Effective Date: 7/2/2019
- General Data Protection Regulation (“GDPR”) means the European Union (“EU”) law on data protection and privacy applicable to individuals within the EU.
- Personal Data means any information relating to an identified or identifiable natural person, an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Professional Service Provider(s) means licensed who create an account and subscribe to Services through Step1.
- Client(s) means individuals who access, use, and create an account with the Website via their Professional Service Provider.
- User(s) means any individual that accesses the Website, including Professional Service Providers and Clients.
- You/Your may refer to Professional Service Providers, Clients, and/or Users.
- Services means the Step1 Client Nurturing Service available for use by Professional Service Providers with their Clients and other related offerings.
Types of Personal Data We Collect.
Step1 collects the following Personal Data from Professional Service Providers who subscribe to Services:
- First name;
- Last name;
- Email address;
- Phone number;
- User name;
- Password (encrypted);
- Profile photo;
- Payment information;
- Any other information that you voluntarily upload or submit to the Website directly or indirectly.
Step1 collects the following Personal Data from Clients who use Step1 with their Professional Service Provider:
- First name;
- Last name;
- Email address;
- Phone number;
- Profile photo.
Step1 collects the following Personal Data from all Users who contact Step1 seeking more information:
- Email address.
- State of residence.
In addition, Step1 collects the following Personal Data from all Users:
- Your geolocation;
- Your IP address;
- Your browser and search engine information;
- Your device information;
- Your visitor history;
- Your usage of the Website, including, without limitation, any links or items clicked or pages viewed and statistics;
- Information stored in cookies, pixel tags, or web beacons;
- Analytical data from Google Analytics and/or Google AdSense; and
- Any other additional analytic data that you voluntarily submit to the Website.
Cookies & Similar Technologies.
The table below sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:
|Type of Cookie||Description||Managing Settings|
|Required Cookies (Strictly Necessary)||Required – or strictly necessary – cookies enable you to navigate the Website and use its features.||Because required cookies are essential to operate the Website there is no option to opt out of these cookies.|
|Functional Cookies (Non-Strictly Necessary)||
Functional – or non-strictly necessary cookies – allow us to remember information you have entered or choices you make, and provide enhanced, more personal features.
We use Google Analytics to help us analyze how our Website is used, including the number of visitors, where the website visitors have come from, and the pages they visit. This information is used by us to improve our Website.
To manage the use of functional cookies on the Website, please consult your individual browser settings for cookies. Note that opting out may impact the functionality you receive when using our Website.
To learn more about safeguarding your data for websites using Google Analytics, visit here. To opt of our data collection by Google Analytics, you can download and install a Google Analytics opt-out browser add-on here.
To learn more about how Google Analytics Cookie Usage on Website visit here.
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook here.
To opt-out of Facebook’s interest-based ads follow these instructions from Facebook.
You can also adjust your individual browser settings relating to cookies by visiting these pages:
Google Chrome Internet Explorer Mozilla Firefox Safari (Desktop) Safari (Mobile) Android Browser
For other browsers not listed, please consult the documentation that your browser manufacturer provides.
|Targeting or Advertising Cookies (Non-Strictly Necessary)||
We use Google Webmaster Tools and Google Analytics to log when users view specific pages or take specific actions on or getting to the Website. Google Analytics specifically allows us to provide targeted advertising in the future.
We may also use Google AdWords as a tool to acquire relevant new clients who are looking for our service and Google AdSense to show our clients other relevant advertising that may assist them while they are using our site.
We also use Hubspot to for social media marketing.
Lawful Basis for Processing Your Personal Data
The lawful basis for us processing your Personal Data for the uses described above will typically be because you have provided your consent; it is necessary for our contractual relationship; the processing is required for us to comply with legal obligations; and/or the processing is in our legitimate interest of providing the Client Nurturing Service and related offerings to Professional Service Providers, Clients, and all other Users.
How Step1 Uses Your Personal Data.
We use your Personal Data based upon the legal basis of Users’ consent to provide you with the Website, process any requests made by you, communicate with you, identify and fix problems with the Website, communicate with you, and update you regarding changes to the Website and the Step1 and third-party services offered through the Website.
By using the Website, you further authorize the following specific uses of your Personal Data:
- Enable your use of the Website and its associated services;
- Improve algorithms;
- Measure service usage;
- Develop new features;
- Contact and communicate with you, whether through email, telephone, text message, and/or chat messages within the Website;
- Customize and/or tailor the Website and your user experience, which may include targeted selection and display of third party advertisements within the Website;
- Aggregate certain information that does not include your personal information and disclose it for analysis, demographic profiling and/or targeted advertising;
- Advertise products and services of Step1;
- Transmit and process your information and actions within the Website;
- Provide statistical information, and include you in the same, where applicable;
- Provide you with technical service and support, including updates;
- Provide you with information concerning Step1’s benefits or services;
- Store, archive, retrieve, and make copies of your user generated content;
- Understand your needs and requests;
- Communicate promotions or other offers;
- Process payments;
- Combine your personal and personally identifiable information with information from other Step1 applications and/or services; and
- Facilitate your use of the Website and upgrades/replacements to the Website.
Sharing of Your Personal Data.
Step1 will never sell your Personal Data to Personal Data to any third-party without your permission. However, Step1 will Share Your Personal Data with third parties in the following circumstances:
- Where Step1 has obtained your consent;
- Where sharing or disclosure of your Personal Data is necessary to provide you with the Website, and/or associated services (We may share your personal or personally identifiable information with trusted third-parties who assist us in operating the Website, providing the associated services, and conducting our business);
- Where sharing or disclosure of your Personal Data is necessary pursuant to a campaign with Facebook and/or Instagram;
- Where sharing or disclosure of your Personal Data is necessary to share personal or personally identifiable information with Step1’s parents, subsidiaries, successors, assigns, licensees, affiliates, or business partners;
- Where Step1 has been purchased by a third party;
- Where sharing or disclosure of your Personal Data is necessary to respond to requests by government authorities;
- Where your Personal Data is demanded by a court order or subpoena;
- Where sharing or disclosure of your Personal Data is needed to protect the employees, independent contractors, officers, directors, members, users, or owners/shareholders of Step1;
- Where sharing or disclosure of your Personal Data is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty; and
- Where Step1 is otherwise legally obligated to share your personal or personally identifiable information.
Step1 Shares Your Personal Data With the Following Third-Parties:
No Liability Third-Party Services and Third-Party Links.
The third-party service providers affiliated with Step1 have their own independent privacy policies governing the use of your Personal Data pursuant to the GDPR and we encourage you to read those privacy policies carefully. You understand that even if Step1 deletes your Personal Data that it may still be available in a third-party service provider’s database. Step1 has no responsibility or liability for the Personal Data collection, use, or storage activities of the third-party services providers used by Step1 to provide you with the services associated with the Website.
Step1 may include or offer third-party products or services on the Website and provide third-party links to the same. These third-party websites have separate and independent privacy policies. Step1 has no responsibility or liability for the content and activities of such third parties or their websites. We encourage you to read carefully the privacy policies of all such third-party websites. We seek to protect the integrity of the Website and therefore welcome any feedback about any such third-party websites.
Personal Data Transfer and Storage.
Your Personal Data is stored and processed on computers and servers in the United States and through your use of the Website, you consent to the processing and storage of your Personal Data and personally identifiable information. You understand that your Personal Data may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction. If you are located outside the United States and choose to provide Personal Data to us, please note that we transfer your Personal Data to the United States and process it here, and that we may store portions of your Personal Data in the United States.
Website Users understand and agree that if they provide Step1 with Personal Data that it is stored indefinitely, unless the User contacts Step1 to have their Personal Data removed from storage. As specified above, even if Step1 deletes your Personal Data from its own serves, it may still be available in a third-party service provider’s database. You should consult with those third-parties in the event you would like Personal Data deleted therefrom.
Personal Data Security.
Step1 uses standard technology to store and help prevent against the unauthorized disclosure of your Personal Data. Though we undertake commercially reasonable efforts to protect your information, no website, software, or online service is completely safe. Accordingly, you provide all such information at your own risk.
In order to protect your Personal Data, Step1 uses specific security measures, such Secure Sockets Layer (SSL) protocol, which encrypts information you input at 128-bit strength. This is denoted in most web browsers by a small padlock appearing on the bottom bar of the window and the address of the window changing from http:// to https://, indicating a secure connection.
EU Users’ Rights Under the GDPR.
The GDPR provides Users located in the EU under its protection certain rights with respect to their Personal Data collected by us on the Website. Accordingly, Step1 recognizes and will comply with the GDPR and those rights, except as limited by applicable law. The rights under the GDPR include:
- Right of Access: This includes the right to obtain from us your Personal Data and whether it is being processed, along with the purposes of the processing; categories of Personal Data concerned; recipients to whom your Personal Data has been disclosed; the period for which your Personal Data is being stored; and the right to lodge a complaint.
- Right of Rectification: This includes the right to correct inaccurate Personal Data collected and/or stored by us.
- Right of Erasure (“Right to be Forgotten”): This includes the right to have your Personal Data deleted. However, if applicable law requires us to comply with your request to delete information, fulfilment of your request may prevent you from using our services and may result in closing your account.
- Right to Restriction of Processing: This includes the right to request restriction of how and why your Personal Data is used or processed by us.
- Right to Data Portability: This includes the right to receive your Personal Data in a structure, readable format and the right to have your Personal Data transferred.
- Right to Object: This includes the right to object to us processing your Personal Data for reasons such as direct marketing purposes and for scientific or historical research or statistical purposes.
- Right to not be Subject to Automated Decision-Making: This includes the right to not be subject to a decision based solely on automated processing, including profiling, that could have a legal, or similarly significant, effect on you from being made solely based on automated processes.
Purchase or Sale of the Website or Other Assets.
How To Stop Step1 from collecting your Personal Data.
You can stop Step1 from collecting your Personal Data by contacting Step1 at email@example.com and requesting that Step1 stop collecting your Personal Data. Additionally, you can adjust your web browser settings to limit or turn off Cookies or other tracking techniques, or you can cease use of the Website. You may contact Step1 with any requests regarding your Personal Data. Step1 also honors Do Not Track requests and signals.
Your account and all data associated with it can be deleted by emailing firstname.lastname@example.org. After your identity has been verified, your account will be completely deleted within five business days.
When using the Website, you are obligated to inform Step1 of any changes to your Personal Data.
Under California’s “Shine the Light Law,” California residents have the right to receive information that identifies any third-party companies or individuals that Step1 has shared your Personal Data with in the previous calendar year, as well as a description of the categories of Personal Data disclosed to that third party. You may obtain this information once a year and free of charge by contacting Step1 at the address below.
Children’s Online Privacy Protection Policy.
The Website is not intended for or directed to users under the age of 18, and Step1 does not knowingly or intentionally collect Personal Data from children under the age of 13 or other minors. Where appropriate, Step1 takes reasonable measures to determine that users are adults of legal age and to inform minors not to submit such information to the Website or in response to advertisements. If you are concerned that Personal Data may have been inadvertently provided to or collected by Step1, please contact us immediately so appropriate steps may be taken to remove such information from Step1’s database.
Contact and Notices.
Step 1 Strategies, Inc.
1151 S. 3rd St.
Austin, Texas 78704