Bander Privacy Notice

Last Updated: May 23, 2026

This privacy notice ("Privacy Notice") is intended to provide you with specific details about how FUNCORP LIMITED LTD ("Bander," "we," and "us"), which owns and operates the Bander iOS application and its associated products and services (collectively the "Services"), collects and processes your personal and personally identifiable information through your use of the Services.

You understand and agree that we may store and process your personal information on computers located outside of your jurisdiction, including, but not limited to, in the United States or the European Union. By using the Services, you agree to the collection and processing of your personal or personally identifiable information outside of your jurisdiction.

Before using the Services or providing information to us, please carefully review this Privacy Notice. By using or accessing the Services, you agree that we may collect and use your personal and personally identifiable information in accordance with this Privacy Notice, as revised from time to time. We may modify, amend, replace, or suspend this Privacy Notice at any time. If you have any questions or suggestions regarding our Privacy Notice, or if your personal information is not accurate or complete, please contact us at:

FUNCORP LIMITED LTD Digeni Akrita, 1, Blue Ocean Building Mezzanine Floor Limassol, Cyprus 3035 Or email us at hey@bander.live.

By providing Bander with your personal or personally identifiable data and using the Services, you warrant and agree that you have the right and legal capacity to enter into this Agreement and to adhere to its terms and conditions.

You understand and agree that Bander complies with the Children's Online Privacy Protection Act ("COPPA"). Individuals under the age of eighteen (18) but at least thirteen (13) years of age ("Minors") may access and use the Services solely with verifiable parental consent. By permitting a Minor to use the Services, the parent or legal guardian of the Minor agrees to the collection, use, and disclosure of the Minor's personal information as described in this Privacy Notice and acknowledges responsibility for the Minor's activity on the Services. If parental consent is not provided or verifiable, Minors will be denied access to the Services.

You warrant that you are either a human individual that is eighteen (18) years of age or older or a Minor who has received verifiable parental consent from your parent or legal guardian and that you are not a bot, script, or other computer or machine. You warrant that you are not prohibited from assenting to this Agreement by any preexisting Agreement. If you are using the Services on behalf of a third party, including, but not limited to, a business entity, you warrant that you are the authorized representative of that third party and have the authority to bind that third party to the terms of this Agreement.

The Services may include links to websites or may include the use of analytics tools that are owned, operated, and maintained by third parties. Bander does not exercise control over the privacy practices of such third-party websites or analytics tools, and you are encouraged to review the privacy practices of all such third-party websites or analytics tools disclosed within this Privacy Notice.

Our Data Practices

What Data We Collect, How and Why We Collect it, and How We Use and Secure it

What information do we collect and how do we use it?

When you use the Services, we may collect personal or personally identifiable information from you ("PII"). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include anonymized data.

We may collect and process the following categories of PII about you:

Communication Data. Communication data includes any communication that you may send to us through the Services, including, but not limited to, by email. We process this data to communicate with you, to provide you with customer support, to record logs of our communication, and to store information to respond to legal claims. Bander's lawful ground for collecting and processing this PII is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.

User Data. User data includes data about how you use the Services and any data that you authorize through the Services, such as your Invite Code and a stable installation identifier we generate. This includes analytics data that is collected when you use the Services. We collect and process this data to operate the Services, to authenticate you as a user of the Services, to ensure that timely and relevant content is provided to you, to secure the Services, to ensure that the Services operate in a fast and efficient manner, and to maintain backups of the Services. Bander's lawful ground for processing this user data is its legitimate business interests in administering and offering the Services.

Technical Data. Technical data includes data about your use of the Services, such as your IP address, your mobile device model, your operating system version, your application version, your time zone, and diagnostic and performance data about the operation of the Services on your device. We may collect this data from your use of the Services and from advertising IDs or pixels. Bander processes this data to analyze your use of the Services, to route traffic, to administer and secure the Services, and to troubleshoot problems with the Services. Bander's lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy.

Audio Data. Audio data consists of recordings from your device's microphone collected while you use the Services. We collect and upload this data only with your explicit consent, which you may grant or withdraw at any time in the application's settings. Recordings already uploaded may be deleted upon request to hey@bander.live. Bander's lawful ground for processing audio data is your affirmative consent.

Marketing Data. Marketing data includes data about your actions and preferences in receiving and interacting with Bander's advertisements or content on the Services or on third party websites or applications. We collect this data from your use of the Services and from third party advertising IDs created through advertising programs and pixels, such as Apple's Advertising Identifier, Google Advertising IDs, and Facebook Advertising IDs. Bander does not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs. Bander's lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy by providing advertisements, including remarketing advertisements, to you.

Bander will only use your PII for the purpose for which it was collected. If Bander needs to use your PII for an unrelated, new purpose, Bander will provide you with notice of this new use and will explain the lawful ground for such processing. Bander may process your PII without your knowledge or consent where required or permitted by law. Where consent is required by applicable law, we will request and rely on your affirmative consent before collecting or using your data for marketing or tracking purposes.

How do we collect this information?

We collect PII from you through a variety of different means:

What information do we collect from third parties and how do we use it?

Bander may collect data about you through cookies and other technologies. This helps Bander understand how you use the Services and to understand any patterns that may be associated with your use of the Services. This aids Bander in developing or improving its Services and marketing communications in response to your needs or wants.

Bander may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the Services and are automatically deleted when you close your web browser. Persistent cookies are stored as a file on your computer or mobile device that remains on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the Services that created the cookie when you revisit it again. Bander may use persistent cookies to authenticate you when you return to the Services or when it utilizes analytics providers, which is intended to track the origin and behavior of traffic to the Services.

Bander may also use tracking pixels to track how often a specific page of the Services is visited, to capture IP addresses, browser types and versions, device types, and geographic locations, to identify when a user submits a form or completes a sign-up, or to measure impressions, clicks, or post-click conversions for the purposes of analyzing its advertising campaigns.

Bander may use the following analytics providers, and you are directed to review their respective privacy policies or notices:

How We Use Pixels on Our Site

We want to be upfront with you about how we collect and use data when you visit our websites or interact with our advertisements. Like many other publishers, we use tracking technologies, identified above, which include pixels. These technologies help us understand how visitors and users interact with our marketing and how to improve our marketing efforts. We may also use other tracking technologies, including other pixels, in the future. If we do, we will notify users by updating this Privacy Notice.

What are Pixels?

A pixel is a small piece of code that we've added to our websites or to our advertising campaigns. When you visit, this code helps us track actions you take, such as clicking on a link, viewing a page, or installing the application. The pixels send this information back to the pixel provider, which helps us:

These pixels do not collect personal details like your name, email, or phone number — instead, they track actions and behaviors.

Your Consent

By using our Services, you consent to the use of pixels as described above. If you don't want these pixels to track your activity, you can:

Opting Out

We respect your privacy, and if you have any concerns or questions, feel free to contact us at hey@bander.live.

How do we use your information for marketing communications?

As stated above, Bander's lawful ground for sending you marketing communications is either consent or its legitimate business interests, such as to grow its business by advertising products and services to you. Bander may send you marketing communications if you have asked for information concerning its services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask Bander to stop sending you marketing messages at any time by following the opt-out link in any marketing message sent to you, or by emailing hey@bander.live. If you opt out of receiving marketing communications, your opt-out does not extend to PII provided for other purposes.

When do we disclose your information?

Bander may share your PII with the following parties:

Bander may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets.

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information. However, no security measures are impenetrable and there are always security risks. We will notify you and any regulatory body of any breach of your PII or our security measures if we are legally required to do so. Bander allows access to your PII only by employees and service providers who have a need to know or access your PII on our instructions.

Do we use cookies?

Yes, as stated above, we may use persistent and session cookies. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

We may use cookies to understand and save your preferences for future visits, to authenticate you to the Services, and to compile aggregate data about traffic and interaction so that we can offer better experiences and tools in the future.

We never use cookies to store sensitive customer information such as names, addresses, passwords, or credit card information.

For how long do we retain your data?

We will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Notice or for the purposes of satisfying any legal, accounting, or reporting requirements. With respect to technical data, usage and interaction data, and marketing data, we may retain this data for so long as it is relevant to the uses disclosed in this Privacy Notice. We may retain account data and communications data for so long as your Invite Code remains active, and we may retain this data for longer periods where there is a need to retain this data to comply with Bander's legal obligations, such as the preservation of electronic evidence or compliance with a preservation order.

Email Marketing – User Consent

By opting into email marketing, you consent to receive promotional messages, including our e-newsletters. You can opt out at any time by:

Your Privacy Choices

Right of Access, Rectification, Correction, Erasure, Transfer, and Withdrawal

Under the law, you may have a right to request access to your PII for rectification, correction, erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact our Privacy Officer as disclosed in this Privacy Notice.

You do not need to pay a fee to access your PII or to exercise your rights. However, we may charge a reasonable fee if your request is unreasonable or excessive.

To confirm your request, we may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.

Rights of European Citizens

To exercise these rights, you may either opt out of receiving communications from us by unsubscribing to our e-mails or by emailing us at hey@bander.live. You do not need to pay a fee to exercise these rights, however, we reserve the right to charge a reasonable fee if your request is unreasonable or excessive. To confirm your request, we may need to request specific information from you as a security measure to ensure that personal data is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.

California Privacy Rights

The following rules apply solely to visitors, users, and others who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, we collected the following categories of PII (A, F, and, with consent, H) as defined in the California Consumer Privacy Act within the last twelve months. Our uses of this PII are detailed above in this Privacy Notice:

Category Examples Collected
A. Identifiers Unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers. YES
B. Personal information categories listed in Cal. Civ. Code § 1798.80(e) Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. NO
C. Characteristics of protected classifications under State or federal law Religious affiliation, ethnicity, etc. NO
D. Commercial Records of products/content or services purchased. NO
E. Biometric Data Fingerprints or footprints. NO
F. Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a Services, application, or advertisement. YES
G. Geolocation data Physical location or movements. NO
H. Audio, electronic, visual, thermal, olfactory, or similar information Audio recordings. YES (with consent)
I. Professional or employment-related information N/A NO
J. Educational information N/A NO

We obtain the categories of PII marked "YES" in the above table directly from California residents through their use of the Services and through their submission of any forms or inquiries. We also obtain these categories of PII indirectly from California residents while observing their actions on the Services and from third parties or service providers that they have authorized to receive and share PII.

California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you.

California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state "Do Not Sell My Personal Information." By selecting this link or icon, you "Opt Out," which means that you have opted out of the sale of your personal information as set forth in the California Consumer Privacy Act. However, even though you may have opted out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.

To submit a request for a list of the categories of personal information collected from you or to request that we delete your personal information, please send a letter to us at the following address:

FUNCORP LIMITED LTD. Digeni Akrita, 1, Blue Ocean Building Mezzanine Floor Limassol, Cyprus 3035 Or email us at hey@bander.live.

Other U.S. State Disclosures

Colorado — Bander does not conduct business in Colorado, control or process the personal data of 100,000 or more consumers during a calendar year, or derive revenue or receive a discount on the price of goods or services from the sale of personal data.

Connecticut — During the preceding calendar year, Bander did not control or process the personal data of at least 100,000 consumers or derive more than 25% of our gross revenue from the sale of personal data.

Florida — Bander does not control or process the personal data of 100,000 or more Florida residents during a calendar year, nor do we derive 50% or more of our gross annual revenue from the sale of personal data. As a result, the Florida Digital Bill of Rights does not apply to our data practices.

Montana — Bander does not control or process the personal data of 50,000 or more Montana residents during a calendar year or derive over 25% of its revenues from the sale of personal data and control or processing of personal data of 25,000 or more Montana residents. Therefore, the Montana Consumer Data Privacy Act does not apply to our collection or use of PII.

Nevada — If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may contact us at hey@bander.live and include in the message field, "Nevada Do Not Sell Request," along with your name, address, and user account information.

Oregon — Bander does not control or process the personal data of 100,000 or more Oregon residents during a calendar year or derive over 25% of its gross revenue from the sale of personal data. Therefore, the Oregon Consumer Privacy Act (OCPA) does not apply to our collection or use of PII.

Tennessee — Bander does not exceed $25 million in annual revenue, control or process the personal information of 175,000 or more Tennessee consumers, or control or process the data of 25,000 consumers while deriving more than 50% of its gross revenue from the sale of personal information.

Texas — Bander is considered a small business as defined by the Small Business Administration and, therefore, is exempt from the Texas Data Privacy and Security Act. However, we generally collect and process PII only to the extent that it is adequate, relevant, and reasonably necessary for the purposes disclosed in this Privacy Policy. The categories of PII collected by Bander are disclosed within this Privacy Policy, in particular in Table T.1 above, and Texas residents may request, free of charge, information of the PII collected from them twice annually.

Utah — Bander does not have annual revenues of $25,000,000 or more and control or process the PII of 100,000 or more consumers. Therefore, the Utah Consumer Privacy Act does not apply to our collection and use of PII.

Virginia — Bander does not control or process the personal data of at least 100,000 Virginia residents or control or process the personal data of at least 25,000 Virginia residents and derive more than 50% of its gross revenue from the sale of personal data. For these reasons, the Virginia Consumer Data Protection Act (VCDPA) does not apply to Bander's collection and use of PII.

If Bander becomes subject to one or more of the above State's privacy laws other than California's privacy laws, we will update this Privacy Notice to reflect your rights under those laws.

Third Party Links

Bander's Services may include links to third-party websites and applications. By clicking on third party links, you may allow third parties to collect or share data about you. Bander does not control these third-party links and you are advised to review their respective privacy policies.

Responding to Do Not Track Signals

You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI Services and DAA Services. Our Services is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what "do not track" means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at http://optout.aboutads.info/.

Children's Online Privacy Protection Act Compliance

We comply with the requirements of COPPA (Children's Online Privacy Protection Act). We do not knowingly collect any information from anyone under 13 years of age, and our products and services are aimed at individuals 13 years of age or older. If you believe that we have collected PII from someone under the age of 13, you are directed to notify us immediately at hey@bander.live.

Changes to our Privacy Notice

Whenever we change our Privacy Notice, we will post those changes to this Privacy Notice on the Services and other places that we deem appropriate and, if necessary, provide you with notice via email. Your use of our Services following these changes indicates your consent to the practices described in the revised Privacy Notice.

Contacting Us

If you have any questions about this Privacy Notice or the manner by which we collect or use Personal Information about you, contact us at hey@bander.live.