Privacy Policy

Last updated: January 23, 2024

Introduction

Boost is a provider of software and services that includes its B2B commerce platform.

This Privacy Policy (“Policy”) describes the “Personal Data” that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices. This Policy also outlines your data subject rights, including the right to object to some uses of your Personal Data by us.

“Boost”, “we”, “our” or “us” means the Boost entity responsible for the collection and use of personal data under this Privacy Policy. It differs depending on your country, as listed in our Privacy Resources.

“Personal Data” means any information that relates to an identified or identifiable individual (or person, depending on jurisdiction; see section 8), and can include information about how you engage with our Services (e.g. device information, IP address).

“Services” means the products and services that Boost indicates are covered by this Policy, which may include Boost-provided platforms, websites, devices and apps. Our “Business Services” are Services provided by Boost to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. “Sites” means withboost.co and other subdomains and websites that Boost indicates are covered by this Policy. Collectively, this Policy refers to Business Services and Sites as Services.

Depending on the context, “you” means End Customer, Representative or Visitor:

Depending on the activity, Boost acts as a “data controller” or “data processor” and for more information about this and on the Boost entity that is responsible under this Policy, see our Privacy Resources.

1. Personal Data that we collect and how we use it

1.1 End Customers

Boost offers Business Services to our Business Users (e.g. an online catalogue, allowing End Customers to purchase goods). When we are acting as a Business User’s service provider (or data processor), we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions. For example, we process orders for a Business User because you purchased a product from them.

Business Users are responsible for making sure that their End Customer’s privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their services. If you are an End Customer (e.g. a purchaser of a product from a Business User’s online catalogue), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly.

For further information on the legal bases which we rely on for using (processing) your Personal Data, see our Privacy Resources.

a. Personal Data that we collect about End Customers

b. How we use and share Personal Data of End Customers

We generally use and share Personal Data of End Customers with Business Users to provide Business Services as described below, as well as for Boost’s own purposes to secure, improve and provide our Business Services, as described below.

1.2 Representatives

To provide Business Services, we collect, use and share Personal Data from Representatives of our Business Users (e.g. a business owner). For further information on the legal bases which we rely on for using (processing) your Personal Data, see our Privacy Resources.

a. Personal Data that we collect about Representatives

b. How we use and share Personal Data of Representatives

We generally use Personal Data of Representatives to provide the Business Services to the associated Business Users.

1.3 Visitors

This section covers Visitors to Boost Sites who are not also an End Customer or Representative. See our Privacy Resources for further information on the legal bases which we rely on for using (processing) your Personal Data.

a. Visitor personal data that we collect

When you visit our Sites, we generally receive your Personal Data either from you providing it to us or through our use of cookies and similar technologies. See our Cookie Policy.

b. How we use and share Visitor Personal Data

2. More ways we collect, use and share Personal Data

In addition to the ways we collect, use and share Personal Data that are described above, we also process your Personal Data as follows.

a. Personal Data Collection

b. Personal Data Usage

In addition to the ways described above in which we use Personal Data, we use Personal Data in the following ways:

c. Personal Data Sharing

In addition to the ways described above, we share Personal Data in the following ways:

3. Legal bases for processing Personal Data

For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data. For more information see our Privacy Resources.

a. Contractual and Pre-Contractual Business Relationships

We process Personal Data for the purpose of entering into business relationships with prospective Business Users and to perform the respective contractual obligations that we have with these Business Users. Activities include:

b. Legal Compliance

We process Personal Data to verify the identity of our Business Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as "Anti-Money Laundering ("AML") and Know-Your-Customer ("KYC")" obligations, and financial reporting obligations. For example, we may be required to record and verify a Business User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our Financial Partners, and may require us to report our compliance to third parties, and to submit to third-party verification audits.

c. Legitimate Business Interests

Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes for which we have a legitimate interest in processing your data:

d. Consent

We may rely on consent to collect and process Personal Data as it relates to how we communicate with you and for the provision of our Services. When we process Personal Data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.

4. Your rights and choices

You may have choices regarding our collection, use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us

If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, our Business Users may still send you messages and direct us to send you messages on their behalf.

b. Your data protection rights

Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:


c. Process for exercising your data protection rights

To exercise your data protection rights please also see our Privacy Resources or contact us as described below.

5. Security and retention

We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organisational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorised access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

To help us protect Personal Data, we encourage you to use a strong password and never share your password with anyone or use the same password with other sites or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your account has been compromised), please contact us immediately.

We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your Boost account or complete a transaction with a Business User, we retain your Personal Data in order to comply with our legal and regulatory obligations. We may also retain it to allow for fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our Financial Partners, and where data retention is mandated by the payment methods you used. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

6. International data transfers

We are a global business. Personal Data may be stored and processed in any country where we do business, where our service providers do business or if you use an international payment method or Financial Partner service, the countries in which that payment method or Financial Partner operates. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from officials (such as law enforcement or security authorities).

Where applicable law requires a data transfer mechanism, we use one or more of the following: EU Standard Contractual Clauses (“SCCs”) for data recipients outside the EEA, Switzerland or the UK, verification that the recipient has implemented Binding Corporate Rules, or other legal methods available to us under applicable law.

While Boost Technology Ltd remains self-certified under the set of SSCs for cross-border data transfers, it is not currently relying on these frameworks for the transfer of personal data outside of the EEA/UK.

7. Updates and notifications

We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” date provided at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Services.

We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are a Business User, by contacting you through your Boost Dashboard, email address and/or the physical address listed in your Boost account.

If applicable law requires that we provide notice in a specified manner prior to making any changes to this Policy applicable to you, we will provide such required notice.

8. Jurisdiction-specific provisions

EEA and the United Kingdom (“UK”)

The provisions covered in this Policy comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

To exercise your rights, you may contact us through any of the methods detailed in section 9. If you are a resident of the EEA or the UK, or we have identified Boost Technology Ltd as your sole data controller, and believe we process your information within the scope of the GDPR, you may direct your questions or concerns to the UK Information Commissioner’s Office. Where Personal Data is used for regulated activities in the UK, Boost Technology Ltd and Boost local regulated entities (defined as those who are licensed, authorised or registered by a Local Regulatory Authority) are considered joint controllers.

Egypt

The Boost entity for all Business Users and End Customers in Egypt as outlined in this Policy is Performa Edge Technology.

Registered address: MQR Spaces Co., Melanite Mall, Gardenia Street, El-Wahat Road, El-Motamayez District, 6th of October City, Giza, Egypt.

Ghana

The Boost entity for all Business Users and End Customers in Ghana as outlined in this Policy is ConvyPlus Ghana Limited.

Registered address: 19 Mango Lane, Haatso, Accra, Ghana.

Contact details: gh.withboost.co, info@gh.withboost.co and +233 59 582 0250.

Nigeria

The Boost entity for all Business Users and End Customers in Nigeria as outlined in this Policy is Uwaya Gbemiga Ltd.

Registered address: 160 Bamgbose St, Lagos Island, Lagos, Nigeria.

South Africa

The provisions covered in this Policy comply with the Protection of Personal Information Act, 4 of 2013 ("POPI").

The Boost entity for all Business Users and End Customers in South Africa as outlined in this Policy is Kasi Stocka (Pty) Ltd.

Kindly note that, under POPI, juristic persons are also provided data subject protection rights similar to those one would expect e.g. for individuals under the GDPR. POPI refers to a "person" and then defines "person" as including both a natural person and a juristic person

For the purposes of compliance:

Where this Policy makes reference to the “individual” as the data subject—these rights can be read as equivalent to those of a “person” under POPI, including both natural and juristic persons.

We are the “responsible party” in addition to where this Policy identifies us as the data controller, and we are the “operator” where this Policy identifies us as the data processor. Similarly, our Business Users are the responsible parties in respect of the Personal Data they have instructed us to process in order to provide our Services. In any instance where we provide services to an End Customer directly, we will process Personal Data as the responsible party.

To exercise your rights, you may contact us. You may also direct your questions or concerns to the Information Regulator via:

depending on your request.

Legal status: Kasi Stocka (Pty) Ltd is a private company, duly incorporated in terms of the applicable laws of the Republic of South Africa.


Directors: Noxolo Nokwethemba Pearl Mthethwa and Elidah Zipiwe Banda.

Physical and registered address: 33B Begonia Road, Kyalami, Johannesburg, Gauteng, 1684, South Africa.

Postal address: Posnet Box 077, Private Bag X 11, Halfway House, Gauteng, 1685, South Africa.

Contact details: za.withboost.co and info@za.withboost.co

9. Contact us

If you have any questions or complaints about this Policy, please contact us via email at privacy@boost.technology, or via mail at Boost Technology, 128 City Road, London EC1V 2NX, United Kingdom. If you are an End Customer (i.e. an individual doing business or transacting with a Business User), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly.