Privacy 

Last updated May 8, 2022

The Boonly (“Company,” “we,” “us,” or “our ”) is committed to protecting your personal information and your right to privacy.

If you have any questions or concerns about this privacy notice, please contact us at [email protected]

We value and respect the privacy of the parties visiting our website (the “Website”) and those who agree to use our services (the “Services”). Services in this privacy notice refers to our Website and our newsletters (the “Newsletters”)

This privacy notice explains what information we collect, how we use it, how we disclose it and what rights you have in relation to it.

By using our Services, you agree that we collect and use your information in accordance with this privacy notice.

This privacy notice applies to all information collected through our Services, as well as, any related services, marketing, events or sales.

1. What Information Do We Collect?

Personal Information Provided by You

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on our Services or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include, but is not limited to:

  • Email address;

  • First name and last name

  • Mailing address

  • Usage data

All information that you provide to us must be true, accurate and complete, and you must notify us of any changes to your personal information.

We don’t process sensitive information.

Information Automatically Collected

We automatically collect certain information when you visit and use our Services. This information may include, but is not limited to, device and usage information such as: browser and device characteristics;  your IP address; operating system; language preferences; referring URLs; device name;  country;  location;  information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes

2. Cookies and Similar Tracking Technologies 

We may use cookies and similar technologies (beacons, tags, and scripts) when you use the Service to track the activity on the Services and store certain information. We use them to collect and track information and to improve and analyze the Services.

Cookies: are small data files that are placed on your computer’s hard drive or mobile device when you visit a website. Cookies hold information that may be accessible by the party that places the cookie, which is either the website owner (first-party cookie) or a third party (third-party cookies). Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites

You  have control over cookies, and can refuse the use of cookies by choosing the appropriate setting on your browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable or delete existing cookies. However, by not accepting or deleting the use of cookies, you may not be able to use our Services. Also, you can exercise your cookie rights by setting your preferences (select which categories of cookies you accept or reject) in the Cookie Consent Manager. Please note that essential cookies cannot be rejected as they are strictly necessary to provide you with services. The Cookie Consent Manager can be found in the notification banner and on our website.

Web Beacons: certain sections of our Service may contain small electronic files known as web beacons (also known as pixel tags, clear gifs, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics and reporting.

Cookies can be session cookies and persistent cookies. Session cookies are deleted as soon as you close your web browser. Persistent cookies remain on your computer or mobile device when you go offline. We use both session and persistent cookies.

Essential cookies are session cookies that are essential to provide you with services on the Website and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. For example, they are important for user authentication and prevention of  fraudulent uses of user accounts.

Functionality cookies are persistent cookies that allow us to remember choices you make when you use the Service. They are used to improve our Services and their functionalities. For example, to remember your login details or language preference. Also, the purpose of these cookies is to provide you with a more personalized experience and to avoid you having to re-enter your preferences every time you use the Services.

Notice acceptance cookies are persistent cookies that identify if users have accepted the use of cookies on the Website.

Analytics and customization cookies are persistent cookies that collect information that is used either in aggregate form to help us understand how our Services are being used or how we can  customize our Services for you.

3. How Do We Use Your Information?

When you provide your information, we use it for the following purposes:

  • To provide, maintain and improve our Services.

  • To manage your account so that you have access to all our Services.

  • To contact you in regard to updates, changes in our Services, to respond to your requests or enquiries.

  • To track, monitor and analyze use of our Services so that we can improve our Services.

  • For the performance of a contract, meaning to fulfill the terms of a contract we have with you.

  • For business transfer, which means to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which your information is among the assets transferred.

  • To provide you special offers and general information about other products, services and events which we offer that are similar to those that you have already inquired about unless you have opted not to receive such information.

  • To protect our Services, meaning to keep our Services safe and secure.

  • To respond to legal requests and prevent harm.

4. When and with Whom Do We Share Your Personal Information?

We may need to share your personal information in the following situations:

  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

  • With Third-Party Service Providers: We may share your personal information with service providers. They include, but are not limited to: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Service to allow them to collect data on our behalf about how you interact with our Services over time. We do not share, sell, rent or trade any of your information with third parties for their promotional purposes. Service providers have access to your information only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.

  • With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

We do not sell, rent or trade your personal information.

5. Data Disclosure 

We may disclose your data in case of business transfer, law enforcement (if requested by public authorities), or to comply with other legal requirements that include but are not limited to: protect rights and assets of the Company; protect the safety of our users; investigate possible wrongdoing in connection with the Service.

6. Is Your Information Transferred Internationally?

We may transfer, store and process your information in countries other than your own.

We are a US-based company and your information might be transferred, stored and processed by us in the United States and in any other places where the parties involved in the processing are located. Your consent to this policy notice followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy notice and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data.

Data transfers outside the EEA

If you are located in the European Economic Area (EEA), please note that the laws in countries where your data might be transferred may not offer an adequate level of data protection. In particular, personal data may be transferred to the United States.

When we transfer your personal data outside the EEA, we will protect your personal data as described in this privacy notice and in accordance with applicable law, such as by entering into the European Commission’s Standard Contractual Clauses for the transfer of personal data to a processor located outside of the European Union.

7. How Long Do We Keep Your Information? 

We will retain your personal information only for as long as is necessary for the purposes set out in this privacy notice and to comply with our legal obligations. No purpose in this notice will require us to keep your personal information after termination of your account.

8. Security of Your Personal Information 

The security of your information is important to us. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information.

9. GDPR Privacy

This section applies to you if you are located in the EU or UK.

Legal Basis for Processing Personal Information under GDPR

We may process personal information under the following conditions:

  • Consent: you have given us specific consent to use your personal information for one or more specific purposes.

  • Performance of a contract: provision of personal information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.

  • Legal obligations: processing personal information is necessary for compliance with our legal obligation as a company.

  • Vital interests: processing personal information is necessary in order to protect your vital interests or vital interests of a third party.

  • Public interests: processing personal information is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

  • Legitimate interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

We will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

We undertake to respect the confidentiality of your personal information and to guarantee you can exercise your rights. You have the right under this privacy notice, and by law, to:

  • Request access to your personal information. The right to access, update or delete the information we have about you. Whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us for help.  This also enables you to receive a copy of the personal information we have about you.

  • Request correction of the personal information that we have about you. You have the right to have any incomplete or inaccurate information we have about you corrected.

  • Object to processing of your personal information. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal information on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

  • Request deletion of your personal information. You have the right to ask us to delete or remove personal information when there is no good reason for us to continue processing it.

  • Request the transfer of your personal information. We will provide to you, or to a third-party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw your consent. You have the right to withdraw your consent on using your personal information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us at [email protected]

Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will respond to you as soon as possible. You have the right to complain to a data protection authority about our collection and use of your personal information.

10. CCPA Privacy

This privacy notice section applies solely to all users, visitors, and others who reside in the State of California and this section supplements other information contained in this privacy notice.

The California Consumer Privacy Act (CCPA) gives California residents certain rights with regards to their personal information as collected by companies.

Your Rights under the CCPA

If you are a resident of California, you have the following rights:

  • The right to notice. You have the right to be notified what personal information we collect and how we use it.

  • The right to request. You have the right to request that the Company disclose to you  information on our collection, use, disclosure for business purposes, sale and share of personal information. After receiving and confirming your request, we will disclose to You: The categories of personal information we collected about you; The categories of sources for the personal information we collected about you; Our business or commercial purpose for collecting or selling that personal information; The categories of third parties with whom we share your personal information; The specific pieces of personal information we collected about you. If we sold your personal information (note that we do not sell your personal information)  or disclosed your personal information for a business purpose, we will disclose to you: The categories of personal information categories sold; The categories of personal information categories disclosed.

  • The right to say no to the sale of personal information (opt-out). You have the right to direct us to not sell your personal information. This does not apply here because we do not sell your personal information.

  • The right to delete personal information. You have the right to request the deletion of your personal information, subject to certain exceptions. After receiving and confirming your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to: Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; Debug products to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; Comply with a legal obligation; Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by: Denying goods or services to you; Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; Providing a different level or quality of goods or services to you; Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise your rights under the CCPA, you can contact Us:

By email: [email protected]

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. Your request to us must: Provide sufficient information that allows us to verify you are the person about whom we collected personal information or an authorized representative; Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with the required information if we cannot:

verify your identity or authority to make the request and confirm that the personal information relates to you

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. For data portability requests, We will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Services do not respond to Do Not Track signals. However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you would like to request more information under the California Shine the Light law, you can contact us at: [email protected]

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such information, you can contact us using the contact information provided below, and include the email address associated with your account. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

11. Unsubscribe from Our Newsletters

If you no longer wish to receive our Newsletters to your email, you may click the unsubscribe link located at the bottom of each email message received and/or contact us at [email protected] and we will immediately remove you from our email list.

12. Children and Privacy 

People under 18 are not permitted to use our services on their own. We do not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services. If you believe that a child has provided us with personal information, please contact us at [email protected]

13. Updates to This Privacy Notice 

We will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. Contact Us 

If you have questions about this policy, or about the site, please contact us at: [email protected]

We’ll make every effort to resolve your concerns.