Privacy Policy & Data Protection Notice

StepOne Group LTD (the “Company,” “we,” “us,” or “our”) has created this privacy notice to explain our data collection and processing practices. By using our Services, you acknowledge and agree to our policies and procedures regarding personal information. If you have any questions or concerns, feel free to reach out to us at [email protected]. If you do not agree with our policies, please refrain from using our Services.

What Information Do We Collect?

Personal information is gathered from you through voluntary means when you register on our Services, show interest in learning about us or our products/services, take part in activities on the Services, or make contact with us.

The personal information we collect is based on your interactions with us and the Services, the choices you make, and the products/features you use. This can include:

• Names
• Phone numbers
• Email addresses
• Physical address
• Billing addresses

Sensitive Information

We do not collect sensitive information such as social security numbers or other information not necessary to the operation of the Company’s business.

Payment Information

In case of any purchases, we may gather data necessary to process your payment, such as the payment instrument number and security code linked to your payment method. The storage of all payment information is handled by our payment processors. Their respective privacy notices can be accessed on their websites.

It’s crucial that all personal information you provide us is truthful, comprehensive, and up to date. In the event of any changes to your personal information, it’s your responsibility to notify us.

Information Automatically Collected

During your visit, usage, or navigation of the Services, certain information is automatically collected by us. This information, while not revealing your specific identity (e.g. name or contact details), may include device and usage data such as IP address, browser and device specifications, operating system, language preferences, source URLs, device name, country, location, usage information of our Services, and other technical details. This information is mainly utilized for ensuring the security and functioning of our Services, as well as for internal analysis and reporting purposes

Similar to other businesses, we also gather information through the use of cookies and similar technologies.

Log and Usage Data

This refers to information related to service, diagnostics, usage, and performance, which our servers automatically gather when you access or utilize our Services. This data is stored in log files and may include details like your IP address, device information, browser type and settings, and information about your activities within the Services (such as timestamps of usage, pages/files viewed, searches performed, and other actions like feature usage), and device event information (such as system activity, error reports, and hardware configurations), depending on your interaction with us.

How Do We Process Your Information?

Your personal information is processed by us for several purposes, based on your interaction with our Services. These may include: Easing account creation and authentication and identifying fraudulent activity We may use your information to seek feedback and communicate with you regarding your usage of our Services. Processing of your information may also occur when necessary to protect someone’s vital interests, for instance, to prevent harm

What Legal Bases Do We Rely On To Process Your Information?

We process your personal data only when necessary and when we have a valid legal justification, such as with your consent, to follow laws, provide services, fulfill contracts, protect your rights, or serve our legitimate business interests, inclusive of those set forth in our Terms & Conditions and to protect the Company against fraud.

This section applies to Users located in EU or UK

The GDPR and UK GDPR mandate us to outline the legal grounds for processing your personal data. Therefore, we process your information based on the following legal grounds:

Consent

We may process your information if you have provided us with consent to use your personal information for a specific purpose. You have the right to revoke your consent at any time. To do so, simply reach out to us through the contact form or send an email to [email protected].

Legitimate Interest

We may use your information if it is necessary for our legitimate business interests, provided that these interests do not override your interests or basic rights and freedoms, inclusive of those set forth in our Terms & Conditions and to protect the Company against fraud.

Legal Obligation

We may handle your information to fulfill our legal obligations, such as cooperating with law enforcement or regulatory bodies, protecting our legal rights, or providing your information as evidence in relevant legal proceedings.

Vital Interests

We may also process your information if it is crucial to safeguarding your vital interests or the vital interests of others, for example in emergency situations where safety is at risk.

If you are located in Canada, this section applies to you

We can only process your information if you have either given us express consent for a specific purpose or if it can be assumed from the circumstances (implied consent). However, you have the right to revoke this consent at any time. In exceptional cases where the law permits, we may process your information without your consent such as:

• It is in an individual’s best interests and consent cannot be obtained promptly.
• It is necessary for fraud investigation and prevention.
• It is required for commercial transactions under certain conditions.
• It is contained in a witness statement for insurance claim evaluation and settlement.
• It is needed to identify injured, ill, or deceased people and communicate with next of kin.
• There are reasonable grounds to believe an individual has been or may be a victim of financial abuse.
• Collection and use with consent would jeopardize information availability or accuracy and collection is necessary for breach of agreement or violation investigation.
• Disclosure is required by law, such as a subpoena or court order.
• It was created in the course of employment, business, or profession and consistent with the information’s original purpose.
• Its sole purpose is for journalism, art, or literature.
• It is publicly available and required by law.

When And With Whom Do We Share Your Personal Information

Your personal information may be shared in the following cases:

• Business Transfers: During negotiations or completion of a merger, sale of assets, financing, or acquisition of our company or a part of it, your information may be shared or transferred to another company.
• Working with Vendors: To provide the Services, the Company works with various third-parties. The Company may share your personal information to the extent it ensures adherence to the Company’s Terms & Conditions and to otherwise protect against fraud or manipulation involving the Company or third-parties.

Do We Use Cookies and Other Tracking Technologies?

The use of cookies and other tracking technologies (e.g., web beacons, pixels) may allow access or storage of information. Our Cookie Notice provides detailed information on our usage of these technologies and offers options to decline certain cookies.

We also utilize various tracking methods such as Google AdWords, Meta Advertising, and Google Analytics to gather and store data on user interactions with our websites.

How Long Do We Keep Your Information?

We retain your personal information only as long as necessary or legally allowed, including for tax, accounting, or other legal reasons. When our business no longer requires it, we will either delete or anonymize your personal information. If deletion is not feasible, we will securely store it and restrict access until it can be deleted.

How Do We Keep Your Information Safe?

We have taken necessary and reasonable technical and organizational measures to secure personal information in our possession. However, the Internet and information storage technology are not foolproof, so we cannot guarantee that your information will not be accessed, stolen, or altered by unauthorized third parties.

While we strive to protect your personal information, it is your responsibility to ensure the safety of the information you transmit through our Services. Use caution when using the Services and only in a secure environment.

Do We Collect Information from Minors?

We do not intentionally gather information from or target individuals under 18. By using our services, you certify that you are 18 or older, or the parent/guardian of a minor using the services with your consent.

In case we discover any personal information from minors, we will promptly disable their account and erase the data from our records. If you become aware of any information collected from minors, please contact us at [email protected].

What Are Your Privacy Rights?

In some regions with applicable data protection laws (such as the EEA, UK, and Canada), you have certain rights, such as:

• Requesting access and a copy of your personal information.
• Requesting correction or deletion.
• Limiting the processing of your personal information and data portability (if applicable).
• Objecting to the processing of your personal information under certain circumstances.

If you wish to make such a request, please contact us. If you reside in the European Economic Area or the UK and think that your personal information is being mishandled, you can file a complaint with your local data protection authority. Find their contact details at: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are in Switzerland, the data protection authorities’ information can be found at: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your Consent

If your personal information is being processed based on your consent, either expressed or implied as per the relevant laws, you have the right to withdraw it at any moment.

Opting out of marketing and promotional communications

To stop receiving our marketing and promotional emails, simply click the unsubscribe link in the emails we send you. You will then be removed from our marketing lists. Note that we may still send you non-marketing communications such as service-related updates, account administration, responding to your service requests, etc.

Account Information

To review or change information in your account or close it, follow these steps:

• Log in to your account settings and update your user account.
• Contact us using the provided contact information.

Note: Upon request, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files for fraud prevention, problem resolution, investigations, enforcement of legal terms, and compliance with legal requirements.

Cookies and similar technologies

Web browsers are typically configured to accept cookies by default. You can choose to remove or reject cookies, but this may impact certain features or services of our Services. To opt out of interest-based ads by advertisers on our Services, go to https://youradchoices.com/control.

For privacy-related questions or comments, email us at [email protected].

Controls For Do-Not-Track Features

Many web browsers, mobile OS and apps have a Do-Not-Track (“DNT”) feature to signal your preference for not having your online browsing activities monitored and collected. However, as there is no agreed technology standard for DNT, we do not currently respond to DNT browser signals or any other mechanism that communicates your preference not to be tracked. If a future standard for online tracking is adopted, we will update this privacy notice and inform you.

Do California Residents Have Specific Privacy Rights?

As a California resident, you have specific rights. While the Company does not solicit or accept minors under 18 years of age, if you are a minor under 18 years old and have a registered account with us, you have the right to request the removal of unwanted data from your account.

To make this request, please reach out to us via email at [email protected] with your email address and a statement confirming your residency in California. We will take steps to ensure that the data is not publicly displayed on our services, but please note that it may not be fully or entirely deleted from all of our systems (such as backups, etc.).

CCPA Privacy Notice

According to the California Code of Regulations, a “resident” is defined as: (1) any individual who is in California for purposes other than temporary or transitory, and (2) any individual who has a permanent home in California but is temporarily outside the state for a transitory purpose. Individuals who do not meet the definition of “resident” are defined as “non-residents.” If you are considered a “resident” under this definition, certain rights and obligations must be followed in regards to your personal information.

How Do We Use and Share Your Personal Information?

For additional details on our data collection and sharing procedures, please refer to our privacy notice. To get in touch with us, you can email us at [email protected], call us +443300272809, visit www.steponefx.com, or find the contact information at the bottom of this document.

If you choose to use an authorized agent to opt out, please note that we may reject the request if the authorized agent cannot provide proper proof of their authorization to act on your behalf.

Will Your Information Be Shared with Anyone Else?

We may share your personal information with our service providers in accordance with the terms outlined in our contracts with them. These service providers are for-profit entities that process information on our behalf while complying with the CCPA’s rigorous privacy standards.

We may use your personal information for internal business purposes, such as technological advancement and demonstration research, but this is not considered “selling” your personal information.

Your Rights with Respect to Your Personal Data

Right to request deletion of the data — Request to delete: You have the right to request the deletion of your personal information. We will comply with your request, subject to certain exceptions under the law, such as (but not limited to) when another consumer is exercising their right to free speech, when we are obligated to comply with a legal requirement, or when processing is necessary to prevent illegal activities.

Right to be informed — Request to know: You have the right to know:

• If we collect and use your personal information.
• The types of personal information we collect.
• The reasons for collecting the personal information.
• Whether we sell or share personal information with third parties.
• The types of personal information that have been sold, shared, or disclosed for business purposes.
• The third parties to whom the personal information was sold, shared, or disclosed for business purposes.
• The purpose of collecting, selling, or sharing personal information.
• The specific personal information we have collected about you.

By law, we are not obligated to supply or remove consumer information that has been de-identified in response to a consumer’s request, or to re-identify individual data to confirm a consumer’s request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not engage in discrimination if you exercise your privacy rights. You have the right to limit the use and disclosure of sensitive personal information, and we do not handle consumers’ sensitive personal information.

Verification Process

To confirm your identity when we receive your request, we may need to verify that you are the same person whose information we have on record. This verification process may require us to ask for additional information from you that matches what we already have.

The personal information you provide in your request will only be utilized to verify your identity and authority to make the request. We will aim to minimize the need to request additional information from you for verification purposes. If our existing information is insufficient to verify your identity, we may ask for additional information to verify your identity, as well as for security and fraud prevention purposes. Once the verification process is completed, any additional information you provide will be promptly deleted.

Other Privacy Rights

You have the right to object to the processing of your personal information. You have the right to request correction of your personal data if it is inaccurate or outdated, or to request that processing be limited.

You may appoint an authorized agent to make a request under the CCPA on your behalf, but we may reject the request if the authorized agent fails to provide proof of their authorization to act on your behalf.

You may request that your personal information not be sold or shared with third parties in the future. We will respond to your opt-out request within 15 days from the date of receipt.

To assert these rights, contact us via [email protected], visit www.steponefx.com, or refer to the information at the bottom of this document. If you have a concern about our data handling, we’d like to hear from you.

Do We Make Updates to This Notice?

This privacy notice may be revised periodically, with the updated version indicated by a new “Revised” date. It will become effective immediately upon release. We may notify you of significant changes by posting a prominent notice or sending you a notification. It’s important to regularly review this privacy notice to stay informed of how we safeguard your information.

How Can You Contact Us About This Notice?

For questions or comments regarding this notice, you may reach us via email at [email protected].

How Can You Review, Update, Or Delete the Data We Collect From You?

Depending on your country’s laws, you may have the right to access, modify, or delete the personal information we have collected from you. To do so, please send your request via email at [email protected].