Privacy Notice

1. What types of information does BuyerAssist collect?

Personal Data. “Personal Data” is information that, directly or indirectly, identifies you or another individual and which may include: name, title, company name, job function, expertise, postal address, telephone number, email address, browser and device information (including IP Address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers in connection with the Sites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

Other Information. “Other Information” is any information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Sites and for other purposes described below.

2. How does BuyerAssist collect information?

We and our service providers collect Personal Data and Other Information in a variety of ways, including the following:

• We collect information through the Sites, e.g., when you request a free trial or demo, register for a webinar, contact us, subscribe to our email newsletter, download content (e.g. whitepapers), or register to use our Sites.
• We collect information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact a BuyerAssist representative.
• We collect information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Data, this information does not personally identify you or any other user of the Sites.
• In order to enhance our ability to provide relevant marketing, offers, and services to you, we obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
• Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. BuyerAssist uses IP Addresses to calculate usage levels of the Sites, help diagnose problems with its servers, administer the Sites, and for monitoring the regions from which you navigate to BuyerAssist’s Sites.
• When you download and use an App, we and our service providers track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• “Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the Sites. When you visit our Sites, we may send one or more cookies to your device. They enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse our Sites and enhance the level of services and functions provided. We also use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Sites and other websites. To do so, these companies may place or recognize a unique cookie or similar on your browser. BuyerAssist recognizes automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions. For any further questions regarding our Cookies Policy, contact us on privacy@buyerassist.io.

3. How does BuyerAssist use personal data?

• To respond to your requests or provide you with information requested by you.
• To send administrative or account related information to you.
• To communicate with you about updates to the Services.
• To maintain the website and tailor the website to your needs.
• To provide you with marketing and promotional communications (where this is in accordance with the law). For more information about managing your marketing preferences, please see the “What Are My Data Protection Rights?” section of this Privacy Notice below.
• To comply with and enforce applicable legal requirements, agreements and policies.
• To prevent, detect, identify, investigate, respond and protect against potential or actual claims, liabilities, prohibited behavior, and criminal activity.
• For other business purposes such as data analysis, identifying usage trends, determining the effectiveness of our marketing and to enhance, customize and improve our Websites, products and services.
• In relation to EU employee data, to facilitate the employer/employee relationship.
• To better understand the individuals who use and interact with our Online Properties, where they come from, and what content on our Online Properties is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Online Properties.

4. How will BuyerAssist share personal data it receives?

We may disclose your Personal Data to the following categories of recipients:

• to our contractors, third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Online Properties), or who otherwise process Personal Data for purposes that are described in this Privacy Notice or notified to you when we collect your Personal Data;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Privacy Notice;
• to our marketing partners to send emails on our behalf, and/or for co-branded and/or co-sponsored marketing and promotional events (such as conference events) offered in conjunction with another company or companies. If you register for or participate in such marketing and promotional events, we and the relevant partner companies may receive information collected in conjunction with the co-branded and/or co-sponsored marketing and promotional events. Our Privacy Notice will apply to our use of your Personal Data. We have no control over any other companies’ privacy practices, so please read their applicable privacy.
• to any other person with your consent to the disclosure.

We may also release Personal Data as we believe necessary and appropriate to law enforcement, tax, fraud prevention, credit risk agencies and other companies and organizations for the reasons given in the sixth and seventh bullets under Section 3 above.

5. How does BuyerAssist use and disclose other information?

We have implemented appropriate organizational, technical, and administrative measures to protect Personal Data within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Questions, Concerns and Complaints” section below.

6. How can I access, correct, amend or remove information about me?

If you would like to access, correct, amend, remove or limit the use or disclosure of any Personal Data about you that has been collected and stored by BuyerAssist, or have it transferred to another organization, please notify us at privacy@buyerassist.io so that we may consider and respond to your request in accordance with applicable law. If you would like to object to the processing of your Personal Data for direct marketing purposes, please use the mechanisms outlined in Section 8 (“What Are My Data Protection Rights”).

For your protection, we only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we need to verify your identity before implementing your request. We will respond to your request within 30 days.

Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such access, change or deletion.

7. For how long will BuyerAssist retain my personal data?

We will retain your Personal Data for a period of time consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes and enforce applicable agreements.

8. What are my data protection rights?

You have the following data protection rights:

• You can access, review, change, update or delete your Personal Data at any time by contacting us at privacy@buyerassist.io.
• To remove your Personal Data from a Website testimonial or request removal of your Personal Data from our blog or community forum, contact us at privacy@buyerassist.io. In some cases, we may not be able to remove your Personal Data, in which case we will let you know if we are unable to do so and why.
• In addition, if you are a resident of the European Union, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. To exercise these rights email privacy@buyerassist.io.
• You can opt out of receiving promotional emails from us by emailing privacy@buyerassist.io. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or other transactional, non-marketing/administrative related purposes.
• If we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area (“EEA”), Switzerland and certain non-European countries (including the US and Canada) are available here.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your Personal Data.

9. What rights do I have if I am a California consumer?

The information in this section applies to residents of California. Please contact us at privacy@buyerassist.io if you have any questions about this privacy policy, including this section specific to California residents, or if you would like a printed copy of this privacy policy. You may also print a copy of this privacy policy by selecting the “Print” button in your web browser.

10. How we collect and use personal information

This section describes the personal information (as defined by the California Consumer Privacy Act of 2018 or the “CCPA”) we may collect about California residents, the intended sources of that information, our business or commercial purposes for collecting the information, and the third parties with whom we may share that information. Please refer to the corresponding sections of this policy for details on the following:

• Information We Collect and How We Collect It: this section describes the categories of personal information we collect and the categories of sources from which the information will be collected.
• How We Use Your Information: this section describes the business or commercial purposes for which we collect the information.
• How We Share Your Information: this section lists the categories of third parties with whom we will share personal information.

Your rights and how to exercise them

California residents have certain rights under the CCPA. Those rights may only apply in certain circumstances and may be subject to limitations or exceptions. A summary of those rights is provided below as well as information on how to exercise your rights. Please note that by requesting to exercise any of these rights, represent that you are a California resident. Also note that we will require certain identifying information about you as necessary for us to verify your request in accordance with applicable law.

• Right to Know: You have the right to know what personal information we collect, use, disclose and/or sell about you. To exercise this right, please email us on privacy@buyerassist.io with the necessary details.
• Right to Opt Out of Sale: You have the right to opt out or ask us not to sell your personal information. To exercise this right, please email us on privacy@buyerassist.io with the necessary details. We do not sell your personal information in exchange for money. We do share certain information with third parties to market products, services, and other offers we think may be of interest to you. The CCPA broadly defines the concept of “selling” information so we offer the opportunity for CA residents to opt out of our sharing information with third parties in this manner. Please note that if you opt out of this information sharing with us, we will remove you from these activities; however, other companies may continue to use and disclose your information in the same manner. You should opt out of these practices with those other companies and websites, as applicable.
• Right to Delete: You have the right to request us to delete the personal information we collect or maintain about you. To exercise this right, please email us on privacy@buyerassist.io with the necessary details. Please note that certain exceptions may apply to your right to delete information, such as when we must retain your information to comply with law. We will notify you if any such exceptions apply to your request.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for exercising any of your rights under the CCPA. However, we may offer certain financial incentives, charge reasonable fees related to your requests, or deny your right to know, right to opt out of sale or right to deletion in accordance with applicable law.

You can exercise these rights yourself or you can designate an authorized agent to make a request on your behalf. Your authorized agent must be able to demonstrate authority to act on your behalf as further instructed when submitting a verifiable request on your behalf.

Can children use BuyerAssist’s Sites?

The Website and its content are not directed at children. We do not knowingly collect any information from anyone under 13 years of age. If you are under the age of 18, you may not use this Website unless you have the consent of, and are supervised by, a parent or guardian.

Sensitive information

We ask that you not send us or disclose any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Sites or via other means.

Changes to this Privacy Notice

We will update this Privacy Notice from time to time in response to changing legal, technical or business developments. The most current version of this Privacy Notice will govern our use of your Personal Data. If we make a material update to our Privacy Notice, we may provide you with notice prior to the update taking effect, consistent with the significance of the updates we make. We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing and sharing of your Personal Data. You can see when this Privacy Notice was last updated by checking the “last modified” date displayed at the top of this Privacy Notice.

EU data protection

Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in the Privacy Notice. We also comply with certain legal frameworks relating to the transfer of data, such as the European frameworks described below.

The European Commission has determined that certain countries outside of the European Economic Area (EEA) adequately protect Personal Data. You can review current European Commission adequacy decisions here. To transfer data from the EEA to other countries, such as the United States, we comply with legal frameworks that establish an equivalent level of protection with EU law.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection and privacy laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, the BuyerAssist group of companies (BuyerAssist.io, Inc. and its subsidiaries) operates around the world, viz. in the United States, India and any other location as listed on our contact page. We also use cloud applications hosted by third-party service providers, whose servers are often located in the United States and other locations across the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group of companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection and privacy law.

Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Questions, concerns or complaints

Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information as a data Controller, please contact CEO, BuyerAssist.io, Inc by email at privacy@buyerassist.io, or by mail at: 355 Bryant Street, #403 San Francisco, CA 94107, ATTN: Privacy, Legal.

DPO contact details: Amit Dugar, amit@getboomerang.ai, 415-316-5162.

Because email communications are not always secure, please do not include credit card information or other sensitive information in your emails to us.

BuyerAssist will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

If you are from certain regions like Europe, you also have the right to lodge any complaints or concerns with your DPA. You can find a list of the European DPAs here.

App notice

Boomerang App for ChatGPT

This section is specific to the App. The rest of this Privacy Notice, above, covers our marketing websites and cookies; where the two overlap, this section governs use of the App.

1. What the App does

The App lets a signed-in Boomerang user search the data already held in their Boomerang workspace — target accounts (companies), target contacts (prospects), workspace members and Super Connectors — and upload small files for use in the conversation. All tools exposed to ChatGPT are read-only. The App cannot create, edit or delete Boomerang records, send email, or trigger workflows. A full tool-by-tool list of inputs and outputs is in the Appendix below.

2. Data we collect through the App

Data returned to ChatGPT (tool outputs). In response to a tool call the App returns records from your workspace. These records can contain personal data about people who are not users of the App:

• Target contacts (prospects): first and last name, work email, job title, most-recent title, employer, LinkedIn profile URL, profile-picture URL, ICP persona grade (A–D), CRM record ID, internal IDs.
• Accounts (companies): name, domain, website, LinkedIn page, office city, state, country and ZIP, industry, employee size, relationship strength, ICP status, CRM record ID and CRM URL, internal IDs.
• Workspace members and Super Connectors: name, work email, roles, LinkedIn ID and URL, category, date added, management flag, and — via get_super_connector_metadata_bulk — provisioning evidence explaining why the person was added as a connector (e.g. employment history overlap, investor or board relationships, public-research findings, calendar-meeting evidence, and a notes summary).
• Workspaces: name, description, type, contact counts, configuration values, logo, your roles.
• You: user ID, name, email (get_current_user).

This data originates from your organization’s Boomerang workspace: CRM syncs (Salesforce, HubSpot), CSV imports, LinkedIn and ledger uploads, calendar and email metadata you or your organization connected, and Boomerang’s enrichment of public professional-profile data. Boomerang processes it on behalf of your organization under our customer agreement; your organization is the controller of that data.

What we do not collect. The App does not receive, request, or reconstruct your ChatGPT conversation history. It receives only the tool-call parameters listed above. We do not collect payment card data, health data, government identifiers, passwords or other credentials through tool inputs, and you should not put such data in uploaded files. We do not collect location data from ChatGPT.

3. Why we use it (purposes)

We do not use App data to train AI models, for advertising, or for profiling of App users. We do not sell personal data.

4. Who receives it (recipients)

We do not share App data with data brokers or advertising partners.

5. How long we keep it (retention)

6. Your controls

• Disconnect: remove the Boomerang app in ChatGPT (Settings → Apps/Connectors). This revokes ChatGPT’s access; no further data flows.
• Revoke from our side: email privacy@buyerassist.io or ask your workspace admin; we revoke the OAuth client session.
• Delete uploaded files: email privacy@buyerassist.io with the file name and approximate upload time; we delete within 30 days.
• Access, correction, deletion, portability, objection, restriction: email privacy@buyerassist.io. We verify identity and respond within 30 days. EEA/UK and California rights — right to know, delete, opt out of sale or sharing (we do not sell or share for cross-context advertising), and non-discrimination — apply as described in the sections above.
• Prospects and connectors who are not App users: if your data appears in a Boomerang workspace and you want it removed, contact privacy@buyerassist.io; we will process the request directly or route it to the controlling customer.
• Workspace admins can remove members, delete contacts and accounts, and disable the workspace from the Boomerang web app; those changes are reflected immediately in App results.

7. Security

Traffic is TLS-encrypted. Every tool call is authenticated with a short-lived OAuth token and scoped to one user and one workspace; role checks are enforced server-side. Tool responses exclude auth secrets and debug payloads. Uploaded files are stored under a per-user key in a private S3 bucket.

8. International transfers

Data is processed in the United States. For EEA and UK personal data we rely on Standard Contractual Clauses with our processors and within our group (US, India).

9. Children

The App is for business users and is not directed at anyone under 18.

10. Changes

We will update this notice when the App’s tools, data flows or recipients change, and update the effective date. Material changes are announced in the Boomerang app.

Appendix: tools exposed to ChatGPT (current build)

All tools are read-only. Every tool also accepts _triggered_by (the triggering user message; see section 2) and injects your user ID and active workspace ID from the session.