Privacy Policy

Effective Date: December 1, 2021 — Last Revised: December 1, 2021.

This policy applies to Boster Group, Ltd. and its affiliated companies (collectively “Boster Group”). We are the data controller for your personal data and will ensure it is used and stored in accordance with the Data Protection Act (2018) and the Privacy and Electronic Communication Regulations (2003).

Boster Group is a company limited by guarantee (5097003) registered in England and Wales.

Boster Group understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.

This Privacy Policy describes how Boster Group handles and protects your personal information in connection with the hosting of this website, and the provision of its diverse business advisory services in cross-sector partnerships (“Services”), as explained in more detail here.

Scope of this policy

This policy applies to personal information which is collected and/or used by Boster Group in its capacity as a controller as that term (or another term with equivalent meaning) is defined in the EU General Data Protection Regulation (GDPR) and other similar laws. 

Quick Read

 Boster Group collects some personal information from visitors to this website, and recruitment applicants. Boster Group uses personal information to deliver its newsletter to website visitors. For its own purposes, it also uses personal information to analyse and improve how it delivers its services, to contact representatives of its clients or prospective clients and to market to them, and to administer recruitment.

The primary point of contact at Boster Group for questions regarding your personal information is georgina@bostergroup.com.

Your Acceptance

In respect of personal information collected over this website, your continued use of these websites constitutes your understanding of, and agreement to, the practices described in this Privacy Policy as well as any subsequent updates. 

When do we collect personal information?

We collect information about you if:

  • you use this (or any other Boster Group) website;
  • you enquire about, or engage Boster Group to provide, its Services (either in a personal capacity, or as a representative for your employer or client);
  • the use of your personal information is reasonably necessary to provide our Services (in these circumstances, we may obtain your personal information directly from you, or from your associates or persons known to you);
  • you apply for a position with Boster Group
  • you attend a Boster Group-hosted or sponsored event or webinar
  • you sign up to receive the Boster Group newsletter;
  • you contact us with any other enquiry, complaint or notice.

What types of personal information are collected and what do we use it for?

The following is a summary of the types of personal information we collect, and the purposes for which that information is used.

Website Users

Boster Group collects your name, address, e-mail address, telephone number and any other personally-identifiable information which you voluntarily provide as “comments” when you submit an inquiry through the “Contact Us” tool. Boster Group also collects other background information about you in connection with career-related inquiries that you submit through its website.

Boster Group may also automatically collect personal information (through the use of Cookies – see below for full Cookie policy – or similar technologies, including your IP address, device identifier, browsing patterns on its websites, click stream data, and HTP protocol elements) to ensure the effective operation of the website or in order to track the traffic and behaviour patterns of our website visitors. This tracking information is stored in an anonymous, aggregated and non-personal format, and is used to understand and analyze trends, to administer the website, and to learn about user behavior on the websites.

In certain instances, Boster Group may use IP addresses to help identify you when Boster Group feels, in its sole discretion, that it is necessary to enforce compliance with this Privacy Policy, to protect its services, websites, systems, information, employees, business partners, subsidiaries, affiliates, users, customers or others, or when required by law or for law enforcement purposes.

Cookie Policy

Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function as well to provide website operators with information on how the site is being used. Most web browsers enable you to erase cookies, block cookies, receive a warning before a cookie is stored on your device or disable cookies. Boster Group uses cookies to identify how the website is being used and what improvements Boster Group can make. This includes using the cookies for the purposes of:

  • Ensuring professional, efficient and user-friendly website functionality
  • Remembering user settings during and between visits
  • Improving the speed/security of the site
  • Allowing you to share pages with social networks like LinkedIn and Twitter
  • Continuously improving our website
  • Making our marketing more efficient (ultimately helping us to offer our Services)

We do not use cookies to:

  • Collect any sensitive information
  • Pay sales commissions

First Party Cookies

Our first party cookies are set by the Boster Group website and are required to perform basic functionality. There is no way to prevent these cookies being set other than to not use our site. 

Anonymous Visitor and Third Party Statistics Cookies

Boster Group uses cookies to compile visitor statistics such as how many people have visited the website, what type of technology users are using (e.g. Mac or Windows which helps to identify when the site isn’t working as it should for particular technologies), how long users spend on the site, what page users look at, etc. This helps Boster Group to continuously improve the website. These analytics programs also tell Boster Group on an anonymous basis how users reached this site (e.g., from a search engine) and whether they have been here before. You can opt-out of being tracked by Google Analytics across all websites here: http://tools.google.com/dlpage/gaoptout. 

Boster Group also uses Mailchimp, a marketing automation platform and email marketing service, to manage our mailing and distribution lists for our newsletters. The information generated by a Mailchimp cookie will be transmitted to and stored by Mailchimp on servers in the United States. Mailchimp will use this information to enable Boster Group to contact you with our thought leadership, case study and insights-based content, as well as relevant Boster Group news. Mailchimp may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Mailchimp’s behalf. By signing up for our newsletter, you consent to the processing of data about you by Mailchimp in the manner and for the purposes set out above.

Boster Group’s Former, Current and Prospective Clients

If you submit an enquiry to Boster Group about our Services (either over the website, or by emailing, telephoning or meeting with one of our colleagues), then we will process information such as your name, job title and contact information in order to respond to your enquiry.

If you associate with an Boster Group colleague at, for example, an industry event, then Boster Group may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as an actual or prospective client.

If you or the organisation you are associated with becomes an Boster Group client, then we may process your personal information in order to:

  • carry out our due diligence process after starting a new engagement;
  • carry out client communication, service, billing and administration;
  • deal with client complaints; and
  • administer claims.

Taking account of applicable marketing laws, we also process personal information about our clients (former, current and prospective) in order to:

  • send our clients newsletters, know-how, promotional material and other marketing communications;
  • invite our clients to events (and arrange and administer those events).

Performing Services for Our Clients

Many of our Services involve the processing of personal information. In the majority of cases, personal information is provided to us in strict confidence, subject to restrictive undertakings on its use / disclosure.

Third Parties

We may also obtain your data from third parties, such as partner organisations with whom we are collaborating.  These organisations should not pass on your data to us without your knowledge and only if it is required in the performance of a contract.  The third party will require your permission in order to share your data with us for marketing purposes. You should check their Privacy Policy when you provide your information to understand fully how they will process and safeguard your data.

Social Media

Depending on your settings or the privacy policies for social media services like LinkedIn, Instagram or Twitter, you may give us permission to access information from those accounts or services, such as your behaviour on these services and across our site. The majority of this behaviour is anonymised.

Other Uses

If you apply for a position with Boster Group, we will need to collect personal information in order to consider your application, and during any interview and assessment phase.

If we hire you as a vendor, supplier or contractor, we will need to collect personal information in order to complete transactions and, where applicable, complete appropriate screening activities.

Finally, if you contact us for any other reason, we will collect basic contact details, as well as any other personal information relevant to the reason for your enquiry, in order to resolve that enquiry.

What is our legal basis for collecting personal information?

The GDPR, requires us to establish a ‘lawful basis’ for our processing of your personal information. In the majority of cases, processing will be justified on the basis that:

  • the processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where you request certain Services as an individual client);
  • the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to make disclosures to courts or regulators); or
  • the processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal information in connection with the provision of our Services, and also for the purposes of most client on-boarding, administration and relationship management activities).

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required by applicable law to obtain your prior consent in order to send you marketing communications.

Before collecting and/or using any special categories of data (as that term is defined in the GDPR), or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:

  • your explicit consent;
  • the establishment, exercise or defence by us or third parties of legal claims; or
  • other uses allowed by applicable law, such as in relation to the processing of special category data for the purposes of preventing or detecting fraud

Disclosure of Personal Information to Third Parties

Boster Group will not disclose your personal information to third parties other than as described in this Privacy Policy unless Boster Group has your permission or is required or permitted by law. Boster Group may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied or collected. These third parties will be subject to their own data protection requirements providing the same or greater level of security provided by Boster Group and in many instances will also have entered into a written agreement with Boster Group which addresses the protection of your personal information.

Boster Group may also disclose your personal information for the purposes of:

  • responding to requests from law enforcement agencies, regulators or courts, or to subpoenas, search warrants, or other legal requests;
  • the prevention and/or detection of crime;
  • establishing legal rights or to investigate or pursue legal claims;
  • preventing risk of harm to an individual.

Information Security

Boster Group has reasonable technical safeguards, security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Measures we take include placing confidentiality requirements on our staff members and limiting access to your personal information on a “need to know” basis. 

Despite Boster Group’s best efforts, however, security cannot be absolutely guaranteed against all threats.

Retention of your personal information

Boster Group retains your personal information for the period of time required for the purposes for which it was collected, any compatible purposes which we subsequently establish, or any new purposes to which you subsequently consent, or to comply with legal, regulatory and Boster Group policy requirements. This period of time will usually be the period of your, or the relevant client’s, relationship or contract with Boster Group plus a period reflecting the length of time for which legal claims may be made following the termination of such relationship or contract. Some information (such as call recordings, tax records and certain information required to demonstrate regulatory compliance) may need to be kept for longer. Personal information will be kept for a shorter or longer period of time if so required by law or a Boster Group policy, if the information becomes subject to a legal hold (for example, following a communication from our regulator) or if we have identified through a data protection impact assessment that a different retention period is appropriate.

Your Rights in Jurisdictions Covered by the GDPR and Similar Laws

If your personal information is processed by an Boster Group entity in the EEA or another jurisdiction that has adopted the GDPR, then, subject to certain exemptions, and dependent on how and why we use it, you have certain rights in relation to your personal information. The rights described below may vary depending on the specific laws that apply to you.

We may ask you for additional information to confirm your identity before disclosing any personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to Access

You have the right to access personal information which Boster Group holds about you, together with certain information about how and why your personal information is processed.

Right to Rectification

You have a right to request us to correct your personal information where it is inaccurate or out of date.

Right to be Forgotten (Right to Erasure)

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.

Right to Restrict Processing

You have the right to restrict the processing of your personal information, but only where:

  • its accuracy is contested, to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. 

Right to Object to Processing

You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

If you reside in the European Economic Area (EEA) or the UK and would like to exercise your right to access, review, correct or discuss how your personal information is processed by Boster Group please contact us at georgina@bostergroup.com.

If you reside outside of the EEA you can also make a request to update or remove information about you by contacting georgina@bostergroup.com. Boster Group will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

In addition, under applicable local law you may have the legal right to lodge a complaint with the relevant supervisory authority or local data protection authority.

Marketing

Boster Group may send you information related to its services, products and events that we believe are of interest to you. This information may be sent by post or via email. If at any point you no longer prefer to receive marketing communications from Boster Group you can (i) unsubscribe from Boster Group communications sent by email using a link provided in marketing emails sent from Boster Group; or (ii) contact us to exercise your right to prevent all forms of marketing (both post and email).

Children

Boster Group’s websites are not intentionally designed for or directed at children under the age of 13. It is Boster Group’s policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

Links

Boster Group websites may contain links to other sites, including websites maintained by Boster Group affiliates that are governed by other privacy policies that may differ somewhat from this one. Users should review the privacy policy of each website visited before disclosing any personal information. To the extent that Boster Group provides links to third party websites, such links do not constitute an endorsement, sponsorship, or recommendation by Boster Group of the third parties, the third party websites, or the information contained on those websites, and Boster Group is not responsible or liable for your use of such third party websites. Where appropriate you should review the privacy polices of any websites or applications before submitting personal information.

Changes to this Policy

By using Boster Group websites you consent to the collection, use and storage of personal information as described in this Privacy Policy and elsewhere on the websites. Boster Group reserves the right to make changes to this Website Privacy Policy from time to time. Boster Group will notify you by posting amendments to the Privacy Policy on this website.

Contact Us

If you have questions or concerns regarding this policy or Boster Group’s personal data processing policies, please contact Boster Group at: georgina@bostergroup.com.

If you reside in the EEA or UK and have questions or concerns regarding this policy or processing of your personal information by Boster Group please contact us at georgina@bostergroup.com.

 

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