The protection of your privacy is of great importance to us. sobu Ltd therefore carries out its activities in compliance with the applicable statutory regulations for data protection. In this document, we will explain what information we collect and how and for what purpose we use it.

1. Types of data collected
2. Mode and place of processing the data
3. The purposes of processing
4. Facebook permissions asked by sobu Ltd
5. Detailed information on the processing of personal data
6. Further information about Personal Data
7. The rights of users
8. Additional information about data collection and processing
9.Owner and Data Controller


Among the types of personal data that sobu Ltd collects, by itself or through third parties, there are: first name, last name, email address, various types of data, cookies, usage data, country, password, gender, date of birth, address, username, ZIP/Postal code, language and phone number. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using sobu Ltd. Unless specified otherwise, all data requested by sobu Ltd is mandatory and failure to provide this data may make it impossible for sobu Ltd to provide its services. In cases where sobu Ltd specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the availability or the functioning of the service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of cookies - or of other tracking tools - by sobu Ltd or by the owners of third-party services used by sobu Ltd serves the purpose of providing the service required by the user, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through sobu Ltd and confirm that they have the third party's consent to provide the Data to the Owner.


Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of sobu Ltd (administration, sales, marketing, legal, system administration) or external parties (such as third- party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by the owner. The updated list of these parties may be requested from the owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply whenever the processing of personal data is subject to European data protection law;
  • provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the owner or by a third party. 

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of
Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.


The data is processed at the owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the owner to safeguard their data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

retention time

Personal data shall be processed and stored for as long as required by the purpose they have been collected for.


  • Personal data collected for purposes related to the performance of a contract between the owner and the user shall be retained until such contract has been fully performed.
  • Personal data collected for the purposes of the owner's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the owner within the relevant sections of this document or by contacting the owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.


The data concerning the user is collected to allow the owner to provide its services, as well as for the following purposes: contacting the user, access to third-party accounts, data transfer outside the EU, heat mapping and session recording, hosting and backend infrastructure, managing contacts and sending messages, registration and authentication, SPAM protection and analytics.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.


sobu Ltd may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows sobu Ltd to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.


The permissions asked are the following:

  • Basic information – By default, this includes certain User's Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the user has made more of their data public, more information will be available.
  • birthday – Provides access to the birthday.
  • Contact email – Access the user's contact email address.
  • list of friends
  • Photos – Provides access to the photos the User has uploaded, and photos the User has been tagged in.
  • Publish to the Wall – Enables the app to post content, comments, and likes to a user's stream and to the streams of the user's friends.


Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts

This type of service allows sobu Ltd to access data from your account on a third-party service and perform actions with it. These services are not activated automatically but require explicit authorization by the user.

  • Facebook account access (sobu Ltd)  This service allows sobu Ltd to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
    Permissions asked: Birthday, Contact email, Current City, List of Friends, Photos and Publish to the Wall.
    Place of processing: United States – Privacy Policy – Privacy Shield participant.
  • Twitter account access (Twitter, Inc.)  This service allows sobu Ltd to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
    Personal data collected: various types of data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy – Privacy Shield participant.


The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior

  • Google Analytics (Google Inc.)  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of sobu Ltd, to prepare reports on its activities and share them with other Google services.
    Google may use the data collected to contextualize and personalize the ads of its own advertising network.
    Personal Data collected: Cookies and Usage Data.
    Place of processing: United States
    Privacy Policyopt out – Privacy Shield participant.

Contacting the user

  • Contact form (sobu Ltd) By filling in the contact form with their data, the user authorizes sobu Ltd to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form's header.
    Personal data collected: email address, first name and last name.
  • Mailing list or newsletter (sobu Ltd)  By registering on the mailing list or for the newsletter, the user's email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning sobu Ltd. Your email address might also be added to this list as a result of signing up to sobu Ltd or after making a purchase.
    Personal data collected: email address, first name and last name.

Data transfer outside the EU

The owner is allowed to transfer personal data collected within the EU to third countries (ie any country not part of the EU) only pursuant to a specific legal basis. Any such data transfer is based on one of the legal bases described below.

Users can inquire with the Owner to learn which legal basis applies to which specific service.

  • Data transfer from the EU and/or Switzerland to the US based on Privacy Shield (sobu Ltd)
    If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU – US and Swiss – US Privacy Shield.

    In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.

    Personal data may be transferred from within the EU or Switzerland to the US to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the owner to learn about such legal grounds.

    Personal data collected: various types of data.

Heat mapping and session recording

Heat mapping services are used to display the areas of a page where users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of user behavior. Some of these services may record sessions and make them available for later visual playback.

  • Crazy Egg (Crazyegg)  Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.
    Personal Data collected: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy

Hosting and backend infrastructure

This type of service has the purpose of hosting data and files that enable sobu Ltd to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of sobu Ltd. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  • DigitalOcean (DigitalOcean Inc.)  DigitalOcean is a hosting service provided by DigitalOcean Inc.
    Personal data collected: various types of data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy – Privacy Shield participant.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of sobu Ltd. The interaction and information obtained through sobu Ltd. are always subject to the user's privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when users do not use it.

  • LinkedIn button and social widgets (LinkedIn Corporation) The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
    Personal Data collected: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy
  • Twitter Tweet button and social widgets (Twitter, Inc.)  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
    Personal Data collected: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy. Privacy Shield participant

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the user. These services may also collect data concerning the date and time when the message was viewed by the user, as well as when the user interacted with it, such as by clicking on links included in the message.

  • MailChimp (The Rocket Science Group, LLC.)  MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
    Personal data collected: country, email address, first name and last name.
    Place of processing: United States – Privacy Policy – Privacy Shield participant.

Registration and authentication

By registering or authenticating, users allow sobu Ltd to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, sobu Ltd will be able to access some data, stored by these third-party services, for registration or identification purposes.

  • Facebook Authentication (Facebook, Inc.) Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
    Personal data collected: various types of data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy – – Privacy Shield participant.
  • Direct registration (sobu Ltd)  The User registers by filling out the registration form and providing the Personal Data directly to sobu Ltd.
    Personal Data collected: address, country, date of birth, email address, first name, gender, language, last name, password, phone number, username and ZIP/Postal code.

SPAM protection

This type of service analyzes the traffic of sobu Ltd, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  • Google reCAPTCHA (Google Inc.) Google reCAPTCHA is a SPAM protection service provided by Google Inc.
    The use of reCAPTCHA is subject to the Google privacy policy other terms of use.
    Personal Data collected: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy – Privacy Shield participant.


Unique device identification

sobu Ltd may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

User identification via a universally unique identifier (UUID)

sobu Ltd may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this application, it persists between application launches and updates, but it is lost when the user deletes the application. A reinstall generates a new UUID.


Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
  • Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, the owner will not process their data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure
    of their Data from the Owner.
  • Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user's consent, on a contract which the user is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where personal data is processed for a public interest, in the exercise of an official authority vested in the owner or for the purposes of the legitimate interests pursued by the owner, users may object to such processing by providing a ground related to their particular situation justify the objection.

Users must know that, however, their personal data should be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the owner is processing personal data for direct marketing purposes, users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the owner as early as possible and always within one month.


Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of sobu Ltd or the related Services. The user declares to be aware that the owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, sobu Ltd may provide the user with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

System logs and maintenance

For operation and maintenance purposes, sobu Ltd and any third-party services may collect files that record interaction with sobu Ltd (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

sobu Ltd does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within sobu Ltd and/or - as far as technically legally and feasible - sending a notice to Users via any contact information available to the owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the user's consent, the owner shall collect new consent from the user, where required.


6750 Ayala Avenue,
6750 Office Dr, Makati,
metro Manila,
Owner contact email:


Personal Data (or Data) - Any information that directly, indirectly, or in connection with other information - including a personal identification number - allows for the identification or identifiability of a natural person.

Usage Data – Information collected automatically through sobu Ltd (or third-party services employed in sobu Ltd), which can include: the IP addresses or domain names of the computers utilized by the Users who use sobu Ltd, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (eg, the time spent on each page within the application) and the details about the path followed within the application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the user's IT environment.

users The individual using sobu Ltd who, unless otherwise specified, coincides with the Data Subject.

Data Subject – The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor) – The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, as described in this privacy policy.

Data Controller (or Owner) – The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of sobu Ltd. The Data Controller, unless otherwise specified, is the Owner of sobu Ltd.

sobu Ltd (or this Application) – The means by which the personal data of the user is collected and processed.

Service – The service provided by sobu Ltd as described in the relative terms (if available) and on this site/application.

European Union (or EU) – Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

cookies Small sets of data stored in the user's device.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to sobu Ltd, if not stated otherwise within this document.

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