BOAST CANADIAN PRIVACY POLICY

This Privacy Policy was last updated on March 21, 2022.

Protecting your privacy is really important to us. Accordingly, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of personal information in respect of the individuals with whom we interact, including those who use our Services, Website and Application (each as defined below). This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services, Website or Application.

This Privacy Policy applies to your access to and use of the applications, websites, content, products and services (collectively, the “Services”) made available to you (the individual engaging the Services, “you”, “your”) by Boast Capital LP (“Boast”) and any of its subsidiaries or affiliates (collectively, “Boast”, “we”, “us”, “our”) on or through the website at https://boastcapital.com and/or https://boast.ai, which is composed of numerous websites and webpages operated by Boast (collectively, the “Website”), whether accessed or used via personal computers, mobile devices, or otherwise, or Boast’s mobile application provided as part of the Services (the “Application”). 

Any information that we collect is subject to the privacy policy in effect at the time that personal information is collected. We may, however, modify and revise this Privacy Policy from time to time. If we make any changes to this Privacy Policy, we’ll notify you of those changes by posting them on our website or by sending you an email or other notification, and we’ll indicate when those changes will become effective. 

We strongly encourage you to refer to this Privacy Policy often for the latest information about our personal information policies and practices. If you have any questions about this Privacy Policy or don’t see your concerns addressed here, you should contact us by email at [email protected].

PRIVACY POLICY EFFECTIVE FOR CANADA  

It is Boast’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another.  This Privacy Policy covers only those activities that are subject to the provisions of federal and provincial privacy laws in Canada, as applicable.  

This Privacy Policy has a limited scope and application.  Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.  If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.  

TYPES OF PERSONAL INFORMATION WE COLLECT

The term “personal information” means information about an identifiable individual, including name, address, email address, and other information about an individual. 

For the purposes described in this Privacy Policy, we may collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

  1. Your contact information, which may include, but is not limited to: name, email address and telephone number;
  2. Third party account information, which may include, but is not limited to: your account login information (the “Third Party Account”) and other personal information that your privacy settings on the Third Party Account permit us to access;  
  3. Log data, which may include, but is not limited to: Internet Protocol (IP) address, browser type, operating system, the web page that you visited before accessing our Services, the pages or features of our Services to which you browsed and the time spent on those pages or features, search terms, the links on our Services that you clicked on and other statistics;
  4. Information sent by your mobile device: device identifier, user settings, operating system, your calendar entries and address book, including the phone numbers and email addresses of individuals contained in your address book, as well as information about your use of our Services; or
  5. Payment information, which may include, but is not limited to: credit card information and bank account information.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.  

As a general rule, Boast collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

In addition to the above, any information we collect or that you provide directly to us may be de-identified or aggregated with the information of other users in order to gain an understanding of the usage habits and preferences of our users and to assist us with the selection and adjustment of future content and features for the Services.

From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us. 

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

WHY WE COLLECT, USE, AND DISCLOSE PERSONAL INFORMATION

We may collect personal information from you for a variety of purposes, including to:

  • establish, maintain and manage our relationship with you;
  • facilitate and process the delivery of Services by us to you; 
  • enforce our Website terms of use or any other agreement between you and us;
  • review and improve the Services that we provide to you;
  • comply with your requests;
  • enable us to provide certain security and privacy safeguards;
  • deal with security, debugging and technical support issues;
  • protect us against error, fraud, theft and damage to our goods and property; and
  • comply with applicable law or regulatory requirements.

HOW WE USE PERSONAL INFORMATION

Information Related to the Services

When you elect to register for the Services, you will be required to provide us with your contact information and Third Party Account information. We use this information to (a) create your account during the registration process, (b) manage your account and (c) to help us efficiently provide the Services. Additionally, in order to provide you with the Services, we will access and store information and data from your Third Party Accounts. We don’t store passwords for your Third Party Accounts.

Our servers may automatically record your log data. We use this information to administer the Services and we analyze (and may engage third parties to analyze) this information to improve and enhance the Services by expanding their features and functionality and tailoring them to your needs and preferences.

We also use your personal information to contact you in connection with your use of the Services. We may use also use your personal information to tailor our Services to your interests and to track your compliance with our policies and terms.

Feedback, Questions and Comments

You may also provide us with feedback or a comment, question or complaint. We use this information to respond to you and may retain this information to assist you in the future. We also may use your feedback, comments, questions or complaints to monitor and improve our Services.

Surveys, Polls and Customer Research

From time to time, we may offer you the opportunity to participate in one of our surveys, polls or other customer research. The information obtained through our surveys and customer research is used in an aggregated form. We use this information to help us understand Website and Application activity and/or to enhance our Services offerings, promotions and events.

Communications

From time to time, we may also use your personal information to send you email or other communications that may be of interest to you and to tailor communications to you interests. You may opt out of any communications, other than communications necessary as part of any Services you use, by using the “Unsubscribe” mechanism or otherwise contacting us as set out in the “How to Contact Us” section below. 

Information Collected Using Cookies and other Web Technologies

Like many website owners, our Website uses automated data collection tools such as Cookies to collect certain information. “Cookies” are small text files that are placed on your hard drive by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive. Boast does not control these third party Cookies and they are also not subject to this Privacy Policy.

Our Site may also use a technology provided by third parties called “tracer tags” or “Web beacons” which are tiny graphic files embedded in a website or email that send information from your browser back to the Web beacon’s originating server. This technology allows us to understand which pages you visit on our Website and the sites you visit before and after ours and is used to help us optimize and tailor our Website for your visits to our Website. Boast does not control these third party “tracer tags” or “Web beacons” and they are also not subject to this Privacy Policy.

Contests and Promotions

From time to time, we may offer you the opportunity to enter a contest or participate in a promotion, and we may collect your name, address, phone number, email address, age, gender and other information. We use this information to administer your participation in the contest or promotion. If a contest or promotion is jointly offered or sponsored by us and one or third parties, your personal information may be shared with such third parties. By entering the contest or participating in the promotion, you consent to us providing your personal information to those third parties. We do not control how such third parties may use, disclose, secure and otherwise treat your personal information, and recommend your review their respective privacy statements and notices.

DISCLOSURE OF PERSONAL INFORMATION

For the purposes described in this Privacy Policy, we may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you. We may engage third party service providers to work with us to administer and provide the Services. These third-party services providers have access to your personal information only for the purpose of performing services on our behalf. For additional information about the manner in which our third party service providers treat your personal information, contact us by email at [email protected] Boast uses contractual or other means to provide a level of protection comparable to those set out in this Privacy Policy when information is being processed by a third party on Boast’s behalf.   

Information Shared with Third Parties

We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.

Our Site and Application may contain links to other sites that we do not own or operate. Also, links to our Site and links to download our Application may be featured on third party websites on which we advertise. The Services also integrate with third party applications and tools, including but not limited to, project management platforms, payroll providers, accounting systems, social networking websites, plug-ins and applications and other related tools (collectively, the “Third Party Applications”). We do not have any control over the linked websites and the Third Party Applications, and therefore we have no responsibility or liability for the manner in which the organizations that operate the linked websites and the Third Party Applications may collect, use, disclose, secure and otherwise treat any personal information you provide to them. The linked websites and the Third Party Applications have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully.

Information Disclosed in Connection with Business Transactions

We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Boast or as part of a corporate reorganization or stock sale or other change in corporate control.

Information Disclosed for Our Protection and the Protection of Others

We and our service providers may provide your personal information in response to a search warrant or other legally valid enquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, United States or other law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims or to prevent actual or suspected loss or harm to persons or property.

Our third party service providers (or our subsidiaries or affiliate entities) may provide certain information, technology, data, and processing services to us from time to time so that we may operate our business, provide you with our Services and otherwise for the purposes described in this Privacy Policy. As a result, your personal information may be processed by us and/or our service providers in the United States, Canada, Israel, Romania, Ukraine and India. Accordingly, YOUR PERSONAL INFORMATION MAY BE SUBJECT TO THE LAWS OF THOSE JURISDICTIONS, INCLUDING LAWS REGARDING THE DISCLOSURE OF PERSONAL INFORMATION TO GOVERNMENT AUTHORITIES IN THOSE JURISDICTIONS. 

In addition to the above, we may disclose your personal information with your consent for specific purposes that we advise you at or before the time we collect such personal information.

HOW WE SAFEGUARD PERSONAL INFORMATION

Boast endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

The security of your personal information is important to us. Please immediately advise us at [email protected].ai of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

While Boast makes good faith efforts to safeguard your personal information and to secure your data during use of the Services, no transmission of data over the Internet, wireless network, or any other public network can be guaranteed to be 100% secure. In addition, if you are visiting, using or interacting with our Services from a country other than the United States and Canada, your personal information may be transferred to, and maintained on, computers located outside of your province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Boast cannot ensure or warrant the security of any information that you transmit to us and we do not take any responsibility for any breach that may occur.

RETENTION OF PERSONAL INFORMATION

We retain personal information of users for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

YOUR CONSENT IS IMPORTANT TO US 

By using the Website, Services or Application, we assume that you consent to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

In addition, you may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us at [email protected] In some circumstances, a change in or withdrawal of consent may severely limit or even prevent our ability to provide our Services to you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to [email protected]

UPDATING YOUR PERSONAL INFORMATION

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to limited exceptions prescribed by applicable laws. You may do so directly by updating your account or by emailing us at [email protected].

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

HOW TO CONTACT US

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. If you have any questions, concerns or complaints regarding our Privacy Policy or the manner in which we or our service providers treat your personal information, please contact us by email at [email protected].

INTERPRETATION OF THIS PRIVACY POLICY

It is our policy to comply with the privacy legislation within each jurisdiction in which we operate.  Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another.  This Privacy Policy has a limited scope and application.  Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer.  This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Boast any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable laws. Should there be, in a specific case, any inconsistency between this Privacy Policy and such laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such laws.

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