Privacy Policy

1. Introduction & Business Identification

1.1 About BalloAds

BalloAds is a comprehensive customer engagement and analytics platform operated by Ballo Innovations Ltd ("Ballo," "we," "us," "our," or "Company"), a technology company incorporated and registered in the Republic of Zambia with offices located in Lusaka, Zambia.

1.2 Purpose of This Policy

This Privacy Policy ("Policy") explains how BalloAds collects, uses, discloses, retains, and safeguards personal information and non-personal data through our platform, mobile applications, APIs, websites, and related services (collectively, the "Services"). We are committed to protecting your privacy and ensuring that personal information is handled in a safe, secure, transparent, and lawful manner in compliance with applicable data protection regulations.

1.3 Scope and Acknowledgment

This Policy applies to all users of BalloAds Services, including:

• Organisations and businesses using BalloAds to manage, deliver, or analyze marketing campaigns ('Advertisers')
• Publishers, content providers, and partners participating in the BalloAds ecosystem ('Publishers')
• End users and consumers who interact with advertisements, websites, or digital content served through BalloAds ('End Users')
• Visitors to BalloAds websites and digital communication channels

By accessing, registering for, or using BalloAds Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our privacy practices, please do not use our Services.

2. Information We Collect

We collect information necessary to provide, improve, and secure our Services. Information is collected through multiple methods and may be personal or non-personal in nature.

2.1 Information You Provide Directly

Account Registration & Profile Information:

• Full name, company name, business registration details, and organizational structure
• Email address, phone number, and physical business address
• Job title, department, and role within your organization
• Account preferences and communication preferences

Billing and Payment Information:

• Bank account details, credit card information, and payment method preferences
• Billing address, tax identification numbers, and invoice preferences
• Transaction history and payment records
• All payment information is processed securely through PCI-DSS compliant third-party payment gateways and is not stored directly on BalloAds servers

Campaign and Content Data:

• Advertisement creatives, copy, images, and multimedia content
• Target audience parameters, demographic data, and segmentation criteria
• Campaign budgets, scheduling, and performance objectives
• Keywords, hashtags, and campaign-related metadata

Communication Data:

• Customer support inquiries, complaints, and feedback
• Feature requests, bug reports, and product feedback
• Communication with our sales, support, or technical teams
• Survey responses and user research participation

2.2 Information Collected Automatically

Usage and Activity Data:

• Pages visited, features accessed, and functions used within BalloAds
• Clicks, interactions, time spent on pages, and navigation patterns
• Device information including device type, operating system, and device identifiers
• Browser type, version, and user agent information
• Internet Protocol (IP) address, geographic location (derived from IP), and connection information
• Referral source and exit pages

Analytics and Performance Data:

• Campaign metrics including impressions, clicks, conversions, and engagement rates
• Reach, frequency, and audience insights
• Traffic sources, user flow, and conversion funnels
• A/B testing results and optimization data

2.3 Information from Third-Party Sources

• Data received from integrated advertising platforms (Google Ads, Meta Business Suite, LinkedIn Campaign Manager, WhatsApp Business API)
• Audience insights and demographic data from data partners and publishers
• Publicly available data from business registries and industry databases
• Data from payment processors and financial institutions

3. How We Use Information

We use collected information for legitimate business purposes, lawful operations, and to provide and improve our Services. All data processing is conducted in compliance with applicable data protection regulations.

4. Legal Basis for Data Processing

We process personal information under one or more of the following lawful bases, as applicable under relevant data protection regulations including GDPR, CCPA, and Zambian data protection frameworks:

5. Data Sharing and Disclosure

We share personal information with third parties only when necessary to provide Services, comply with legal obligations, or protect our interests. All third-party recipients are bound by confidentiality obligations.

5.1 Service Providers and Vendors

We share information with carefully selected service providers including:

• Cloud hosting and data center providers (bound by data processing agreements)
• Payment processors and payment gateways (PCI-DSS compliant)
• Email delivery, SMS, and push notification service providers
• Analytics service providers and business intelligence platforms
• Customer support and helpdesk platforms

5.2 Integrated Platforms and Partners

We share necessary information with integrated advertising platforms including Google Ads, Meta Business Suite, LinkedIn Campaign Manager, and other advertising networks to deliver your campaigns.

5.3 Affiliates and Ballo Ecosystem

We may share information with other companies within the Ballo Innovations ecosystem (including BalloDash, BalloTask, BalloPay, and other Ballo services) for operational efficiency and service integration.

5.4 Legal and Regulatory Disclosure

We may disclose personal information when required by law, court orders, government or law enforcement requests, or to protect our legal rights and enforce our terms of service.

5.5 Business Transfers

In the event of merger, acquisition, bankruptcy, or sale of assets, personal information may be transferred. You will be notified of any material changes to this Privacy Policy.

5.6 Prohibition on Data Sales

BalloAds does not sell personal information to third parties. We do not engage in the sale, rental, or commercial transfer of personal data for monetary or other valuable consideration.

6. Data Retention

We retain personal information only as long as necessary to fulfill the purposes outlined in this Policy or as required by applicable law.

6.1 Retention Periods by Data Category

7. Cookies and Tracking Technologies

BalloAds uses cookies and similar tracking technologies to enhance functionality, measure performance, and deliver targeted advertising.

7.2 Cookie Management

You can manage or disable cookies through your browser settings. You may opt out of advertising cookies through industry opt-out mechanisms such as the Digital Advertising Alliance portal. Disabling cookies may limit platform functionality.

8. Data Security

We implement comprehensive security measures to protect personal information from unauthorised access, disclosure, alteration, and destruction.

While we implement industry-standard security measures, no system is completely secure. We cannot guarantee absolute security of personal information.

9. International Data Transfers

BalloAds may transfer personal information across international borders to provide Services and operate our global platform. When personal information is transferred outside your country of residence, we use:

• EU Standard Contractual Clauses (SCCs) for transfers from the EU/EEA
• Adequacy decisions where applicable (e.g., EU-US Data Privacy Framework)
• Binding corporate rules within the Ballo Innovations group
• Explicit consent for certain transfers

Personal information of Zambian users may be processed and stored in Zambia where feasible. We comply with Zambian data localisation requirements and restrictions.

10. Your Privacy Rights and Choices

Depending on your jurisdiction and applicable data protection laws, you may have the following rights:

10.9 Exercising Your Rights

11. Children's Privacy

BalloAds Services are not intended for children under 16 years of age. We do not knowingly collect personal information from minors. If we discover that a child under 16 has provided personal information, we will promptly delete such information and notify the parent or guardian. Parents may contact us to report suspected collection of children's data.

12. Third-Party Links and Services

BalloAds may contain links to third-party websites, applications, and services operated by other companies. Third-party sites have their own privacy policies, and we are not responsible for their privacy practices. This Privacy Policy applies only to BalloAds Services.

When you authorise BalloAds to integrate with third-party platforms, you grant permission to share data with those platforms. Third-party data handling is governed by their respective privacy policies. You may revoke authorisation through your account settings.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know — Request what personal information we collect, use, share, and sell
• Right to Delete — Request deletion of personal information we have collected, subject to certain exceptions
• Right to Opt-Out — Opt out of the sale or sharing of your personal information
• Right to Correct — Request correction of inaccurate personal information
• Right to Limit Use — Limit our use of sensitive personal information
• Non-Discrimination — We will not discriminate against you for exercising your California privacy rights

14. European Privacy Rights (GDPR)

If you are located in the European Union or European Economic Area, you have rights under the General Data Protection Regulation (GDPR). We process your information under lawful bases including contract performance, legitimate interests, legal compliance, and consent.

15. Zambian Data Protection Compliance

BalloAds complies with the Data Protection Act No. 3 of 2021 of Zambia, including lawful basis for data processing, data subject rights and protections, security and confidentiality requirements, and regulatory compliance and reporting.

We implement enhanced protections for sensitive personal information including health and medical information, financial and banking details, biometric and genetic data, and criminal records and legal information.

16. Meta and Service Provider Compliance

BalloAds is designed to meet the privacy and data handling requirements of major service providers and advertising platforms, including Meta (Facebook, Instagram, WhatsApp) and Google. We comply with platform-specific data policies, pixel and tracking policies, advertising standards, and implement proper user consent and opt-out mechanisms.

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our data practices, comply with new legal requirements, or improve clarity. The "Last Updated" date will be revised and material changes will be communicated via email or prominent notice on our website. Continued use of BalloAds after updates constitutes acceptance of the revised Policy.

18. Contact Information

We will respond to privacy inquiries within 5 business days and provide substantive responses within 30 days.

19. Definitions