Privacy Policy

Bantoo Link Privacy Policy 

This privacy policy will be effective for all users from September 16, 2023. (Version 1.1) 
Last revised on: September 16th, 2023 

This Privacy Policy describes how Bantoo Pay Ltd. and its subsidiaries and affiliates, including but not limited to Bantoo Pay Africa SAS. and Bantoo Investment Group. (collectively, “BANTOO LINK,” or “we” or “us” or “our”) collect, use, and share Personal Information. This Privacy Policy applies to all services offered through our mobile applications, platforms, and websites (collectively, the “Services”), and to any Personal Information obtained from website visitors and users who provide us with their Personal Information in connection with the Services we provide directly to those users. 

We take your privacy seriously. We encourage you to review this Privacy Policy whenever you access our Services or otherwise interact with us to stay informed about our data privacy practices and the choices available to you. By using the Services,  

The Privacy Policy set forth the legally binding terms and conditions that govern your use of the Ecosystem. By accessing or using the Ecosystem, you are accepting BOTH these Terms and our Privacy Policy, available at, on behalf of yourself or the entity that you represent. You represent and warrant that you have the right, authority, and capacity to enter into BOTH these Terms and the Policy (on behalf of yourself or the entity that you represent). You may not access or use the Ecosystem or accept the Terms or the Policy if you are not at least 13 years old. Do not access and/or use the Ecosystem if you do not agree with all of the provisions of these Terms and the Policy. 

1. Information We Collect 

We collect your Personal Information based on the purpose for which you provide it to us. “Personal Information” includes any information that we collect about you that, alone or in combination with other information, can be used to identify you, such as a personal identifier (e.g., name, email or postal address, phone number, etc.), online identifiers, or inferences about your preferences. For the purpose of this Privacy Policy, Personal Information also includesPersonal Data,” as defined under the General Data Protection Regulation (“GDPR”) or other applicable international data protection laws. 

We collect Personal Information in the following situations, as applicable: 

  1. When you browse our website or use our Services; 

  1. When you voluntarily provide information directly to us (e.g., when you sign up to become a registered user of our Services or provide content to our platforms); and 

  1. When you register to join Bantoo Link platform by logging into an account through a third-party Social Networking Site ("SNS"). Please be advised that if you decide to create your user account by logging into an SNS via the Services, you are using the Personal Information you have already provided to the SNS (such as your  

We collect (or have collected during the preceding 12 months from the date of this Policy) Personal Information that generally falls within one or more of the following categories: 

Direct Identifiers. We collect identifiers such as your real name, alias, email address, phone number, account username and password, photographs, biographical information, and other similar information. 

Protected Classifications: We collect age information based on date of birth. 

Internet Activity. We collect usage and log data about devices you use to access the websites, such as browser type, device manufacturer, operating system, domain name and IP address, the webpage you were visiting before you came to our Services, the webpages of our Services that you visit, information you search for on our Services, access times and dates, and other statistics  

Inferences drawn from other Personal Information: We collect Personal Information reflecting personal preferences of users. 

2. How We Use Your Information  

We may also use the Personal Information we collect as otherwise disclosed to you at the point of collection, or for any other purposes with your consent. We use your Personal Information in the following circumstances: 

Account registration. We create your user account for your use of the Services based upon the Personal Information you provide. You may review, update, correct or delete the Personal Information in your account by editing your profile via the Services. If you choose to completely delete all of your Personal Information, your account may  

Communications. We use your Personal Information to contact you regarding our newsletters, marketing, or promotional materials or other information that may be  

To personalize or improve the user experience. We may aggregate your Personal Information with other information collected from other users to attempt to  

Fraud detection and prevention. We may use your Personal Information to detect and prevent potential fraud with respect to the Services. For example, we use your mobile phone number to provide you with a one-time verification code to ensure you are not a robot. 

3. Information We Disclose to Third Parties 

We will only share your Personal Information at your direction, with your consent, or in the following circumstances: 

Other Users. When you register through the Services and submit Personal Information to create a profile, other users will be able to view your username and channel name (if applicable). If you do not want Personal Information to be viewed by others, we recommend that you do not include Personal Information in your username or channel name. Should you choose to provide additional Personal Information (e.g., photos, location data, or  

Affiliates. We may share your Personal Information with companies under common ownership and control of Bantoo Link, including the parent company and its affiliates. 

Third Party Service Providers. We may retain third party service providers to provide services on our behalf (e.g., maintenance services, web analytics and improvement of the Service's features) or to assist us in analyzing how our Services are used, including with certain third parties for industry analysis, demographic profiling, and other purposes. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We may disclose Automatically Collected Information obtained from your use of the Services to third party service providers who provide services to us. 

Social Networking Sites. When you registered your account with Bantoo Link, you expressly agreed with and consented to this Privacy Policy. With your consent to this Privacy Policy, along with any consent you have given with respect to any Social Networking Sites (“SNS”), blogs titles, posts titles, music/audio titles, video titles, descriptions, and/or thumbnails that you engage with, together with Personal Information that may identify you (e.g., IP address, device ID, or other identifiers) may be shared with an SNS. With your consent to this Privacy Policy, we may also share information regarding the other users account and pages, you visit, blogs you write and read, musics you post or listen, products and services you sale or purchase in the marketplace, funding you received or give, videos you create, post or the ones you watched, and films you watched through the Film/Movie section. All this being discribed services (e.g., films, video, music, titles, descriptions) along with other information, to assist us and other third parties to provide you with more personalized content, including ads displayed on Bantoo Link as well as other platforms. Your SNS consent preferences may be changed at any time through your SNS account. Please be advised that where your SNS account preferences do not grant consent to share information regarding your activies and interactions through the Bantoo Link platforme and Services, we may still share other Personal Information about you for any other purpose described in this Privacy Policy. 

Legal Obligations. We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to satisfy our legal obligations. This may include: (i) to comply with the law or in response to a subpoena, court order, government request, or other legal processor to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (ii) to protect the interests, rights, safety, or property of us, or any of our users, subsidiaries, affiliates, employees, or others; (iii) to monitor compliance with and enforce our Website Terms and Conditions of Use; (iv) to operate the systems that ensures the Services function properly; or (v) if we believe in good faith that a disclosure is necessary. When permitted by law, we will attempt to notify you before we disclose your Personal Information to satisfy our legal obligations. 

Business Transactions. In the event that Bantoo Link goes through a business transition, such as a corporate divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, your Personal Information may be sold, divested, assigned, shared, or otherwise transferred in connection with  

We may use and  

4. Choices Regarding Your Information 

Email Communications. If you decide at any time that you no longer wish to receive email communications from us, please follow the unsubscribe instructions provided in any of the communications or update your account settings. 

Social Networking Sites.When you log-in through an SNS account, such as Facebook, Instagram, Telegram, Vkontact, WeChat, Google+, LinkedIn, the privacy policy of that SNS applies to their collection, use, and disclosure of your Personal Information. In addition, the SNS may collect Personal Information about your activity on the Bantoo Link website for the purpose of providing you with targeted advertising and other services. You may determine whether or not your activity on the Services will be shared and disclosed through the privacy settings on your SNS accounts. Please review the privacy policies of the SNS with whom you engage to better understand the information they collect and the choices you have with respect to the collection, use, and disclosure of your Personal Information. You can disable the feature that links your account to a SNS at any time by logging into your SNS account and selecting the option to disable connection to your SNS. 

5. Links to Other Websites 

Our Services contain links to other third-party websites and online services. If you choose to visit another website or online service by clicking on a link, you will be directed to that third party's website or online service. Other websites and online services follow different rules regarding the collection, use and/or disclosure of Personal Information. We encourage you to read the privacy policies or statements of the other websites or online services you visit before providing any information or using such websites or services to carefully understand their privacy practices. 

6. Data Security 

We care about the security of your Personal Information. Bantoo Link maintains administrative, technical, and physical safeguards reasonably designed to guard Personal Information that has been provided to us from loss, misuse or unauthorized access, disclosure, alteration, or destruction. We utilize commercially reasonable safeguards to preserve the integrity and security of information collected and maintained through the Service and comply with applicable laws and industry standards to secure and protect information transmitted via or stored through our Services. However, while we strive to protect your information, we cannot guarantee the security of information you transmit to our Site. 

7. Cookies and Other Tracking Technologies 

“Cookies” are small amounts of data generated by a website and saved by your web browser. Browsers store the data temporarily and return it to the server on subsequent visits or requests. Web beacons are a small image file (usually a transparent 1x1 pixel image) used for tracking purposes. They may be placed in a webpage or HTML email to record when the content was loaded. We use the information collected by web beacons to statistically monitor how many people are using our Services. We utilize both cookies, pixels, and web beacons to help us keep our Services secure, measure the performance of our Services, understand how visitors interact with them, count numbers of visitors, and improve the user experience. For example, cookies, pixels, and web beacons may be embedded in videos or web pages to collect certain types of information from your device or web browser in order to determine if you have viewed a particular video, web page, or advertisement. 

In addition to Bantoo Link’s use of cookies and web beacons, we have relationships with advertising companies and SNS, including Bantoo Link’s own Ad Manager, who may serve ads and/or collect certain information when you visit our web site. These advertising companies typically use a cookie, pixel, or third-party web beacon to collect this information. For example, these companies may use information collected about you (e.g., IP address, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits in order to provide advertisements about goods and services that may be of interest to you. In addition, these  

Most browsers are set to accept cookies by default, but you can control and manage the use of cookies on your browser or device by deleting them from your browser history when you leave our website. If you do not wish to receive cookies, you may set your browser to reject cookies or alert you when a cookie is set on your computer. If you use a mobile device to access our Services, certain information associated with your device may be collected (e.g., browser type, device manufacturer, device model, etc.) and used for purposes similar to cookies. Most mobile devices allow you to disable the ability for geolocation information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geolocation data. Please be advised, if you disable certain cookies, some of the features of our website may not function properly or be available to you, such as those which require identification. 

Do Not Track Requests. Some web browsers have Do Not Track (“DNT”) or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. Currently, Bantoo Link does not  

8. Notice to California Residents 

The California Consumer Privacy Act (“CCPA”) provides California residents with right to receive certain disclosures regarding the collection, use, and sharing of their Personal Information, and the right to know, access, delete, and limit sharing of Personal Information. In the past twelve months, we may have collected the categories of Personal Information as described in the “Information We Collect” section. We provide California residents the privacy rights listed below in accordance with the CCPA: 

The right to know. You may request the following information about how we have collected and used your Personal Information during the past 12 months: (i) the specific pieces of Personal Information we have about you; (ii) the categories of  

(i) Within the preceding 12 months, Bantoo Link has collected the following categories of Personal Information to provide our Services: Identifiers (e.g., email address, username or  

(ii) We  

(iii) Within the preceding 12 months, Rumble has used the following categories of Personal Information: Identifiers; Categories of Personal Information under the California Customer Records statute; Internet Activity; and Inference Data for the following business purposes: operate and improve  

(iv) Within the preceding 12 months, Bantoo Link has disclosed the following categories of Personal Information for a business or commercial purpose: Identifiers  

The right to deletion. In certain circumstances, you have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why. 

The right to equal service. If you choose to exercise any of these rights, Bantoo Link will not discriminate against you. However, if you exercise certain rights under this Privacy Policy, please be advised that you may be unable to use or access certain features of Bantoo Link’s Services. 

You may exercise your right to know and your right to deletion two times a year free of charge. To exercise your right to know or your right to deletion, contact us through one of the methods listed at the bottom of this Privacy Policy. 

Request Verification and Response. We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you are a registered user of our Services, we will use our existing account authentication practices to verify your request. If you do not have an account with us, we may request additional information about you. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose. We will confirm our receipt of a verifiable consumer request within ten (14) business days and respond to a verifiable consumer request within forty-five (45) days of receipt. If we need more time to respond, we will provide written notification to you, including our reason for the  

Authorized Agent. You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect  

Sale of Personal Information. Bantoo Link does not sell Personal Information, as such term is defined under the CCPA. However, we  

Other California Privacy Rights. Under California’sShine the Light” law (Ca.Civ.Code Section 1798.83), California residents are entitled to request and obtain from Bantoo Link once per calendar year information about when we share your Personal Information with third parties for those third parties’ own direct marketing purposes. To request this information, please email us at the address indicated below in the Contact Us section and note “California Shine the Light” in the subject line. 

9. Notice to Residents of the European Economic Area (“EEA”) and the United Kingdom (“UK”) 

Bantoo Link may collect, process and retain the data of residents of the EEA or the UK in order to provide Services to its customers. If we do collect personal information from data subjects in the EEA or the UK, we are required to comply with the GDPR, UK GDPR, and applicable local laws with regard to certain Personal Information we collect. We process Personal Information for the purposes described above. If we use or process Personal Information in ways other than described in this Privacy Policy, we will provide you with specific notice at the time of collection. 

For such Personal Information, Bantoo Link is the data controller of the Personal Information. 

Any Personal Information we may collect is detailed in “Information We Collect.”We rely on the following legal bases to process your Personal Information (i) valid consent provided by you; (ii) as necessary for the performance of a contract; (iii) compliance with a legal or regulatory obligation; and (iv) to fulfill our legitimate interests unless your fundamental rights and freedoms override those interests. 


How We Use Your Personal Information  


Lawful Basis for Processing Your Personal Information  


Onboard you as a user, verify your identity, process and fulfill your account registration, and perform other activities that are part of our Services  


Our processing may be based on your valid consent or our legitimate interests to provide you with information you need and to respond to your requests 


Communicate with you by promoting our Services, including other marketing communications and newsletters  


Our processing may be based on your valid consent or our legitimate interest to provide you with information you need and to respond to your requests 


Improve the quality of our Services, and for other related internal business purposes  


Our processing may be based our legitimate interest to improve our Services.  


Ensure the  


Our processing is  


Comply with our legal and regulatory obligations, including establishing, exercising and/or defending legal claims  


Our processing is based on complying with applicable legal or regulatory requirements 

Data Subject Rights. If you are a resident of the EEA or the UK, you have rights with respect to your Personal Information under the GDPR or UK GDPR. Subject to certain conditions, if you  

  • Access: You have the right to access certain information about how we process your Personal Information,  

  • Correction: You have the right to rectifyinaccurate Personal Information concerning you and, in certain circumstances, the right to have incomplete Personal Information completed; 

  • Deletion: You have the right to erasure of  

  • Portability: Where processing is based on your consent or on a contract, the right to data portability (the right to obtain a copy of the data  

  • Restrict Processing: You have the right to restrictour processing of  

  • Object to Processing: You have the right to object  

  • Complaints: You have the right to lodge a complaint with your local competent supervisory authority. 

You can submit these requests by email or by post. Addresses are provided below. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. Please note that if you decide to exercise some of your rights, we may be unable to perform  

Special Categories of Personal Information. Bantoo Link does not knowingly collect Special Categories of Person Information, which includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning  

Withdrawal of Consent. Where you have given us valid consent to collect, use, and process your Personal Information in certain ways, we will rely on your consent. In instances in which we have based our processing of your Personal Information on your consent, you have the right to withdraw your consent. Please note that when you withdraw consent, we might not be able to provide you with Services. To withdraw such consent, please contact us through the methods listed below. Please note that in certain situations, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain information if we need to do so to comply with a legal obligation or if it is necessary to do so to pursue our legitimate interest in keeping the Services safe and secure. 

10. Notice to Residents of Brazil  

If you are a resident of Brazil, you have certain protections and rights under the Brazilian General Data Protection Law (“LGPD”). We rely on the following legal bases to process your Personal Information: (i) valid consent provided by you; (ii) as necessary to fulfill a contract; (iii) to fulfill our legitimate interest, unless your fundamental rights and liberties outweigh those interests; or (iv) to comply with a regulatory or legal obligations. 

If you are a resident of Brazil, you have the right to obtain the following regarding your Personal Information: (i) confirmation of processing; (ii) access to data upon  

Sensitive Data. As defined under LGPD, Rumble does not knowingly collect Sensitive Data, which may include information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning  

For website visitors  

11. Notice to Residents of Canada 

If you are a resident of Canada, you have rights under the Personal Information Protection and Electronic Documents Act (“PIPEDA”). We strive to ensure the information we have about you is accurate and will your personal information for as long as required to comply with all business, legal and regulatory record keeping requirements and aligned with our internal policies and retention schedules. You have the right to access, correct, complete or delete  

We will seek your consent, either express or implied, prior to the collection, use, or disclosure of your Personal Information. If you object to the processing of your Personal Information, or if you have provided your consent to processing and you later choose to withdraw it, you have the right to withdraw your consent to the processing of your Personal Information under certain circumstances. We will do our utmost to ensure the information we have about you is accurate and complete and will keep your Personal Information for as long as required to comply with all business, legal and regulatory record keeping requirements and aligned with any internal policies and retention schedules. 

If you wish to exercise any right set forth in this section, please contact us through one of the methods listed at the bottom of this Privacy Policy. We may request specific information from you to confirm your identity prior to processing your request. 

12. International Data Transfers 

Our Services are based, controlled, operated, and administered by us in the United Kingdom, United States, Sweden and South Africa, where Bantoo Link’s servers are located. Please be advised that the laws of the United Kingdom and/or United States, Sweden, South Africa, may not provide the same level of data protection as the jurisdiction in which you reside. If you visit our websites or use our Services from a jurisdiction outside of the United Kingdom and/or United States, Sweden, South Africa, your Personal Information may be transmitted to, stored, or processed in the United Kingdom and/or United States, Sweden, South Africa and by using our websites, you authorize the transfer to and processing of your Personal Information in the United Kingdom and/or United States, Sweden, South Africa. If we transfer your Personal Information internationally in a manner which requires certain legal protections for your Personal Information, we will pursuant to agreements that incorporate standard contractual clauses approved by applicable data protection authorities   

13. Data Retention  

We may retain your Personal Information for as long as reasonably necessary for the purposes for which it was originally collected, and the purposes outlined in this Privacy Policy. In some circumstances, we  

14. Children’s Privacy  

We do not knowingly collect Personal Information from children under 13 and children under the age of 13 are not permitted to use our Services. If we become aware that a child under 13 has provided us with Personal Information, we will promptly delete such information from our systems. If a parent or guardian becomes aware that his or her child has  

15. Contact Information  

If you have any questions or would like to exercise your rights regarding this Privacy Policy, please contact us at the addresses listed below.  Please includePrivacy” in the subject line of your inquiry so that we may route your communication to the appropriate party. Additionally, if you have complaints about Bantoo Link’s processing of your Personal Information,   

Name: Bantoo Link. 

Address: BB Group, Box 1010, Roslagsgatan 34, 114 79 Stockholm, Sweden  



Annex 1 : 

Data Processing Agreement 

This Data Processing Agreement (" DPA") of Bantoo Pay Ltd. and its subsidiaries and affiliates, including but not limited to Bantoo Pay Africa SAS. and Bantoo Investment Group. (collectively, “BANTOO LINK,” or “we” or “us” or “our”) is an extension of Bantoo Link's Terms of Use and the Bantoo Link's Privacy Policy (available at and will outline certain requirements that USERS, Pro USERSs, Contents Owners, Sallers, Buyers and USERSS (collectively, “USERSS,” or “them” or “their) must follow when processing their Data and other USERSs Data (defined below). All capitalized terms not defined in this DPA shall have the meanings set forth in Bantoo Link's Terms of Use or Privacy Policy, as applicable. 

Bantoo Link gives USERS the ability to sell, to buy and/or to offer paid content for Pro Account subscribers in exchange for certain Benefits. In order to enable USERS to connect directly and interact between each other and fulfill these Benefits, Bantoo Link provides access to the personal data of USERS (" USERS Community Data") to the applicable. The USERS may then process such USERS Community Data in order to provide  

This DPA is between Bantoo Link and USERS only and is effective immediately upon a USERS first creating an Account via the Site. All USERS must agree to this DPA in order to protect the privacy rights of the whole USERS Community when processing USERS Community Data. This DPA applies exclusively to the USERS Community Data collected by Bantoo Link and provided to a USERS solely for the purpose of enabling the USERS to provide the Benefits offered to his or her USERS Communitys. 

1. Definitions. 

1.1. "Data Protection Legislation" means all applicable laws, regulations, guidance and codes of practice relating to privacy and the processing of USERS Community Data that may exist in any relevant jurisdiction, issued by the supervisory authorities. Data Protection Legislation includes, but is not limited to, European Directives 95/46/EC and 2002/58/EC (as amended by Directive 2009/136/EC) and any legislation or regulation implementing or made pursuant thereto, or which amends, replaces, or  

1.2. The terms "data controller", "data processor", "subprocessor", "data subject", "personal data", "processing", and "appropriate technical and organizational measures" shall be  

2. Processing. 

2.1. Role of the Parties. As between USERS and Bantoo Link, in relation to USERS Community Data that a USERS processes in the course of providing Offers or/and Benefits to its USERS Communitys, USERS will process USERS Community Data under this DPA only as a data processor acting on behalf of the Bantoo Link and Bantoo Link will act as a data controller. 

2.2. Bantoo Link Processing of USERS Community Data. Bantoo Link will comply with its obligations under Data Protection Legislation in respect of its processing of USERS Community Data and any processing instructions it issues to USERS. Bantoo Link represents that it has all rights and authorizations necessary for USERS to process USERS Community Data pursuant to this DPA. 

2.3. USERS Processing of USERS Community Data. USERS will comply with its processor obligations under Data Protection Legislation and will process USERS Community Data only in accordance with the Bantoo Link Policies (including this DPA), which USERS acknowledges are the complete and final instructions to USERS in relation to the processing of USERS Community Data. Additionally, the nature and purpose of the processing shall be limited solely to that necessary to carry out such instructions, and not for USERS's individual purposes, or for any other purpose except as required by law. If USERS is required by law to process USERS Community Data for any other purpose, USERS will inform each USERS Community of such requirement prior to the processing unless prohibited by law from doing so. USERS will not retain any USERS Community Data for longer than is necessary to provide the applicable Offers or/and Benefits. 

2.4. Processing of USERS Community Data. 

2.4.1. Subject matter. The subject matter of the data processing is the USERS Community Data. 

2.4.2. Duration. The duration of the processing is for as long as a USERS retains USERS Community Data. 

2.4.3. Nature and Purpose. The nature and purpose of the processing under this DPA is limited to a USERS's fulfillment of Offer or/and Benefits for its USERS Communitys. 

2.4.4. Categories of data subjects. The category of the data subjects are USERSs who sign up for Paid Subscriptions on the Ecosystem in order to receive Benefits as USERS Communitys of certain USERS. 

2.4.5. Categories of data. The type of personal data covered by this DPA includes contact information, including without limitation first and last name or account username, email address, shipping address, and amounts paid for Subscription Fees. 

3. Security Measures. 

3.1. Security Measures by Bantoo Link. Bantoo Link is responsible for using and configuring the Ecosystem in a manner that enables Bantoo Link to comply with Data Protection Legislation, including implementing appropriate technical and organizational measures. 

3.2. Security Measures by USERS. USERS will implement and maintain appropriate technical and organizational security measures to protect against USERS Community Data breaches and to preserve the security and confidentiality of USERS Community Data processed by USERS on behalf of Bantoo Link (" Security Measures"). The Security Measures shall be appropriate to the harm which might result from any unauthorized or unlawful processing, accidental loss, destruction, damage or theft of the personal data and having regard to the nature of the personal data which is to be protected and as a minimum  

3.3. Personnel. USERS restricts its personnel from processing USERS Community Data without authorization (unless required to do so by applicable law) and will ensure that any person authorized by USERS to process USERS Community Data is subject to an obligation of confidentiality and shall comply with the obligations set forth in the Bantoo Link Policies (including this DPA) and applicable Data Protection Legislation. 

4. USERS Community Data Breach Response. 

Upon becoming aware of a USERS Community Data breach, USERS will notify Bantoo Link without undue delay and will provide information relating to the USERS Community Data breach as reasonably requested by Bantoo Link. USERS will use reasonable endeavors to assist Bantoo Link in mitigating, where 

5. Data Transfers. 

USERS may not transfer USERS Community Data to any third party (including any affiliates, group companies or subcontractors) without the prior consent of Bantoo Link. USERS shall at all times ensure that any such transfers are made in compliance with the requirements of Data Protection Legislation and ensure the reliability and competence of such third parties, and must include in any contract with such third parties provisions protecting USERS Community Data which are equivalent to those in the Bantoo Link Policies (including  

6. Deletion of Data. 

Following expiration or termination of the Bantoo Link Policies (including this DPA) as they apply to USERS, USERS will delete or return to Bantoo Link all USERS Community Data in USERS's possession except to the extent USERS is required by applicable law to retain some or all of the USERS Community Data (in which case USERS will archive the data and implement reasonable measures to prevent the USERS Community Data from any further processing). The terms of this DPA will continue to apply to any retained USERS Community Data. 

7. Cooperation. 

7.1. Data Protection Requests. If USERS receives any requests from individuals or applicable data protection authorities relating to the processing of USERS Community Data under the Bantoo Link Policies, including requests from individuals seeking to exercise their rights under Data Protection Legislation, USERS will promptly redirect the request to the Bantoo Link. USERS will not respond to such communication directly without Bantoo Link's prior authorization, unless legally compelled to do so. If USERS is required to respond to such a request, USERS will promptly notify Bantoo Link and provide Bantoo Link with a copy of the request, unless legally prohibited from doing so. 

7.2. Bantoo Link Requests. USERS will reasonably cooperate with Bantoo Link, at Bantoo Link's expense, to permit Bantoo Link to respond to any requests from individuals or applicable data protection authorities relating to the processing of USERS Community Data under the Bantoo Link Policies to the extent that Bantoo Link is unable to access the relevant USERS Community Data. 

7.3. Legal Disclosure Requests. If USERS receives a legally binding request for the disclosure of USERS Community Data which is subject to this DPA, such request will be dealt with in accordance with the Bantoo Link Policies. 

7.4. Additional Cooperation. USERS shall assist Bantoo Link in complying with its applicable obligations under Data Protection Legislation and provide reasonable information requested by Bantoo Link to demonstrate compliance with the obligations set forth in this DPA. USERS will also notify Bantoo Link immediately if, in USERS's opinion, an instruction for processing of any personal data given by Bantoo Link may violate a country's Data Protection Legislation. 

8. General 

8.1. Relationship with Bantoo Link Policies. Any claims brought under this DPA will be subject to the terms and conditions of the Bantoo Link Policies, including the exclusions and limitations set forth in the Bantoo Link Policies. 

8.2. Conflicts. In the event of any conflict between this DPA and any privacy-related provisions in the Bantoo Link Policies, the terms of this DPA will prevail. 

8.3. Modification and Supplementation. Bantoo Link may modify the provisions of this DPA consistent with the terms of the Bantoo Link Policies, in circumstances such as: (i) if required to do so by a supervisory authority or other government or regulatory entity, (ii) if necessary to comply with Data Protection Legislation, or (iii) to implement or adhere to standard contractual clauses, approved codes of conduct or certifications, binding corporate rules, or other compliance mechanisms, which may be permitted under Data Protection Legislation. Supplemental terms may be added as an Annex or Appendix to this DPA where such terms only apply to the processing of USERS Community Data under the Data Protection Legislation of specific countries or jurisdictions. Bantoo Link will provide notice of such changes to USERS, and the modified DPA will become effective, in accordance with the terms of the Bantoo Link Policies or as otherwise provided on Bantoo Link's website if not specified in the Bantoo Link Policies 



Cookies and  

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. Other technologies, including data that we store on your web browser or device, identifiers associated with your device and other software, are used for similar purposes. In this policy, we refer to all of these technologies as  


We use cookies. If you have a Bantoo Link account, or if you use Bantoo Link Products, including our website and apps, or visit other websites and apps that use the Bantoo Link Products (including the Like button or other Bantoo Link Technologies). Cookies enable Bantoo Link to offer the Bantoo Link Products to you and to understand the information that we receive about you, including information about your use of other websites and apps, whether or not you are registered or logged in.  


This policy explains how we use cookies and the choices you have. Except as otherwise stated in this Privacy Policy (available at will apply to our processing of the data that we collect via cookies.  


Why do we use cookies? 

Cookies help us provide, protect and improve the Bantoo Link Products, such as by personalizing content, tailoring and measuring ads, and providing a safer experience. The cookies that we use include session cookies, which are deleted when you close your browser, and persistent cookies, which stay in your browser until they expire or you delete them. While the cookies that we use may change from time to time as we improve and update the Bantoo Link Products, we use them for the following purposes: 



We use cookies to verify your account and determine when you’re logged in so that we can make it easier for you to access the Bantoo Link Products and show you the appropriate experience and features. 

For example: We use cookies to keep you logged in as you navigate between Bantoo Link Pages. Cookies also help us remember your browser so you don't have to keep logging in to Bantoo Link and so you can more easily log in to Bantoo Link via third-party apps and websites. For example, we use the "c_user" and "xs" cookies, including for this purpose, which have a lifespan of 365 days.  


Security, site and product integrity 

We use cookies to help us keep your account, data and the Bantoo Link Products safe and secure. 

For example: Cookies can help us identify and impose additional security measures when someone may be attempting to access a Bantoo Link account without authorization, for instance, by rapidly guessing different passwords. We also use cookies to store information that allows us to recover your account in the event that you forget your password or to require additional authentication if you tell us that your account has been hacked. This includes, for example, our "sb" and "dbln" cookies, which enable us to identify your browser securely. 


We also use cookies to combat activity that violates our policies or otherwise degrades our ability to provide the Bantoo Link Products. 


For example: Cookies help us fight spam and phishing attacks by enabling us to identify computers that are used to create large numbers of fake Bantoo Link accounts. We also use cookies to detect computers infected with malware and to take steps to prevent them from causing further harm. Our "csrf" cookie, for example, helps us prevent cross-site request forgery attacks. Cookies also help us prevent underage people from registering for Bantoo Link accounts. 


Advertising, recommendations, insights and measurement 

We use cookies to help us show ads and to make recommendations for businesses and other organizations to people who may be interested in the products, services or causes they promote. 

For example: Cookies allow us to help deliver ads to people who have previously visited a business’s website, purchased its products or used its apps and to recommend products and services based on that activity. Cookies also allow us to limit the number of times that you see an ad so you don’t see the same ad over and over again. For example, the "fr" cookie is used to deliver, measure and improve the relevancy of ads, with a lifespan of 90 days.  


We also use cookies to help measure the performance of ad campaigns for businesses that use the Bantoo Link Products. 


For example: We use cookies to count the number of times that an ad is shown and to calculate the cost of those ads. We also use cookies to measure how often people do things, such as make a purchase following an ad impression. For example, the "_bbp" cookie identifies browsers for the purposes of providing advertising and site analytics services and has a lifespan of 90 days. 

Cookies help us serve and measure ads across different browsers and devices used by the same person. 


For example: We can use cookies to prevent you from seeing the same ad over and over again across the different devices that you use. 


Cookies also allow us to provide insights about the people who use the Bantoo Link Products, as well as the people who interact with the ads, websites and apps of our advertisers and the businesses that use the Bantoo Link Products. 


For example: 

We also use cookies, such as our "oo" cookie, which has a lifespan of five years, to help you opt out of seeing ads from Bantoo Link based on your activity on third-party websites. Learn more about the information we receive, how we decide which ads to show you on and off the Bantoo Link Products and the controls that are available to you.  


Site features and services 

We use cookies to enable the functionality that helps us provide the Bantoo Link Products. 

For example: 

We also use cookies to help provide you with content relevant to your locale. 

For example: We store information in a cookie that is placed on your browser or device so that you will see the site in your preferred language. 



We use cookies to provide you with the best experience possible. 

For example: Cookies help us route traffic between servers and understand how quickly Bantoo Link Products load for different people. Cookies also help us record the ratio and dimensions of your screen and windows and know whether you’ve enabled high-contrast mode, so that we can render our sites and apps correctly. For example, we set the "dpr" and "wd" cookies, each with a lifespan of 7 days, for purposes including to deliver an optimal experience for your device’s screen.  


Analytics and research 

We use cookies to better understand how people use the Bantoo Link Products so that we can improve them. 

For example: Cookies can help us understand how people use the Bantoo Link service, analyze which parts of the Bantoo Link Products people find most useful and engaging, and identify features that could be improved. 


Third-party websites and apps 

Our business partners may also choose to share information with Bantoo Link from cookies set in their own websites' domains, whether or not you have a Bantoo Link account or are logged in. Specifically, cookies named _btl or btp may be set on the domain of the Bantoo Link business partner whose site you're visiting. Unlike cookies that are set on Bantoo Link 's own domains, these cookies aren’t accessible by Bantoo Link when you're on a site other than the one on which they were set, including when you are on one of our domains. They serve the same purposes as cookies set in Bantoo Link 's own domain, which are to personalize content (including ads), measure ads, produce analytics and provide a safer experience, as set out in this Cookies Policy.  


Where do we use cookies? 

We may place cookies on your computer or device and receive information stored in cookies when you use or visit:  

  • Bantoo Link Products; 

  • Products provided by other members of the Bantoo Link Companies; and 

  • Websites and apps provided by other companies that use the Bantoo Link Products, including companies that incorporate the Bantoo Link Technologies into their websites and apps. Bantoo Link uses cookies and receives information when you visit those sites and apps, including Device information and information about your activity, without any further action from you. This occurs whether or not you have a Bantoo Link account or are logged in. 

Do other Companies use cookies in connection with the Bantoo Link Products? 

Yes, other companies use cookies on the Bantoo Link Products to provide advertising, measurement, marketing and analytics services to us, and to provide certain features and improve our services for you.  


For example, other companies’ cookies help tailor ads off of Bantoo Link, measure their performance and effectiveness and support marketing and analytics. Certain features on the Bantoo Link Products use cookies from other companies to function, for example, certain maps, payment and security features.  


Third party companies also use cookies on their own sites and apps in connection with the Bantoo Link Products. To understand how other companies use cookies, please review their policies.  


How can you control your information? 

We use cookies to help personalize and improve content and services, provide a safer experience and to show you useful and relevant ads on and off Bantoo Link. You can control how we use data to show you ads and more by using the tools described below. 


If you have a Bantoo Link account: 

  • You can use your ad preferences to learn why youre seeing a particular ad and control how we use information that we collect to show you ads. 

  • To show you better ads, we use data that advertisers and other partners provide us about your activity off Bantoo Link Company Products, including websites and apps. You can control whether we use this data to show you ads in your ad settings. 

  • The Bantoo Link Audience Network is a way for advertisers to show you ads in apps and websites off the Bantoo Linklink Company Products. One of the ways that Audience Network shows relevant ads is by using your ad preferences to determine which ads you may be interested in seeing. You can control this in your ad settings. 

  • You can review your Off-Bantoo Link activity, which is a summary of activity that businesses and organizations share with us about your interactions with them, such as visiting their apps or websites. They use our business tools, such as Bantoo Link pixel, to share this information with us. This helps us do things like give you a more personalized experience on Bantoo Link. Learn more about off-Bantoo Link activity, how we use it and how you can manage it. 



You can opt out of seeing online interest-based ads from Bantoo Link and other participating companies through the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada or the European Interactive Digital Advertising Alliance in Europe or through your mobile device settings, where available, using Android, iOS 13 or an earlier version of iOS. Please note that ad blockers and tools that restrict our cookie use may interfere with these controls.  


More information about online advertising: 

The advertising companies we work with generally use cookies and similar technologies as part of their services. To learn more about how advertisers generally use cookies and the choices they offer, you can review the following resources:  



Browser cookie controls: 

In addition, your browser or device may offer settings that allow you to choose whether browser cookies are set and to delete them. These controls vary by browser, and manufacturers may change both the settings they make available and how they work at any time. As of 7 September 2023, you may find additional information about the controls offered by popular browsers at the links below. Certain parts of the Bantoo Link Products may not work properly if you have disabled browser cookie use. Please be aware that these controls are distinct from the controls that Bantoo Link offers you.