Last Updated: June 1, 2025

If you have questions about CCPA, please contact us at privacy@aboon.com.

CALIFORNIA LAW REQUIRES THAT WE PROVIDE YOU THIS NOTICE ABOUT THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION. UPON REQUEST, THIS NOTICE CAN BE MADE AVAILABLE IN OTHER FORMATS BY CONTACTING PRIVACY@ABOON.COM.

Introduction

This notice describes the categories of personal information that Boon Business Solutions, Inc. d/b/a Aboon (“Aboon”) collects about California residents and how we use that information. For purposes of this notice, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 (the “CCPA”) as amended by the California Privacy Rights Act (CPRA). This notice excludes information exempted from the CCPA and does not create or form part of any contract for employment or otherwise. This notice applies to individuals accessing Aboon’s platform.

Types of Personal Information

The types of personal information we may collect and process includes:

• Contact Information: Email address, physical address, phone number, and login credentials
• Demographic Information: Name, gender, date of birth, professional history, title, level, education details
• Business Information: Company name, type of corporation, address, industry profile
• Payroll and Compensation Information: Salary, bonus, compensation history
• Professional Qualifications: Licenses, permits, memberships, and certifications

Providing personal information to us is voluntary. In certain cases, we may ask you for additional information for purposes of complying with applicable laws.

Sources of Personal Information

We collect personal information from you when you register your account to access Aboon. We may also collect your personal information from other sources and combine it with the personal information you provide us, including:

• Integrations with payroll platforms, human resource information systems, or collaboration software
• Your public social media profile or other publicly available sources
• Online activity information collected using cookies and similar technologies (see our Privacy Policy)
• Other company personnel

Use of Personal Information

We may use your personal information for the following purposes:

• Operating, maintaining, and improving our products and services
• Sending communications including account invites, confirmations, technical notices, security alerts, and system updates
• Responding to questions and providing customer or technical support
• Aggregating or combining personal information with other information
• Providing and delivering products and services
• Protecting against fraudulent, unauthorized, or illegal activity
• Complying with internal policies and procedures
• Protecting our, your, or others' rights, safety, and property

Sharing Personal Information

We may share your personal information with other parties as necessary for the purposes described above, including:

• Customers and Partners: Companies and individuals with whom Aboon does business or is exploring a business relationship
• Affiliates: Our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent
• Service Providers: Companies that provide us with services that help us operate our business
• Professional Service Providers: Lawyers, advisors, and other outside professional advisors
• Government Authorities: When required by law, court order, or similar legal process
• Business Transfers: Parties involved in potential business transactions such as a merger, acquisition, or sale of assets

Your Rights Under CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information:

Right to Know and Data Portability

You have the right to request that we disclose information about our collection and use of your personal information over the past 12 months, including:

• Categories of personal information collected
• Sources of personal information
• Business or commercial purpose for collecting or selling personal information
• Categories of third parties with whom we share personal information
• Specific pieces of personal information collected about you

Right to Delete

You have the right to request deletion of personal information we collected from you, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for specific purposes permitted by law, such as:

• Completing transactions, providing requested services, or fulfilling contractual obligations
• Security purposes and fraud prevention
• Debugging and error repairLegal compliance and exercising legal rights
• Internal uses aligned with your expectations based on your relationship with us

Right to Correct

You have the right to request correction of inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of processing.

Right to Limit Use of Sensitive Personal Information

While Aboon generally does not collect sensitive personal information as defined by the CPRA, you have the right to limit the use and disclosure of such information if applicable.

Exercising Your Rights

To exercise your CCPA/CPRA rights, please submit a request by emailing privacy@aboon.com.

Your request must:

• Provide sufficient information to verify your identity
• Describe your request with sufficient detail for us to properly respond

Authorized Agents

You may designate an authorized agent to make a request on your behalf. Authorized agents must provide proof of your written permission and verify their own identity with us.

Verification Process

We will verify your identity before fulfilling your request. The verification method will depend on the nature of your request and our relationship with you, but may include confirming details about information we already have on file.

Response Timing

We will respond to verified requests within 45 days. If we need more time (up to an additional 45 days), we will inform you in writing.

Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. Unless permitted by law, we will not:

• Deny you goods or services
• Charge different prices or rates for goods or services
• Provide a different level or quality of goods or services
• Suggest that you may receive different pricing or service levels

CCPA and Retirement Plan Data

As a Third Party Administrator (TPA) for 401k plans, Aboon handles certain data that may be subject to both ERISA and CCPA. Please note:

• Some retirement plan data may be exempt from CCPA requests due to federal preemption
• Personal information collected in the context of providing services to employer-sponsored retirement plans may be subject to different handling requirements
• We will clearly identify any data that cannot be included in CCPA requests due to other legal requirements

Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Notice and our Privacy Policy, unless a longer retention period is required by law. For retirement plan data, we typically maintain records for at least seven years in accordance with ERISA requirements.

Changes to This Notice

We may modify this CCPA Notice over time. Any changes will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this Notice to stay informed about how we are protecting your personal information.

Contact Information

For questions about this CCPA Notice or to exercise your rights, please contact us at privacy@aboon.com.