BANG ANALYTICS PRIVACY POLICY

This Privacy Policy (“Policy”) explains how Bang Analytics Ltd ("Bang Analytics", "we", "us" or "our") uses personal information in connection with our website, business enquiries and our business activities. This Policy applies to visitors to our website and people who contact us, and identifiable individuals whose information appears in publicly accessible posts included in our analytical work. 

It also explains the rights available to individuals under applicable law. Bang Analytics Ltd is registered in England and Wales under company number 13363793, with its registered office at 19 Austin Street, London, England, E2 7NB. For the processing described in this Policy, Bang Analytics Ltd is the controller unless the circumstances expressly indicate otherwise. Privacy enquiries may be sent to yiannis@banganalytics.agency. We may update it from time to time to reflect changes in our services, processing activities, technology or legal requirements.

1. Information we collect. 

When you visit our website or contact us, we may process your name, email address, business or professional details, correspondence and anything else you choose to provide. 

For client projects, we may process information from publicly accessible professional or social content relevant to the agreed project scope. This may include post text, publication date and time, public engagement information, post or profile URLs, analytical labels such as relevance, topic, brand, theme or sentiment, and limited publicly displayed professional information about an author, such as name, job title, organisation or employer and country. Projects are normally limited by reference to specified brands, topics, events, markets and date ranges. We do not intentionally collect private messages or content that is not publicly accessible to any visitors of respective platforms. 

We generally obtain public-post information indirectly from publicly accessible online sources, including professional and social platforms, websites and public profiles, and from third-party data or technology providers. The particular sources used may vary depending on the scope of the relevant project.

1. Why we use personal information. 

We use website, enquiry and business-contact information to operate and secure our business and website, respond to enquiries, administer commercial relationships, maintain records, establish or exercise legal rights, and comply with applicable legal or regulatory obligations. 

We use public-post information to provide market, brand, topic, communications and related analytical services. This may include analysing public discussion of specified brands, topics, events or markets, identifying themes and trends, assessing engagement and producing statistics, reports, datasets and other analytical outputs. Our analytical activities are directed principally at public conversations, brands, markets and topics rather than at making decisions about individual authors. We do not use public-post information to make solely automated decisions about individuals that produce legal or similarly significant effects.

1. Lawful bases. For public-post information, Bang Analytics generally relies on legitimate interests under Article 6(1)(f) UK GDPR. Those interests include Bang Analytics's and its clients' interests in understanding, measuring and analysing publicly accessible professional and social conversations concerning brands, markets, topics and events. We assess those interests against the rights and reasonable expectations of affected individuals and maintain appropriate safeguards. For website, enquiry and business-contact information, the applicable lawful basis depends on the circumstances and may include our legitimate interests in operating and securing our business, taking steps at an individual's request before entering into a contract, performance of a contract, compliance with a legal obligation, or consent where consent is required.

2. Special-category information. Bang Analytics does not intentionally collect to use special-category personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health information, biometric information used for identification, or information concerning sex life or sexual orientation, as routine criteria for profiling individuals. Because public posts may contain such information as shared by the post author, special-category information may occasionally appear within material relevant to a project. Bang Analytics endeavors to minimise such information by removing it from the data collected, provided.

3. Sharing and disclosure. We may share project information with the client that commissioned the relevant analytical work. Depending on the project, outputs may consist of aggregate analysis or may include limited post-level information and public URLs. Our clients determine its own purposes and means for its subsequent use of information provided by Bang Analytics, acts as a separate controller and is responsible for that subsequent processing under applicable data protection law.

We may also use service providers for public-data retrieval, hosting, storage, analytics infrastructure, information security, email, business systems and other technical or administrative support. Where a supplier processes personal information as our processor, it is subject to contractual and data-protection obligations appropriate to that role.

We may disclose information to professional advisers, insurers, auditors, courts, regulators, law-enforcement authorities or other appropriate recipients where reasonably necessary to comply with law or legal process, obtain professional advice, establish or defend legal rights, investigate security incidents or misuse, or protect Bang Analytics, its clients or others. Personal information may also be disclosed or transferred in connection with an actual or proposed financing, acquisition, sale, merger, restructuring or similar corporate transaction, subject to applicable safeguards. Bang Analytics does not use public-post author information to send marketing communications to those authors. 

1. International transfers. Some clients or service providers may process personal information outside the United Kingdom. Where UK data-protection law requires safeguards for an international transfer, we use an applicable lawful transfer mechanism, such as an adequacy regulation or UK-approved contractual safeguards. Further information about relevant safeguards is available on request where required by law.

2. Security. We maintain technical and organisational measures designed to protect personal information against unauthorised or unlawful access, alteration, disclosure, loss or destruction. Measures are selected having regard to the nature of the information, the processing involved and the associated risks. Access to project information is restricted according to business need. No security system can provide an absolute guarantee against every possible security incident.

3. Retention. We retain personal information only for as long as reasonably necessary for the purposes for which it is processed and to meet applicable legal, contractual and operational requirements. Unless a different period is appropriate for a particular engagement, Bang Analytics ordinarily retains public-post project data for up to six months after completion of the relevant engagement. Information may be retained for longer where reasonably necessary to comply with law, deal with a complaint or rights request, establish or defend legal claims, maintain security, or meet another lawful retention requirement. Where appropriate, we may retain limited information necessary to ensure that an objection or similar request continues to be respected. Business correspondence and enquiry information is retained for as long as reasonably necessary to deal with the relevant matter and for an appropriate period afterwards, including where needed for contractual, legal, security or record-keeping purposes.

4. Your data protection rights. Depending on the circumstances and the lawful basis for processing, you may have rights of access, rectification, erasure, restriction, objection and, where the statutory conditions are met, data portability. Where processing is based on consent, you may withdraw that consent. These rights are subject to the conditions, limitations and exemptions provided by applicable law. Where we rely on legitimate interests, you have the right to object to processing on grounds relating to your particular situation. We will consider any objection in accordance with applicable data-protection law. If you object, we will consider the circumstances and the reasons you provide.  To exercise a right, contact yiannis@banganalytics.agency. 

5. Data related requests. If you have a concern or complaint about Bang's use of your personal information, or want to execute your privacy rights, please contact yiannis@banganalytics.agency. Please provide enough information to allow us to identify the information concerned. If your request relates to a public post, providing the relevant post or public profile URL may help us locate it. We will respond within the period required by applicable law of 30 days which can be extended for another 30 days for specifically explicit requests.  You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection. Current contact details for the ICO are available on its website. The ICO's postal address is Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom.

6. Changes to this Policy. We may amend this Policy from time to time. The date at the beginning of the document identifies when it was last updated. Where appropriate, we may also provide additional or more specific privacy information for particular processing activities.
   
   Questions about this Policy or Bang Analytics handling of personal information should be sent by email to yiannis@banganalytics.agency.