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:

• When you do business with, or otherwise transact with, a Business User (typically a distributor using Boost Services, e.g. when you buy stock from a distributor that uses Boost for order processing) but are not directly doing business with Boost, we refer to you as an “End Customer.”
• When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for a distributor who is a Business User), we refer to you as a “Representative.”
• When you visit a Site without being logged into a Boost account or otherwise communicate with Boost, we refer to you as a “Visitor” (e.g. you send Boost a message asking for more information because you are considering being a user of our products).

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

• Transaction Data. If you are an End Customer, when you place orders with, make payments to, get refunds from or otherwise transact with a Business User that uses us to provide Business Services, we will receive transaction data. The “Transaction Data” that we collect includes Personal Data, and may include the following: your name, phone number, email address, billing address, shipping address, payment method information (such as mobile money number, credit or debit card number, or bank account information), tax-related information, distributor and location, purchase amount, date of purchase and information about what you have purchased. We may also receive your transaction history with the Business User. We may additionally collect information provided when populating a basket or order, even if you choose not to complete the purchase with the Business User.
• Identity/Verification Information. Boost may use your information to allow a Business User to verify Personal Data about you, such as your identity (when applying for a Service that requires Know-Your-Customer ("KYC") validation), age (when purchasing age restricted goods) or your authorisation to use a payment method. You will be asked to share Personal Data and we will collect the information that you share for this purpose, such as your government ID, your image, and Personal Data you input or that is apparent from the payment method. We may compare this information with information about you we collect from Business Users, partners, identity verification services, publicly available sources, and third-party service providers.
• More. Please see Section 2 for information about additional types of Personal Data that we may collect, including about online activity.

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.

• Orders and Payments. We use your Transaction Data to provide our orders and payments related Business Services to Business Users, including to process online orders and transactions, to invoice and bill and to calculate their revenue. We may also use Personal Data to provide and improve our Business Services.
  • For transactions, your Personal Data is shared with a number of parties in connection with your transaction. Because we act as a service provider or processor, we share Personal Data to enable the transaction. For example, when you choose to use a payment method for the transaction (e.g. mobile money, credit card, debit card or Stock Boost), your payment method will receive the Transaction Data that includes your Personal Data. Please review your payment method’s privacy policy to learn more about how they use and share this information.
  • The Business User you choose to do business with will also receive Transaction Data that includes your Personal Data and the Business User may share that Personal Data with others. Please review your Business User’s privacy policy to learn more.
• Other Financial Services. Some of our Business Users use our Services in order to offer financial services to you, through Boost or other financial institutions that we partner with to offer the Services (“Financial Partners,” including payment method providers and banks). For example, they may provide a product that enables you to purchase goods and services. These products may carry the Boost brand, partner brands and/or the brands of Business Users. In addition to any Transaction Data we may produce or receive when these cards are used for purchases, we will also receive and use your Personal Data in order to provide and manage these products. Please also see the privacy policies of the Business User and our partners, if applicable, associated with the financial service (whose brands may be shown on the product).
• Identity/Verification Services. We use Personal Data about your identity, including information provided by you and our service providers, to perform verification Services for Boost or for the Business Users that you are doing business with and to reduce fraud and enhance security.
• Fraud Detection Services. We use your Personal Data collected across our Services to detect and prevent fraud against us, our Business Users and financial partners, including to detect unauthorised log ins using your online activity. We may provide Business Users (including others involved in payment processing activities) with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud risk with a transaction.
• Our Business Users (and their Authorised Third Parties). We share Personal Data of End Customers with their respective Business Users and with parties directly authorised by those Business Users to receive Personal Data (such as a payment processor). This includes sharing Personal Data of End Customers with Business Users when a Business User authorises a third-party application provider to access its Boost account using an integration or API. The Business Users you choose to do business with may further share your Personal Data to third parties they authorise. Please review your Business User’s privacy policy to learn more.
• Advertising by Business Users. If you have started a purchase, we share Personal Data with that Business User in connection with our provision of Services and that Business User may use your Personal Data to market and advertise their products or services. Please review your Business User’s privacy policy to learn more, including your rights to stop their use of your Personal Data for marketing purposes. We do not use or share End Customer Personal Data for our marketing or advertising, or for marketing and advertising by third parties who are not the Business User with which you have transacted or attempted to transact. We do not sell the Personal Data of End Customers.
• More. Please see Section 2 for information about additional ways in which we may use your Personal Data.

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

• Registration and Contact Information. If you register for, or are provided with, a Boost account for a Business User, we collect your name and account log in credentials. If you register for Boost communications, we collect your registration and profile information. If you are a Representative of a potential Business User, we receive your Personal Data from third parties (including data providers) in order to advertise to, market and communicate with you as described further below and in Section 2.
• Identification Information. If you are an owner of a Business User or you are expected to be a shareholder, officer or director of a Business User, we require that you provide your contact details, such as name, postal address, telephone number, and email address to fulfil our regulatory requirements. We may also collect financial and personal information about you, such as your ownership interest in the Business User, your date of birth and government identifiers associated with you and your Business User (such as your social security number, tax number, or employer identification number). You may also choose to provide bank account information.
• More. Please see Section 2 for information about additional types of Personal Data that we may collect, including about online activity.

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.

• Business Services. We use and share Personal Data of Representatives with Business Users to provide the Services.
  • We share data with parties directly authorised by a Business User to receive Personal Data (e.g. Financial Partners servicing the financial product). The use of Personal Data by a Business User’s authorised third-party is subject to the third-party’s privacy policy.
• Advertising. With your permission or where allowed by applicable law, we use and share Representative Personal Data with others so that we may advertise and market our products and services to you, including through interest-based advertising subject to any consent requirements under applicable law. See our Cookie Policy. We do not sell Representative Personal Data.
• More. Please see Section 2 for information about additional ways in which we may use your Personal Data.

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.

• Forms. When you choose to fill in a form on the Site or on third-party websites, apps or other online services (“Third-Party Sites”) featuring our advertising (e.g. LinkedIn or Facebook), we will collect the information included in the form, usually your contact information and other information about your question related to our Services.
• More. Please see Section 2 for information about additional types of Personal Data that we may collect, including about online activity.

b. How we use and share Visitor Personal Data

• Personalisation. We use information about you that we gather from cookies and similar technologies to measure engagement with the content on the Sites, to improve relevancy and navigation, to personalise your experience and to tailor content about Boost and our Services to you.
• Advertising. With your permission or where allowed by law, we use and share Visitor Personal Data with others so that we may advertise and market our Services to you, including through interest-based advertising where allowed by applicable law, including subject to any consent requirements. See our Cookie Policy.
• More. Please see Section 2 for information about additional ways in which we may use your 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

• Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about:
  • Devices and browsers across our Sites and Third-Party Sites,
  • Usage data associated with those devices and browsers, including IP address, plug-ins, language used, time spent on Sites and Third-Party Sites, pages visited, links clicked, and the pages that led or referred you to Sites and Third-Party Sites. For example, activity indicators help us detect fraud. Please also see our Cookie Policy.
• Communication and Engagement Information. We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Boost emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Boost, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Boost events and other interaction with Boost personnel.
• Forums and Discussions. Where our Sites allow you to post content, we will collect Personal Data that you provide in connection with the post.

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:

• Improving and Developing our Services. We use analytics on our Sites to help us analyse your use of our Sites and Services and diagnose technical issues. To learn more about the cookies that may be served through our Sites and how you can control our use of cookies and third-party analytics, please see our Cookie Policy. We also collect and process Personal Data through our different Services, whether you are an End Customer, Representative or Visitor, to improve our Services, develop new Services and support our efforts to make our Services more relevant and more useful to you.
• Communications. We will use the contact information we have about you to perform the Services, which may include sending codes via email, SMS or WhatsApp to authenticate you. We may communicate with you using the contact information we have about you (e.g. using email, phone or text/WhatsApp message) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. For example, when you submit your contact information to us we may use the information to follow-up with you regarding an event, send you information that you have requested on our Services and include you on our marketing information campaigns.
• Social Media and Promotions. If you choose to submit Personal Data to us to participate in an offer, program or promotion, we will use the Personal Data you submit to administer the offer, program or promotion. Based on your permission or opt-out, we will also use that Personal Data and Personal Data you make available on social media to market to you.
• Fraud Prevention and Security. We collect and use Personal Data to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection Business Services, and to otherwise seek to secure our Services and transactions against unauthorised access, use, modification or misappropriation of Personal Data, information and funds. In connection with fraud and security monitoring, prevention, detection, and compliance activities for Boost and its Business Users, we receive information from service providers, third parties, and the Services we provide. We may collect information from you, and about you, from Business Users, financial parties and in some cases third parties. For example, to protect our Services, we may receive information from third parties about IP addresses that malicious actors have compromised. This Personal Data (e.g. name, address, phone number, country) helps us to confirm identities, run credit checks subject to applicable law and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by an End Customer with a Business User or Financial Partner.
• Compliance with Legal Obligations. We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas, and other legal obligations. We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is critical to this effort. For example, we may monitor patterns of payment transactions and other online signals and use those insights to reduce the risk of fraud, money laundering and other activity that is harmful to Boost, our Business Users and their End Customers.
• Minors. The Services are not directed to minors, including children under the age of 18, and we request that they do not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law. We do not sell any Personal Data of End Customers, Representatives or Visitors, including those under the age of 18.

c. Personal Data Sharing

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

• Boost Entities. We share Personal Data with other Boost affiliated entities. When we share with these entities, it is for purposes identified in this Policy.
• Service Providers or Processors. In order to provide Services to our Business Users and to communicate, market and advertise to Visitors and Representatives regarding our Services, we will rely on others to provide us services. Service providers provide a variety of critical services, such as hosting (storing and delivering), analytics to assess the speed, accuracy and/or security of our Services, identity verification, customer service, email and auditing. We authorise such service providers to use or disclose the Personal Data of our Business Users that we make available to perform services on our behalf and to comply with applicable legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United Kingdom.
• Financial Partners. We share Personal Data of Business Users and End Customers with certain Financial Partners to provide the Services to the associated Business Users and to offer certain Services in partnership with our Financial Partners.
• Others with Consent. In some cases we may not provide a service, but instead refer you to, or enable you to engage with, others to get services (e.g. professional services firms that we partner with). In these cases, we will disclose the identity of the third party and the information that will be shared with them, and seek your consent to share the information.
• Corporate Transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganisation, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy.
• Compliance and Harm Prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) to comply with rules imposed by payment method in connection with use of that payment method; (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Boost, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

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:

• Creation and management of Boost Business User accounts and Boost account credentials, including the evaluation of applications to commence or expand the use of our Services;
• Creation and management of Boost End Customer accounts;
• Accounting, auditing, and billing activities; and
• Processing of orders, payments, including fraud detection and prevention, optimising valid transactions, communications regarding such transactions, and related customer service.

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:

• Detect, monitor and prevent fraud and unauthorised payment transactions;
• Mitigate financial loss, claims, liabilities or other harm to End Customers, Business Users and Boost;
• Determine eligibility for and offer new Boost products and services;
• Respond to enquiries, send Service notices and provide customer support;
• Promote, analyse, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services;
• Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimising our digital assets;
• Analyse and advertise our Services;
• Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
• Share Personal Data with third-party service providers that provide services on our behalf and business partners which help us operate and improve our business;
• Enable network and information security throughout Boost and our Services; and
• Share Personal Data among our affiliates.

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:


• The right to request confirmation of whether Boost processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
• The right to request that Boost rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
• The right to request that Boost erase your Personal Data in certain circumstances provided by law;
• The right to request that Boost restrict the use of your Personal Data in certain circumstances, such as while Boost considers another request that you have submitted (including a request that Boost make an update to your Personal Data);
• The right to request that we export your Personal Data that we hold to another company, where technically feasible;
• Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or
• Where we process your Personal Data based on our legitimate interests, you may also have the right to object to the processing of your Personal Data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your Personal Data when you object.

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.

Contact details: info@eg.withboost.co.

Ghana

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

Registered address: 264 Haatso-Atomic Road, Haatso Supermarket Junction, Accra, Ghana.

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

Kenya

The Boost entity for all Business Users and End Customers in Kenya as outlined in this Policy is Nexon Technology Limited.

Registered address: PO Box 28164 G.P.O, Plaza Two Thousand, Mombasa Road, Nairobi, Kenya.

Contact details: info@ke.withboost.co.

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.

Contact details: info@ng.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.