End user privacy policy

BOON

END USER PRIVACY POLICY

Current as of June 16 2020

BOON ONLINE LIMITED (“we”, “us”, “our”, “BOON”) are committed to protecting and respecting your privacy.

This policy applies to the users (“Users”, “End Users”) of our personalisation services (“Services”), such as BOON Spotlight, which are supplied to the individuals or entities who enter into a subscription agreement with us (“Customers”).

This end-user privacy policy (“Privacy Policy”) and any other documents referred to herein, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our Services, you are accepting and consenting to the practices described in this Privacy Policy.

DATA PROCESSOR

For the purposes of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, (“GDPR”), the Data Protection Act 2018 and any applicable national implementing laws, regulations and secondary legislation relating to the processing of personal data (together “Data Protection Law”), the data controller is the Customer who subscribes to the Services. BOON acts as a data processor, performing specified processing as set out in our Data Processing Agreement with the Customer.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following information about you:

Information you give us. You may give us the following information when you use our Services or when you report a problem with our Services.

Information we collect about you. If you interact with our Services, we automatically collect the following information; During the usage of our Services we may automatically collect the following information using common information-gathering tools, such as cookies, web beacons, pixels, and similar technologies:

Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected in our Services.

COOKIES

We use cookies on our in our Services to distinguish you from other users of our Services. This helps us to provide you with a good experience when you use our Services and also allows us to improve them.

What are cookies?

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the operators of the Services. Cookies can be “persistent” or “session” cookies.

We only use session cookies in our solution.

Session Cookies

A session cookie allows the Services to link your actions during a browser session. We use session cookies to enable certain features of the Services, to better understand how you interact with the Customers website and gather feedback which we use to improve the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the website and then close your browser. We also utilise similar technologies such as “Session storage”, which is only maintained for the duration of a browser session.

Which cookies we use and why

The table below explains the cookies we use and why we use each of them.

Cookie Type Purpose Duration
boon-spotlight-session Session storage This is a unique identifier which allows us to differentiate between users of the Services and is essential to their operation. It allows us to attribute responses to, make recommendations for and collect feedback from the users of our Services. It is set on the Customer’s website domain, which means it is only accessible when using that site. Session
boon-spotlight-questions Session storage Contains cached question information and state, giving an improved experience when using the Services. Session
boon-spotlight-submit-time Session storage Contains a timestamp of when recommendations were requested, allowing detection of when new recommendations are required. Session
boon-spotlight-recommendations Session storage Contains cached item recommendations and the session ID with which they are associated, giving an improved experience when using the Services. Session
boon-spotlight-session Session cookie This cookie is used to track user interactions, including purchases, made when using the Services. It is set on the Customer’s website domain, which means it is only accessible when using that site. Session

You can set up your browser options, to stop your computer accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, the Services may not fully function or may not function at all.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

USES MADE OF THE INFORMATION

We use information held about you in the following ways.

Information you give to us. We will use this information:

Information we collect about you. We will use this information:

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We will not sell or rent your personal data to anyone.

DISCLOSURE OF YOUR INFORMATION

Information we share with third parties. We may share your information with selected third parties including:

Information we disclose to third parties. We may disclose your personal data to third parties:

WHERE WE STORE YOUR PERSONAL DATA

Our Services are global and your information (including personal data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer your information to countries outside of your country of residence, which may have data protection rules that are different from those of your country of residence.

The personal data that we collect from you may therefore be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) or the UK. It may also be processed by staff operating outside the EEA or UK who work for us or for one of our suppliers or partners. Such staff or subcontractors may be engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing outside of the EEA or the UK.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In particular, this means that your personal data will only be transferred to a country that provides an adequate level of protection (for example, where the European Commission has determined that a country provides an adequate level of protection) or where the recipient is bound by standard contractual clauses according to conditions provided by the European Commission (“Standard Contractual Clauses”).

Our Services are accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Services from outside the EEA or the UK. This means that where you chose to post your data within the Services, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the EEA or the UK may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.

PROTECTION OF YOUR INFORMATION

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your personal data, we cannot guarantee the security of your data transmitted to our Services. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

YOUR RIGHTS

BOON has no direct relationship with End Users. Even where the data is input into an interface which we may provide as part of our Services, unless we are the owner of the website on which the Services are employed, we have no control over the data which is collected. Accordingly, we rely upon our Customers to comply with the underlying legal requirements for subject access requests. If an End User requests that we access, correct, update, or delete their information, or no longer wishes to be contacted by one of our Customers that use our Services, we will direct that End User to contact the Customer website(s) with which they interacted directly. Our Customers are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their users.

DATA RETENTION

We retain personal data for as long as necessary for the relevant activity for which it was provided or collected. This will be for as long as we provide access to the Services to you, your account with us remains open or any period set out in any relevant contract you have with us. However, we may keep some data after your account is closed or you cease using the Services for the purposes set out below.

After you have closed your account or ceased using the Services, we usually delete personal data, however we may retain personal data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our Terms and Conditions, or fulfil your request to “unsubscribe” from further messages from us.

We will retain de-personalised information after your account has been closed.

Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from the Services. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.

COMPLAINTS

If you have any complaints about our use of your personal data please contact us as set out at the end of this Privacy Policy or contact your data local protection supervisory authority:

*From the 01/01/2021: For all individuals located in the EU, your local data protection supervisory authority in the country in which you are located.

AGE OF USERS

The Services are not intended for and shall not be used by anyone under the age where parental consent is required in the jurisdiction in which you are located.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

This Privacy Policy was last updated on June 16 2020 and this version replaces any other Privacy Policy previously applicable from this date.

CONTACT

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to us by email at: [email protected]