PRIVACY POLICY

Dated JUNE 06, 2023

Visotsky Consulting Inc. takes confidentiality and security of information very seriously. The protection of Users' personal data is one of our key priorities. In order to respect the rights and freedoms in the field of protection of Users' Personal Data, this Policy has been developed. It explains on what basis, how and for what purposes Personal Data is processed and the possibilities of your choice in relation to these personal data. This Policy also applies to other means by which the Personal Data Operator collects information. For example, it collects information in personal conversations, telephone conversations and through non-electronic communications (that is collecting through other means than our on-line systems and real Website). Please read this Policy carefully to understand the policies and practices regarding your information (Personal Data) and how the Personal Data Operator will handle it. If you disagree with our policies and practices set out here, you may not use this Website. By accessing or using this Website, you agree to the terms of this Policy. This Policy may change from time to time. Your continued use of this Website after the Copyright Holder makes changes to the Policy is considered acceptance of these changes, so please periodically check the Policy for updates.

1. Introduction

  1. 1. This document defines out the policy regarding the protection and processing of Personal Data of Users (hereinafter referred the "Policy").
  2. 2. This Policy has been developed in accordance with the current legislation of the countries of the European Union, the United Mexican States, the United States of America.

2. The basic term used in this Policy:

Application - forms for collecting Personal data posted on the Website and intended for filling out and sending in electronic form through the Website. Applications are presented on the Website in the form of questionnaires containing questions-tips related to the Personal Data Subject;

Button - a graphic element of the Website, highlighted in color and containing an inscription in a contrasting color, indicating a programmatically related action that will be performed when you click on it;

Cookies - is a text files placed on the computer (other device) of the Personal Data Subject when he visits the Website through a web browser. You can read more about cookies https://my.bbooster.io/info/cookie-policy.html;

Personal Data Processing - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with Personal Data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data; Personal Data Operator (hereinafter referred to as the Personal Data Operator, as well as the Copyright Holder within the framework of this document) - is a legal entity that processes Personal Data, as well as determines the purposes of Personal Data Processing, the composition of Personal Data to be processed, actions (operations) performed with Personal Data Personal Data Operator - Visotsky Consulting Inc., address: 368 9th Ave 6FL New York, NY 10001);

Personal Data - any information relating to a directly or indirectly defined or defined individual (Personal Data Subject). Personal Data of the User shall also be understood to mean the information that the User provides to the Personal Data Operator when entering the Website, Platform, Personal Account, when registering and/or authorizing the Website, Platform and/or Personal Account and using the Website, Platforms, Personal Account, Service Packages, Application Forms. For more information on the composition of Personal Data see Section 7 of this Policy;

User of the information system - an employee of the Personal data operator who has been granted access to the Personal Data of the Personal data subject;

Website - a set of texts, graphic elements, design, images, program code, software, photo and video materials and other results of intellectual activity of the Copyright Holder contained on the Internet and located at: https://my.bbooster.io;

Personal Data Subject (for the purposes of this document also "User") - the natural person who has logged on to the Website and completed an Application on any of its pages;

Services - the services provided by the Personal data operator to an unlimited number of persons under the terms and conditions set out on the Website, information about which is provided on the Website.

Personal Account - is a page available only to the User who has logged in to the Website, thereby confirming his identity and leaving his Personal Data.

Platform - a resource located at https://my.bbooster.online/full30, which is an online platform for the Operator Personal Data to provide of the Services Packages of the Services to the Customer.

Customer - is means the Personal data subject who intends to purchase or has purchased the Services or the Package of Services from the Personal Data Operator.

Service Packages - a set of several Services that the Data Subject (Customer) intends to purchase or has purchased by the Personal Data Subject (Customer) from the Personal Data Operator.

Internet - is a global system of interconnected computer networks that uses a set of Internet protocols (TCP/IP) to communicate between networks and devices.

3. Principles of Personal Data Processing

  1. 3.1. When Personal Data Processing, the Personal Data Operator shall be guided by the following principles:
    • - Personal Data Processing shall be carried out with the consent of the Personal Data Subject and prior to its revocation. Consent to Personal Data Processing shall be deemed to be received by the Personal Data Operator at the time when the Personal Data Subject completes registration on the Website using the Application posted on the Website (or entering Personal Data in the Personal Account, if applicable). Registration on the Website shall be considered completed when the Subject Personal Data clicks after filling in the Application Button, which is an element of this Application, having under (right) the last question-prompt of the Application;
    • - The Personal Data Processing is limited to the achievement of specific, predetermined and legitimate goals. The Personal Data Operator shall not Process Personal Data incompatible with the purposes of Personal Data collection;
    • - The content and volume of Personal Data processed correspond to the stated purposes of processing;
    • - When Personal Data Processing by the Personal Data Operator, the accuracy of Personal Data, its sufficiency, and, if necessary, its relevance to the purposes of Personal Data Processing shall be ensured. The Personal Data Operator shall take the necessary measures to delete or clarify incomplete or inaccurate data;
    • - Personal Data processed by the Personal Data Operator is subject to destruction upon achievement of the processing goals or in case of loss of the need to achieve these goals.
  2. 3.2. The Personal Data Operator does not verify the accuracy of the Personal Data provided by the Personal Data Subject when filling out Applications on the Site, as well as the actual ownership of Personal Data to a specific Personal Data Subject who indicated them as his own when filling out Applications on the Site. The Personal Data Operator assumes that the Personal Data Subject provides Personal Data in his own interest without the intention to violate the rights and legitimate interests of third parties, the Personal Data Operator or cause them losses.
  3. 3.3. The collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction of Personal Data of Personal Data Subjects is carried out using databases located in the United States of America.

4. Information received by the Personal Data Operator

  1. 4.1. The Personal Data Operator collects, accesses and uses Personal Data of Users, technical and other information related to Users for the purposes defined in the Policy.
  2. 4.2. Technical information is not Personal Data, however, the Personal Data Operator uses Cookies that allow Users to be identified. Cookies are text files available to the Personal Data Operator for the Personal Data processing about the activity of Users on the Website, Platform, in the Personal Account, including information about which pages the User visited and the time that the User spent on the page, about the speed of mastering the Service Packages by Customers (Clients). The User can disable the use of Cookies in the browser settings. Cookies are processed in accordance with the COOKIES POLICY.
  3. 4.3. Also, technical information means information that is automatically transmitted to the Personal Data Operator during the use of the Website, Platform and/or Personal Account using the software installed on the User's device, namely:
    1. 4.3.1. Data on the User's activity on the Internet, in particular about the pages visited, the date and time of URL transitions, etc.;
    2. 4.3.2. Information about the device and browser with which the User accessed the Internet: IP-address and (if the User accesses the Website from a mobile device) the type of device and its unique identifier;
    3. 4.3.3. Data on interaction with the advertisements of the Personal Data Operator displayed outside the resource (Website), their number, frequency and depth of viewing.
  4. 4.4. The specified third-party software includes:
    • - system for determining the location (city and country) of the User maxmind.com;
    • - Google Analytics web analytics system;
    • - Roistat end-to-end business intelligence system.
  5. 4.5. The composition and conditions for collecting anonymized data using third-party software are determined directly by their copyright holders.
  6. 4.6. The Personal Data Operator processes Personal Data, technical information and other information of Customers (Clients) during the entire term of the agreement concluded between the Customer (Client) and the Personal Data Operator. With respect to other Users who are not Customers (Clients), the Personal Data Processing is carried out during the entire period of use of the Website and other resources of the Personal Data Operator.
  7. 4.7. The User understands and accepts the possibility of using the software of third parties on the Website, Platform and/or in the Personal Account of the operator, as a result of which such persons can receive and transfer the data specified in clause 4.6 Policy in an impersonal form.

5. Personal Data

  1. 5.1. Personal Data Processing of the User means recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data of the User, which do not fall under special categories, for processing of which the Personal Data Operator requires a written consent of the User.
  2. 5.2. The User agrees to the Personal Data Operator to process its Personal Data provided during registration and/or authorization and use of the Site, Platform, Personal Account, filling out the Application (Questionnaires), including the transfer of such Personal Data to third parties pursuant to the agreement between the Personal Data Operator and the Customer (Client), and for the purpose of implementing partner programs with such third parties, even when such transfer is made outside the United States of America, United Mexican States or European Union countries (the place of storage of Personal Data), to the territory of other countries (cross-border transfer).
  3. 5.3. Processing of Personal Data shall take place with or without the use of automation tools.
  4. 5.4. Personal Data Processing of the User's shall be carried out by the Personal Data Operator in the United States of America.
  5. 5.5. Personal Data of the following subjects shall be processed in the Personal Data Operator information systems:
    • - The Personal Data Operator employees;
    • - Customers (Clients) of the Personal Data Operator;
    • - Providers, contractors and other third parties providing services and/or carrying out work commissioned by the Personal Data Operator;
    • - Participants of events held by the Personal Data Operator;
    • - subscribers to the Personal Data Operator newsletter;
    • - Information partners of the Personal Data Operator, invited guests and presenters of events held by the Personal Data Operator;
    • - Hereinafter all the above-mentioned entities shall be referred to as "Users". The term "Customers (Clients)" is used when referring to Customers (Clients) only and not to all Users.
  6. 5.6 This Policy applies to all processes of collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer (dissemination, submission, access), anonymization, blocking, deletion, destruction of Personal Data, with or without the use of automated means.
  7. 5.7 Use of the Website and GetCourse Platform, the Service Packages and other resources of the Personal Data Operator means that the User expresses unqualified consent to the Policy and the specified terms of Personal Data Processing. The User may also consent to this Policy by subscribing to the Personal Data Operator's mailing list or by providing written consent to the Personal Data Operator for processing.
  8. 5.8. The Website is not intended for children under 18 (eighteen) years of age under the laws of the European Union (depending on jurisdiction) and United Mexican States, or children under 16 (sixteen) years of age under United States of America law. No one under the age specified in this article may provide the Personal Data Operator with any personal information on or through the Website.
    1. 5.8.1. The Personal Data Operator deliberately does not collect information from children under 13 years old. If you are under 13 years old, do not use or provide any information on this Site or in any of its functions or with their help, do not register on the Website (if such a feature is available), do not make any purchases through the Website (if such a feature is available), do not use any interactive or public comment features on the Website (if such features are available) or provide the Personal Data Operator with any information about yourself, including your name, address, phone number, email address or any display name. or the name of the User you can use.
    2. 5.8.2. If the Personal Data Operator learns that he has collected or received personal information from a child under thirteen (13) years of age without verification of parental consent, the Personal Data Operator will delete this information.
    3. 5.8.3. If you believe that the Personal Data Operator may have any information from or about a child under thirteen (13) years of age, please contact the Personal Data Operator at support@bbooster.online.

6. Purposes of Personal Data Processing

  1. 6.1. The information provided by the User is used by the Personal Data Operator solely for the purposes of:
    1. 6.1.1. The performance by the Personal Data Operator of its obligations to the Customer (Client) under the agreement in relation to the use of the Site, Platform, Personal Account, materials, other intellectual property in the process of providing the Services;
    2. 6.1.2. Establishing and maintaining communication with the User;
    3. 6.1.3. Sending informational and other messages to the User's email address;
    4. 6.1.4. Improving the quality of service and upgrading the Site, the Platform, the Personal Account;
    5. 6.1.5. Registering the User on the Website, the Platform, in Personal Account, and managing the User's account on the Website, the Platform and/or in Personal Account;
    6. 6.1.6. Administration of justice, in the event of a request of the authorised bodies to the Personal Data Operator;
    7. 6.1.7. Implementation of partner programs with third parties;
    8. 6.1.7. Implementation of partner programs with third parties;
    9. 6.1.9. Notifying the User about the Personal Data Operator's services and the way they are provided;
    10. 6.1.10. Analysis of the results achieved by the User in the process or as a result of the provision of services by the Personal Data Operator.
  2. 6.2. The Personal Data Operator does not check the accuracy of the Personal Data provided by the Users, the capacity of the Users.
  3. 6.3. Personal Data of the Personal Data Subject are processed for the following purposes:
    • - execution by the User of the information system of a call to the of Personal Data Subject or sending him an electronic message to clarify his intention to purchase the Services of the Personal Data Operator, information about which is presented on the Website;
    • - conclusion of an agreement with the Personal Data Subject on the provision of the Services provided by the Personal Data Operator, including invoicing for payment, sending notifications and information related to the provision of the Personal Data Operator's Services to the Personal Data Subject;
    • - processing requests and Applications of the Personal Data Subject received by the Personal Data Operator;
    • - receipt by the Personal Data Subject of newsletters on recruitment and selection of personnel;
    • - development and adjustment of the marketing policy of the Personal Data Operator, taking into account the preferences of the Personal Data Subjects, depending on their location, current position.

7. Composition of processed personal data

  1. 7.1. The Personal Data of the User processed by the Personal Data Operator (may be different in different Applications):
    • - Name, first name, patronymic;
    • - E-mail address;
    • - Contact phone number;
    • - Accounts for the exchange of messages;
    • - Links to profiles (pages) in social networks;
    • - Image (photo) of the Account;
    • - Other information provided by the User to the Operator of Personal Data through the Site, Platform, Application-Questionnaire, Personal Account and in the process of rendering Services within the Service Packages.

8. Rights of the Personal Data Operator

9. Rights of the Personal Data Subject (User)

  1. 9.1. Each User whose Personal Data is processed by the Personal Data Operator has the following rights, specified in this Section.
  2. 9.2. By posting information about itself on the Website, Platform, in the Application (Questionnaire) and in the Personal Account, the User can make it publicly available, while the User understands that the information can be indexed in search engines and accepts the associated risks of disclosing information related to personal, family and other secrets.
  3. 9.3. The User may at any time delete or change the information provided by the User by performing the necessary actions on the Website, the Platform and in the Personal Account, and in the absence of such an opportunity - by contacting the Personal Data Operator at the e-mail address: support@bbooster.online. At the same time, the User understands that the Personal Data Operator has the right to continue using such Personal Data in cases permitted on the territory of the Operator by law. Consent to receive newsletters and promotional materials may be revoked by the User at any time by sending a notification to the Personal Data Operator in the same way.
  4. 9.4. The Personal Data Subject has the right to request confirmation of the fact of processing of his Personal Data. In the case of such processing, the Personal Data Subject has the right to familiarize himself with the processed Personal Data, as well as information about the purposes of processing, the category of data processed, actions with data, data recipients and guarantees when transferring data to third parties, processing times, sources of data, availability of an exclusively automated decision-making process. The Personal Data Subject also has the right to receive a list of processed Personal Data.
  5. 9.5. In situations where the Personal Data Operator uses the Subject's consent as the basis for processing the Personal Data, the Personal Data Subject has the right to withdraw the consent given by him at any time. Each consent to the Personal Data Processing, which the Subject provides to the Personal Data Operator, provides for the procedure for its withdrawal - if the Subject wants to withdraw any of the consents given to him by the Personal Data Operator, then he can use the procedure directly provided for in such consent.
  6. 9.6. The Personal Data Subject has the right to demand correction of his Personal Data in case of detection of inaccuracies in the Personal Data that are processed by the Personal Data Operator. Taking into account the purposes of processing, the Data Subject has the right to make additions/corrections to the Personal Data, including through the provision of an additional application.
  7. 9.7. The Personal Data Subject has the right to initiate a restriction on the processing of all or part of his Personal Data if one of the following conditions applies:
    • - The accuracy of the Personal Data is disputed by the Personal Data Subject (limitation for the period necessary for the Personal Data Operator to confirm the correctness of the Personal Data); unlawful processing of Personal Data has been identified, the Data Subject objects to the deletion of his Personal Data and instead requests to restrict their use;
    • - The Personal Data Operator no longer needs the Personal Data for the purposes of processing, but it is required by the Personal Data Subject to assert and exercise legal claims and claims or in legal proceedings;
    • - The Personal Data Subject objects to the processing of his or her personal data (limitation on the period necessary for the Personal Data Operator to determine whether the legitimate grounds of the Personal Data Operator for the processing of Personal Data prevail over the grounds of the Data Subject's objection).
  8. 9.8. The Personal Data Subject has the right to request the removal of his personal data from the Personal Data Operator’s systems and/or other available material sources if one of the following conditions applies:
    • - Personal Data are no longer required for the purposes for which they were obtained;
    • - The Personal Data Subject withdraws its consent on the basis of which the processing was carried out and unless there is another legal basis for processing;
    • - The Personal Data Subject objects to the processing of his Personal Data, and if there are no legal grounds that prevail for the processing of his Personal Data;
    • - Personal Data are processed illegally;
    • - Personal Data must be destroyed in order to comply with the legal obligation in accordance with the requirements of the law;
    • - at the time of collection of Personal Data, the Personal Data Subject is a minor under the age of 16 (or another age in accordance with the current legislation of the country of the Personal Data Subject), while the Personal Data was not obtained on the basis of the consent of the legal representative to provide services to the minor using remote service channels (information society services). For more information, see Article 5.8. of this Policy.
  9. 9.9. The Personal Data Subject shall have the right to request in a structured, universal and machine-readable format a list of their Personal Data provided to the Personal Data Operator for processing, and to instruct the Personal Data Operator to transfer their Personal Data to a third party if the Personal Data Operator is technically able to do so. In this case, the Personal Data Operator shall not be liable for any further actions of the third party with the Personal Data.
  10. 9.10. The Personal Data Subject has the right to object to the processing of part or all of his Personal Data for the purposes specified when providing the Personal Data Operator with his Personal Data, except in cases where the legal grounds of the Personal Data Operator for processing prevail over the interests, rights and freedoms of the Personal Data Subject or the processing is necessary to substantiate, exercise or defend legal claims.
  11. 9.11. The Personal Data Subject has the right to request restriction of processing of his Personal Data for the purposes of marketing activities of the Personal Data Operator.
  12. 9.12. The Personal Data Subject has the right to lodge a complaint with the supervisory authority if the Personal Data Operator in any way violates his rights in the field of processing personal data.

10. Commencement of Personal Data Processing. Duration of consent to data processing

  1. 10.1 Processing of Personal Data shall commence upon receipt of the Personal Data Subject's consent to the processing of Personal Data and shall continue until the expiry of the Personal Data Subject's consent to the Processing of Personal Data or until the Personal Data Subject withdraws their consent to the Processing of Personal Data.
  2. 10.2. The validity period of the consent of the Personal Data Subject to the Personal Data Processing is indefinite from the date of receipt of such consent by the Personal Data Operator.
  3. 10.3. The consent of the Personal Data Subject to the Personal Data Processing may be withdrawn at any time on the basis of a personal statement sent (submitted) by him to the Personal Data Operator at: support@bbooster.online. Upon receipt of such an application, the processing of personal data of the Personal Data Subject is terminated immediately, and all Personal Data of the Personal Data Subject is destroyed.

11. Confidentiality of Personal Data

  1. 11.1. The operator of personal data undertakes not to disclose or distribute Personal data to third parties without the consent of the Personal Data Subject, unless the operator of personal data is required by law to disclose such data.

12. Information on the requirements for protecting Personal Data implemented by the Operator of Personal Data.

  1. 12.1. In order to protect the Personal Data of the Personal Data Subjects, the Operator of Personal Data takes the following measures:
    • - Ensures the safety of the storage media of Personal Data;
    • - Takes measures to identify and authenticate all Users of the information system (Site), as well as access objects;
    • - Determines the list of persons who need access to the Personal Data of the Personal Data Subject to perform their job duties;
    • - Appoints a responsible person for ensuring the security of Personal Data in the information system;
    • - Manages user accounts in the information system (Website) and implements measures to restrict user access rights;
    • - Applies antivirus protection to the information system of Personal Data;
    • - Organizes periodic checks of the conditions for Personal Data Processing ;
    • - Organizes training in the form of instructions for Users of the information system (Website) who have permanent or temporary access to Personal Data Subjects of personal data;

13. Limitation of Liability

  1. 13.1. The Website, the Platform and the Personal Account are not publicly available sources of Personal Data. At the same time, if the User performs certain actions, his Personal Data may become available to an indefinite circle of persons, about which the User hereby gives his consent.
  2. 13.2. The User agrees to receive newsletters and promotional materials from the Personal Data Operator, or from other persons on behalf of the Personal Data Operator, to the e-mail address and contact phone number specified by the User when registering on the Website, Platform and / or in the Personal Account or when filling out the Application.
  3. 13.3. The Personal Data Operator is not responsible for the use of the User's (Subject's) Personal Data by third parties with whom the User interacts as part of the use of the Website, Platform and/or Personal Account.

14. Measures taken to protect the Personal Data provided by the User and guarantees of the Personal Data Operator

  1. 14.1. The Personal Data Operator takes the necessary and sufficient legal, organizational and technical measures to protect the Personal Data provided by Users from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties with it, by restricting access to such information of other users of the Website and the Platform, employees and partners of the Operator of Personal Data of third parties (for except for providing the Operator Personal Data information necessary for the Operator Personal Data to fulfill obligations to the User and the requirements of the legislation in force on the territory), as well as imposing sanctions on such persons for violating the confidentiality regime in relation to such data.
  2. 14.2. The Personal Data Operator guarantees that the information provided by Users (including Personal Data) is not combined with statistical data of third parties, while the Personal Data Operator keeps its internal statistics using Personal Data, is not provided to third parties and is not disclosed, except as provided in this Policy.
  3. 14.3. The Personal Data Operator does not sell or transfer information about Users separately. Such information can only be transferred in case of partial or complete reorganization of the Personal Data Operator.
  4. 14.4. The Personal Data Operator takes technical and organizational measures to provide the User with the opportunity to access the Personal Data provided by him, edit such information.
  5. 14.5. In case of detection of illegal Personal Data Processing carried out by the Personal Data Operator or a person acting on behalf of the Personal Data Operator, the Personal Data Operator shall cease illegal processing of Personal Data or ensure termination of illegal processing of Personal Data by the person acting on behalf of the Personal Data Operator within 3 (three) business days from the date of such detection. If it is impossible to ensure the validity of personal data processing, the Personal Data Operator shall destroy such personal data or ensure its destruction within ten (10) business days from the date of detection of illegal Personal Data Processing.

15. Cookie Notice

  1. 15.1. The Website uses Cookies. Cookies are not Personal Data because they are not personal information.
  2. 15.2. The IP address, domain name, browser type and operating system used on the Personal Data Subject's device, the date and time of the Personal Data Subject's visit to the Website is collected and stored by the Personal Data Operator in depersonalized form to maintain traffic statistics. The collection of this information allows the Personal Data Operator to timely identify and eliminate technical problems in the work of the Website.

16. California (USA) Resident Policy

  1. 16.1. Pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), the Personal Data Operator provides the following information about the categories of Personal Data it collects, uses, and discloses about California residents and their rights. The CCPA applies to these Terms. The Personal Data Operator collects and has collected during the preceding 12 months the following categories of Personal Data as set forth in the CCPA:
    • - Category A. Identifiers such as name, contact information, IP address, and other online identifiers;
    • - Category B. Personal information as defined in the California Customer Records Act, such as name, contact information, medical information, insurance information, education information, employment information, and government-issued identification numbers;
    • - Category C. Characteristics of protected classifications under California or U.S. federal law, such as age, sex, disability status, primary language, race, citizenship, and marital status, to the extent required or permitted by applicable law;
    • - Category D. Commercial information, such as transaction information and purchase history;
    • - Category E. Information about Internet activity or network activity, such as browsing history and interaction with the Website;
    • - Category F. Audio, electronic, visual and similar information, such as photographs or audio and video recordings, created in connection with the Personal Data Operator business activities;
    • - Category G. Professional or employment-related information, such as work history and previous employer, information relating to references, details of qualifications, skills and experience, human resources data, and data required for benefits and related administrative services; and
    • - Category H. Inferences drawn from any of the Personal Data listed above to create a profile, such as a person's preferences and abilities.
    You can find information about the sources of these categories of Personal Data in Sections 4 and 5 of this Policy.
  2. 16.2. In certain cases, the actions of the Personal Data Operator may qualify as a «sale» (as defined by the CCPA) of Personal Data (personal information) of Category A, B, C, E, F, H. «Sale» under the CCPA broadly includes any disclosure of Personal Data (personal information) to a third party that is not a service provider or is not carried out at the direction of an individual (User). In addition, sharing information obtained from publicly available government documents does not qualify as a «sale» of Personal Data (Personal Information) under the CCPA. For limited services, the Personal Data Operator may transfer the Personal Data of the Data Subject (in particular, name, surname, photographs, etc.) to its subsidiaries or contractors. For information on the purposes of collecting and "selling" the above categories of Personal Data, see Section 6 of this Policy.
  3. 16.3. The Personal Data Operator has disclosed the following categories of Personal Data listed in the CCPA to third parties for our operational business purposes during the preceding 12 months:
    • - Category A. Identifiers, such as name, contact information, IP address, and other online identifiers;
    • - Category B. Personal information, as defined in the California customer records law, such as name, contact information, education information, medical information, insurance information, employment information, and government-issued ID numbers;
    • - Category C. Characteristics of protected classifications under California or federal law, such as age, sex, disability status, primary language, race, citizenship, and marital status, to the extent required or permitted by applicable law;
    • - Category D. Commercial information, such as transaction information and purchase history;
    • - Category E. Internet or network activity information, such as browsing history and interactions with our website;
    • - Category F. Audio, electronic, visual and similar information, such as call and video recordings;
    • - Category G. Professional or employment-related information, such as work history and prior employer, information relating to references, details of qualifications, skills and experience, human resources data, and data necessary for benefits and related administration services; and
    • - Category H. Inferences drawn from any of the Personal Data listed above to create a profile about, for example, an individual’s preferences and abilities.
      • Information about third parties to whom these categories of Personal Data are transferred can be found in Section 8 of this Policy.
  4. 16.4. If the Personal Data Subject is a resident of the U.S. state of California, it may request that the Personal Data Operator disclose to the Personal Data Subject the following information 12 months prior to the request:
    • 16.4.1. Categories of Personal Data (personal information) that the Personal Data Operator has collected about the Personal Data Subject and categories of sources from which the Personal Data Operator has collected such Personal Data (personal information).
    • 16.4.2. Specific parts of Personal Data (personal information) that the Personal Data Operator has collected about the Personal Data Subject, business or commercial purpose of collecting (if applicable) Personal Data (personal information) about the User.
    • 16.4.3. Categories of Personal Data on the Personal Data Subject that the Personal Data Operator has transferred or otherwise disclosed, as well as categories of third parties to which the Personal Data Operator has provided or to which the Personal Data Operator has provided such Personal Data (if applicable).
    • 16.4.4. Erasure the Personal Data (personal information) that the Personal Data Operator has received about the Personal Data Subject.
  5. 16.5. Stop "selling" Personal Data. The CCPA gives California residents the right to opt out of the "sale" of their Personal Data (personal information) to "third parties" and the "distribution" of their personal information. information in the context of behavioral advertising and limit the use of "sensitive personal information" (as defined in the CCPA) about the User. This may include the disclosure by the Personal Data Operator of information about the Personal Data Subject to Customers (Clients), contractors, etc. to provide certain services. The right to opt-out has certain exceptions, for example, it will not affect the exchange of information between the Personal Data Operator and the providers of the services it needs, and the Personal Data Subject's request for opt-out will not affect the Personal Data Operator business activities where there is no "sale" of Personal Data (personal information). If the Personal Data Subject is a resident of the State of California, USA, he or she may exercise these rights by sending a notice to: support@bbooster.online. By submitting a notification, the Personal Data Subject must confirm that he is exercising his right to refuse the sale or exchange of his Personal Data (personal information) or to restrict the use of Personal Data (sensitive personal information).
  6. 16.6. Delete Personal Data (personal information) that the Personal Data Operator has received from the Personal Data Subject. A request for disclosure, removal or refusal to sell shall be sent to the address specified in para. 16.5 of the Policy. After receiving the request, the Personal Data Operator will verify the request, for which the Personal Data Subject must: (1) confirm that he controls the e-mail address associated with his Personal Data (personal information); and (2) to confirm that the Personal Data Subject does indeed interact with the Personal Data Operator. If necessary, the Personal Data Operator may require additional information to verify such a request. If the Personal Data Subject makes a request on someone’s behalf, it must also provide a signed confirmation of authorization and, if necessary, the Personal Data Operator may request additional information.
  7. 16.7. The Personal Data Operator responds to such a request in accordance with the CCPA, but not more than 45 days, and if necessary, the processing of such a request can be increased to 90 days.
  8. 16.8. A Personal Data Subject has the right to freedom from unlawful discrimination in the exercise of his rights under the CCPA.
  9. 16.9. CalOPPA (California Online Privacy Protection Act) is a statute that requires the Personal Data Operator collecting Personal Data of Users from the U.S. state of California to publish this Policy on its Website. The personal data operator does not use or support the "Do Not Track" ("DNT") function. Do Not Track is a setting that the Personal Data Subject can set in their web browser to inform websites that they do not want to be tracked. DNT is a concept promoted by some regulators and industry groups to develop and implement a mechanism that will allow internet users to monitor the tracking of their online activity on websites. Currently, various browsers (including Internet Safari, Explorer, Firefox) offer the DNT option, which allows the User to set a preference in the browser so that his actions on the Internet are not monitored.
  10. 16.10. The provisions of this Section 16 of the Policy shall apply only to Personal Data Subjects - citizens of the State of California, United States of America and shall prevail over the provisions of other articles of this Policy (and replace them) in case of conflict.

17. Policy on Personal Data Subjects of the Countries of the European Union (European Economic Area)

18. Policy on Personal Data Subjects of the Countries of the United Mexican States

  1. 18.1. Visotsky Consulting inc, address: 368 9th Ave 6FL New York, NY, Postal Code: 10001, responsible for processing Personal Data that are subject to the Federal Act «Protection of Personal Data Held by Individuals» (jointly named «Law»).
  2. 18.2. The Personal Data Operator uses the Personal Data of the Personal Data Subjects for the purposes set out in Section 6 of the Regulation. All these purposes, except for marketing purposes, are necessary to maintain the relationship between the Personal Data Operatorr and the Personal Data Subject. If the Personal Data Subject intends to opt out of receiving marketing communications from the Personal Data Operator, they must send an email to: support@bbooster.online for the Personal Data Subject's contact information to be removed from the Personal Data Operator's marketing databases.
  3. 18.3. The Personal Data Operator transfers Personal Data to third parties in Mexico and abroad, as described in Sections 4, 5 and 8 of the Policy. Such transfer does not require the consent of the Personal Data Subject, except for the transfer of Personal Data in the event of a merger, consolidation or sale of the assets of the Personal Data Operator or affiliate. The Personal Data Operator will transfer Personal Data in the event of a merger, consolidation or sale of assets. The use of the Services/Service Packages by the Personal Data Subject means that he accepts this transfer. If the Personal Data Subject does not agree with such transfer of Personal Data, he must send an e-mail to the Personal Data Operator at support@bbooster.online.
  4. 18.4. ARCO rights. According to the Law, the Personal Data Subject has the right to exercise his ARCO Rights by contacting the Personal Data Operator at support@bbooster.online. ARCO rights include:
    1. 18.4.1. Right to access: The Personal Data Subject has the right to request information on what Personal Data about him is stored with the Personal Data Operator and for what purposes they are processed.
    2. 18.4.2. Right to rectification. The Personal Data Subject has the right to request correction of his Personal Data if they are outdated, inaccurate, incorrect or incomplete.
    3. 18.4.3. Right to erasure. The Data Subject has the right to request the erasure of his Personal Data from the Personal Data Operator's databases if he considers that the Personal Data is not being used in accordance with the principles, duties and obligations set out in the Law. If the Personal Data Subject's request for erasure is granted, the Personal Data Subject's ability to use the Services/Service Packages, the Website as well as the Platform may be restricted. WARNING To ensure consistency of the Personal Data Operator's Services/Service Packages to the Personal Data Subject, the Personal Data Operator maintains database backup systems. The Personal Data Operator may need to retain the Personal Data Subject's Personal Data, e.g. email address, in order to interact with and exercise the Personal Data Subject's ARCO rights.
    4. 18.4.4. Right of objection. The Personal Data Subject has the right to object to the Personal Data Operator’s use of Personal Data for certain purposes. If the relevant request of the Personal Data Subject for objection is satisfied by the Personal Data Operator, the Personal Data Subject’s ability to use the Services/Service Packages, the Website and the Platform may be restricted.
    5. 18.5. To exercise ARCO rights, the Personal Data Subject sending an email to the Personal Data Operator at: support@booster.online marked "Exercise of ARCO Rights." In the request, the Personal Data Subject specifies what rights ARCO intends to exercise and provide confirmation of its identity. In the request, the Personal Data Subject shall indicate:
      • - name and photocopy of the official ID, a document confirming the authority of the person - representative;
      • - the e-mail address that the Personal Data Subject used to register in the Personal Account on the Website or on the Platform, to fill out the Application;
      • - user ID for the Services/Packages provided by the Personal Data Operator, if applicable;
      • - a clear and accurate description of the Personal Data in respect of which the Personal Data Subject intends to exercise his rights ARCO.
    6. 18.6. In the event that the Personal Data Operator requires additional information from the Personal Data Subject in accordance with this Section 18 of the Policy, to confirm his identity or understand which information the Personal Data Subject intends to access, rectification (correct), erasure or object, the Personal Data Operator has the right to request the specified documents from the Personal Data Subject and provide them within 5 days after receiving such request. The Personal Data Subject shall be provided with a period of 10 days to respond to such request of the Personal Data Operator starting from the day following the day of its receipt. If the Personal Data Subject does not respond during this period, his request will be considered not received. The Personal Data Operator shall provide a response by e-mail within 20 days of receipt of the Personal Data Subject's request or additional information, if applicable.The Personal Data Operator will fulfill the Personal Data Subject's request within 15 days after receipt of all necessary documents.
    7. 18.7 Right to revoke consent to processing: The Personal Data Subject has the right to revoke their consent to the Processing of Personal Data if the Personal Data Operator processes the Personal Data on the basis of consent. In order to do so, the Personal Data Subject sends a request by e-mail with the same information as for requests for ARCO rights (clause 18.5 of the Regulation) to: support@bbooster.online, marked "Revocation of consent", stating their request briefly and clearly. If the Personal Data Subject revoke their consent to the Processing of Personal Data, their ability to use the Services/Packages of the Services, use of myAlpari, the Website or the Platform may be restricted.
    8. 18.8 The Personal Data Operator shall respond to requests from the Personal Data Subject in accordance with applicable United Mexican law and the Law. The Personal Data Operator shall have the right to refuse to process requests from the Personal Data Subject if such requests may endanger the confidentiality of others or endanger the intellectual property of the rights Copyright Holder.
    9. 18.9. The provisions of this Section 18 of the Policy shall apply only to Personal Data Subjects - citizens of the European Mexican Union States and shall prevail over the provisions of other articles of this Policy (and replace them) in case of conflict.

19. Final provisions

  1. 19.1. The Personal Data Operator reserves the right to make changes to the Policy. The User is obliged to independently familiarize himself with the current text of the Policy each time he accesses the Services (Service Packages), the Website, the Platform and/or the Personal Account.
  2. 19.2. The new version of the Policy comes into force from the moment it is posted on the Website. Continued use of the Services (Service Packages), the Website, the Platform and/or the Personal Account after the publication of the new version of the Policy means full acceptance of the Policy and its terms by the User.
  3. 19.3. In case of disagreement with the Policy, the User shall not continue to use the Services (Service Packages), the Website, the Platform and the Personal Account.
  4. 19.4. Contact Information: Personal Data Operator - Visotsky Consulting inc, 368 9th Ave 6FL New York, NY 10001)

    Email: support@bbooster.online.

    Phone: +1 (646) 878-60-47.

20. Exclusion of contradictions

  1. 20.1 Where the agreement between the Personal Data Operator and the Customer (Client) contains provisions on the use of the Customer's (Client's) Personal Data, the provisions of the Policy and the agreement shall apply to the extent not inconsistent with the Policy.