Bunpo Privacy Policy

In this GDPR section, we use the terms "Personal Data" and "processing" as defined in the GDPR. "Personal Data" typically refers to information that can identify an individual, and "processing" encompasses actions related to data, such as collection, use, storage, and disclosure. Bunpo will be the controller of your Personal Data processed in connection with the Sites. Note that we may also process Personal Data of our customers' end users or employees in connection with providing services to customers, in which case we act as the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party first to address your rights concerning such data.

If any conflicts arise between this section and any other provision of this Privacy Policy, the policy or portion that offers greater protection to Personal Data will prevail to the extent of such conflict. If you have any questions about this section or whether it applies to you, please contact us at help@bunpo.app.

What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Sites.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

• Required:
• First and last name
• Email address
• IP address(es)
• Optional:
• General location

Information we receive from third party sources: Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following:

• Account information for third party services: If you interact with a third party service when using our Sites, such as if you share content from our Sites through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.

Information we automatically collect when you use our Sites: Some Personal Data is automatically collected when you use our Sites, such as the following:

• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information
• Transaction information (e.g. transaction amount, date and time such transaction occurred)
• Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) — For more information, please review our Cookie Policy.
• Location inferred from your IP address
• Log data (e.g. access times, hardware and software information)

How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalize our Sites. For example, we use Personal Data to:

• Create and manage user profiles
• Communicate with you about the Sites
• Process orders
• Contact you about Site announcements, updates or offers
• Provide support and assistance for the Sites
• Personalize website content and communications based on your preferences
• Meet contract or legal obligations
• Respond to user inquiries
• Fulfill user requests
• Comply with our legal or contractual obligations
• Resolve disputes
• Protect against or deter fraudulent, illegal or harmful actions
• Enforce our Terms and Conditions

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our "legitimate interests" or the legitimate interest of others, as described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of "contractual necessity," meaning we need to process the data to perform under our Terms and Conditions with you, enabling us to provide you with the Sites. Failure to provide such Personal Data will result in your inability to use some or all portions of the Sites requiring such data.
  • First and last name
  • Email address
  • General location
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
  • First and last name
  • Email address
  • IP address(es)
  • Examples of these legitimate interests include:
    • Operation and improvement of our business, products, and services
    • Marketing of our products and services
    • Provision of customer support
    • Protection from fraud or security threats
    • Compliance with legal obligations
    • Completion of corporate transactions
  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
  • Other Processing Grounds: From time to time, we may also need to process Personal Data to comply with a legal obligation, protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms and Conditions. These parties include:

• Payment processors
• Ad networks
• Analytics service providers
• Services to provide customer support
• Hosting service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. These parties include:

• Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Sites)
• Social media services (if you interact with them through your use of the Sites)
• Other parties authorized by you

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).

We also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our Terms and Conditions, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services
• Provide a service directly authorized and requested by you, the end user

If we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we or substantially all our assets were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets transferred or acquired by a third party, and we would share Personal Data with the party acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data? We retain Personal Data about you as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

Personal Data of Children: We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Sites or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at help@bunpo.app.

What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights or to submit a request, please email help@bunpo.app. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. In certain circumstances, you can correct some of this information directly by either updating directly in the relevant Account settings.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. However, if you exercise this right, you may need to provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data if such use or disclosure is necessary to enable you to utilize some or all of our Sites.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

Right to File Complaint: You have the right to lodge a complaint about Bunpo's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Option 1: Delete from the App
Open the Bunpo app → Settings (gear icon) → "Delete Account" → Confirm your identity and follow the prompts.

Option 2: Request via Email
Send an email to help@bunpo.app with the subject "Account Deletion Request" and include the email address associated with your account.

What data is deleted:

• Profile information (name, email address)
• Learning progress and history
• Subscription information
• Any other data associated with your account

Account deletion is permanent and cannot be undone. If you have an active subscription through Apple App Store or Google Play Store, you must cancel it separately before deleting your account. App-initiated deletions are processed immediately; email requests are processed within 7 business days. We may retain certain data as required by law or for fraud prevention purposes.

For more details, visit our Account Deletion page.