1. General

Boostern (“Boostern”, “we”, “us”) represents the group of a private limited liability company incorporated and existing under the laws of Hungary, with registered office at 2030 Erd, Nera str. 27, Hungary (VAT: HU 27336540-2-13) called Boostern Hungary Szolgaltato Kft., and another private limited liability company incorporated and existing under the laws of Belgium, with registered office at at Rue Charles Martel 8, 1000 Bruxelles (VAT: BE 0780 392 417) called Boostern Belgium BV/SRL. Boostern collects data when you send us an e-mail, when you use our website https://boostern.com (“website”) or social media (“Services”), and when you participate in user surveys organized by and on our behalf (“user surveys”).

You may not always be aware of it, but using our website and/or Services implies sharing Personal Data (as defined below). According to the legal definition, personal data means any information relating to an identified or an identifiable natural person (“Personal Data”). It is sufficient to be regarded as Personal Data if the data allows us to make a direct or indirect link between one or more data on the one hand and a natural person on the other hand.

We believe the protection of your privacy is very important and would like to provide clarity, and, hence, we have prepared this privacy policy (“Privacy Policy”). Boostern will only use your Personal Data for the purposes stated in this Privacy Policy and we will not disclose your Personal Data to any natural person, legal person, or entity other than Boostern (“Third Party”).

The collection and processing of Personal Data is subject to strict legal conditions to give you, as a user, the necessary guarantees that your Personal Data will not be publicly disclosed in an unauthorized manner.

Each processing will therefore always be done in compliance with the applicable EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), together with the codes of practice, codes of conduct, regulatory guidance and standard clauses and other related legislation resulting from such Regulation, as updated from time to time (the “Privacy Legislation”).

This Privacy Policy applies to the relationship between you and Boostern. Boostern will only process, store and use your Personal Data in accordance with this Privacy Policy and in accordance with the provisions of the Privacy Legislation.

We assume that you have read this Privacy Policy before using the website, our Services, or participate in user surveys, as well as given your consent to the collection and processing of the Personal Data by Boostern in accordance with this Privacy Policy.

2. Principles for processing personal data

Our principles for processing personal data are:

• Fairness and lawfulness. When we process personal data, the individual rights of the Data Subjects must be protected. All personal data must be collected and processed in a legal and fair manner.
• Restricted to a specific purpose. The personal data of Data Subject must be processed only for specific purposes.
• Transparency. The Data Subject must be informed of how his/her data is being collected, processed and used.

3. What personal data we collect and process

Boostern collects several different types of personal data for various purposes. Personal Data may include, but is not limited to:

• Contact details (e.g. your name, place of residence, telephone number, date of birth, sex, e-mail address, job title, business name, VAT number, CV, Portfolio);
• Data on the use of the website / Log file information (e.g. browser and IP address)
• Data of e-mails (e.g. number of times the e-mail was opened); and/or
• In general any and all Personal Data obtained in view of executed user surveys.
• Local storage: using browser web storage, application data caches and other mechanisms on your device we can collect and store your data (including personal data)
• Cookies: we use cookies to identify our visitors in order to remember your preferences such as the default language. For more information about cookies, please refer to our cookie policy.

How did we obtain your personal data?
We obtain this data via any means by which we were in touch with you. Contact forms that you have filled out, via email, via phone calls, live conversations or business cards we got from you.

4. How we use the personal data

Boostern uses the collected personal data for various purposes, including to:

• Provide, operate, and maintain our website
• Improve, personalize, and expand our website
• Understand and analyze how you use our website
• Develop new products, services, features, and functionality
• Contact you in response to your specific request via the contact form or by e-mail
• Prevent fraud and abuse
• Provide you with services
• Notify you about changes to our services and/or products
• Provide customer support
• Detect, prevent and address technical issues
• Send you invitations to participate to our user surveys

Furthermore, Boostern has free access to your Personal Data, and may freely save and publish your Personal Data in the following cases:

• To comply with applicable laws or regulations
• If a law enforcement authority or other government agency so requests
• For investigating suspicious or fraudulent or illegal activities; and/or
• To protect security and/or your rights or Boostern’s

5. Legal basis for collecting and processing personal data

Boostern’s legal basis for collecting and using the personal data described in this Data Protection Policy depends on the personal data we collect and the specific context in which we collect the information:

• Boostern needs to perform a contract with you
• You have given Boostern permission to do so
• Processing your personal data is in Boostern’s legitimate interests
• Boostern needs to comply with the law

6. Retention of personal data

Boostern will retain your personal information only for as long as is necessary for the purposes set out in this Data Protection Policy.

Boostern will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

Your personal data will only be stored within the European Economic Area.

7. Data protection rights

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what personal data we hold about you and if you want it to be removed from our systems, please contact us at info@boostern.com

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you
• The right of rectification
• The right to object
• The right of restriction
• The right to data portability
• The right to withdraw consent

8. Cookies

When using the website, we collect certain information through automated systems, including cookies (small text files stored in your browser) and similar technologies, including mobile app identifiers, to increase security, measure use and effectiveness of the website, identify problems and then resolve them. We may also use cookies and other automated systems for other purposes including the management of the website and other aspects of the commercialization of our company.

The information we collect in this way includes the IP address, browser properties, device properties, version of the operating system, information about actions taken on our website (including use, activity logs and click-throughs), and dates and times of the visits to the website. Data logs are deleted on a regular basis.

You can check the use of cookies through your browser settings and other tools. You can configure your browser to disable, reset or block (the use of) cookies or similar technologies. However, it is possible that without our use of cookies, our website does not work properly, or that not all features of the website are available.

Third Parties may also use cookies to gather information about your activities on our website in order to understand and continuously improve the functioning of the website. For more information about the use of cookies by Third Parties, we refer you to the website of the relevant Third Party, as they will use cookies in accordance with their own cookie policy, which may differ from our own policy.

By continuing to use the website you accept the use of cookies in your browser in accordance with this Privacy Policy.

9. Your Rights

Guarantee of compliance with principles specific to the processing of personal data

Boostern only processes your personal data:

• In accordance with the purposes set forth herein or in a manner that is not incompatible with this original purpose;
• In a proper, lawful and transparent manner in which the processing, depending on the case, is based on the following grounds: consent, legitimate interest, execution of an agreement or a legal obligation;
• In a way that is proportional to the stated goal;
• In a proper way;
• In principle during a period equal to 5 years after the last activities on the website or 5 years after execution of the agreement;
• In cases determined by law, during a period that is equal to the statutory retention period;

Right of access

Any Visitor who can adequately prove his/her identity has the right to obtain confirmation from Boostern about whether or not personal data concerning him/her is processed and, if that is the case, to obtain access to the personal data.

You have the right to receive information about the processing purposes, the categories of personal data that are processed, the recipients of the personal data, the (criteria for determining) the period during which your personal data will be stored and the rights you can exercise in accordance with the GDPR.

If you wish to use your right of access / rectification / erasure, Boostern will comply with this within 30 days after receiving the request and only if you have this right. The request is made by registered mail or by e-mail to: info@boostern.com

Personal data that is incomplete or inaccurate can always be corrected or deleted. You can exercise your right to rectification by providing Boostern with an additional statement. Boostern will comply with this within 30 days after receiving the additional statement.

In addition, you have the right to have your personal data deleted by Boostern without undue delay. You can only invoke this right in the following cases, which Boostern will assess:

• When your personal data is no longer necessary for the purposes for which it was collected or processed;
• When you withdraw your consent and there is no other legal ground for the processing;
• When an objection is made to the processing and there are no overriding legitimate grounds for the processing;
• When the personal data has been unlawfully processed;
• When your data must be erased in accordance with a legal obligation.

Right to restriction of processing / right to object

You have the right to obtain from Boostern a restriction of the processing if one of the following applies:

• You dispute the accuracy of the personal data;
• Boostern's processing appears to be unlawful and you do not wish to delete the personal data;
• Boostern no longer needs your personal data for the processing purposes, but you still need it for the establishment, exercise or defense of legal claims;
• Boostern must assess the existence of the grounds for deleting the personal data and this during this period.
• You also have the right at any time to object to the processing of your personal data for reasons related to your specific situation. Boostern will then cease processing your personal data, unless Boostern can demonstrate compelling legitimate grounds for processing your personal data that outweigh your right to object.

You also have the right not to be subject to individualized and fully automated decision-making where it has legal consequences or can significantly affect you. However, you can always intervene in such decision-making yourself or demand human intervention.

Finally, you have the right to object at any time to the processing of personal data for direct marketing.

If you wish to exercise your right to object / restriction of processing, Boostern will comply with this within 30 days after receiving the request. The request is made by registered mail or by e-mail to: info@boostern.com

Right to data portability

You have the right to obtain the personal data provided to Boostern in a structured, common and machine-readable form. In addition, you have the right to transfer this personal data to another controller if the processing of your personal data is based solely on your consent.

If you wish to use your right to data portability, Boostern will comply with this within 30 days after receiving the request. The request is made by registered mail or by e-mail to:info@boostern.com

Right to be forgotten

Whenever you have rightly requested Boostern to rectify, delete or process data to a limited extent, Boostern will notify each recipient of this personal data, unless this proves impossible or would require unreasonable effort. You can also always receive information about these recipients.

Right to withdraw your consent / right to lodge a complaint

You always have the right to withdraw your consent. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal. You also have the right to submit a complaint regarding the processing of your personal data by Boostern to the competent supervisory authorities.

If you wish to withdraw your consent or exercise your right to file a complaint, Boostern will comply with this within 30 days after receiving the request. The request is made by registered mail or by e-mail to: info@boostern.com

Right to information and transparency

When exercising your rights, Boostern will always act in accordance with the GDPR and thus provide all information required by the GDPR in a concise, transparent, comprehensible and easily accessible form, which you will receive in plain language.

The deadlines for responding to your requests may be extended in exceptional circumstances, including the complexity / multiplicity of your requests. Boostern will inform you of this extension and the reasons for this extension within 30 days after receipt of your request.

10. Storage and removal of personal data

We may store your Personal Data as long as reasonably required to provide you with the Services, and for the Purpose as described in this Privacy Policy. Afterwards, your Personal Data will be erased.

This means that we may retain your Personal Data until we receive your request to unsubscribe through an opt-out sent by e-mail at info@boostern.com In such event Boostern ensures that any and all of your Personal Data will be deleted within 30 calendar days following such opt-out request.

11. Safety

Boostern has developed security measures adapted from a technical and organizational point of view to avoid the destruction, loss, falsification, modification, unauthorized access or the accidental disclosure to third parties of personal data collected on the website as well as any other unauthorized permitted processing of this data.

Under no circumstances can Boostern be held liable for any direct or indirect damage resulting from incorrect or unlawful use by a third party of the personal data.

Boostern would like to advise you that the website may contain links, hyperlinks or references to other sites, which Boostern does not control and to which this Privacy Policy does not apply. Indeed, these sites are not operated by Boostern. Boostern is not liable for the content of such websites to which reference is made, nor for the offers, products or services mentioned on them. Boostern therefore recommends that you carefully read each privacy policy of any site you visit as it may differ from this one.

12. Updates or changes to our privacy policy

If required, this Privacy Policy may be modified or updated to allow Boostern to process your previously collected Personal Data for new purposes. In such a case, you will be informed about this via a notification on our website or your submitted e-mail address that the Privacy Policy has been amended and you will be requested to agree to this.

13. Complaints

All persons whose personal data we store have the right to submit a complaint to the Commission for the Protection of Privacy (Drukpersstraat 35, 1000 Brussels, commission@privacycommission.be).

14. CCPA Privacy Rights

Under the CCPA, among other rights, California consumers have the right to:

• Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
• Request that a business delete any personal data about the consumer that a business has collected.
• Request that a business that sells a consumer's personal data, not sell the consumer's personal data.
• If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us by e-mail at info@boostern.com

15. Children’s Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Boostern does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.