Our Commitment to You:
At Banba, we take our obligations under data protection law very seriously and we’re committed
to keeping your personal data private and secure. This notice is designed to help you
understand what personal data we hold, why it is required, and how it is used.
This privacy notice (“Privacy Notice”) explains how Banba collect, share, and use your
personal information. You’ll also find information about how you can exercise your privacy
rights. By using our Services you acknowledge that Banba will use your personal information as
described in this Privacy Notice. This notice should be read in conjunction with our terms and
conditions.

About us
Banba is our trading name. Our company is Bartapp Limited. We are a company registered in
Ireland under company number 671542 and our office address is at 15 Carmen Law, Garryduff,
Cork, T12P8NK.

Please read the following carefully to understand our views and practices regarding your
personal information and how we will treat it.

We provide a way for consumers to communicate their Orders (“Orders”) for food along with
alcoholic and non-alcoholic beverages to bars and/or pubs (“Bars”) through our App. Our App is
a contactless ordering application (our “Services”). The Bars will display its menus on our App
and Orders can be selected through our App.

What personal data do we use?
We may collect and process the following personal data (hereafter referred to as “Data”) about
you:

Registration Information: Upon registration for the App, your email address, gender
and date of birth will be collected for the purpose of uniquely identifying you. The type of
smart phone being used to download the App, the browser (or browser version) being
used to access the App and the geographic location or region of where the App was
downloaded to will also be collected.

Additional information:
o if you contact Us, We may keep a record of that correspondence (including any
information you provide if you report a problem with our Services);
o when you use our App we will collect traffic data (i.e. how and when you access
the App), the Orders you make and location data on the the Bars that you have
visited.

Device Information: We may collect information about the device you may use to
download or stream a copy of the App onto your device, including, where available, the
device’s or computer’s unique device identifiers, operating system, browser type and
mobile network information, for system administration and to report aggregate
information to Our advertisers. We may associate device information with other
information you provide to us and will treat the combined information as Data in
accordance with this notice for as long as it is combined.

Location Information: When you use our App, we collect your geo-location and we
may use this information to show you Bars or content that is local to you as a user of
our App. This information will also support the users experience in discovering Bars
where you can use our Services.

Log Information: When you use our App, we may automatically collect and store
certain information in server logs, including but not limited to internet protocol (IP)
addresses, internet service provider (ISP), clickstream data, browser type and
language, viewed and exit pages and date or time stamps.

Why do we collect your information?
We collect your Data in order to:
● provide you with information and services that you request from us;
● register and maintain your Banba account. When you sign up to use our App, we will
use the details provided on your account registration form to create and administer your
account;
● provide you with access to the Banba App in a manner convenient and optimal for you
and with personalized content relevant to you, including enabling you to create a profile;
● allow you to participate in interactive features of our App when you choose to do so;
● provide you with marketing information about other services or products we offer that
are similar to those that you have already requested, or about the services or products
of third parties that you have consented to receiving marketing about;
● manage our relationship with you, including notifying you about changes to our services
and/or products;
● provide customer support;
● gather information and insights on how users are using our service in order to deliver
improvements and new features;
● administer our App and for internal operations, including troubleshooting, data analysis,
testing, research, statistical and survey purposes;
● deliver (whether directly or indirectly via third parties) effective and personalized
marketing material and content where you have consented to such and to assist us in
the improvement and optimization of advertising, marketing material and content, our
services and our App; and
● comply with our legal obligations, policies, and procedures.
● aggregate and anonymise your Data so that it can be used for market analysis.

Who we share Data with:

In delivering the Services to you, depending on the circumstances, we may share your Data
with the following entities:
● The Bars that you place Orders with so that the Bar can process the Order and prepare it for
you.
● Companies within the Banba group of companies (which means our subsidiaries and
affiliates) – these companies act for us and process your personal information for the
purposes set out in this Privacy Notice.
● Third parties who undertake various activities to promote, market or support our Services.
This includes social media platforms, offshore customer support agents, website and
Application support and hosting providers, marketing service providers, partners who
manage our marketing emails and push notifications, the companies who send you text
messages when your Order is ready for collection, market research companies and payment
processing providers which process payment card transactions.

● As mentioned above, we may also share information with third parties (for example, in the
food, drink and entertainment sectors) so that they can contact you about goods or services
which may interest you (either through the App or otherwise). We will only share your
information with these third parties where you have given your consent. If you don’t want us
to use your Data in this way or generally change your mind about receiving any form of
marketing communications, you can unsubscribe at any time using the unsubscribe
methodology in the communication you receive. You can also amend your profile to ensure
you do not receive marketing communications. If you choose to unsubscribe from our
marketing, we will keep a record of your preferences so that we don’t bother you with
unwanted marketing in future.
● If any part of our business enters into a joint venture, purchases another business or is sold
to or merged with another business entity, your information may be disclosed or transferred
to the target company, or new business partners or owners or their agents and advisors. In
these circumstances we will always inform the relevant entities that they must only use your
Data for the purposes disclosed in this Privacy Notice and all transfers of Data will be done in
accordance with applicable data protection law.
● Any law enforcement or regulatory body, government agency, court or other third party where
we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to
exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of
any other person.
● Any other person provided that you have given your consent to the disclosure. We will not
sell, distribute or lease your Data unless we have your permission or it is legally permissible
to do so.


Information for Bars using our Bar App
To the extent that you are using our App as a Bar and not a consumer the following won’t apply:
● We will not share your Data with the other Bars who use our App.
● We will not aggregate your Data in order to store your user history to market products or
offers that we think would interest you as a user of our App.
● You will not be required to provide details of your age, gender or date of birth in order to
use our App.


Legal basis for processing personal information
Our main reason for collecting and using your Data is to perform our contract with you (i.e. to
make sure you get you can place an Order with the Bar that you have selected from our App).
However we will also use your Data where it is in our legitimate business interests to do so (but
only if our interests are not overridden by your data protection interests or your fundamental
legal rights and freedoms). Relevant legitimate interests include:
a) to analyse and understand how our services are used and so to improve them;
b) to market to you or make you offers that we believe will interest you;
c) for the prevention of fraud or the prevention of other criminal acts; or
d) to keep our systems safe and secure.
In some cases, we may have a legal obligation to process your Data (e.g. in the event of legal
proceedings) or we might need to process it or share it with others to protect your vital interests
or those of another person (e.g. in a case where another person’s life is in danger).
If we ask you to provide Data to comply with a legal requirement or to perform a contract with
you, we will make this clear at the relevant time and advise you whether the provision of your
personal information is mandatory or not (and we’ll also explain the possible consequences of
you not providing it).


If we process your Data to market to you or make offers that we will believe will interest you, we
will always request your consent before we do this. If you do not wish for us to process your
Data for this purpose, we will retain a record of your objection to the processing of your Data so
that we can continue to respect your wishes and not market to you.
When we collect your consent, we will explain what we need it for and how you can change your
mind in the future. If we process your Data based on consent, you have the right to withdraw
that consent at any time.


If you have questions about or need further information concerning the legal basis on which we
collect and use your personal information, please contact us using the contact details provided
under the “How to contact us”.


Where is personal data stored and sent?
All information which you provide to us is stored in the EU.


Data Aggregation and Anonymization
We may aggregate certain Data of our users for the purposes of market analysis and we may
provide this aggregated data to third parties. However all such aggregated data will be fully
anonymised so it no longer contains personal data.
Security


We place great importance on keeping your Data safe and secure. As such, we put in place
appropriate technical and organisational measures / industry standard technology to protect it
from unauthorised access and unlawful processing, accidental loss, destruction and damage.
The security measures we use are designed to provide a level of protection security appropriate
to the risk of processing your Data.


You are responsible for protecting your account login details and must not share them with, or
disclose them to anyone. Where you have chosen a password which allows you to login to the
App, you are responsible for keeping this password confidential. We advise you not to share
your password with anyone and to use a unique password for our Services. We will not be liable
for any unauthorised transactions entered into using your name and password.


Children’s Privacy
Our App is not intended for the use of children. We do not knowingly collect personally
identifiable information from children under the age of 18. If we become aware that we have
collected personal information from a child under the age of 18, we will take immediate steps to
remove that information from our servers and shut down the account.


How long we keep your information for?
Your Data that we collect will be retained by us for as long as needed in order to fulfil the
purposes outlined in the ‘Why do we collect your information?’ section above. This means that
we will keep your personal information for the duration you hold an account with us. If you opt
to cease using our App, we will retain your Data for six months post deletion of the App in case
you decide to start reusing it. It will be deleted on the expiry of this six month period.
There may however be situations in which we are required to keep certain Data following expiry
of this period (for example where it is needed to comply with applicable regulations or laws, to
meet regulatory and financial reporting obligations, for tax, accounting and audit purposes, and
to fulfil and protect our contractual obligations and rights). When determining the relevant retention 

periods, we consider guidelines issued by relevant data protection authorities, as well as applicable law.


Your GDPR rights
Individuals in the EU have a number of rights under data protection law in relation to the way we
process your Data. These are set out below. You may contact us using the details on our App
or by emailing us directly at info@banba-app.com to exercise any of these rights, and we will
respond to any request received from you within one month from the date of the request.
Please address any questions, comments, and requests regarding our data processing
practices to info@banba-app.com in the first instance.


NUMBER DESCRIPTION OF RIGHT
Right 1 A right to access personal information held by us about you.
Right 2 A right to require us to rectify any inaccurate personal information held by us about you.
Right 3 A right to require us to erase personal information held by us about you. This right will only
Apply where, for example, we no longer need to use the personal information to achieve
the purpose we collected it for; or where you withdraw your consent if we are using your
personal information based on your consent; or where you object to the way we process
your information (in line with Right 6 below).

Right 4 In certain circumstances, a right to restrict our processing of personal information held by
us about you. This right will only Apply where, for example, you dispute the accuracy of the
personal information held by us; or where you would have the right to require us to erase
the personal information but would prefer that our processing is restricted instead; or where
we no longer need to use the personal information to achieve the purpose we collected it
for, but you require the information for the purposes of dealing with legal claims.

Right 5 In certain circumstances, a right to receive personal information, which you have provided
to us, in a structured, commonly used and machine-readable format. You also have the
right to require us to transfer this personal information to another organization, at your
request.

Right 6 A right to object to our processing of personal information held by us about you (including

for the purposes of sending marketing materials to you).

Right 7 A right to withdraw your consent, where we are relying on it to use your personal
information (for example, to provide you with marketing information about our services or
products).

If you have any concerns regarding our processing of your personal information, or are not
satisfied with our handling of any request by you in relation to your rights, you also have the
right to make a complaint to the Data Protection Commissioner in Ireland
(https://www.dataprotection.ie/) as well as a right to lodge a complaint with the relevant
authority.


Please note that we may need to retain certain information for our own record-keeping and
research purposes. We may also need to send you service-related communications relating to
your App user account even when you have requested not to receive marketing
communications.


Changes to our privacy notice
Any changes We may make to Our Privacy Notice in the future will be notified to you by
notifying you of a change when you next start our App. The new terms may be displayed on-
screen and you may be required to read and accept them to continue your use of our App.

Contact Us
If you need to contact us for any reason, including for any questions, comments or requests
regarding this notice, including the collection and / or use of your Data, or as otherwise indicated
in any section of this Privacy Notice, Our contact details are as follows:
Address: 15 Carmen Law, Garryduff, Cork, T12P8NK
Email: info@banba-app.co