and your device details so we can set up an account for you, and you can start using our Services.
To connect your Banafo account with third-party services – we use your account information and any credential information that you decide to provide us with to integrate Banafo with any one of the supported third-party services.
To provide you with Banafo’s transcription and voice analytics services – we use your conversation recordings and records, as well as device and platform information, so we can provide you with our transcription and voice analytics services.
To support your use of our Services – we use your communication details, device information, and usage data so we can support you whenever necessary – for example, when you’re having issues logging in or simply when you have a question or feedback for us.
To communicate with you
To notify you about important updates to our Services and other urgent matters, related to your account – we may use your contact details to send you e-mails and other notifications when there are relevant changes to our Services that might affect you or when your attention is required due to matters, related to your Banafo account.
To send you marketing information and information materials related to Banafo – if you request information from us, register for our Services, or take part in any surveys or feedback forms, we may send you newsletters, product news, and other information that you might find interesting. We will only do this if it is permitted by law and we have your prior consent, and you will always have the option to unsubscribe.
To comply with law
If necessary and appropriate, we may use your personal data to comply with applicable laws, lawful requests, and any other relevant legal reason, such as a subpoena or an official request from a government authority.
To prevent fraud, defend ourselves against legal claims and disputes, and ensure safety
We will use your personal data if necessary or appropriate:
- to enforce the terms and conditions that govern our Services;
- to protect our rights, privacy, safety, property, and that of you and others;
- to monitor the use of our Services to detect fraud or any other harmful and illegal behaviour.
4. HOW WE SHARE INFORMATION WE COLLECT
Banafo is a cloud-based service intended to help your team collaborate. This naturally means that information, including personal data, is often shared with both Users and third-party service providers.
- Sharing with other Users
Depending on your specific settings, other Users of our Services might be able to see information about you, including, but not limited to personal data such as your name, contact details and conversation metadata.
- Sharing with cloud service providers
We want to keep your personal data as safe as possible, which is why we have invested in our own EU-based infrastructure.
- Sharing with payment processors
We work with Stripe and PayPal, who are responsible for the processing of all your payments to us. The payment processors may use your Personal Information for their own purposes in accordance with their privacy policies.
- Sharing with transcription service providers
Until we become 100% independent when handling your voice-to-text transcriptions, we might have to rely on third-party transcript providers for some of the transcripts. If this is the case, we will inform you about it before you have provided us with your recording.
- Sharing with the providers of the integrated third-party services
When you connect Banafo to any of the supported third-party service providers, you specify the information that we are authorized to share and receive on your behalf. We are not responsible for their data protection practices and policies, which are part of your legal relationship with them as a user of their services. We encourage you to learn about their privacy and security policies before deciding to integrate your Banafo account with them.
- Sharing with Banafo’s subsidiaries & affiliates
- Sharing with law enforcement authorities
We might be legally obliged to disclose your personal data to law enforcement agencies, public authorities, or other judicial bodies and organizations in connection with any actual or prospective legal proceedings or in order for us to exercise or defend our legal rights.
5. HOW LONG WE STORE YOUR PERSONAL INFORMATION
Banafo will store your Personal Information for as long as necessary to fulfill the purpose for which it was collected, including to satisfy any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider various factors, such as the amount, nature, level of sensitivity, the potential risk of harm from unauthorized use or disclosure, as well as the specific purposes for which it was collected and whether or not it has become possible to achieve those purposes through other means. In many cases, we are legally obligated to keep your data for a specific period of time, which is the case with your billing information.
We may anonymize your personal data (which will make it impossible for any person to be identified through it, either directly or indirectly) so we can use it to improve further the services we provide to you.
6. WHAT LEGAL RIGHTS DO YOU HAVE
As a data subject under the GDPR, in certain circumstances, you have the following rights in relation to your Personal Information that we hold:
ACCESS: You have the right to access the personal information we hold about you and to receive an explanation of how we use it and with whom we share it.
RECTIFICATION: You can ask us to have inaccurate Personal Information amended.
ERASURE: You have the right to request to have your account deleted, along with all your personal data.
OBJECTION: You have the right to object to our processing of your PersonalInformation. If you object, we will no longer process your personal data in the future unless we can prove compelling grounds for the processing that outweigh your interests.
RESTRICTION: If you have previously agreed to us collecting and using yourPersonal Information, you are free to change your mind at any time by contacting us at firstname.lastname@example.org. However, keep in mind that this might mean that you will no longer be able to use our Services.
PORTABILITY: You have the right to data portability. You can ask us to provideyou with a copy of your Personal Information in such a form that you can send it to a third party, which we will do in accordance with your user plan.
WITHDRAWAL OF CONSENT: You have the right to withdraw any consent youhave previously applied to us and prevent further processing if there is no other legitimate ground upon which Banafo can process your Personal Information. This will not affect the lawfulness of the processing before you have withdrawn your consent.
UNSUBSCRIPTION: You can always unsubscribe from our non-transactional and non-account-related promotional emails by clicking on the “unsubscribe” link located at thebottom of all our email communication with you. You can submit these requests by email by sending them to email@example.com. We may ask for specific information from you so we can confirm your identity and process your request. Depending on the applicable law, we might not be able to fulfill your request, in which case we will provide you with information about the reasons. We may also redact from the data which we make available to you any personal data related to others.
Banafo does not provide services designed to be used by children under the age of 16, nor do we knowingly collect or solicit personal data from anyone under the age of 16. If we learn that we have collected any such data, we will delete it right away – both from our service and backups and third-party service providers.
If you learn that a child under the age of 16 has provided us with any Personal Information in violation of this Policy, please contact us at firstname.lastname@example.org.
8. DATA SECURITY
We use situation-appropriate security measures to protect the security of your Personal Information. These measures may vary in accordance with the level of sensitivity of the personal data. We also take measures to ensure that all the third-party service providers that we use for personal data processing on our behalf have appropriate security controls in place.
However, please keep in mind that no service is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or a data breach will never occur. The transfer of Personal Information through the internet will carry its own inherent risks, and we do not guarantee the security of your data transmitted through the internet. You make any such transfer at your own risk.
Please, be informed, that Banafo beta version does not represent the final product and may contain bugs that may cause system or other failure and data loss. Any beta integrations will be automatically transitioned to the final version and data may be lost during the migration.
If necessary for complying with applicable law, we will seek your consent to any important changes.
However, you can always file a complaint with the Bulgarian Data Protection Authority – the Bulgarian Commission for Personal Data Protection (on +359 02 9153 519 or via email@example.com).