Steven Ma

Privacy and Cookies Policy

Privacy and Cookies Policy of www.stevenma.com

This is the privacy policy of www.stevenma.com (the Company, the Website, we, us and our) and covers this website and our activities regarding your Personal Data you provide to us.

We are committed to protecting the privacy of our site visitors and customers. Here you will find details of our privacy policy, information on what identifying information we collect from you, how we store and use this information, cookies that we use and ways that we may track you across our social media, website and emails we send you. From time to time, we may change and update this policy and post it on our website.

To get in touch with our Data Protection Officer with any concerns you may have about your privacy, please email us on info@stevenma.com using Privacy as the first word of your subject.

This policy was last updated on 3rd February 2023.

DEFINITIONS AND LEGAL REFERENCES

Personal Data (or Data) Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the users of this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by you, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment.

User (You) The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor) The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or the Company, the Website, we, us and our) The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is Booboobae L Ltd.

This Website The means by which your Personal Data is collected and processed.

Service The service provided by this Website as described in the Terms and Conditions and on this site.

European Union (or EU) Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie Cookies are Trackers consisting of small sets of data stored in your browser.

Tracker Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of users of this website, for example by accessing or storing information on your device.

LEGAL INFORMATION

This privacy statement has been prepared based on provisions of multiple legislations, including The Data Protection Act 2018 (General Data Protection Regulation).

This privacy policy relates solely to this Website, if not stated otherwise within this document.

OWNER OF WEBSITE AND DATA CONTROLLER

Booboobae L Ltd, 3403 Principal Tower, 2 Principal Place, London, EC2A 2BA, United Kingdom

Owner contact email: info@stevenma.com

TYPES OF DATA COLLECTED

We may collect and process information that you give to us by filling in forms on our website or by corresponding with us by phone, e-mail, in person or otherwise. Data which can be used to identify you, or Personal Data, we collect about you may include your name, date of birth, email address, billing/delivery address, Cookies, Usage Data, geographic location, gender, phone number, username, password, payment information, device information, unique device identifiers for advertising (e.g Google Advertiser ID) orders and products you have purchased from us and telephone numbers. We may also collect information about your social media handles if you interact with us through those platforms.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by you, or, in case of Usage Data, collected automatically when using this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for us to provide you services. In cases where this Website specifically states that some Data is not mandatory, you are free not to communicate this Data without consequences to the availability or the functioning of the Service. If you are uncertain about which Personal Data is mandatory, you are welcome to contact us for full details. Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by you, in addition to any other purposes described in the present document.

You are responsible for any third-party Personal Data obtained, published or shared through this Website and you confirm that you have the third party's consent to provide the Data to us.

MODE AND PLACE OF PROCESSING THE DATA

Methods of processing

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to ourselves, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, logistics providers, courier companies, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. The updated list of these parties may be requested from us at any time.

Legal basis of processing

We may process Personal Data relating to you if one of the following applies:

You have given your consent for one or more specific purposes. Note: Under some legislations we may be allowed to process Personal Data until you object to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which we are subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in our Company;
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at our operating offices and in any other places where the parties involved in the processing are located. Depending on your location, data transfers may involve transferring your Data to a country other than your own. To find out more about the place of processing of such transferred Data, you can check the section containing details about the processing of Personal Data. You are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your Data. If any such transfer takes place, You can find out more by checking the relevant sections of this document or write to us at info@stevenma.com.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between us and you shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests pursued by us within the relevant sections of this document or by contacting us.

We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

Data concerning you is collected to allow us to provide our Service, comply with our legal obligations, respond to enforcement requests, protect our rights and interests (or those of yours, other users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Location-based interactions, Displaying content from external platforms, Tag Management, Remarketing and behavioral targeting, Contacting you, Handling payments, Interaction with external social networks and platforms, Registration and authentication, Data transfer outside the EU, Traffic optimization and distribution, SPAM protection, Managing contacts and sending messages, Advertising, Platform services and hosting, Managing support and contact requests, Connecting Data, Selling goods and services online, Internal processing tools and Marketing.

For specific information about the Personal Data used for each purpose, you may refer to the section “Detailed information on the processing of Personal Data”.

COOKIES AND TRACKERS This website uses certain technologies that help this Website to achieve the purposes described below. Such technologies allow us to access and store information (for example by using a Cookie) or use resources (for example by running a script) on your device as you interact with this Website. For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate. For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

Some of the purposes for which Trackers are used may also require the your consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

This Website uses Trackers managed directly by ourselves (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.

The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by us or the relevant provider. Some of them expire upon termination of your browsing session.

In addition to what’s specified in the descriptions within each of the categories below, you may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers - in the linked privacy policies of the respective third-party providers or by contacting us.

Types of activities we need to use Cookies and Trackers to perform are listed below and further details on Cookies and Trackers used, are listed in the “Detailed information on the processing of personal data and trackers”

Activities involving the use of trackers

Activities strictly necessary for the operation of this Website and delivery of the Service: This Website uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service

SPAM protection: This type of service analyzes the traffic of this Website, potentially containing your Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Other activities involving the use of Trackers

Basic interactions & functionalities: This Website uses Trackers to enable basic interactions and functionalities, allowing you to access selected features of the Service and facilitating the your communication with us.

Connecting Data: This type of service allows us to connect Data with third-party services disclosed within this Privacy and Cookies policy. This results in Data flowing through these services, potentially causing the retention of this Data.
Managing support and contact requests: This type of service allows us to manage support and contact requests received via email or by other means, such as the contact form.
Selling goods and services online: This type of service helps us to sell goods, provide services or monetize online content. To this end, the services listed below may for instance allow us to process payments, set up subscription models, track orders, and manage deliveries.

Experience enhancement: This Website uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms.

Displaying content from external platforms: This type of services allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when you do not use it.

Measurement: This Website uses Trackers to measure traffic and analyze user behavior with the goal of improving the Service.

Analytics: These services enable us to monitor and analyze web traffic and can be used to keep track of user behavior.
Anonymized analytics services These services enable us, through the use of third-party Trackers, to collect and manage analytics in an anonymized form.

Targeting & Advertising:This Website uses Trackers to deliver personalized marketing content based on user behavior and to operate, serve and track ads.

Some of the advertising services used by us adhere to the IAB Transparency and Consent Framework, an initiative that facilitates responsible privacy practices across the digital advertising industry - providing you with enhanced transparency and control over how your data are used for advertising tracking purposes.

Advertising: This type of service allows your Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on your interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, You may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Managing contacts and sending messages This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with you. These services may also collect data concerning the date and time when the message was viewed by you, as well as when you interacted with it, such as by clicking on links included in the message.
Remarketing and behavioral targeting: This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by you. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out feature provided by any of the services below, you may opt out by visiting the Network Advertising Initiative opt-out page. You may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

How to manage preferences and provide or withdraw consent

There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant.

You can manage preferences related to Trackers from directly within your own device settings, for example, by preventing the use or storage of Trackers. It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the your initial consent. Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.

With regard to any third-party Trackers, You can manage their preferences and withdraw your consent via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.

Locating Tracker Settings

You can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

You may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (You may open the device settings and look for the relevant setting).

How to opt out of interest-based advertising

Notwithstanding the above, you may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow you to select their tracking preferences for most of the advertising tools. We recommend that you make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps you to control interest-based advertising on mobile apps.

Note on Third Party Trackers

Since the use of third-party Trackers through this Website cannot be fully controlled by us, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, you are kindly requested to consult the privacy policies of the respective third-party services listed in this document.

Given the objective complexity surrounding tracking technologies, you are encouraged to contact us should you wish to receive any further information on the use of such technologies by this Website.

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA AND TRACKERS

Personal Data is collected for and Trackers are used for the following purposes and using the following services:

Advertising

This type of service allows Usage Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on your interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Trackers to identify you or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the you interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services. Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, you may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

Facebook Lookalike Audience

Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, that uses Data collected through Facebook Custom Audience in order to display ads to you with similar behavior to other users who are already in a Custom Audience list on the base of their past use of this Website or engagement with relevant content across the Facebook apps and services. On the base of these Data, personalized ads will be shown you suggested by Facebook Lookalike Audience.

You can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Analytics

The services contained in this section enable us to monitor and analyze web traffic and can be used to keep track of User behavior.

Display Advertising extension for Google Analytics (Google Inc.)

Google Analytics on this Website might use Google's Interest-based advertising, 3rd-party audience data and information from the DoubleClick Cookie to extend analytics with demographics, interests and ads interaction data.