Privacy Policy

BOOKOO TECH LIMITED Privacy Policy

Last updated: 2024/06/27

We bookoocoffee.com including all affiliates and subsidiaries (hereinafter referred to as “bookoocoffee.com”, “us” or “we”) are committed to protecting your privacy. Our goal is to provide you with a positive experience on our website www.bookoocoffee.com (“Website”), while at the same time keeping your Personal Information secure.

Your privacy is important to us. Please read this Privacy Policy to learn about the information that we may collect from you and how we use and protect your information. BY VISITING THE WEBSITE, YOU ARE ACCEPTING AND CONSENTING TO THE PRACTICES, TERMS AND CONDITIONS DESCRIBED IN THIS PRIVACY POLICY.

1. About this policy

The Privacy Policy (“Policy“) applies when you purchase and/or use the following products or services:

• BOOKOO Websites (such as bookoocoffee.com);
• Other customer-supporting services provided by BOOKOO and/or its partners, including but not limited to customer support service (“BOOKOOServices”).

For the purpose of this Policy, the above products and services are collectively referred to as “BOOKOO Products and Services“. From time to time, we may develop new or offer additional services or products. Such new products and services will also be subject to this Policy, unless otherwise stated when they are launched by us.

2. Personal Data We Collect

The types of personal information we obtain about you depend on how you interact with our Site and use our Services. When we use the term “personal information”, we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

• Information We Collect Directly from You

Information that you directly submit to us through our Services may include:

– Basic contact details including your name, address, phone number, email.

– Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.

– Account information including your username, password, and security questions.

– Shopping information including the items you view, put in your cart or add to your wishlist.

– Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

• Information We Collect Through Cookies

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, pixels and similar technologies (“Cookies”). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

• Information We Obtain from Third Parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

– Companies who support our Site and Services, such as WordPress.

– Our payment processors collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.

– When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links.

3. Cookies

Like many websites, we use Cookies on our Site. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

4. How We Use Your Personal Data

We use your personal data only on the legal basis permitted by applicable privacy laws. According to applicable local laws, we may use your personal data for the following purposes under one or some of the legal bases: your consent; necessary to perform/enter into a contract between you and us; necessary to protect the legitimate interests of you or others; necessary to fulfill legal obligations; and necessary to protect the legitimate interests of enterprises.

Where we process your personal data to fulfill a legitimate interest, then we have carried out a balancing test to consider whether our interests are overridden by your interests and rights. You can ask us for more information about this by using the contact details at the end of the Policy.

– Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and to enable you to post reviews.

– Marketing and Advertising. We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites.

– Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.

– Communicating with you. We use your personal information to provide you with customer support and improve our services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you.

5. Your Privacy Rights

We protect your rights over your personal data in accordance with GDPR and other applicable laws.

Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. We will be responsible for responding to your request within the relevant periods provided by law

Below we have listed your rights regarding your personal data, including a description of the right (“Right“), and instructions on how to exercise the right (“How to exercise“). For each right, we also specify the circumstances in which it applies, which may include the required Legal Basis.

Be Informed (Art. 13/14 GDPR)

• Right be informed of the personal data we process about you and how we process it.
• How to exercise: You will be informed of the personal data we process about you and how we process it through this Policy, information provided to you when you use BOOKOO Products and Services, or by contacting us at support@bookoocoffee.com.

Right of Access (Art. 15 GDPR)

• Right: Request access to the personal data we process about you.
• How to exercise: You may request access and a copy of your personal data from BOOKOO by contacting us at support@bookoocoffee.com.

When you download your data, you will receive the information about your data that BOOKOO has to provide under Article 15 of the GDPR.

Right of Rectification (Art. 16 GDPR)

• Right: You may request that we amend or update your personal data where it’s inaccurate or incomplete.
• How to exercise: You can edit your Account data by contacting us at support@bookoocoffee.com.

Right of Erasure (“Right to be Forgotten”) (Art. 17 GDPR)

• Right: You may request us to erase certain of your personal data.

For example, you can ask us to erase the personal data:

• which is no longer needed by us in relation to the purpose for which they were collected or otherwise processed;
• which we have been processing based on the legal basis of consent, provided that you withdraw your consent;
• Which has been unlawfully processed by us (if any);
• which you have objected to process (see Section Object in Chapter 4 Your Privacy Rights below); or
• in other scenarios stipulated by law.

In certain situations, BOOKOO is unable to delete your personal data in responding to your requests, including:

• when such personal data is still necessary to be processed to achieve the purpose we collected it for;
• BOOKOO’s interest in using the data overrides your interest in having it deleted (e.g., when we need to process the personal data to protect our services from fraud);
• BOOKOO has a legal obligation to keep relevant personal data; or
• BOOKOO needs the personal data to establish, exercise or defend itself from a legal claim (e.g., when there’s an unresolved dispute relating to your account).
• How to exercise: You can request to delete your Personal Data by contacting us at support@bookoocoffee.com.

Right of Restriction (Art. 18 GDPR)

• Right: You may request restrictions on processing your personal data where:
• You are challenging the accuracy of the information;
• The information has been unlawfully processed, but you are opposing the deletion of that information;
• We no longer need your information for a specific purpose, but such information is required by the data subject for the establishment, exercise or defense of legal claims; or
• You have objected to our processing and we are assessing your objection request (See Section Right to Object in Chapter 4 Your Privacy Rights below).

You may request us to stop processing your personal data temporarily or permanently.

• How to exercise: you can exercise your right to restriction by contacting us at support@bookoocoffee.com.

Right to Object (Art. 21 GDPR)

• Right: You may object to our processing of your personal data in certain circumstances. This right applies when we are performing a task in the public interest, pursuing our legitimate interests or those of a third party or when you object to the processing of your personal data for direct marketing purposes.
• How to exercise: You may use controls on the BOOKOO Services to switch off or adjust some features that process your personal data. See the end of this section on how you can control tailored advertising, or contact us at support@bookoocoffee.com.

Right of Portability (Art. 20 GDPR)

• Right: You may request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service, when we are processing your personal data on the Legal Basis of consent or performance of contract. BOOKOO will try to respond to your request to the extent possible.
• How to exercise: for information about how to exercise the right to portability, please See Section Right of Access above.

Not Be Subject to Automated Decision Making (Art. 22 GDPR)

• Right: You have the right not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
• How to exercise: BOOKOO does not engage in this type of automated decision-making so far when providing the BOOKOO Products and Services.

Withdrawal of Consent (Art. 7 GDPR)

• Right: You have the right to withdraw your consent from us on processing your personal data. You can implement your right of withdrawing your consent when BOOKOO is processing your personal data on the Legal Basis of consent.
• How to exercise: You can adjust the relevant control on BOOKOO, or contact us at support@bookoocoffee.com.

Right to Lodge a Complaint (Art. 77 GDPR)

• Right: You may contact the European Data Protection Board (“EDPB“) for Privacy Protection or your local data protection authority about any questions or concerns regarding your personal data.
• How to exercise: You can find the EDPB’s details here. You can also go to the website of your local data protection authority to lodge a complaint.

When you want to implement your rights mentioned above, we kindly ask you to:

• Submit requests through the channels we provided above.
• Provide sufficient information for us to verify the identities (to ensure those who initiate the requests are the data subjects themselves or those authorised by them).
• Ensure that the requests are specific and feasible.

We will make every effort to respond within one month of receiving a request to access personal data. This period may be extended if necessary, depending on the number of requests and their complexity. If the request period is to be extended, we will notify you of the situation and reason for delay. In the event of any time conflict between this section and local laws/regulations, the latter shall prevail.

After a request is submitted, we will review your request and decides whether to accept your request.

We may reject your request in the following circumstances:

• Applicable laws do not grant relevant rights to data subjects;
• The identity of the requester cannot be verified;
• The request cannot be verified or is out of scope, especially when requests are sent repeatedly;
• The requested information is related to the compensation that we will make or receive as a result of an ongoing dispute, and the disclosure of such information is likely to damage our interests;
• Other situations stipulated by laws.

If we reject a request from a data subject, we will provide a formal explanation to you.

If none of the situations described in section above occurs, we will honor the request. To increase the likelihood that the request will be accepted, please provide information which is as detailed as possible when submitting your request, such as the request type, specific content, information about the data subject (such as the account name you use for BOOKOO Products and Services), and time frame in which the information was generated or processed.

Typically, we will not provide the following information:

• Information about others: Requests from data subjects may involve other individuals besides the data subject. We will not provide such information, unless authorized by the relevant individuals.
• Repeated requests: If the data subject initiates the same or similar requests related to one data subject for multiple times, and the required information has not changed since the last time we provided such information, we will not provide the copy of such information repeatedly in most cases. Additionally, we have no obligation to provide information that has been publicly available.
• Special Information: We will not disclose any Special Information in response to requests for accessing personal data. For the purpose of this Policy, Special Information refers to any confidential information of BOOKOO (such as attorney/client communication), and information that actually constitutes legal opinion (irrespective of whether it is related to the lawsuit itself or related to information from court proceedings).

6. Disclosure of Personal Data

We may also share, transmit, disclose, grant access to, make available, and provide Personal Data with and to third parties, as described below.

Affiliates

We share Personal Data amongst the legal entities that make up the BOOKOO group, for legitimate business purposes and the operation of our Sites, Applications, products, and services for you, in accordance with applicable law. These legal entities may use your Personal Data in the manner described in this Privacy Notice.

Third-party Processors

We share Personal Data with third-party contractors and service providers subject to reasonable confidentiality terms. The services provided on our behalf by such third-party contractors and service providers may include email service providers; marketing/advertising service providers; call service providers; video shopping support and showroom service providers; text message service providers; venue operators; payment services providers; shipping companies; and postal carriers. They are only authorized to process that information as necessary and as directed by us.

Advertising networks:

To efficiently market our products and services to you, we may share Personal Data with so-called advertising networks. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and similar technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

Business and marketing partners

We may also disclose Personal Data with other business and marketing partners with whom we jointly offer products or services or who are part of our partner program. We may obtain your consent where required by applicable law.

Third-party services integrated in our services (for instance, third-party voice-assisted technologies may receive information you choose to share directly with them);

Individuals you choose, for example through our device-sharing function; we recommend you share information with only people you trust.

Independent advisors

We may disclose Personal Data to our independent advisors, such as accountants, auditors, consultants, lawyers, and other outside professional advisors to BO, subject to binding contractual obligations of confidentiality.

Corporate Transactions

If BOOKOO is involved in a corporate business transaction, such as a merger, acquisition, or sale of all or a portion of our company assets, we may disclose Personal Data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. If BOOKOO completes such a corporate business transaction, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership.

We may also disclose your Personal Data to any other third party or publicly with your prior consent or direction.

Other Conditions as Required by Applicable Law

We may disclose your personal information with or without further consent when permitted or required by applicable laws or regulations.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. Please note that third parties and business partners may process your Personal Data in accordance with their own privacy policies and terms of service.

7. Retention of Personal Information

We will only retain your Personal Information to fulfill the purposes for which it was collected, as required for legitimate business purposes as described in this Privacy Policy, or otherwise permitted by law. When we no longer need to use Personal Information, we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. Transfer to Other Countries

Due to the global nature of our business, we share personal data internationally with our affiliated companies, subcontractors and partners when carrying out the data processing activities described in this Policy.

Whenever we transfer personal data internationally, we will make sure that the data transfer complies with applicable law. We also ensure the personal data benefits from an adequate level of data protection when transferring your information outside of the EEA, the UK, or Switzerland by relying on:

• Adequacy Decisions. This applies when we transfer personal data to countries outside of the European Economic Area (“EEA“) which have adequate laws to protect personal data, as determined by the European Commission under Article 45 GDPR (or equivalent decisions under other laws).
• Standard Contractual Clauses (“SCCs“). The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA to countries without an adequacy decision. These (and their approved equivalent for the UK and Switzerland) are called SCCs. For example, we use SCCs to transfer the personal data described in Chapter 2 (Personal Data We Collect) to our data hosting provider located in the US. You can exercise your rights under the Standard Contractual Clauses by contacting us at support@bookoocoffee.com.
• For a copy of these adequacy decisions or standard contractual clauses, please contact us via support@bookoocoffee.com.

9. Data Security

We’re committed to protecting our users’ personal data. We, with our best efforts, use certain physical, organizational, and technical security measures that are designed to improve the integrity and security of the personal data that we collect and maintain. We use cryptographic technologies to ensure the confidentiality of data transmission and storage, and implement reliable protection mechanisms to protect data from attacks. We deploy access control mechanisms to prevent unauthorized to your personal data. In addition, we limit the number of authorised personnel and implement hierarchical permission management based on service requirements and personnel levels. Access to personal data will be logged and reviewed by authorised personnel on a regular basis.

However, please be aware that no security measures are perfect or impenetrable and no system is ever completely secure thus we cannot and do not guarantee that your personal data will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational security measures.

If other individuals have access to your BooKoo Account, then they may access your personal data, controls and the service available in your account. For example, you may allow someone to use your account on a shared device. It’s your responsibility to only allow individuals to use your account where you’re comfortable sharing your personal data with them. Anyone else’s use of your BooKoo Account may impact your personalized settings and be included in your data records. To protect your user account and privacy, we encourage you to:

use a strong password which you only use for your BooKoo Account;

• never share your password with anyone else;
• limit access to your own computer and browser; and
• log out each time you finish using the BOOKOO Products and Service in a shared or public environment.

10. Children’s Data

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

11. Third-Party Websites and Links

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

12. Updates to this Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the “Last updated” date and take any other steps required by applicable law.