BOOSTY LABS PRIVACY POLICY

General

This Privacy Policy (“Policy”) describes how we collect and use your personal data in connection with Boosty Labs websites, portals and services.
The terms “Boosty Labs”, “we”, “us”, or “our” refer to Creditor Group Corp.

Scope

This Policy applies to personal data collected through the Boosty Labs website (https://boostylabs.com/) and related communications.

Who is responsible for your data

Registered name: Creditor Group Corp.
Registered address: 108 W. 13th Street, Suite 100, Wilmington, DE 19801, County is New Castle
General contact address: interact@boostylabs.com

Key terms and definitions

Personal data:: any information relating to an identified or identifiable natural person (“Data subject”). For the purposes of GDPR, personal data means any information
relating to You such as a name, surname, gender, age, health information, preferences, etc.
Processing:: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as
collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination
or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data controller:: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of
the processing of personal data.
Data processor:: means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
You:: means any individual accessing or using the Website (“Visitor”), obtaining the services (“Customer”), or otherwise interacting with us directly or indirectly,
including as a prospective customer (“Lead”) and job applicants applying for roles through the Career page on the Website.
Website visitor:: an individual who visits Boosty Labs’ website or otherwise interacts with Boosty Labs online.
Cookies:: text files that are stored on a website visitor’s computer or mobile device by a website’s server.

Sources of personal data

Boosty Labs may collect personal data through:

Website forms, including Contact Us, Book a Call (e.g. via Calendly), and career or job application forms;
Direct communications, such as emails or messages sent for inquiries or support;
Client onboarding, where information is provided to establish or manage a business relationship.

Why we process your data

We process personal data to communicate with you, manage meetings and recruitment, deliver services, and improve our website.

Types of personal data & legal basis for processing

Purpose of Processing	Categories of Data Subjects	Categories of Personal Data	Legal Basis
Respond to business inquiries and requests for consultations	Visitors, Leads	Identification and contact data (e.g. name, email address, phone number), communication content	Legitimate interests: to respond to inquiries, provide relevant information, and maintain potential business relationships. Consent may be relied upon if the communication goes beyond expected inquiries.
Schedule and manage meetings with prospective clients	Leads, Customers	Identification and contact data (e.g. name, email address, phone number), scheduling information	Contract performance: to organise and manage meetings.
Review and evaluate job applications and communicate with candidates	Job Applicants	Identification data, contact details, CV/resume, application documents, communication content	Contract performance (pre-contractual): to assess candidate suitability, manage recruitment, and communicate decisions.
Provide requested services (project discussions, proposals)	Customers	Identification and contact data (e.g. name, email address, phone number), company information, project-related information, communication content	Contract performance: to deliver the requested services and manage project-related communications.
Improve the website via analytics (user behavior analysis)	Visitors	Usage data, website interactions, analytics identifiers (e.g. IP address, device and browser details, pages viewed and interactions, timestamp of visits, referrer (where the user came from).	Legitimate interests: to analyse website performance, understand visitor behaviour, and optimise user experience and functionality. Consent may be sought where tracking exceeds reasonable expectations.
Send official correspondence related to business operations, service delivery, and notifications	Visitors, Leads, Customers	Identification and contact data, communication content	Contract performance: to deliver operational or service-related communications. Legitimate interests: to provide important business updates or notifications relevant to ongoing relationships.

The use of Cookies & other tracking technologies

Boosty Labs uses “cookies” – small text files stored on your computer or mobile device by our website’s server, and other limited tracking technologies
to ensure smooth platform functionality and enhance your user experience.

For more details about our use of cookies, please visit our Cookie Policy.

Automated decisions

We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

Below are the circumstances under which personal data may be shared:

Corporate transaction: in the event of a potential or actual corporate transaction (e.g., a merger, acquisition, reorganisation, sale of assets,
or insolvency proceeding), we may transfer your personal data to relevant parties involved in the transaction. Such transfers will occur only to the extent
necessary and subject to appropriate confidentiality and data protection safeguards.
Compliance with the laws: we may disclose your personal data to third parties where necessary to comply with legal obligations, including to:
- comply with applicable laws and regulatory requirements (e.g., tax reporting).
- respond to valid legal requests, such as court orders, subpoenas, or lawful requests from public authorities.
Service providers and professional advisors: we may share your personal data with carefully selected providers and professional advisors, such as:
- Document storage and corporate email services (Google)
- Web hosting provider (https://www.ukraine.com.ua/)
- Scheduling & Meetings (Calendly)

We do not sell user data to any third parties. All service providers engaged by us operate under standard Data Processing Addendums (DPAs).
We adhere to the principle of data minimization, sharing only the information necessary to deliver each specific service. Additionally, third-party integrations
are user-controlled and require explicit consent before any data is shared.

International data transfers

The Company operates and works with service providers in the United States and other countries. As a result, your personal information may be transferred to
locations outside your state, province, country, or other jurisdiction, where privacy protections may differ from those in your location.

We take steps to ensure that any transfer of personal data is handled securely and in accordance with applicable privacy and data protection principles.
This may include implementing appropriate safeguards, contractual measures, and other mechanisms to protect your information and uphold your rights.

If you would like more information about how your personal data is transferred and protected when handled outside your jurisdiction, please contact us.

Data retention practices

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable laws. In particular:

Leads and Contact Us submissions (e.g., name, email, company, phone, request details) are retained for up to 2 years after the last interaction or period of inactivity.
Job applicant data (e.g., CVs, contact information, application responses) is retained for up to 2 years after the record is created or the recruitment process is closed.
Analytics data is retained for up to 2 years to help us understand website usage and improve our services.

After these periods, personal data is securely deleted or anonymised.

Information security

We employ industry standard security measures designed to protect the security of all information submitted through the services.

While we take reasonable steps to protect your personal data, no system can be completely secure. Therefore, we encourage you to take precautions to protect
your own information, including maintaining the confidentiality of login credentials.

To protect you and your data, we may suspend your use of any of the services, without notice, pending an investigation, if any breach of security is suspected.

Updating personal data

If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made
of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to
interact@boostylabs.com.
We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Children’s Privacy

Boosty Labs does not knowingly collect any personal data from children under the age of 18. If you think that your child provided this kind of information on our
Platform, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Your Rights and Choices

Under data protection laws you have certain rights concerning your personal information. You may request that we take the following actions in relation to the
personal data we hold about you:

Opt-out: opt-out from the processing of personal data based on your consent.
Access: provide details about how we process your personal information and give you access to it.
Request: You have the right to receive your personal data in a structured, commonly used, and machine-readable format. If you wish, you can
also request that we transfer this data directly to another data controller, where technically feasible.
Correct: update or correct any inaccuracies in your personal data.
Delete: remove your personal information from our records. In certain circumstances, you have the right to request the deletion of your personal
data. This may apply if:
- your data is no longer necessary for the purposes for which it was collected.
- you object to the processing, and there are no overriding legitimate grounds for the processing.
- your data has been unlawfully processed.
*Please note that this right is not absolute and may be subject to exceptions, such as compliance with legal obligations or the establishment, exercise,
or defense of legal claims.
Transfer: send you or a third party a machine-readable copy of your personal data.
Restrict: You have the right to request the restriction of processing of your personal data in certain situations, such as:
- when you contest the accuracy of the data, for a period enabling us to verify its accuracy.
- when you object to the processing, pending verification of whether our legitimate grounds override your rights.
- when the processing is unlawful, and you request restriction instead of erasure.
While the processing is restricted, we will only store your personal data and will not process it further unless specific conditions apply.
Object: You have the right to object to the processing of your personal data based on our legitimate interests, unless we can demonstrate
compelling legitimate grounds for the processing that override your rights and freedoms.

To further exercise any of these rights, you may contact us at interact@boostylabs.com.
We may need to request specific information from you to verify your identity and process your request. In some cases, applicable laws may require or allow us to
decline your request. If we are unable to comply, we will explain the reason, subject to any legal restrictions.

If you have concerns about how we handle your personal information or our response to your requests, you may contact us at
interact@boostylabs.com or file a complaint with the data protection authority in your jurisdiction.

Updates to this Privacy Policy

We reserve the right to update and change this Policy to reflect any changes to the way in which we process your personal data or changing legal requirements.
We regularly update our Privacy Policy. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact information

We welcome your comments or questions about this Policy, and you may contact us at the following address: interact@boostylabs.com