Privacy Policy

Boost Capital Privacy Policy

Boost Capital (“Boost”) takes your privacy very seriously. This Privacy Policy explains what personal information we collect, why we collect it, with whom we share it, and how you (the user of the Service) can prevent us from sharing certain information with certain parties.  

The use of Boost services is governed by this privacy policy.  By using our App or communicating with us, you agree to these terms.

SECTION 1. SCOPE OF POLICY AND TERMS

This Privacy Policy applies to your use of:

1. Conversations with Boost and its staff and contractors, including but not limited to conversations conducted through Facebook Messenger.

2. Boost mobile application software (“App”) available on our site, or hosted on Google Play or the App Store (“App Site”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

3. Any of the services accessible through the App which are available on the App Site or other sites of ours (“Services Sites”).

4. Data related to your loan(s) and the disbursement or repayment of the loan(s).

Terms used in this Privacy Policy shall have the following meanings:

“Authorities” includes any judicial, administrative, public or regulatory body, any government, any Tax Authority, securities or futures exchange, court, central bank or law enforcement body, or any of their agents with jurisdiction over Boost.

“Compliance Obligations” means obligations of Boost to comply with: (a) Laws or international guidance and internal policies or procedures, (b) any demand from Authorities or reporting, disclosure or other obligations under Laws, and (c) Laws requiring us to verify the identity of our customers.

“Customer” or “User” means any individual to which Boost provides its products or services.

“Customer Information” means your Personal Data, confidential information, and/or Tax Information, including relevant information about you, your transactions, your use of our products and services, and your relationships with Boost.

“Financial Crime” means money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions, and/or any acts or attempts to circumvent or violate any Laws relating to these matters.

“Laws” include any local or foreign law, regulation, judgment or court order, voluntary code, sanctions regime, an agreement between any member of Boost and an Authority, or agreement or treaty between Authorities and applicable to Boost.

“Personal Data” or “Personal Information” refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

“Sensitive Personal Information” refers to Personal Information (1) about an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; (2) about an individual’s health, education, genetic or sexual life, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings; (3) issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns.

“Services” includes maintaining the App available on our site OR hosted on the App Site, once you have downloaded or streamed a copy of the App onto your Device.

“Tax Authorities” means your country of residence or foreign tax, revenue or monetary authorities.

“Tax Information” means documentation or information about your tax status.

“We”, “Our” and “Us” refer to Boost.

SECTION 2. INFORMATION WE COLLECT

We may collect, use, and share Customer Information. Customer Information may be requested by us or on our behalf or that of our partners, and may be collected from you directly, from a person acting on your behalf, from other sources (including from publicly available information), and it may be generated or combined with other information available to us.

We may collect the following information about you, which may include non-public Personal Information:

i. Information you give us about you (Submitted information):

This may include information:

  • provided by filling in forms in the App or on the App Site (together Our Sites);
  • provided by corresponding with us (for example, by e-mail or chat);
  • provided by registering to use the App Site, downloading or registering the App, subscribing to any of our Services (such as applying for a loan), searching for an app or Service, sharing data via the App’s social media functions, entering a competition, promotion or survey, and reporting a problem with the App, our Services, our App Site or any of Our Service Sites.

This information may include your name, address, e-mail address and phone number, the Device’s phone number, SIM card details, age, username, password and other registration information, financial and credit information (including your mobile money account details, bank account details, and bank verification number, where applicable), personal description and photograph.

ii. Information we collect about you and your device.

Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:

  • technical information, including the type of mobile device you use, unique device identifiers (for example, your Device’s IMEI or serial number), information about the SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information);
  • information stored on your Device, including contact lists, call logs, SMS logs, Facebook friends, contact lists from other social media accounts, photos, videos or other digital content (Content Information);
  • data from your use of any other third-party application on the Device or the Service Sites; and
  • details of your use of any of our Apps or your visits to any of Our Service Sites; including, but not limited to, traffic data, location data, weblogs and other communication data (Log Information).

iii. Location information.

We may also use GPS technology OR other location services to determine your current location. You can withdraw your consent to our collection, processing or use of this information at any time by logging out and uninstalling the App from your Device.

i
v. Unique application numbers and cookies.

When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

We and our third-party service providers, including our marketing partners and analytics providers, may use mobile tracking technologies and/or website cookies to distinguish you from other users of the App, App Site or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and Our Sites.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include your internet protocol (IP) address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. From time to time, we may combine this automatically collected data to other information we collect about you for reasons such as analysis, security, content generation or marketing.

SECTION 2A. COOKIES AND GOOGLE ANALYTICS

We may use cookies and other technologies or methods of web and mobile analysis (e.g., Pixels) to gather, store, and track certain information related with your access to and activity through the Services Sites, including when you visit our website.

A “cookie” is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services Sites quicker, easier and smoother.

We may use the following types of cookies:

  • Session Cookies
     which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.
  • Persistent Cookies
     which are saved on your device for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to identify who you are for repeated visits (for instance, to allow us to store your preferences for the next sign-in).
  • Third-Party Cookies
     which are set by other online services that run content on the page you view on your browser (for example, by third-party advertising companies who monitor and analyze our website access).

You may remove the cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Services Sites may not operate properly and your online experience may be limited.

We may also use a tool called Google Analytics to collect information about your use of the Services Sites. Google Analytics collects information such as how often users access the Services Sites, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Services Sites. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the 

Google Analytics Terms of Service 

and the 

Google Privacy Policy

.

SECTION 3. WHY WE COLLECT INFORMATION

We collect information for the following purposes, including but not limited to (“Purposes”):

  • To process your transactions;
  • To verify your identity;
  • To disburse loans and collect payments for your use of the Service;
  • To build the credit models and perform credit scoring;
  • To analyze customer behavior;
  • To allow our partners to fulfill their obligations to you;
  • To allow us to fulfill our obligations to our partners;
  • To troubleshoot problems with the Service;
  • To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” and anti-money laundering requirements;
  • To detect and prevent fraud and other illegal uses of the Service;
  • To send you marketing notices, service updates, and promotional offers; and
  • To contact you by telephone or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.

SECTION 4. HOW WE USE, SHARE AND VERIFY INFORMATION

These clauses explain how we will use and share your information. By using the Services, you agree that we and members of Boost shall use Customer Information in accordance with such clauses.

Uses made of the information

  • Information collected by us shall be used for the Purposes defined in this Privacy Policy.
  • We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
  • We do not disclose information about identifiable individuals to other parties, unless it is necessary for providing the Services. We may share limited personal information with select partners for research and development. We may provide other parties with anonymous individual information about our users for the purposes of compiling statistics relating to our user base or loan portfolio and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.
  • We may use the analytics tools and software in order to develop and
    analyze the use
     of the Service. Analytics companies may access
     
    individual data to help us understand how the Service is used. We may link the information we store within the analytics software to any Personal Information you submit within the mobile applications.

Sharing

By using the Services, you agree that we may, as necessary and appropriate for the Purposes, transfer and disclose any Customer Information to the following recipients globally (who may also process, transfer and disclose such Customer Information for the Purposes):

  • any member, affiliate or partner of Boost and any subcontractors, agents, service providers, or associates of Boost (including their employees, directors and officers);
  • persons acting on your behalf, payment recipients, beneficiaries, account nominees, intermediary, correspondent and agent banks, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, swap or trade repositories, stock exchanges, companies in which you have an interest in securities (where such securities are held by us for you);
  • any third party to whom we provide introductions or referrals;
  • any party in connection with any Boost business transfer, disposal, merger or acquisition, wherever located, including in jurisdictions which do not have data protection laws that provide the same level of protection as the jurisdiction in which the Services are supplied.
  • third-party service providers under contract with Boost that help us with our business operations, such as transaction processing, fraud prevention, and marketing. We share your Personal Information with these companies only as necessary to provide you with our Service; and
  • law enforcement, government officials or other third parties, but only
  • in connection with a formal request, subpoena, court order, or similar legal procedure; or
  • when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, report suspected illegal activity, or to investigate violations of our user agreement
    e.

Verification:

By using the Services, you agree that we may, as necessary and appropriate for the Purposes, verify and investigate the information you provide as may be required, including contacting references provided.

SECTION 5. WHERE WE STORE INFORMATION

The data that we collect from you may be transferred to, and stored at a destination outside your country of residence. It may also be processed by staff operating outside your country of residence who work for us or for one of our suppliers. These staff members may be engaged in the fulfillment of your requests. By submitting your Personal Data, you agree to this transfer, storing or processing of data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We may also disclose your data to anyone we consider necessary in order to provide you with services in connection with an account.

Where we have given you (or where you have chosen) a password or PIN that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; 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 unauthorized access. 

SECTION 6. CUSTOMER OBLIGATIONS AND RIGHTS

You agree that We may occasionally send you marketing messages and other Service or transaction-related messages that may be of importance to you. These may come as push notifications, SMS messages, phone calls, or through other channels. You may at any time opt-out from receiving marketing communications by turning them off at the device level through your settings or through the mobile application settings, or by sending an email to

info@boostkh.com

. As always, message and data rates may apply for use of the App, and for any messages sent to you from us and to us from you.

You agree that We shall not be liable for any loss or damage arising from or incidental to Our use, collection, processing and sharing of Customer Information, and any action we have taken in relation to this Section.

Should we wish to use your information for marketing purposes, you shall be entitled to prevent such usage by informing us, you can also exercise the right at any time by contacting us at

info@boostkh.com

.

By uninstalling the app from your Device, you can withdraw your consent from accessing your Customer Information in the future. We may keep and share stored Customer Information after the point of uninstall for as long as necessary for the fulfillment of the purposes for which Customer Information was obtained or for the establishment, exercise or defense of legal claims, or for legitimate business purposes, or as provided by law.

SECTION 7. THIRD-PARTY COLLECTION OF INFORMATION

Our Privacy Policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.

You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

SECTION 8. FOR HOW LONG WE RETAIN THE INFORMATION

We retain the information we collect from you for as long as needed to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. Without derogating from the foregoing, in any other case we will retain the information for a maximum period of
5
 years. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

SECTION 9. YOUR PRIVACY RIGHTS

Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:

  • Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
  • Right to see what Personal Information about you we have;
  • Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
  • Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
  • Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at:

info@boostkh.com

. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services.

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at:

info@boostkh.com

.

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.

SECTION 10. HOW WE PROTECT YOUR INFORMATION

We take great care in implementing and maintaining the security of the Services and safeguarding information that relates to you. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard such information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

If you believe that your privacy was not treated in accordance with our Privacy Policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, it will be advisable to contact us directly at:

info@boostkh.com

.

SECTION 11. ADVERTISEMENTS

We may use a third-party advertising technology to serve advertisements when you use the Services. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). We may also use our third-parties and share with them Users’ information to assist us in evaluating the success of our advertising campaigns and help us retargeting our Users.

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites:

http://optout.networkadvertising.org/#!/

 and

http://optout.aboutads.info/#!/

.

SECTION 12. MARKETING

We may use your Personal Information, such as your full name, email address, etc. ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, concerning the Services.

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to 

info@boostkh.com

.

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

SECTION 13. CORPORATE TRANSACTION

We may share information, including Personal Information, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

SECTION 14. MINORS

The Services are not designated to individuals under the age of 18. If you are under 18 years old, you should not download the Application, use the Services, or provide any Personal Information to us.

We reserve the right to access and verify any Personal Information collected from you by us. In the event that we become aware that an individual under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, it will be advisable to contact us at:

info@boostkh.com

.

SECTION 15. ADVERTISING ID AND ADVERTISING IDENTIFIER

The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. We may also use Apple’s Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple, and any information obtained through the use of the Advertising Identifier, for the purpose of advertising.

By downloading the Application or using the Services you explicitly agree that we may associate your Advertising ID and your Advertising Identifier with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID or Advertising Identifier respectively, we will use other identifiers.

SECTION 16. UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website or Application (as reflected in the “Last Revised” heading). In the event of a material change to the Privacy Policy, we will notify you through the Services or via email, or you may be notified within the Application. We encourage you to review this Privacy Policy regularly for any changes.

Your continued use of the Services, following the notification of such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

SECTION 17. QUESTIONS AND CHANGES

Any changes we may make to our Privacy Policy in the future will be posted on this page. Where appropriate, the new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to

info@boostkh.com

.

SECTION 18. INFORMATION ABOUT US

The details of the Company are as follows:


Boost Capital


20A Tanjong Pagar Road, Singapore

Email:


info@boostkh.com