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Privacy Notice

Last Updated: September 16, 2024

Version: 1.0

1. Overview

Please read this Privacy Notice carefully. It details how we process (collect, store and use) your personal data when you use our Platform and the Services. We handle your data in line with this Privacy Notice and strive to comply with applicable laws, including the Data Protection Act 2018 (UK GDPR).

2. Interpretation

  1. Definitions

    Capitalised terms not defined in this Privacy Notice have the meanings given in the BoostWorkforce Terms of Service (“Terms”). We recommend reading the Terms carefully as they impact your rights and obligations.

  2. Terminology

    In this Privacy Notice, “personal data” and “personal information” are synonyms. They refer to any information that identifies or can reasonably identify you, either directly or indirectly.

3. Contact Details

We are the data controller for the data collected under this Privacy Notice, meaning we determine how and why your data is processed. If you have questions about this Privacy Notice or your data processing, please contact us at:

Name: Wow-How Studio Ltd, D/B/A BoostWorkforce
Company number: 11540577
Address: 80 Coleman Street, London, England, EC2R 5BJ

4. Type of Data

We collect personal information about you as listed below. We may also collect certain other information required by law. Please only share information that is necessary or we ask for.

  1. Account Data

    This may include your full name, email address, Account ID, and any other data we request or that you choose to provide.

    If the Platform functionality allows so, you can use a Google or Apple account to create your Account. In this case, we will get some information from them, like your email address, authentication token, etc., as notified to you when you link these accounts. You can disconnect your Account from Google or Apple accounts by contacting us or using their settings. Once we are notified of the deactivation, we will delete the information we got from them, except for the data that became a part of your Account. Google and Apple are independent controllers, and we are not responsible for how they handle your personal data.

  2. Payment Data

    This includes your billing address, VAT number, card details, such as card number, name of the holder, security code (also known as CVV or Card Verification Value code), expiry date, country of card issuance, etc., as well as your billing history, such as payment amount, the type of funds used, date, status, etc. In exceptional cases, you pay via wire transfer, this may include your account details, such as IBAN code or account number.

    We do not store your card details, they are handled by the respective payment service providers. These providers are separate data controllers from us, and we do not manage, control, or have any affiliation with them. When you share your payment data via the Platform, you share it with the respective payment service provider. Please consult their applicable terms of service and privacy policies.

  3. Marketing Data

    This includes your email address that you provide to us.

  4. Analytical Data

    1. Google Data

      This includes (i) internet protocol (IP) address, which, according to the Google Analytics documentation, is anonymised (masked) and cannot be used to identify a specific Platform visitor or their exact location; (ii) the browser type and its version; (iii) the type of device (e.g., computer, tablet, or smartphone); (iv) the type and version of the operating system on your device; and (v) other usage information, such as when you clicked a certain button or made some input. Google Data is collected via Google Analytics solution, operated by Google Ireland Limited and its affiliates, including Google LLC (“Google”). More information regarding Google Analytics is available here.

    2. Microsoft Data

      This includes information about how you interact with the Platform, like clicks, scrolls, mouse moves, window resize, selections, inputs, and so on. Microsoft Data is collected via Microsoft Clarity solution, operated by Microsoft Corporation and its affiliates, including Microsoft Ireland Operations Limited (“Microsoft”). More information regarding Microsoft Clarity is available here.

    3. Roles and Details

      Google and Microsoft collect information using cookies — small data files placed on your device to recognise it when you visit the Platform. With respect to Analytical Data, Google and Microsoft act as our data processors. However, if they use this data for their own purposes, they are independent data controllers, and we are not responsible for their actions. You can learn more about how they process personal data in their privacy policies: Google’s privacy policy and Microsoft’s privacy policy.

  5. Contact Data

    This includes your full name, contact details and any other data we request or that you choose to provide.

5. Data Use

We use the personal data as follows:

  1. Account Data

    1. Purposes:

      To allow you to subscribe to the Services and/or create an Account to access certain Platform features. We may also use the data for financial, accounting, and tax purposes.

    2. Lawful basis:

      To take steps to enter into a contract at your request and, further, the performance of a contract with you. If you act on behalf of a legal entity — our legitimate interest to ensure the entity you represent achieves the above purposes. With respect to the financial, accounting, and tax purposes, the legal basis is compliance with the applicable law.

  2. Payment Data

    1. Purposes:

      To maintain financial records and enable you to subscribe to the Services and pay the Fees.

    2. Lawful basis:

      The performance of a contract with you and our legal obligation to comply with the applicable laws.

  3. Marketing Data

    1. Purpose:

      To provide you with marketing and newsletter emails concerning the Platform and Services.

    2. Lawful basis:

      Our legitimate interest in providing you, as our former or current client, with information regarding the Platform and Services. However, if you have subscribed to receiving our newsletter, your consent.

  4. Analytical Data

    1. Purposes:

      To analyse how the Platform is used and enhance the user experience by improving its functionality, usability, user flow, and interface.

    2. Lawful basis:

      Your consent. When you visit the Platform, you can opt out of cookies placed by our providers. You may also be able to prevent use of cookies by downloading and using third-party add-on or solutions.

  5. Contact Data

    1. Purposes:

      To contact you in Services-related matters, as well as to respond to your inquiry.

    2. Lawful basis:

      Our legitimate interest to achieve the above purposes.

6. Storage Period

We keep your information as long as we need it for the purposes we collected such information. We may retain it longer if required to meet our legal obligations, in relation to legal proceedings, or to protect our rights and legitimate interests or those of third parties. The storage periods are as follows:

  1. Account Data

    1. If you had a subscription

      If you commenced a subscription, as long as your subscription and Account are active, and for six years after the end of the last financial year in which your last subscription ends and Account is terminated, whichever is later. We set this retention period to: (i) fulfil our contract with you; (ii) handle disputes, legal claims, or lawsuits related to your subscription and use of the Services, if any; and (iii) retain financial, accounting, and tax records to comply with laws.

    2. If you did not have a subscription

      If you have not commenced a subscription, for twelve months after the later of: (i) the last date you contacted us about the Services or Platform; or (ii) your Account termination. This period aligns with the statutes of limitations in the Terms.

    3. Account Termination

      To terminate your Account, contact us or use the Platform functionality, if available.

  2. Payment Data

    For six years from the end of the last financial year the payment pertains to. In some cases, we may retain it longer if required by law, especially for payments that cover multiple accounting periods. We set this retention period due to our legal obligations under the applicable laws.

  3. Marketing Data

    As long as you remain a subscriber. You can unsubscribe from marketing emails at any time by (i) contacting us, or (ii) clicking the unsubscribe button at the bottom of each marketing email. We will then remove your email address from our marketing database.

    Please note that administrative or service-related communications (like email verifications or maintenance notifications) are not considered marketing and may not include an unsubscribe option.

  4. Analytical Data

    We do not establish a storage period for the Analytical Data, as such data is anonymous, aggregated, and does not allow for identifying any particular person against the visitors of the Platform. If and to the extent we become able to identify any particular person, we will promptly update this Privacy Notice and establish a certain limitation period for processing the Analytical Data.

  5. Contact Data

    For twelve months after the later of: (i) the last date you contacted us about the same matter; or (ii) your Account termination. This period aligns with the statutes of limitations in the Terms.

7. Data Sharing

  1. General Terms

    We do not sell or rent your data. We may share it in line with this Privacy Notice, applicable laws, the Terms, or with your consent. We will take appropriate measures to protect your data during such transfers.

  2. International Transfers

    When transferring personal data outside the UK or EEA to countries without adequate protection, we take steps to ensure it is protected. Typically, we use the respective international data transfer agreement or addendum to the standard contractual clauses approved by regulators. Upon request, we will provide information about these transfers and a copy of the relevant documents.

  3. Recipients

    Your personal information is shared with the following categories of recipients:

    • Affiliates
    • support and technical teams;
    • marketing teams;
    • analytical solution providers, such as Google Analytics and Microsoft Clarity;
    • email delivery service providers;
    • hosting service providers;
    • government authorities, upon their request or if necessary to comply with our legal obligations;
    • another entity if we sell or otherwise transfer the Platform or their parts; and
    • other third-party solutions, which may be from time to time integrated in relation to the Platform.

8. Rights

  1. Verification

    To exercise your data subject rights, we may request information to verify your identity and confirm that you have the right to make the request.

  2. Data Subject Rights

    Subject to the applicable laws, you have the following rights:

    1. Right to Access

      You can request to see if we process your personal data. If we do, you can ask for details about the processing and a copy of the data to verify its accuracy and legality.

    2. Right to Correction

      You can request to correct or complete any incomplete or inaccurate data. We may need to verify the accuracy of the new information you provide.

    3. Right to Deletion

      You can request the deletion of your personal data if we no longer need it, you have successfully objected to processing, we processed it unlawfully, or we must erase it to comply with the law. We may not always be able to fulfil your request due to legal or technical reasons, which we will explain in our response.

    4. Right to Objection

      You can object to the processing of your data if it does not comply with applicable laws. We may, however, show that we have compelling legitimate grounds for processing that override your rights.

    5. Right to Opt-Out of Sale or Sharing

      You can opt out of the sale or sharing of your personal data at any time. “Sale” refers to disclosing your data to third parties for compensation. “Sharing” involves disclosing your data for targeted advertising or similar purposes.

    6. Right to Opt-Out of Marketing

      You can ask us to stop sending you marketing materials and cease processing your data for marketing purposes.

    7. Non-Discrimination Right

      You cannot be discriminated against for exercising your rights under applicable laws. We will not treat you unfairly based on your personal data.

    8. Right to Restrict Processing

      You can ask us to suspend processing your data if: (i) you need to verify its accuracy, (ii) it is used unlawfully, but you do not want it deleted, (iii) you need it to establish, exercise, or defend legal claims, or (iv) you have objected to its use, and we need to verify if we have overriding grounds.

    9. Right to Data Portability

      You can request your personal data be transferred to you or a third party in a structured, commonly used, machine-readable format. This right applies only to automated data processed based on your consent or performance of contract.

    10. Right to Withdraw Consent

      You can withdraw your consent at any time if we are processing your data based on your consent.

    11. Right to Human Review

      You can request a human review of decisions made solely based on automated processing, including profiling, if such decisions impact your rights.

    12. Right to File a Complaint

      You can file a complaint with a supervisory authority if we violate your rights or legal obligations. The competent authority may depend on your location. Our supervisory authority is the UK Information Commissioner’s Office.

9. Third-Party Links

Our Platform may include links and social media plugins to third-party sites and apps. Clicking these may allow third parties to collect or share your data. We do not control or endorse these third parties and are not responsible for their privacy practices. We recommend reviewing the privacy policies of any external sites or apps you visit.

10. Data of Children

Our Platform is not for children under 18 (or older if local laws set a higher age). We do not knowingly collect or use personal data from children. If we learn that a child has provided us with personal information, we will promptly delete it. Parents or guardians who believe their child’s data has been collected should contact us.

11. Modifications and Updates

We regularly review and may update our Privacy Notice. Any changes will be reflected by updating the “Last Updated” date at the top of this document. We encourage you to review this Privacy Notice periodically for any updates. If we make substantial changes to how we handle your personal information, we will: (i) display a notice on the Platform, and/or (ii) notify you by email before the changes take effect.