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Privacy Policy

Last Updated: April 3, 2023

This Privacy Policy (“Policy”) explains what personal data and information you submit (“Information” or “Data”) is collected and how it is used by Boosta Start Up Factory OÜ (“Provider”, “we”, “us”) when you access or use our Site. This Policy and other documents referenced in it apply to all personal data collected through our Site and any related services, sales, marketing or events.

The Site is operated by Boosta Start Up Factory OÜ, a legal entity, duly incorporated in Estonia under the company number 16638584 having its registered office at Kaupmehe tn 7-120, Kesklinna linnaosa, Tallinn, Harju maakond, Estonia, 10114. Boosta Start Up Factory OÜ will be the controller of your personal data.

By visiting the Site, you agree that your information will be handled as described in this Policy.

1. Information We Collect About You

Information we collect about you depends on how you use our Site.

Registration, Services and Account Information. You can browse the Site without registering for an account with us in that case we may collect information regarding your device, geolocation data, behavioral, target job and target profile. When you register an account or use certain of our services, create a profile, create a cover letter, search for or purchase services, make questions and requests or otherwise engage with our Site, you must provide certain information such as a valid email address and Account password, otherwise, you will not be able to create an account.

When creating documents, we will also collect other data you voluntarily provide and enter on the Site, such as name, surname, job details (position, company name), work experience (years of experience, recent job position, certifications, skills, achievements), education (education level and major), files created/uploaded by you to the Site.

You must also provide payment information such as credit or debit card information to purchase services. This information is only associated with your account after you have signed in as a subscribed user.

*We use third party payment processors (each, a “Payment Processor”) to bill you through a payment account linked to your Account. The processing of payments will be subject to the terms, conditions and privacy policies of the Payment Processor.

User Interaction Information. We can also receive other information (e.g., content viewed and information about the advertisements within the content you have been shown or have clicked on, etc.) from your interaction with our Site. To the extent permissible by law of the country of your residence, you agree that we can share your interaction information with, or obtain information about your interaction from, analytics providers, advertising partners, third-party partners, and social media sites for two years or until you withdraw your consent for the purpose of providing or improving our services. Certain information that we may have access to from third-party services providers may be controlled by your privacy settings on that service and by your consent. Information that can be passed to analytics providers and advertising partners can be via cookies and tracking technologies.

Whenever you interact with our Site and/or use our Services we may collect such information as (IP) address; your login information; browser type and version; time zone setting and location; browser plug-in types and versions; operating system and platform and other technology on the devices you use to access our Site; Cookie ID; Other technical information.

2. Uses, Retention and Storage

We process your information for the following purposes and legal bases:

Operate our Site and Provide You with Our Services. We use the Information we collect to (i) respond to your questions and requests; (ii) provide customer service (e.g., to fulfill product and service orders made by you, give you information about your account to resolve disputes, problems with your account/profile or the Site, administer a contest, sweepstakes or promotions, or to provide information to third parties at your request such as potential employers, job matching services or third party websites, or other career-related services); (iii) personalize your experience by providing content on the Site, including targeted advertising or job-related advertising, that we believe can be of most interest to you; (iv) improve the Site, and; (v) provide you with a safe, efficient, and customized experience.

Analyze and Aggregate Non-Personal Information. We use aggregate information about our users and non-personal information to analyze Site and user behavior and prepare aggregated reports.

Protecting our Services and maintaining a trusted environment. We use information from the Site to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, establish, exercise or defend a legal claim, and enforce our Terms of Use. We also use information in response to requests by government or law enforcement authorities, or in response to complaints where we are under a legal or regulatory obligation to adhere to a complaint-handling procedure.

Communications. We use your information to contact you to maintain the Site, your account, or to comply with your stated communication preferences, or to provide other services as described at the time when we collect the information from you, or to contact you for other purposes authorized by law.

Advertising and Marketing. We use your information to determine the effectiveness of our marketing and promotional campaigns; for maintaining appropriate business records; to have the opportunity to communicate with you about our products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us.

To the extent permissible by applicable law, we retain Information for as long as it is necessary to fulfil the purpose(s) for which it was collected, our business purposes, and/or to comply with the applicable laws and regulations.

Personal Information collected when you opted in to receive marketing letters will be stored as long as you are interested in receiving our marketing emails and newsletters. We consider that you’re interested in this until you unsubscribe from the mailing list.

3. Disclosure

We may share Information we collect in specific situations described in this section and/or with the third parties.

Corporate and Service Partners. We may disclose the information we collect about you with our corporate partners (our affiliates and subsidiaries). If we disclose your information with them, their use and disclosure of your information will be subject to this Policy. We also may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, fraud investigations, bill collection, payment processing, and site analytics and operations)

Legal and Law Enforcement. We may disclose information that we collect if we believe that such action is necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

Analytics Providers. We may disclose information we collected through our Site to our analytics providers such as Google Analytics, to evaluate usage of our Site, and to help us improve our services, performance and user experiences.

To Protect Us and Others. We may share your information where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, potential threats to the safety of any person, violations of our Terms of Use, or this Policy, or as evidence in litigation in which we are involved.

We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy, only to the extent necessary as per the applicable purpose of the disclosure and in strict compliance with applicable data privacy laws (including by observing the requirement to conclude compliant data processing agreements with any third-party processor carrying out their tasks on our behalf and upon our instructions).

4. Accessing, Reviewing, and Changing Your Personal Information

Registered users may review and change the Information at any time by accessing their accounts on the Site (through the Account Details or Experience and Skills). You must promptly update your information if it changes or becomes inaccurate.

5. Your Choices

Opt-Out of Electronic Communications. You may opt out of receiving promotional messages from us. Just follow the instructions in those messages, or toggle the setting on your account dashboard. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.

Update/Delete or Change Your Cover Letter. To change or delete your cover letters that you have uploaded to our site – email us at admin@coverler.com.

Administrative/Transactional Messages Cannot Be Turned Off. As we provide an online service, you cannot opt-out of administrative or transactional emails (for example emails about your transactions or policy changes) for your registered account.

Deletion of Your User Content/Account. You may request that we delete your account and/or certain personal identifiable information we have collected from our systems. You can do so by sending us an email at admin@coverler.com. When you request that your account or that your personal identifiable information is deleted, your cover letter and profiles will be deleted and no longer available to you. When you delete your information, we will retain logs of your information along with an archival copy of your information, which is not accessible by you or third parties but which might be used by us for recordkeeping and internal purposes, including enforcing this Policy. To the extent permitted by applicable law, we may retain information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account or subscription is terminated or suspended, we may maintain information to prevent re-registration.

Third-Party Ad Network Opt-Out. We may use third-party network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. We may provide these third-party advertisers with information about you, if you granted your consent.

Set Your Browser to Reject Cookies. You can choose to set your browser to remove or reject browser cookies before using our Site, with the drawback that certain features of the Site may not function properly without the aid of cookies.

Other Data Options. Unless otherwise required by the laws of the country of your residence, you may request: (i) a copy of the of the specific pieces of personal identifiable information that we have collected about you in the last 12 months from the date of your request, and; (ii) that we that we disclose certain information about how we have handled your personal identifiable information in the prior 12 months. You can make such requests by sending us an email at admin@coverler.com.

6. California Residents’ Privacy Rights

This section provides specific information and only applies for residents of California (“California consumers” in this section). The California Consumer Privacy Act (“CCPA”), requires that we provide certain information to California consumers about how we handle certain personal information that we have collected, whether online or offline. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

Categories of Personal Information that We Collect and Disclose. We may collect and disclose for a business purpose the following personal information from California Consumers: (1) name, contact information and identifiers (real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers); (2) customer records (electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, employment, employment history); (3) protected classifications (characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information); (4) purchase history and tendencies (commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); (5) usage data (internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a California consumer’s interaction with an Internet website, application, or advertisement); (6) geolocation data (precise geographic location information about a particular individual or device); (7) employment history (professional or employment-related information); (8) education information (information about education history or background), (9) Audio/Visual: audio, electronic, visual, thermal, olfactory, or similar information, and; (10) profiles and inferences (inferences drawn from any of the information identified above to create a profile about a California consumer reflecting the California consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).

We do not sell any of the information stated above. Furthermore, the list above does not address our handling of personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.

California Consumer Rights. California law grants California consumers certain rights and imposes restrictions on particular business practices as set forth below.
(1) Do-Not-Sell. California consumers have the right to opt-out of the sale of their personal information. We do not sell personal information.

(2) Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, and as a California consumer, you have the right to make the following requests: at no charge, up to twice every 12 months:

(i) Deletion. You have the right to request deletion of personal information that we have collected about you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).
(ii) Copy. Consumers have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months.
(iii) Right to Know. Consumers have the right to request that we disclose certain information about how we have handled personal information in the prior 12 months, including the:

categories of personal information collected
categories of sources of personal information
business and/or commercial purposes for collecting and selling their personal information
categories of third parties/with whom we have disclosed or shared their personal information
categories personal information that we have disclosed or shared with a third party for a business purpose.
categories of personal information collected
categories of third parties to whom the consumer’s personal information has been sold and the specific categories of personal information sold to each category of third party.

Submitting Requests. You can submit a copy, deletion and right-to-know request online by sending a request through your account in case you are registered in the Site, by emailing us at admin@coverler.com.

Incentives and Discrimination. The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information. Businesses may offer different prices, rates, or quality of goods or services if the difference is reasonably related to the value of the consumer’s data.

7. Canada Residents’ Privacy Rights

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

if collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
if it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
if it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
if it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
if the collection is solely for journalistic, artistic, or literary purposes;
if the information is publicly available and is specified by the regulations.

8. Tracking Technologies (Cookies)

Depending on your country of residence, when you first accessed this Site you may have been prompted to set your cookie setting preferences. Your cookie settings will be saved in accordance with privacy laws. Otherwise, when you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site including, but not limited to, video-viewing, site views, key stroke data, mouse movement, scrolling, clicks, and typing ("usage information"). We use tracking technologies to collect usage information. We can use tracking technologies for a variety of purposes, including:

Essential cookies. Some cookies are essential for our service to function and cannot be switched off in our systems. They are used to enable core functionality, such as authentication, security, connection stability, etc. You can always set your browser to block or alert you about these cookies, but this may affect the Site functions.

Analytics Cookies. Analytics cookies help us know which pages are popular and how visitors move around the site. We use them to count visits, check traffic sources, and measure and improve the Site’s performance.

Marketing Cookies. Certain 3rd-party service providers and advertising partners manage our advertising on other sites. Such 3rd parties use cookies through our site to provide you with advertising on other sites based on your interests and preferences.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the sites you visit.

9. European Economic Area Residents

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the "GDPR"), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

request access to your personal data;
request correction or deletion of your personal data;
object to our use and processing of your personal data;
request that we limit our use and processing of your personal data; and
request portability of your personal data.

10. Third Parties

Our Site can contain links to other third-party websites. We are not responsible for the privacy practices or the content of these third-party sites so it is important to familiarize yourself with their privacy policies before providing your Information.

11. Information Security

We maintain appropriate technical, physical, and administrative security measures designed to protect the security of your information against loss, misuse, unauthorized or accidental access, disclosure, copying, use or alteration. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, we cannot guarantee its absolute security.

12. Children's Privacy

The Site is a general audience site and it is not intended for children under the age of 16. We do not knowingly collect information via our websites, applications, services, or tools from users in this age group. Therefore, we recommend that parents or legal guardians be involved in the online activities of their children in order to prevent the collection of their personal data without parental consent. If you become aware that a child under 16 has provided us with information, please contact us via admin@coverler.com immediately so we can delete such information from our system.

13. Notification Regarding Review and Updates.

From time to time and at least once every twelve (12) months we review this Privacy Policy and we may choose to update its terms. The Privacy Policy posted at any time or from time to time via the Site shall be deemed to be the Privacy Policy then in effect. You agree that we can notify you about material changes in the way we treat your Information by placing a notice on the Site. You should check the Site frequently for updates. In addition, we have provided the Privacy Policy Highlights section to offer a summary of the main points of our Full Privacy Policy for your convenience. In the event of a conflict between the Privacy Policy Highlights and the Full Privacy Policy, the Full Privacy Policy will control.

15. Contact Us

The Site is controlled and operated by Provider. Whether you access the services through any of our Site, you may contact Provider by email us at admin@coverler.com, write to us at Boosta Start Up Factory OÜ, Kaupmehe tn 7-120, Kesklinna linnaosa, Tallinn, Harju maakond, Estonia, 10114.