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Privacy Policy – thebooost

Effective Date: 01/01/2026 · Last Updated: 01/01/2026

This Privacy Policy (“Policy”) sets out the manner in which Semeion Consulting Private Limited, a company duly incorporated under the laws of India, having its registered office at 11/602 Vijay Park, Godhbunder Road, Thane, Mumbai 400615 (“Company”, “we”, “us”, or “our”), collects, receives, accesses, uses, processes, stores, secures, transfers, and discloses personal data of users (“User”, “you”, or “your”) in connection with your access to and use of the thebooost platform, including all associated applications, software, services, content, features, and functionalities (collectively, the “Platform”).

This Policy is intended to ensure compliance with applicable data protection and privacy laws, including but not limited to:

  • the Digital Personal Data Protection Act, 2023;
  • the General Data Protection Regulation; and
  • any other applicable international, regional, or sector-specific data protection laws and regulations.

By accessing, browsing, registering on, or otherwise using the Platform, you expressly acknowledge and agree that:

  • you have read, understood, and accepted the terms of this Policy;
  • you provide your free, informed, specific, and unambiguous consent for the collection and processing of your personal data; and
  • such processing shall be carried out in accordance with this Policy and applicable laws.

If you do not agree with this Policy, you must immediately discontinue use of the Platform.

2. SCOPE AND APPLICABILITY

This Policy applies to all Users accessing or using the Platform globally, irrespective of geographic location, and governs all forms of personal data processing undertaken by the Company in connection with the Services.

This Policy applies to personal data collected through, including but not limited to:

  • direct interactions via the Platform interface;
  • completion of assessments, questionnaires, and profiling tools;
  • account creation, onboarding, and subscription processes;
  • communications through email, chat, or support channels;
  • automated collection through cookies and similar technologies.

This Policy does not apply to:

  • third-party websites, platforms, or services that are not owned, operated, or controlled by the Company;
  • data collected by third parties independently of the Platform, even if accessed through links or integrations;
  • any information processed by third-party service providers in their independent capacity.

The Company shall not be responsible for the privacy practices of such third parties, and Users are advised to review their respective privacy policies.

3. CATEGORIES OF PERSONAL DATA COLLECTED

The Company may collect, process, and store various categories of personal data, depending on the nature of interaction with the Platform.

(a) Identity and Contact Information

This includes personal identifiers and contact details necessary for account creation, communication, and service delivery, such as:

  • full name and user identification details;
  • email address and phone number;
  • organization, employer, designation, or professional affiliation.

(b) Assessment and Behavioral Data

The Platform collects and processes data provided by Users during assessments and interactions, including:

  • responses to questionnaires and assessment inputs;
  • behavioral indicators, preferences, and personality traits;
  • inferred insights and analytical outputs generated by the Platform.

Such data may be used for profiling, analysis, and generation of reports.

(c) Technical and Usage Data

The Company automatically collects certain technical data, including:

  • IP address and approximate location;
  • device identifiers and hardware configuration;
  • browser type, operating system, and session data;
  • interaction logs, usage patterns, and navigation behavior.

(d) Transactional Data

Where applicable, the Company may collect:

  • payment transaction details (excluding full card information);
  • subscription plans, billing history, and invoices;
  • payment status and related financial records.

All payment processing is handled through secure third-party gateways.

(e) Communication Data

This includes data exchanged between the User and the Company, such as:

  • support queries and responses;
  • feedback, complaints, or suggestions;
  • survey responses and communication logs.

4. PURPOSE OF PROCESSING

The Company processes personal data strictly for legitimate and lawful purposes, including but not limited to:

  • providing access to, operating, and maintaining the Platform;
  • generating AI-driven insights, analytics, and reports based on User inputs;
  • personalizing and enhancing User experience;
  • processing payments, subscriptions, and transactions;
  • communicating updates, notifications, and support responses;
  • detecting, preventing, and investigating fraud, abuse, or security incidents;
  • ensuring compliance with legal, regulatory, and contractual obligations.

The Company undertakes to ensure that:

  • processing is limited to what is necessary and proportionate;
  • data is not used for purposes incompatible with those stated herein;
  • adequate safeguards are implemented to protect User interests.

5. LEGAL BASIS FOR PROCESSING

Where required under applicable laws, the Company relies on one or more of the following legal bases:

(a) Consent

Processing based on explicit consent provided by the User, including consent for AI processing and profiling.

(b) Contractual Necessity

Processing necessary for the performance of contractual obligations, including provision of Services.

(c) Legitimate Interests

Processing undertaken for legitimate business purposes, such as:

  • improving Platform functionality;
  • ensuring security and fraud prevention;
  • analyzing usage trends.

Such processing shall be conducted after balancing User rights and interests.

(d) Legal Obligations

Processing required to comply with applicable laws, regulatory requirements, or lawful requests by authorities.

Users may withdraw consent at any time; however, such withdrawal may affect the availability of certain Services.

6. AI AND AUTOMATED PROCESSING

The Platform utilizes artificial intelligence, machine learning models, and automated processing systems to analyze User inputs and generate outputs.

The User expressly acknowledges and agrees that:

  • personal data may be processed using automated systems and algorithms;
  • profiling, behavioral analysis, and inference-based processing may occur;
  • outputs generated are probabilistic, predictive, and non-deterministic in nature.

The Company does not warrant:

  • accuracy, completeness, or reliability of outputs;
  • absence of bias or unintended results in AI processing.

Users are advised not to rely solely on such outputs for critical decision-making.

7. DATA SHARING AND DISCLOSURE

The Company may disclose personal data under the following circumstances:

(a) Service Providers

To trusted third-party service providers engaged for:

  • cloud infrastructure and hosting;
  • payment processing;
  • analytics and performance monitoring.

Such providers are contractually bound to maintain confidentiality and data protection standards.

(b) Legal and Regulatory Authorities

Where disclosure is required:

  • under applicable laws;
  • pursuant to court orders or legal processes;
  • for enforcement of legal rights.

(c) Business Transfers

In connection with mergers, acquisitions, restructuring, or sale of assets, subject to confidentiality obligations.

The Company shall ensure that all disclosures are subject to appropriate safeguards.

(d) No Sale or Commercialization of Personal Data

The Company does not sell, rent, trade, or otherwise commercialize personal data shared by Users on the Platform. Personal data shall not be disclosed to third parties for their independent marketing or commercial purposes. Any sharing of personal data shall occur only for the purposes stated in this Policy, for the provision and operation of the Services, or where required under applicable law.

The Company shall ensure that all disclosures are subject to appropriate safeguards and data protection obligations.

8. CROSS-BORDER DATA TRANSFERS

Personal data may be transferred to and processed in jurisdictions outside the User’s country of residence.

Such transfers may occur where:

  • the Company or its service providers operate globally;
  • infrastructure or processing systems are located in other jurisdictions.

The Company shall implement appropriate safeguards, including:

  • contractual data protection clauses;
  • compliance mechanisms aligned with global standards;
  • security and confidentiality controls.

By using the Platform, the User consents to such cross-border transfers.

9. DATA RETENTION

The Company retains personal data only for as long as necessary to:

  • fulfil the purposes set out in this Policy;
  • comply with applicable legal and regulatory obligations;
  • resolve disputes and enforce agreements.

Retention periods shall be determined based on:

  • nature and sensitivity of data;
  • legal requirements;
  • operational necessity.

Upon expiry of retention periods, data shall be:

  • securely deleted; or
  • irreversibly anonymized.

10. DATA SECURITY

The Company implements commercially reasonable technical and organizational measures to safeguard personal data, including:

  • encryption of data in transit and at rest;
  • role-based access controls;
  • system monitoring and intrusion detection;
  • periodic security reviews and audits.

Notwithstanding the foregoing, the User acknowledges that:

  • no system is completely secure;
  • the Company cannot guarantee absolute protection against all threats.

11. USER RIGHTS

Subject to applicable laws, Users may exercise the following rights:

  • right to access and obtain a copy of personal data;
  • right to correct or update inaccurate data;
  • right to erase or restrict processing of data;
  • right to object to certain forms of processing;
  • right to data portability;
  • right to withdraw consent.

Requests may be submitted to: ops@semeionconsulting.com and shall be processed in accordance with applicable laws.

12. COOKIES AND TRACKING TECHNOLOGIES

The Platform may use cookies, web beacons, and similar technologies to:

  • enhance functionality and user experience;
  • analyze usage and performance;
  • support security and authentication.

Users may manage or disable cookies through browser settings; however, certain features may be impacted.

13. CHILDREN’S PRIVACY

The Platform is not intended for use by individuals under the age of 18.

The Company does not knowingly collect personal data from minors. If such data is identified:

  • it shall be promptly deleted;
  • appropriate corrective measures shall be taken.

14. CHANGES TO THIS POLICY

The Company reserves the right to modify or update this Policy at any time.

Revised versions shall be published on the Platform and shall become effective immediately upon publication.

Continued use of the Platform constitutes acceptance of the updated Policy.

15. CONTACT INFORMATION

For any queries, requests, grievances, or complaints regarding this Policy or data processing practices, Users may contact:

Semeion Consulting Private Limited

11/602 Vijay Park,

Godhbunder Road,

Thane, Mumbai 400615

Email: ops@semeionconsulting.com