Privacy Policy

This Privacy Policy (“Policy”) explains how Personal Data is collected, used, processed, shared and protected when you access or use bethebossclub.com (the “Website”), participate in the Be the Boss program (the “Program”), create or manage a Boss Portal, or use related technology, marketing, AI, analytics and other services made available in connection with the Program (collectively, the “Services”).

This Policy describes how Personal Data is handled in connection with the Website, Program and Services.

We are committed to ensuring transparency in our data processing practices and complying with applicable privacy and data protection laws, including, where applicable, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other relevant data protection legislation.

By accessing or using the Website, Program or Services, you acknowledge that you have read and understood this Policy.

This Policy describes:

• the types of Personal Data we collect and how we obtain it, including information you provide directly and information collected automatically through your use of the Website, Program and Services;
• how we use, process and store your Personal Data;
• the legal bases for processing your Personal Data under applicable data protection laws;
• how we share Personal Data with service providers, affiliated entities, regulatory authorities and other third parties;
• the security measures we implement to protect Personal Data; and
• your rights in relation to your Personal Data and how you can exercise them.

“Personal Data” means any information that identifies, relates to, describes or could reasonably be linked, directly or indirectly, to an identifiable natural person.

This Policy primarily applies to Personal Data processed in connection with participation in the Be the Boss Program and use of the Website and Services by Bosses, prospective Bosses, representatives of business entities, affiliates and other business partners.

Where users access gaming or other player-facing services through a Boss Portal, the processing of their Personal Data in connection with those services is governed by the privacy policy applicable to the relevant player-facing service.

The Be the Boss Program and related Services are operated by Play Media Limited, a company incorporated in the Autonomous Island of Anjouan, Union of Comoros (“Company”, “Play Media”, “we”, “us” or “our”).

Play Media Limited acts as the data controller responsible for the collection, use and processing of Personal Data in connection with the Website, Program and Services, except where another entity acts as an independent controller in respect of a particular service or processing activity.

Certain Services may involve affiliated entities or independent third-party service providers that process Personal Data either on our behalf or as independent data controllers in accordance with their own privacy policies.

If you have questions about this Policy or your Personal Data, or would like to exercise your data protection rights, you may contact us at support@playmedialimited.com or through the official support channels available on the Website.

We may collect Personal Data in the following ways:

• when you register for or create a Boss account;
• when you apply to participate in or participate in the Program;
• when you create, configure or manage a Boss Portal, subdomain or domain;
• when you provide information for KYC, KYB, compliance, regulatory or verification purposes;
• when you purchase or use subscriptions, packages, marketing services, AI Tools or other paid Services;
• when you connect a social-media or other third-party account to the Services;
• when you use AI, automation, analytics, dashboard or marketing functionality;
• when you refer users, affiliates or other Bosses through the Program;
• when compensation, commissions, payments or other amounts are calculated or processed in connection with your participation in the Program;
• when you communicate with us through customer support or other official communication channels;
• when we receive information from payment processors, verification providers, social-media platforms, technology providers or other third parties involved in providing the Services; and
• when we automatically collect information about your use of the Website and Services through cookies, logs and similar technologies.

We seek to limit the Personal Data we collect directly to what is reasonably necessary for the operation of the Program and provision of the Services. Where appropriate, certain information may be collected and processed directly by third-party service providers, such as payment processors, identity or business verification providers, authentication providers, wallet technology providers and connected social-media platforms. In such cases, we may receive only the information, confirmation or results necessary for the relevant purpose.

Providing Personal Data is generally voluntary. However, certain information is necessary for us to provide the Website, Program or Services, establish and manage your Boss account, process payments, administer your participation in the Program, comply with applicable regulatory requirements or provide particular functionality.

If you do not provide information that is required for these purposes, we may be unable to register or maintain your account, provide certain Services, process payments or compensation, complete verification procedures, or allow you to participate in some or all aspects of the Program.

Certain processing activities, including non-essential cookies, marketing communications and the connection of certain third-party accounts, may require your consent or separate authorization. Where processing is based on consent, you may withdraw that consent in accordance with applicable law.

The Personal Data we collect depends on how you access and use the Program and Services. Certain information is collected as part of the standard account registration process, while other information may be collected only where you use particular Services or where required for verification, compliance, payment or other purposes.

Personal Data Collected Upon Registration:

When you register for or access a Boss account, we collect certain information necessary to establish and maintain your account, including:

• email address;
• crypto wallet address; and
• account identifiers and authentication information.

You may register or access your account using supported third-party authentication methods, such as Google, Apple or a compatible crypto wallet provider. When you use a third-party authentication method, we may receive information associated with your account in accordance with the permissions you grant to that provider.

You may connect an existing crypto wallet to your account. Where supported, a wallet may also be created for you automatically through the wallet technology used by the Platform. In such cases, we process the wallet address and information necessary to associate the wallet with your Boss account.

Depending on your participation in the Program, the Services you use and applicable verification or compliance requirements, we may also collect additional Personal Data, including:

• full name;
• telephone number;
• Telegram username or identifier;
• country of residence;
• residential or business address;
• business or professional information; and
• other information reasonably necessary to provide the relevant Services or administer your participation in the Program.

Personal Data Collected During Use of the Program and Services:

• Boss account and profile information;
• Boss Portal, subdomain and domain information;
• configuration and settings associated with your Boss Portal;
• dashboard activity and use of Program functionality;
• referral, attribution and traffic information;
• information concerning users, affiliates or other Bosses attributed to your activities, to the extent necessary to administer the Program;
• statistics, analytics, performance and engagement information;
• subscription, package and Service information;
• payment and compensation records;
• communications and interactions with the Company; and
• records relating to use of marketing, automation and AI Tools.

Know Your Customer (KYC) and Know Your Business (KYB) Data, where applicable:

Where identity or business verification is required, verification may be performed by third-party verification or compliance providers. Depending on the relevant process, certain identification documents and verification information may be collected and processed directly by those providers rather than by us.

We may receive verification results and, where necessary for compliance, due diligence, licensing or regulatory purposes, may collect or receive:

• full legal name;
• date of birth;
• nationality and country of residence;
• residential or business address;
• passport, national identity card or other government-issued identification;
• proof of address;
• company name, registration number, registered address and jurisdiction of incorporation;
• information relating to directors, officers, shareholders, Ultimate Beneficial Owners (“UBOs”) and authorized representatives;
• ownership and control information;
• professional title, role and business contact information;
• source-of-funds or related compliance information, where required; and
• additional documents or information reasonably required for KYC, KYB, AML, sanctions screening, fraud-prevention, licensing or other regulatory or compliance purposes.

Information collected for these purposes may also be used to verify eligibility to participate in the Program, conduct due diligence and compliance assessments, manage our business relationship with you, and satisfy applicable legal, licensing and regulatory requirements, including requirements relating to Boss Portals, domains or subdomains.

Personal Data You Provide Voluntarily:

• information submitted through customer support or other communications;
• feedback, requests or complaints;
• materials uploaded or otherwise provided in connection with your Boss Portal or marketing activities; and
• other information you choose to provide to us.

AI Tools and Connected Third-Party Accounts:

Where you use AI Tools or connect a social-media or other third-party account to the Services, we may collect and process information such as:

• your email address and associated Boss Portal or subdomain;
• the connected social-media platform, account identifiers and available profile information;
• the date and status of the connection;
• authorization and permission information, including authentication or access tokens where technically required;
• follower counts and other available social-media metrics;
• content, instructions, prompts or other information submitted to AI Tools;
• AI-generated or AI-assisted content;
• content scheduled, published, transmitted or managed through the Services;
• publication, campaign and engagement information; and
• technical and operational information necessary to maintain the connection and provide the requested functionality.

The categories of information available to us depend on the relevant platform, integration, permissions granted and functionality activated.

Payment and Transaction Information:

We may process information relating to payments for subscriptions, packages, domains, marketing, AI Tools and other Services, including:

• transaction amount and currency;
• payment status;
• transaction and payment identifiers;
• billing information;
• payment method type; and
• information received from payment processors concerning successful, unsuccessful, disputed, refunded or reversed transactions.

Complete payment-card credentials may be collected and processed directly by third-party payment service providers and may not be received or stored by us.

Automatically Collected Data:

• IP address;
• device type;
• operating system;
• browser information;
• session and log information;
• Website and Service interactions;
• timestamps;
• approximate or general location derived from your connection; and
• information collected through cookies and similar technologies.

Third-Party Data:

We may receive Personal Data from third parties, including payment processors, identity and business-verification providers, fraud-prevention and compliance providers, analytics providers, social-media platforms, AI and technology providers, affiliated entities and publicly available sources.

We may process Personal Data for the following purposes:

• to register, authenticate and manage Boss accounts;
• to provide and administer the Website, Program, Boss Portals and Services;
• to create, configure, maintain and administer Boss Portals, subdomains and domains;
• to provide dashboards, statistics, analytics and attribution functionality;
• to track referrals and administer Program participation;
• to calculate and administer compensation, commissions or other amounts payable in connection with the Program;
• to provide subscriptions, marketing services, AI Tools, automation and other functionality;
• to connect and maintain authorized third-party integrations;
• to generate, schedule, manage or publish content where you activate the relevant AI or automation functionality;
• to process payments and maintain transaction records;
• to perform KYC, KYB, sanctions, AML, fraud-prevention and other compliance checks where applicable;
• to satisfy licensing, regulatory and legal requirements;
• to detect, investigate and prevent fraudulent, abusive, suspicious or unauthorized activity;
• to maintain the security and integrity of the Website, Program and Services;
• to provide customer support and resolve technical or account-related issues;
• to analyze and improve the Website, Program and Services;
• to manage our relationships with Bosses, affiliates, service providers and other business partners;
• to send operational, account-related and service communications; and
• where permitted by applicable law or based on your consent, to send marketing or promotional communications.

We process Personal Data only where there is an appropriate legal basis under applicable law. Depending on the circumstances, this may include performance of a contract, steps taken at your request before entering into a contract, compliance with a legal obligation, our legitimate interests or those of a third party, or consent where required.

Payments relating to subscriptions, packages, domains, marketing services, AI Tools or other paid Services may be collected by Play Media, an affiliated entity acting as an authorized payment collection agent, or processed through third-party payment service providers.

Where payments are processed by a third-party payment service provider, payment information may be provided directly to that provider. The provider may process such information in accordance with its own terms and privacy policy.

We may receive transaction-related information from payment providers, including transaction identifiers, payment status, amount, currency, payment method type and information concerning refunds, reversals or disputes.

We do not generally need to receive or store complete payment-card credentials where payment information is processed directly by a payment service provider.

Payments, compensation or other settlements associated with the Program may also be processed using other payment methods or technologies made available from time to time.

We implement appropriate technical and organizational measures designed to protect Personal Data and transaction information. However, no payment or information system can be guaranteed to be completely secure.

We do not sell your Personal Data.

We may disclose or make Personal Data available to third parties where reasonably necessary to operate the Website, Program and Services, perform our contractual obligations, process payments, provide requested functionality, comply with applicable law or protect the Company, the Program and its users.

These third parties may include:

• Payment processors and financial service providers, which may process payment and transaction information and conduct financial, fraud-prevention or compliance checks;
• Affiliated companies, including where an affiliate provides technology, operational, administrative or payment-collection services in connection with the Program;
• KYC, KYB, identity verification and compliance providers, which may process identity documents, company information and other information required for verification, AML, sanctions, fraud-prevention or compliance purposes;
• AI model and technology providers, which may process information required to provide AI-powered functionality, content generation, automation or related Services;
• Social-media platforms and integration providers, where you connect an account or authorize functionality involving a third-party platform;
• Hosting, infrastructure and technology providers, which support the Website, Program, Boss Portals and related systems;
• Analytics and performance providers, which assist us in understanding usage, performance and security;
• Advertising and marketing service providers, where used to deliver, manage or measure marketing activities;
• Professional advisers, including legal, compliance, accounting and audit advisers where reasonably necessary;
• Licensing and regulatory authorities, including relevant Anjouan authorities, where information is required in connection with licensing, regulatory compliance, Boss Portal or subdomain validation, investigations or other regulatory requirements; and
• Law enforcement agencies, courts and other public authorities, where disclosure is required or permitted by applicable law.

Service providers acting on our behalf are required, where applicable, to process Personal Data in accordance with appropriate contractual and data protection obligations.

Certain third parties, including payment providers, social-media platforms and other independent service providers, may process Personal Data as independent data controllers under their own privacy policies and terms. We do not control their independent processing practices.

We use cookies and similar technologies to operate the Website and Services and to improve functionality, security and user experience.

These technologies may be used to:

• maintain sessions and authentication;
• remember preferences and settings;
• maintain security and prevent fraud;
• understand how the Website and Services are used;
• analyze performance and improve functionality; and
• provide or measure marketing and promotional activities where permitted.

You can control or disable certain cookies through your browser or available cookie-management settings. Disabling certain cookies may affect your ability to use some features of the Website or Services.

Where required by applicable law, we obtain consent before placing non-essential cookies or similar technologies on your device.

For more information regarding cookies and similar technologies, please see our Cookies Policy.

Depending on your jurisdiction and applicable data protection laws, you may have rights in relation to your Personal Data, including:

• Right to Access – to request information about the Personal Data we process about you;
• Right to Rectification – to request correction of inaccurate or incomplete Personal Data;
• Right to Erasure – to request deletion of Personal Data in circumstances provided by applicable law;
• Right to Restrict Processing – to request restriction of certain processing activities;
• Right to Data Portability – to receive certain Personal Data in a structured, commonly used and machine-readable format where applicable;
• Right to Object – to object to certain processing based on legitimate interests or to processing for direct marketing purposes; and
• Right to Withdraw Consent – where processing is based on consent, to withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

You may also have the right to lodge a complaint with the competent data protection authority in your jurisdiction.

Account deletion or termination of participation in the Program does not necessarily result in immediate deletion of all Personal Data associated with the account.

Where you request deletion of Personal Data, we will process the request in accordance with applicable data protection laws and may retain information where necessary or permitted for purposes including:

• compliance with legal, tax, accounting, AML, licensing or regulatory obligations;
• fraud prevention and security;
• establishing, exercising or defending legal claims;
• maintaining records of payments, compensation and contractual relationships;
• investigating suspected violations of the Terms or applicable law; and
• maintaining records reasonably necessary to protect the integrity of the Program.

Where information is no longer required and no lawful basis for continued retention exists, we will delete or anonymize it in accordance with our retention practices.

Where an account is associated with participation in the Be the Boss Program and includes a dedicated Boss Portal, subdomain or branded instance of the Services, deletion or closure of the Boss account may result in termination of the associated Program access.

Following account closure:

• the associated Boss Portal or subdomain may be deactivated;
• access to dashboards, statistics, analytics and Program functionality may be removed;
• promotional or participation rights associated with the account may terminate;
• connected third-party accounts may be disconnected; and
• the relevant subdomain may be reclaimed, reassigned or retired by the Company in accordance with the Terms.

Account closure does not necessarily require deletion of historical records relating to referrals, payments, compensation, regulatory matters, compliance checks or other information that the Company is required or permitted to retain.

Information previously transmitted to independent third-party platforms, including social-media platforms, may remain subject to the retention practices and privacy policies of those platforms.

We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected or as required or permitted by applicable legal, regulatory, tax, accounting, contractual or compliance obligations.

Retention periods may vary depending on the type of information and the context in which it is processed.

For example:

• Boss account, contractual, payment and compensation records may be retained for the duration of the business relationship and for an appropriate period thereafter where necessary for legal, regulatory, tax, accounting, fraud-prevention or dispute-resolution purposes;
• KYC and KYB records, where collected, may be retained for the periods required under applicable AML, licensing and regulatory requirements;
• regulatory and compliance records may be retained for the period necessary to demonstrate compliance with applicable requirements;
• support inquiries and correspondence may be retained for an appropriate period following resolution of the relevant matter;
• AI Tool, integration and connected-account data may be retained for as long as necessary to provide the relevant functionality and for reasonable security, compliance and operational purposes; and
• analytics and technical logs may be retained for shorter periods depending on operational, security and legal requirements.

Where Personal Data is no longer necessary for the relevant purposes and there is no lawful reason to retain it, we will delete or anonymize it.

We may retain anonymized or aggregated information that no longer identifies an individual.

The Company operates internationally and uses service providers and technology infrastructure located in different jurisdictions. As a result, Personal Data may be transferred to and processed in countries outside your country of residence.

Where Personal Data is transferred outside the European Economic Area (“EEA”), United Kingdom or another jurisdiction that imposes restrictions on international data transfers, we take appropriate steps to ensure that transfers are made in accordance with applicable data protection laws.

Depending on the circumstances, these safeguards may include:

• Standard Contractual Clauses approved by the European Commission or another competent authority;
• adequacy decisions;
• contractual, technical and organizational safeguards; or
• another lawful transfer mechanism available under applicable law.

Personal Data processed by independent third-party platforms or service providers may also be transferred internationally in accordance with those providers' respective privacy policies and transfer mechanisms.

We implement appropriate technical and organizational measures designed to protect Personal Data against unauthorized access, disclosure, loss, misuse, alteration or destruction.

Depending on the relevant systems and Services, these measures may include:

• access controls and role-based permissions;
• secure authentication mechanisms;
• encryption and secure communication protocols, including HTTPS and TLS;
• monitoring and security tools designed to detect suspicious or unauthorized activity;
• controls relating to access to production and administrative systems;
• internal policies and procedures concerning data protection and information security; and
• appropriate security measures implemented by service providers processing Personal Data on our behalf.

Where you connect a third-party account to the Services, you remain responsible for maintaining the security of that account, including passwords, authentication methods, recovery mechanisms and administrator access.

No system or method of transmission or storage can be guaranteed to be completely secure.

If you become aware of a potential security vulnerability or unauthorized access to your account, please contact us promptly at support@playmedialimited.com.

If you have any questions, concerns or requests regarding this Privacy Policy or our processing of Personal Data, please contact:

Play Media Limited

Registration No. 16288

Hamchako, Mutsamudu

Autonomous Island of Anjouan

Union of Comoros

Email: support@playmedialimited.com

We will address privacy-related inquiries and requests in accordance with applicable data protection laws.