This
Privacy Policy was last updated on December 31, 2023
Thank you for joining Steps4Growth. We at Steps4Growth (“Steps4Growth”, “we”, “us”) respect your
privacy and want you to understand how we collect, use, and share data about you.
This Privacy Policy covers our data collection practices and describes your
rights regarding your personal data. We may update this
privacy notice from time to time.
Unless we link to a different policy
or state otherwise, this Privacy Policy applies when you visit or use Steps4Growth website or related services (the “Services”). It also
applies to prospective customers of our business products.
By using the Services, you agree to
the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with
this Privacy Policy or any other agreement that governs your use of the
Services.
You can contact us at contact@steps4growth.org.
Starting from May 25, 2018, Regulation 2016/679/EU on the
protection of natural persons with regard to the processing of personal data
and on the free movement of such data (hereinafter "the Regulation")
is also applicable in Romania. We have an obligation to keep confidential and
use the personal data you provide us about you in a secure manner and only for
the purposes mentioned below, which are directly or indirectly related to the
materials and services made available by Steps4Growth.
1.
KEY DEFINITION
The key terms that we use throughout this privacy notice are
defined below, for ease:
1.1 Personal Information: Personal
data (“Personal Data”) is any information that is directly or indirectly linked
to you as a natural person, in particular by reference to an identification
element such as name, identification number, online type identifier email,
phone number or to one or more specific elements, specific to his physical,
physiological, genetic, psychological, economic, cultural or social identity.
1.2 Special Information –
certain very sensitive personal information requires extra protection under
data protection law. Sensitive data includes information relating to health,
racial and ethnic origin, political opinions, religious and similar beliefs,
trade union membership, sex life and sexual orientation and also includes
genetic information and biometric information.
2. DATA RETENTION PERIOD
2.1 Your personal data
will be deleted when it is no longer reasonably necessary for the authorized
purposes or when you withdraw your consent (where applicable) and it is no
longer legally necessary for us to we still store this data. However, we will
retain your personal data, where it is necessary for us to assert legal claims,
until the end of the relevant retention period or until the claims in question
have been finally resolved.
2.2 The types of personal data we
collect about you may differ from person to person, depending on who you are
and the relationship between us.
3.
DETAILS OF SPECIAL INFORMATION THAT WE COLLECT AND HOLD ABOUT YOU
3.1 Special information is explained in section
1 above. We do not collect or hold any special information about you.
3.2 We do not collect information from you relating
to criminal convictions or offences.
4.
DETAILS OF HOW AND WHY WE USE PERSONAL INFORMATION
Steps4Growh does not sell, trade or rent personal data to third
parties. In order to take over and complete your request, Steps4Growh
will be able to process the personal data you provide for the following
purposes:
a) Taking over the request, to allow
access to Steps4Growh materials;
b) Confirming access to the Steps4Growh Materials
and possibly providing additional information regarding the data contained in
the Materials;
c) Any notifications regarding the changes
made to the site;
d) Responding to requests and complaints;
e) Carrying out customer satisfaction
surveys, conducting statistics with the objective of improving the quality of Steps4Growh
services - with your consent as a data subject;
f) Sending offers, advertising and
marketing messages regarding products and/or services provided by Steps4Growh or
its partners, in order to customize the services according to your needs and to
offer you services that we believe you would be interested in you acquire them
- with the consent of the data subject.
4.1 We are only able to use your personal
information for certain legal reasons set out in data protection law. There are
legal reasons under data protection law other than those listed below; but, in
most cases, we will use your personal information for the following legal
reasons:
1. Contract
Reason: this is in order
to perform our obligations to you under a contract we have entered into
with you;
2. Legitimate
Interests Reason: this is
where the use of your personal information is necessary for our (or a
third party’s) legitimate interests, so long as that legitimate interest
does not override your fundamental rights, freedoms or interests;
3. Legal
Obligation Reason: this is
where we have to use your personal information in order to perform a legal
obligation by which we are bound; and
4. Consent
Reason: this is where you have
given us your consent to use your personal information for a specific
reason or specific reasons.
4.2 As explained in section 3 above, there are
more sensitive types of personal data, which require higher levels of
protection. Where we process such sensitive types of personal data, we will
usually do this in the following circumstances:
1. We have your
explicit consent;
2. Where it is
necessary in relation to legal claims;
3. Where you have
made the personal data public.
4.3 So that we are able to provide you with
goods and services, we will need your personal information. If you do not
provide us with the required personal information, we may be prevented from
supplying the goods and services to you.
4.4 It is important that you keep your
personal information up to date. If any of your personal information changes,
please contact us as soon as possible to let us know. If you do not do this,
then we may be prevented from supplying the goods and services to you (for
example, if you move address and do not tell us, then your goods may be
delivered to the wrong address).
4.5 Where we rely on consent for a specific
purpose as the legal reason for processing your personal information, you have
the right under data protection law to withdraw your consent at any time. If
you do wish to withdraw your consent, please contact us using the details set
out at the beginning of this notice. If we receive a request from you
withdrawing your consent to a specific purpose, we will stop processing your
personal information for that purpose, unless we have another legal reason for
processing your personal information – in which case, we will confirm that
reason to you.
4.6 We have explained below the different
purposes for which we use your personal information and, in each case, the
legal reason(s) allowing us to use your personal information. Please also note
the following:
if we use the
Legitimate Interests Reason as the legal reason for which we can use your
personal information, we have also explained what that legitimate interest
is; and
for some of the
purposes, we may have listed more than one legal reason on which we can
use your personal information, because the legal reason may be different
in different circumstances. If you need confirmation of the specific legal
reason that we are relying on to use your personal data for that purpose,
please contact us using the contact details set out at the start of this
privacy notice.
4.7 Sometimes we may anonymise personal
information so that you can no longer be identified from it and use this for
our own purposes. In addition, sometimes we may use some of your personal
information together with other people’s personal information to give us
statistical information for our own purposes. Because this is grouped together
with other personal information and you are not identifiable from that combined
data we are able to use this.
4.8 Under data protection laws, we can only use
your personal information for the purposes we have told you about, unless we
consider that the new purpose is compatible with the purpose(s) we told you
about. If we want to use your personal information for a different purpose that
we do not think is compatible with the purpose(s) we told you about, then we
will contact you to explain this and what legal reason is in place to allow us
to do this.
5.
DETAILS OF HOW WE COLLECT PERSONAL INFORMATION AND SPECIAL INFORMATION
5.1 We usually collect Identity Information,
Contact Information, Payment Information, Transaction Information, Survey
Information, Marketing Information, Special Information; directly from
you when you fill out a form, survey or questionnaire, purchase services and/or
digital content from us, contact us by email, telephone, in writing or
otherwise. This includes the personal information that you provide to us when
you subscribe to our mailing list.
5.2 We may receive some of your personal
information from third parties or publicly available sources. This includes:
1. Contact
Information and Payment Information from our selected third-party
suppliers, such as Stripe;
2. Identity
Information and Contact Information from publicly available sources such
as The Companies Office, others;
3. Website, Device
and Technical Information from third parties such as analytics providers
(like Google);
4. Any other
methods by which you collect personal data;
5.3 We may also receive Website, Device and
Technical Information automatically from technologies such as cookies that are
installed on our website.
6.
DETAILS ABOUT WHO PERSONAL INFORMATION MAY BE SHARED WITH
We may need to share your personal
information with other organisations or people.
These data recipients can be:
a) partners of Steps4Growth, such as IT service providers, necessary for the execution
of the Contract;
b) possibly partners with whom we collaborate for the preparation
of Steps4Growth
Materials;
c) public authorities, according to the legal obligations set in
charge of Steps4Growth.
d) Our advisors: such as lawyers, accountants, bankers,
auditors, insurance
companies who are based in countries;
7.
DETAILS ABOUT TRANSFERS TO COUNTRIES OUTSIDE OF THE EEA
7.1 If any transfer of personal information by us
will mean that your personal information is transferred outside of the EEA,
then we will ensure that safeguards are in place to ensure that a similar
degree of protection is given to your personal information as is given to it
within the EEA and that the transfer is made in compliance with data protection
laws (including, where relevant, any exceptions to the general rules on
transferring personal information outside of the EEA that are available to us –
these are known as ‘derogations’ under data protection laws). We may need to
transfer personal information outside of the EEA to other organisations within
our group or to the third parties listed above in section 6 who may be located
outside of the EEA.
7.2 The safeguards set out in data protection laws
for transferring personal information outside of the EEA include:
1. where the
transfer is to a country or territory that the EU Commission has approved
as ensuring an adequate level of protection;
2. where personal
information is transferred to another organisation within our group, under
an agreement covering this situation, which is known as ‘binding corporate
rules’;
3. having in place
a standard set of clauses that have been approved by the EU Commission;
4. compliance with
an approved code of conduct by a relevant data protection supervisory
authority
5. certification with an approved certification
mechanism where the EU Commission has approved specific
arrangements in respect of certain countries, such as the US Privacy
Shield, in relation to organisations that have signed up to it in the USA.
8.
YOUR RIGHTS UNDER DATA PROTECTION LAW
8.1 Under data protection laws, you have certain
rights in relation to your personal information, as follows:
1. Right to
request access: (this is
often called ‘subject access’). This is the right to obtain from us a copy
of the personal information that we hold about you. We must also provide
you with certain other information in response to these requests to help
you understand how your personal information is being used.
2. Right to
correction: this is the
right to request that any incorrect personal data is corrected and that
any incomplete personal data is completed.
3. Right to
erasure: (this is often
called the ‘right to be forgotten’).This right only applies in certain
circumstances. Where it does apply, you have the right to request us to
erase all of your personal information.
4. Right to
restrict processing: this
right only applies in certain circumstances. Where it does apply, you have
the right to request us to restrict the processing of your personal
information.
5. Right to data
portability: this right
allows you to request us to transfer your personal information to someone
else.
6. Right to object: you have the right to object to us
processing your personal information for direct marketing purposes. You
also have the right to object to us processing personal information where
our legal reason for doing so is the Legitimate Interests Reason (see
section 4 above) and there is something about your particular situation
that means that you want to object to us processing your personal
information. In certain circumstances, you have the right to object to
processing where such processing consists of profiling (including
profiling for direct marketing).
8.2 In addition to the rights set out in section 8.1, where we rely on consent as the legal reason for using your personal
information, you have the right to withdraw your consent. Further details about
this are set out in section 4.5.
8.3 If you want to exercise any of the above rights
in relation to your personal information, please contact us using the details
set out at the beginning of this notice. If you do make a request, then please
note:
1. we may need
certain information from you so that we can verify your identity;
2. we do not charge
a fee for exercising your rights unless your request is unfounded or
excessive; and
3. if your request
is unfounded or excessive, then we may refuse to deal with your request.
9.
MARKETING
- You may receive
marketing from us about similar goods and services, where either you have
consented to this, or we have another legal reason by which we can
contact you for marketing purposes.
- However, we
will give you the opportunity to manage how or if we market to you. In
any email that we send to you, we provide a link to either unsubscribe or
opt out, or to change your marketing preferences. To change your
marketing preferences, and/or to request that we stop processing your
personal information for marketing purposes, you can always contact us on
the details set out at the beginning of this notice.
- If you do
request that we stop marketing to you, this will not prevent us from
sending communications to you that are not to do with marketing (for
example in relation to goods and services that you have purchased
from us).
- We do not pass
your personal information on to any third parties for marketing purposes.
10.
THIRD-PARTY WEBSITES
Our website may contain links to third-party websites. If you
click and follow those links, then these will take you to the third-party
website. Those third-party websites may collect personal information from you,
and you will need to check their privacy notices to understand how your
personal information is collected and used by them.