Privacy Policy.
Effective Date: August 5, 2026
This Privacy Policy explains how WT PUBLISHING LTD, a company incorporated under the laws of the Republic of Cyprus under registration number HE 401623 (“WT PUBLISHING”, “we”, “us” or “our”), collects, uses, discloses, stores and otherwise processes Personal Data in connection with Bander.
Bander includes the mobile application, website and any related features, tools and services made available under the Bander brand (collectively, the “Services”). WT PUBLISHING is the controller of the Personal Data described in this Privacy Policy, except where another party is identified as an independent controller.
This Privacy Policy should be read together with the Bander Terms of Use, available at https://bander.live/tos, and any permission request, in-app disclosure or sharing notice presented when you use a particular feature. The Terms of Use govern your access to and use of the Services, while this Privacy Policy explains how Personal Data is collected, used, disclosed, stored and otherwise processed.
If a feature-specific privacy notice provides additional information concerning the processing of Personal Data, that notice will supplement this Privacy Policy and will apply to the relevant feature. In the event of a conflict relating specifically to the processing of Personal Data, the more specific privacy notice will apply to the extent of that conflict.
1.SCOPE AND KEY PRINCIPLES
1.1No User account or registration is required to use the current version of Bander. We do not ask for a name, profile, password or payment information in order to provide the core Services.
1.2Bander requires access to the microphone in order to analyse a musical performance and generate accompanying musical backing. Audio may be processed partly on the User’s device and partly through remote servers operated by WT PUBLISHING or authorised technology providers.
1.3A completed recording saved by the User remains stored locally on the User’s device unless the User separately and affirmatively chooses to share that recording through Bander.
1.4We collect limited device, network, usage and diagnostic information required to provide, secure, troubleshoot and improve the Services. Push notifications are optional.
1.5We do not sell Personal Data, share Personal Data for cross-context behavioural advertising, use Personal Data for targeted advertising, or use third-party advertising trackers in the current version of Bander.
2.DEFINITIONS
2.1“Personal Data” means information relating to an identified or identifiable individual and includes “personal information” or an equivalent term under applicable privacy law.
2.2“Audio Data” means microphone input, musical performance, voice, background sounds and related audio information processed through Bander.
2.3“Local Recording” means a completed recording created and stored solely on the User’s device and not affirmatively shared with WT PUBLISHING.
2.4“Shared Recording” means a recording that the User separately and affirmatively chooses to upload or otherwise transmit to WT PUBLISHING through the sharing functionality made available in Bander.
2.5“User” means any individual who accesses or uses Bander or any part of the Services.
3.NOTICE AT COLLECTION
3.1Where applicable, this Section serves as our Notice at Collection. The categories of Personal Data that we may collect include identifiers and device information, internet or other electronic network activity, approximate location inferred from an IP address, Audio Data, notification data, and support or correspondence information.
3.2We collect and use these categories to provide the Services and AI-assisted audio functionality, operate optional sharing and notification features, maintain security and reliability, diagnose errors, evaluate and improve relevant functionality, and, where clearly disclosed and permitted by applicable law, test, train, develop, evaluate or improve Bander-specific artificial-intelligence and machine-learning models. We also process Personal Data to respond to support requests, comply with law and protect our rights and the rights of others.
3.3The sources, recipients and retention criteria applicable to these categories are described in Sections 4, 7, 8 and 10. We do not collect categories of Personal Data for materially different purposes without providing additional notice and obtaining consent where required by law.
4.PERSONAL DATA WE COLLECT
4.1Device and network data. We may collect an IP address, device model, operating system, app version, language, time zone, approximate country or region inferred from the IP address, session timestamps, network status, and an app-instance or similar technical identifier.
4.2Usage and diagnostic data. We may collect information about feature interactions, connection status, performance, latency, errors, crashes and other diagnostic events. Depending on the device and operating-system settings, diagnostic information may also be supplied by Apple, Google or another platform provider.
4.3Live Audio Data. When microphone permission is enabled and the relevant feature is active, Bander processes Audio Data in order to analyse the User’s performance and generate musical backing. Live Audio Data may be processed partly on the User’s device and partly through remote infrastructure.
4.4Local Recordings. Local Recordings remain on the User’s device. WT PUBLISHING does not receive, access, restore or remotely delete a completed Local Recording merely because it was created through Bander.
4.5Shared Recordings. if the User chooses to share a recording, we receive the relevant audio file, which may include a musical performance, the User’s voice, other people’s voices and background sounds. We may also receive the upload date and time, file information, limited device metadata and an upload reference. Depending on the functionality and technical configuration of Bander, and where disclosed in the applicable sharing notice, a Shared Recording may also be processed for research, testing, evaluation, development, training or improvement of Bander-specific audio functionality and artificial-intelligence or machine-learning models.
4.6Notification data. If the User enables push notifications, we may receive a push token, device platform, notification preferences and delivery or interaction status from the device and the relevant Apple or Google notification service.
4.7Support and privacy communications. If the User contacts us, we may collect the email address, message, attachments and any other information voluntarily provided, including information necessary to locate a Shared Recording or verify a privacy request.
4.8Website and cookie data. When a person visits the Bander website, we may receive standard server logs and essential technical information. We do not currently use non-essential advertising cookies or third-party advertising trackers. If non-essential analytics or similar technologies are introduced, we will provide any notice and consent mechanism required by law.
4.9Bluetooth and connected-device information. Bluetooth, local-network and paired-device information may be processed by the User’s device, operating system or equipment provider. WT PUBLISHING may receive limited connection status or diagnostic information where necessary to support compatible devices.
4.10Data we do not intentionally collect. We do not intentionally collect precise location, contacts, photos, media-library contents, payment information, government identifiers, health information or biometric identifiers. We do not use voice or audio to identify a person biometrically. Audio may incidentally contain personal or sensitive information, and Users should not share such information unless they have a lawful basis to do so.
5.MICROPHONE, REMOTE AUDIO PROCESSING AND AI-ASSISTED FEATURES
5.1Microphone access is required for Bander’s core audio functionality. The User may refuse or withdraw this permission through the device settings, but the relevant features will then be unavailable or may not function as intended.
5.2Live Audio Data may be transmitted over the internet to remote servers operated by WT PUBLISHING or authorised technology providers where remote processing is necessary to analyse the User’s performance and generate musical backing.
5.3Before Personal Data is disclosed to a third-party artificial-intelligence or technology provider where a separate disclosure or permission is required, Bander will provide an appropriate in-app notice and request an affirmative action from the User.
5.4Live Audio Data is not retained by WT PUBLISHING as a completed recording file unless the User separately shares a recording. Transient copies may be processed for the period reasonably necessary to provide the real-time feature, maintain security and reliability and diagnose technical issues. Live Audio Data will not be used to test, train, develop or improve an artificial-intelligence or machine-learning model unless that purpose is separately and clearly disclosed before the relevant processing and the User provides any affirmative consent required by applicable law.
5.5A Shared Recording is processed only for the purposes identified in the applicable sharing notice and this Privacy Policy. Such purposes may include operating the sharing feature, providing support, investigating technical or security issues, conducting research and testing, evaluating Bander’s audio performance, and training, developing or improving Bander-specific artificial-intelligence or machine-learning models.
5.6We do not publicly post Shared Recordings or use them in advertising without separate permission. Depending on the functionality and technical configuration of Bander, Shared Recordings may be used to test, evaluate, develop, train or improve Bander-specific audio functionality and artificial-intelligence or machine-learning models. Where such processing applies, the relevant purpose will be clearly described in the applicable sharing notice or other in-app disclosure, and WT PUBLISHING will obtain any affirmative consent required by applicable law. We will not use Shared Recordings to train a general-purpose artificial-intelligence model or for a materially unrelated purpose without separate notice and any additional consent required by applicable law.
5.7Bander does not use Audio Data to make decisions about a User that produce legal or similarly significant effects.
6.HOW AND WHY WE USE PERSONAL DATA
6.1Providing the Services. We process device, network, usage, diagnostic and Audio Data to operate Bander, provide the requested AI-assisted audio functionality, support compatible devices and maintain the application and website.
6.2Optional sharing and model development. We process a Shared Recording when the User affirmatively chooses to upload it and for the purposes described in the applicable sharing notice. Depending on the functionality and technical configuration of Bander, those purposes may include research, testing, evaluation, development, training or improvement of Bander-specific audio functionality and artificial-intelligence or machine-learning models, subject to any notice and consent requirements under applicable law.
6.3Security and troubleshooting. We process technical, diagnostic and, where necessary, Audio Data to detect, prevent and investigate errors, misuse, security incidents and threats to the Services or other persons.
6.4Service evaluation, research and improvement. We may use technical and diagnostic data to understand performance, conduct research and improve the Services. We use Live Audio Data or Shared Recordings to test, train, develop, evaluate or improve audio functionality or artificial-intelligence and machine-learning models only to the extent disclosed in this Privacy Policy and any feature-specific notice, and subject to consent or another lawful basis where required.
6.5Notifications. We use notification data to send service messages, product news or update notices after the User opts in. Notifications can be disabled through the device settings.
6.6Support, compliance and legal protection. We process communications and relevant records to respond to requests, comply with legal obligations, enforce our agreements, establish or defend legal claims, and protect Users, WT PUBLISHING and third parties.
6.7Additional information concerning the legal bases relied upon for processing Personal Data of Users in the European Economic Area, the United Kingdom and Switzerland is provided in Section 13.
7.SOURCES OF PERSONAL DATA
7.1We obtain Personal Data directly from the User when the User enables a permission, uses a feature, shares a recording, enables notifications or contacts us.
7.2We obtain technical and usage information automatically from the device, application, network and website when they communicate with our systems.
7.3We may receive limited information from operating-system providers, notification services, hosting and technology providers, diagnostic tools and other service providers acting in connection with the Services.
8.DISCLOSURE OF PERSONAL DATA
8.1Service providers and contractors. We may disclose Personal Data to providers supporting cloud infrastructure, remote audio and AI processing, model testing and development, hosting, storage, security, diagnostics, customer support and push-notification delivery. Such providers may process Personal Data only for authorised purposes and subject to contractual, confidentiality, security and data-protection safeguards.
8.2Professional advisers. We may disclose Personal Data to legal advisers, accountants, auditors, insurers and other professional advisers where reasonably necessary to obtain advice, comply with obligations or protect legal interests.
8.3Authorities and protection of rights. We may disclose Personal Data to courts, regulators, law-enforcement bodies or other authorities where required by law or where reasonably necessary to protect rights, safety, security or the integrity of the Services.
8.4Corporate transactions. Personal Data may be disclosed to a prospective or actual buyer, investor, lender, affiliate or successor in connection with a merger, financing, acquisition, reorganisation or sale of all or part of the business or assets relating to Bander, subject to appropriate confidentiality and data-protection measures.
8.5We do not sell Personal Data, share it for cross-context behavioural advertising, disclose it to data brokers, or use it for targeted advertising. If these practices change, we will update this Privacy Policy and provide any notice, consent or opt-out mechanism required before the change applies.
9.INTERNATIONAL DATA TRANSFERS
9.1WT PUBLISHING is established in Cyprus. Depending on the infrastructure and providers used, Personal Data may be processed in the European Economic Area, the United States or other countries.
9.2Where Personal Data is transferred from the European Economic Area, the United Kingdom or Switzerland to a country that is not recognised as providing an adequate level of protection, we use an applicable lawful transfer mechanism, such as the European Commission’s Standard Contractual Clauses, the United Kingdom International Data Transfer Addendum or another recognised safeguard.
9.3Where appropriate, we also apply supplementary technical, organisational and contractual measures. A User may contact us for further information about safeguards relevant to a particular transfer.
10.RETENTION AND DELETION
10.1General retention criteria. We retain Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy and any feature-specific notice. In determining an appropriate retention period, we consider the nature, amount and sensitivity of the data; the purposes for which it is processed; operational, production, research and product-development requirements; the risk of harm from unauthorised use or disclosure; applicable legal, regulatory, contractual and accounting obligations; relevant limitation periods; and whether the purpose can be achieved using aggregated or de-identified information. Retention needs are reviewed periodically, and Personal Data is deleted, anonymised or securely restricted when it is no longer reasonably required.
10.2Live Audio Data. Live Audio Data transmitted for remote processing is not retained as a completed recording file unless the User shares a recording. Transient copies may exist only for as long as reasonably necessary to provide the relevant feature, maintain security and reliability, diagnose technical issues and, where separately disclosed and lawfully authorised, conduct testing, research, development or improvement. Such copies are deleted, aggregated or de-identified when they are no longer reasonably required for those purposes.
10.3Local Recordings. Local Recordings remain on the User’s device until the User deletes them, removes the application or otherwise manages them through the device. WT PUBLISHING cannot remotely delete a Local Recording that has not been shared through Bander.
10.4Shared Recordings. Shared Recordings are retained for as long as reasonably necessary for the purposes stated in the applicable sharing notice and this Privacy Policy. Depending on the disclosed purpose, this may include operating the sharing feature, providing support, maintaining security, investigating technical issues, conducting research and testing, and training, developing, evaluating or improving Bander-specific audio functionality and artificial-intelligence or machine-learning models. A User may request deletion of the source recording, subject to verification and any lawful need to retain it for security, legal compliance or the establishment, exercise or defence of legal claims.
10.5Technical, notification and support data. Technical logs, diagnostics, push tokens, notification preferences and support or privacy communications are retained for as long as reasonably necessary to operate and secure the Services, maintain relevant preferences, investigate incidents, respond to requests, comply with law and establish, exercise or defend legal claims. Push tokens are deleted or deactivated when we learn that they are invalid, the User opts out, or they are no longer reasonably required.
10.6Derived, aggregated and model-related information. Where Personal Data has been aggregated or de-identified so that it no longer reasonably identifies a User, we may retain and use that information for research, analytics, security and product-development purposes. To the extent permitted by applicable law, deletion of a source recording does not necessarily require deletion or reversal of statistical results, evaluation metrics, model parameters or other outputs that no longer reasonably identify the User.
10.7Backups and legal retention. Deleted Personal Data may remain temporarily in protected backup systems until it is overwritten in accordance with our ordinary backup and disaster-recovery cycles. We may retain information for a longer period where required by law, necessary to protect rights or security, or subject to a valid legal hold. Where possible, information retained for these reasons will be restricted to the relevant purpose and will not be used for unrelated activities.
11.USER CHOICES AND DEVICE CONTROLS
11.1Microphone. The User may accept, refuse or revoke microphone permission through the device settings. Bander’s core audio functionality will not operate without microphone access.
11.2Remote processing. Where required, Bander will present an in-app disclosure before Audio Data is transmitted to an authorised third-party AI or technology provider and will request the User’s affirmative permission.
11.3Sharing. The User should not select the sharing option if they do not want a recording uploaded. Sharing a completed recording is not required to use the core Services.
11.4Local Recordings. The User may manage or delete Local Recordings through Bander or the device. WT PUBLISHING cannot restore an unshared Local Recording.
11.5Notifications. The User may accept or decline the operating-system notification request and may change the notification setting at any time.
11.6Diagnostics and cookies. Where the operating system or website provides a diagnostic or cookie preference, the User may manage that preference through the relevant settings or consent interface.
12.PRIVACY RIGHTS
12.1Depending on the User’s location and applicable law, the User may have the right to request access to, correction of, deletion of or a portable copy of Personal Data, to restrict or object to processing, to withdraw consent, and to lodge a complaint with a supervisory authority.
12.2A User may submit a privacy or deletion request by emailing hey@bander.live. Because Bander does not create User accounts, we may request limited information reasonably necessary to identify the relevant data and verify the request, such as an approximate upload date and time, device type, upload reference or the email address previously used to contact us.
12.3If we cannot reasonably identify Personal Data as relating to the requesting User, we may be unable to fulfil a request concerning that data. We may also decline or limit a request where permitted by law, including where it is manifestly unfounded or excessive, would adversely affect the rights of another person, or the data must be retained by law.
13.EUROPEAN ECONOMIC AREA, UNITED KINGDOM AND SWITZERLAND PRIVACY NOTICE
13.1Applicable Data Protection Laws. Where the processing of Personal Data is subject to European data-protection law, WT PUBLISHING processes Personal Data in accordance with Regulation (EU) 2016/679 (the “GDPR”), the Cyprus Law Providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of Such Data, Law 125(I)/2018, and any other applicable national data-protection legislation. Where applicable, references in this Section to the GDPR include the United Kingdom GDPR and corresponding United Kingdom data-protection legislation.
13.2Data Controller. WT PUBLISHING is the controller responsible for determining the purposes and means of the processing described in this Privacy Policy. Certain third-party providers may act as processors on our behalf or as independent controllers where they determine their own purposes and means of processing.
13.3Legal Bases for Processing. Depending on the relevant purpose and circumstances, WT PUBLISHING relies on one or more of the following legal bases:
(a)Performance of a contract. We process Personal Data where such processing is objectively necessary to provide the Services or a particular feature requested by the User, including analysing the User’s musical performance, transmitting Audio Data to authorised technology providers where necessary for remote processing, and generating the corresponding musical backing. Device or platform permissions requested by Bander are separate from the legal basis relied upon under applicable data-protection law.
(b)Consent. We rely on consent where required for optional processing, including push notifications, the voluntary sharing of a recording, and the use of Live Audio Data or Shared Recordings to test, train, develop, evaluate or improve artificial-intelligence or machine-learning models. Where applicable law or app-store requirements require separate affirmative permission before Audio Data is disclosed to a third-party artificial-intelligence or technology provider, Bander will request that permission before the relevant transmission. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
(c)Legitimate interests. We process Personal Data where necessary for our legitimate interests in operating, securing, maintaining, troubleshooting, researching and improving Bander, preventing misuse, protecting Users and third parties, and establishing, exercising or defending legal claims, provided that those interests are not overridden by the User’s fundamental rights and freedoms.
(d)Compliance with legal obligations. We process Personal Data where necessary to comply with an applicable legal, regulatory, accounting or law-enforcement obligation.
(e)Protection of vital interests. In exceptional circumstances, we may process Personal Data where necessary to protect the vital interests of a User or another person.
13.4Special Categories of Personal Data. WT PUBLISHING does not intentionally request or use Audio Data to infer racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health information, sexual orientation or biometric identity. To the extent that Audio Data contains information that constitutes a special category of Personal Data under applicable law, WT PUBLISHING will process that information only where a lawful basis under Article 6 of the GDPR and an applicable condition under Article 9 of the GDPR are available.
13.5Data Subject Rights. Subject to the conditions and limitations established by applicable law, a User may have the right to:
(a)obtain confirmation as to whether Personal Data concerning the User is being processed and request access to that Personal Data;
(b)request correction of inaccurate Personal Data and completion of incomplete Personal Data;
(c)request deletion of Personal Data;
(d)request restriction of processing;
(e)receive Personal Data provided by the User in a structured, commonly used and machine-readable format and, where applicable, have that data transmitted to another controller;
(f)object to processing based on legitimate interests, including profiling based on those interests;
(g)withdraw consent at any time where processing is based on consent;
(h)object at any time to the processing of Personal Data for direct-marketing purposes; and
(i)lodge a complaint with a competent supervisory authority.
13.6Exercising GDPR Rights. Requests may be submitted to hey@bander.live. Because Bander does not require User accounts, we may request limited additional information reasonably necessary to identify the relevant Personal Data and verify the request. We will not request more information than is reasonably necessary for that purpose.
13.7Response Period. We will respond to a valid request without undue delay and normally within one month of receipt. Where permitted by applicable law, this period may be extended by up to two additional months where necessary due to the complexity or number of requests. We will inform the User of any extension and the reasons for it.
13.8Automated Decision-Making. Bander does not make decisions based solely on automated processing that produce legal effects concerning a User or similarly significantly affect the User.
13.9Complaints. A User may lodge a complaint with the data-protection supervisory authority in the country of the User’s habitual residence, place of work or place of the alleged infringement. Because WT PUBLISHING is established in Cyprus, a complaint may also be submitted to the Office of the Commissioner for Personal Data Protection of Cyprus.
13.10International Transfers. International transfers of Personal Data subject to the GDPR, the United Kingdom GDPR or applicable Swiss data-protection law are carried out in accordance with the safeguards described in Section 9, including an applicable adequacy decision, the European Commission’s Standard Contractual Clauses, the United Kingdom International Data Transfer Addendum, the United Kingdom International Data Transfer Agreement or another lawful transfer mechanism, as applicable.
14.CALIFORNIA AND OTHER UNITED STATES PRIVACY NOTICE
14.1This Section supplements the remainder of this Privacy Policy for residents of California and other United States jurisdictions with comprehensive privacy laws, to the extent those laws apply to WT PUBLISHING.
14.2During the preceding twelve months, and as reasonably expected going forward, we may collect the following categories: identifiers, including IP address, app-instance identifier, push token and support email; internet or electronic network activity, including device, application, interaction and diagnostic information; approximate geolocation inferred from an IP address; audio or electronic information, including Live Audio Data and Shared Recordings; and correspondence or customer-support information.
14.3We obtain these categories from the User, the User’s device and network, operating-system services and authorised service providers. We use and retain them for the purposes and in accordance with the retention criteria described in Sections 6 and 10.
14.4We may disclose these categories for business purposes to service providers and contractors supporting hosting, remote audio and AI processing, storage, security, diagnostics, support and push delivery, and to advisers, authorities and transaction parties as described in Section 8.
14.5We do not sell or share Personal Data as those terms are defined by the California Consumer Privacy Act, use Personal Data for targeted advertising, offer financial incentives for Personal Data, or use or disclose sensitive Personal Data for purposes that require a right to limit. We therefore do not currently provide “Do Not Sell or Share My Personal Information” or “Limit the Use of My Sensitive Personal Information” links.
14.6Applicable rights may include the right to know or access, delete, correct and obtain a portable copy; opt out of sale, sharing, targeted advertising or certain profiling; limit certain uses of sensitive Personal Data; appeal a denied request; and use an authorised agent.
14.7Requests and appeals may be submitted to hey@bander.live. We may request information reasonably necessary to verify the request or the authority of an agent. We will not discriminate against a person for exercising an applicable privacy right.
14.8Bander does not knowingly sell or share the Personal Data of Users under sixteen. If our practices change, we will honour legally recognised opt-out preference signals and provide any required links or controls.
15.CHILDREN
15.1Bander is intended for Users aged thirteen and older and is not directed to children under thirteen. We do not knowingly collect Personal Data from a child under thirteen.
15.2Users who have not reached the age at which they may independently consent to the processing of Personal Data in their jurisdiction must use Bander only with the involvement and permission of a parent or legal guardian where required by law.
15.3If a parent, guardian or other person believes that a child under thirteen has provided Personal Data or shared a recording with us, they should contact hey@bander.live. We will take appropriate steps to investigate and delete the information where required.
16.DATA SECURITY
16.1We use reasonable administrative, technical and organisational measures designed to protect Personal Data against unauthorised access, loss, alteration, disclosure or destruction. Measures may include access restrictions, secure transmission, logging, staff confidentiality obligations and contractual safeguards for service providers.
16.2No method of transmission or storage is completely secure. Users should protect their devices and should not share recordings containing information that they do not want transmitted to WT PUBLISHING or its authorised providers.
17.THIRD-PARTY SERVICES AND LINKS
17.1Bander may rely on or link to operating systems, app stores, notification services, hardware providers or other third-party services. Those parties may process Personal Data under their own privacy policies where they act as independent controllers.
17.2This Privacy Policy does not govern independent third-party websites, applications or services. Users should review the privacy information provided by the relevant third party before using such services.
18.CHANGES TO THIS PRIVACY POLICY
18.1WT PUBLISHING may amend or update this Privacy Policy from time to time to reflect changes to Bander, the Services, the Terms of Use, technology, legal requirements, security practices or business operations.
18.2The revised Privacy Policy will be made available through Bander, the website or another appropriate communication channel, and the Effective Date will be updated accordingly. Where a change materially affects how previously collected Personal Data is used, we will provide reasonable prior notice and obtain renewed consent where required by law.
19.CONTACT
19.1Questions, privacy requests and deletion requests may be submitted to:
WT PUBLISHING LTD
Registration number: HE 401623
Registered office: Digeni Akrita, 1, Blue Ocean Building, Mezzanine Floor, 3035 Limassol, Cyprus
Email: hey@bander.live