Introduction

Welcome to Boostify website (the “Site”). In the course of our business operations, we receive, collect, maintain, use and share personal data on customers and business partners. We are committed to protecting the privacy of individuals who visit our website (visitors) and individuals who register to use our services (customers) collectively hereinafter “User(s)”). Please read this entire Privacy Policy which will inform you as to the types of information we gather, as well as how we will use and protect such information.

We act as a controller with respect to the information we process in connection with our business relationships. For example, we are the controller in relation to Users’ contact details and other commercial Personal Data. On the other hand, we may also act as a processor of Users’ Personal Data when our customer and business partners engage us to process Personal Data on their behalf in connection with the provision of the Services. We may also act as a processor in certain circumstances when our customers use third party service providers in connection with our Services (e.g. Facebook). When we act as the processor, we process the data in accordance with applicable privacy laws and the data processing agreement entered into with the controller, where applicable.

In such a case, please refer to the Privacy Policies of controllers for further information on the processing of Personal Data. Unless otherwise expressly stated herein, the terms used in this Privacy Policy shall have the meaning set forth in the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).

Processing of Personal Data

We process Personal Data of Users to offer the Services, including the processing and execution of demo requests relating to the Services, and to contact and to contact and send marketing material to the visitors of our websites who submit us their information in a form or otherwise with the intent to receive marketing or other information from the Site. In this context, Personal Data may be processed for market and customer analysis, reporting and statistical purposes, marketing purposes such as customized marketing, administration notices, database management and maintenance, product suggestions and offers, interaction with external social networks, access to third party services' accounts and platforms, heat mapping and newsletters. Personal Data may be used for direct marketing, including, where applicable, by electronic means unless objected by the User. Personal Data may also be processed to better understand how website visitors interact with the Site.

Further, Personal Data may be used for invoicing and to send important information to the User e.g. regarding changes of applicable fees, price list and conditions, or to contact the User and provide information customized Services according to the interests of the Data Subject.

We process Personal Data on the following basis:

We may ask for User's consent for the processing of certain type of Personal Data (for example for a campaign). When collecting such consents, we inform the User of the respective purposes of processing and such processing is conducted only when appropriate consent is received. We may ask for certain Facebook permissions allowing us to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This allows our Services to connect with the User's account on the Facebook social network, provided by Facebook Inc. In this context, the following permissions may be asked: Access Rights to Ads Insights, Ads Management and Contact Email. For more information about the Facebook permissions, refer to the Facebook permissions documentation and to the Facebook Data Policy.

Personal Data We Collect and Use

Personal Data processed by us is mainly obtained directly from the User. Provision of such Personal Data is necessary to use and purchase our Services, to accommodate User’s request for information relating to our Services and to organize communication in relation to our business events. We may not provide the Services to a User that refuses the processing of his/her Personal Data. We process also Personal Data accumulating from the use of our Services, and obtained from third party sources related to the Services. Personal Data may be updated and supplemented by collecting data from private and public registers. We collect the following Personal Data in conjunction with the Data Subject's

(i) use of our Services,

(ii) requests for information through our website and

(iii) participation to our business events: name, phone number, e-mail address, usage data and cookies or any other information the user can provide via form (in website).

In addition, we may process various other types of Personal Data generated in connection with the User’s use of any third-party services and applications as specified in the privacy policy of such third-party service or application.

Cookies and other tracking devices

A cookie is a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user returns. The site uses cookies to help identify and track users, patterns of usage, and access preferences. Bowery Boost also uses temporary “session” cookies to make sure that you are remembered as you navigate through various pages of the Site. If you do not want to have cookies placed on your computer you can set your browser to refuse cookies before using the Site. If you do so, however, some Web sites and services, including ours, may not work properly.

We receive data from the various devices you use to access our sites. This may include location and IP information, device ID information, the pages within our site that you visit, or the type of browser you are using. We may even receive GPS information from your device so we can provide you location-based services. We do not collect sensitive information (Personal Data of special categories).

Disclosure of Personal Data

For the purposes stated in this Privacy Policy, Personal Data may be disclosed, when necessary, to authorities, other companies within the same group of companies as us, companies which the group cooperates with and to other third parties, such as third-party service providers used in connection with our Services and services related thereto. Personal Data may be transferred outside the European Union and the European Economic Area (“EU/EEA”), including but not limited to, the United States of America, China, Australia, Singapore and Argentina as well as other locations and jurisdictions in which we conduct our business. Such transfers outside the EU/EEA are performed subject to appropriate safeguards such as standard data protection clauses adopted or otherwise approved by the EU Commission in accordance with the GDPR (“Standard Data Protection Clauses”). The applicable Standard Data Protection Clauses are made available for review to the User upon request.

Retention Period

We retain User’s Personal Data for 3 years from User’s latest purchase or contact with us. Personal Data may be, wholly or in part, retained for longer or shorter term if required by applicable law or if there is other justified reason to retain or delete them. In such a case, User’s Personal Data shall be erased with no further delay after there is no longer any need for such a retention. We evaluate the necessity and accuracy of the Personal Data on a regular basis.

Users’ Rights

User has a right to request from us:

User may exercise the aforementioned rights by sending a written request to us. Where the processing is based on consent, User has a right to withdraw such consent at any time. Please Policy that this will not affect the lawfulness of processing based on consent before its withdrawal. In case the User considers that its rights under the data protection laws are infringed, the User may lodge a complaint with the supervisory authority of the User’s residence in the EU (e.g. in Finland the Finnish Data Protection Ombudsman).

Choice to Opt-out

You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at contact@boostify.io. You can choose not want to have cookies placed on your computer by setting your browser to refuse cookies before using the Site. If you do so, however, some Web sites and services, including ours, may not work properly.

Protection of Personal Information

The security of your personal information is important to us. In fact, we use reasonable physical, electronic, and administrative safeguards to help us protect the security and confidentiality of data stored on our system. The Site encrypts the transmission of that information using secure socket layer technology (SSL). Except as specified in this Privacy Policy, we follow generally accepted industry standards to limit access to your personal information to the employees, officers, third-party contractors, and strategic partners of Bowery Boost who need the information in order to perform their duties. While no method of transmission over the Internet, or method of electronic storage, is 100% secure, we believe that the measures we have implemented minimize the risk of security breach to an appropriate level given the types of information involved.

If you have any questions about security on our Websites, you can contact us at contact@boostify.io