Privacy Policy

Last updated: January 2026

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and explains Your privacy rights and how the law protects You.

We use Your Personal Data to provide, operate, and improve Steven.com and its related services. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

Words with capitalised initial letters have meanings defined under the following conditions. These definitions apply whether the terms appear in singular or plural.

Definitions

For the purposes of this Privacy Policy:

• ‍Account means a unique account created for You to access our Service or parts of our Service.‍
• Company (referred to as "the Company", "We", "Us", or "Our") refers to Steven.com Limited, trading as Steven.com, with its principal office at 73 Cornhill, London, EC3V 3QQ, United Kingdom, together with its affiliates and subsidiaries.‍
• Cookies are small files placed on Your Device that store information about Your browsing activity.‍
• Country refers to the United Kingdom, unless otherwise stated.‍
• Creator means an individual or entity that partners with or uses Steven.com to distribute content, build communities, launch products, or invest.‍
• Device means any device capable of accessing the Service, such as a computer, mobile phone, or tablet.‍
• Personal Data means any information that identifies or relates to an identifiable individual.‍
• Service refers to the Steven.com website, platforms, products, events, tools, and related services.‍
• Service Provider means any third party that processes data on behalf of the Company.‍
• Usage Data refers to data collected automatically through use of the Service.‍
• Website refers to www.steven.com (and any associated domains).‍
• You means the individual or legal entity accessing or using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may collect Personal Data including, but not limited to:

• Name
• Email address
• Phone number
• Company or organisation
• Social media handles or public creator profiles
• Billing and payment details (where applicable)
• Event registration and attendance details
• Investor-related information (where relevant and lawful)

Usage Data

Usage Data is collected automatically and may include:

• IP address
• Browser type and version
• Pages visited and time spent
• Device identifiers
• Operating system
• Referring URLs
• Diagnostic and performance data

When You access the Service via a mobile device, We may collect additional device-specific information.

We also collect use and share aggregated data such as statistical data or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How is Your Personal Data collected?

We use different methods to collect data from and about You including through:

Your interactions with Us. You may give Us Your Personal Data by filling in online forms or by corresponding with Us by post, phone, email or otherwise.

Automated technologies or interactions. As you interact with our website, we will automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below for further details.

Service Provider or publicly available sources. These may include:

• Technical data collected from analytics partners, advertising networks or search information providers
• Contact, financial and transaction data is collected from providers of technical, payment and delivery services
• Identity and contact data is collected from publicly available sources, data brokers or aggregators

Tracking Technologies and Cookies

We use Cookies and similar technologies (including pixels, tags, and scripts) to operate, analyse, and improve the Service.

Types of Cookies We Use

Necessary / Essential Cookies - Required for core functionality, security, and authentication.

Functionality Cookies - Remember preferences such as language or login details.

Analytics & Performance Cookies - Help Us understand how users interact with the Service.

Marketing & Advertising Cookies - Used to deliver relevant marketing and measure campaign effectiveness (where consent is required).

You can manage cookie preferences through your browser settings or Our cookie banner. Refusing certain Cookies may limit functionality.

Use of Your Personal Data

The Company may use Personal Data to:

• Provide, operate, and maintain the Service
• Manage user accounts and Creator relationships
• Deliver content, events, products, and services
• Process transactions and contracts
• Communicate updates, insights, and marketing (where permitted)
• Run events, communities, and Creator programmes
• Conduct analytics, research, and experimentation
• Improve AI, data, and decision-making systems
• Comply with legal and regulatory obligations
• Evaluate mergers, acquisitions, or restructurings

Legal Bases for Processing (UK GDPR & GDPR)

We process Personal Data under one or more of the following legal bases:

• Your consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate interests (e.g. improving services, security, analytics), where these do not override Your rights

Purposes for which We will Use Your Personal Data

We have set out below a description of all the ways We plan to use the various categories of Your Personal Data, and which of the legal bases We rely on to do so. We have also identified what Our legitimate interests are where appropriate.

To register You as a new customerData types: (a) Identity, (b) ContactLegal basis: Performance of a contract with You

To process and deliver Your order including: (a) Manage payments, fees and charges, (b) Collect and recover money owed to usData types: (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and communicationsLegal basis: (a) Performance of a contract with You, (b) Necessary for Our legitimate interests (to recover debts due to us)

To manage Our relationship with You which will include: (a) Notifying You about changes to Our terms or privacy policy, (b) Dealing with Your requests, complaints and queriesData types: (a) Identity, (b) Contact, (c) Profile, (d) Marketing and communicationsLegal basis: (a) Performance of a contract with You, (b) Necessary to comply with a legal obligation, (c) Necessary for Our legitimate interests (to keep Our records updated and manage Our relationship with You)

To enable You to partake in a prize draw, competition or complete a surveyData types: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and communicationsLegal basis: (a) Performance of a contract with You, (b) Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them and grow Our business)

To administer and protect Our Service and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)Data types: (a) Identity, (b) Contact, (c) TechnicalLegal basis: (a) Necessary for Our legitimate interests (for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Necessary to comply with a legal obligation

To deliver relevant Website content and online advertisements to You and measure or understand the effectiveness of the advertising We serve to YouData types: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and communications, (f) TechnicalLegal basis: Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them, to grow Our business and to inform Our marketing strategy)

To use data analytics to improve Our website, products/services, customer relationships and experiences and to measure the effectiveness of Our communications and marketingData types: (a) Technical, (b) UsageLegal basis: Necessary for Our legitimate interests (to define types of customers for our products and services, to keep Our Website updated and relevant, to develop Our business and to inform Our marketing strategy)

To send You relevant marketing communications and make personalised suggestions and recommendations to You about goods or services that may be of interest to You based on Your Personal DataData types: (a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile, (f) Marketing and communicationsLegal basis: Necessary for Our legitimate interests (to carry out direct marketing, develop Our products/services and grow Our business) OR consent, having obtained Your prior consent to receiving direct marketing communications

To carry out market research through Your voluntary participation in surveysLegal basis: Necessary for Our legitimate interests (to study how customers use Our products/services and to help Us improve and develop Our products and services)

Sharing of Your Personal Data

We may share Your Personal Data where necessary with the parties set out below for the purposes set out above:

• With Service Providers supporting analytics, hosting, payments, communications, and security
• With affiliates and group companies
• With Creators or partners, where relevant to a Service You engage with
• During business transfers, mergers, or acquisitions
• With regulators or authorities, where legally required
• With Your consent, for specific purposes

We do not sell Personal Data in the traditional sense.

International Data Transfers

Your Personal Data may be processed outside Your country of residence, including in the UK, EU, and United States. We ensure appropriate safeguards are in place, so that any data transferred is afforded the same protections as it has in the UK, such as the use of standard contractual clauses or equivalent protections.

Retention of Your Personal Data

We retain Personal Data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including legal, accounting, and reporting obligations.

Usage Data is generally retained for shorter periods unless required for security or compliance.

We may retain Your Personal Data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with You.

To determine the appropriate retention period for Personal Data, We consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of Your Personal Data, the purposes for which We process Your Personal Data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law We have to keep basic information about our customers for six years after they cease being customers for tax purposes.

Security of Your Personal Data

We use commercially reasonable technical and organisational measures to protect Your Personal Data, including access controls, encryption, and security audits. However, no system is completely secure, and We cannot guarantee absolute security.

We have put in place procedures to deal with any suspected Personal Data breach and will notify You and any applicable regulator of a breach where We are legally required to do so.

Your Data Protection Rights

Depending on Your location, You may have the right to:

• Access Your Personal Data
• Correct inaccurate or incomplete data
• Request deletion of Your data
• Restrict or object to processing
• Withdraw consent at any time
• Request data portability

If You wish to exercise any of the rights set out above, please contact Us (see "Contact Us" section below).

No fee usually required

You will not have to pay a fee to access Your Personal Data (or to exercise any of the other rights). However, We may charge a reasonable fee if Your request is clearly unfounded, repetitive or excessive. Alternatively, We could refuse to comply with Your request in these circumstances.

What We may need from You

We may need to request specific information from You to help Us confirm Your identity and ensure Your right to access Your Personal Data (or to exercise any of Your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up Our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take Us longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.

Children's Privacy

Our Service is not intended for individuals under the age of 13. We do not knowingly collect data from children. If You believe a child has provided Us with Personal Data, please contact Us immediately.

Links to Other Websites

Our Service may link to third-party websites. We are not responsible for their content or privacy practices and encourage You to review their privacy policies.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Material changes may also be communicated via email or notice on the Service.

Complaints

You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure You have first made Your complaint to Us or asked Us for clarification if there is something You do not understand. The ICO will expect You to have done this before reviewing Your complaint.

Contact Us

If You have any questions about this Privacy Policy or Your data, You can contact Us at:

Email: privacy@steven.com

‍Address: Steven.com Limited, 73 Cornhill, London, EC3V 3QQ, United Kingdom

‍