|Last updated: January 4, 2021|
|by: Step Modifications|
We may collect and receive information about users of our Services from various sources, including: (i) information you provide through your user account on the Services (your "Account") if you register for the Services; (ii) your use of the Services; and (iii) from third-party websites, services, and partners.
Opt-In Notification Policy
To comply with best practice set forth by General Data Protection Regulation (GDPR), STEP adopts an “opt-in” communication policy with respect to automated notifications from within its Services and by email. This means that users must opt-in to receive automated email notifications that STEP periodically sends out to users (for example, release dates and other events) and that in-app notifications default to ‘none’ in all user profiles. Users may elect to make changes to these settings at any time.
Information We Collect
Provided By You
Account Registration. When you register for an Account, we require your email address, which we must retain for the duration that your user Account remains enabled.
User Profile Content. Your Account profile allows you to publicly post your information on our Services (social media links, bio, gender, etc.). By registering and Account, you agree that your profile information and the content you post may be viewed and used by other users and third parties we do not control.
Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.
The personal information that you are asked to provide --and the reasons why you are asked to provide it-- will be made clear if we ever do ask you to provide your personal information.
Collected By Us
Cookies and Other Tracking Technologies. As is true of most websites, we gather certain information automatically and store it in log files. In addition, when you use our Services, we may collect certain information automatically from your device (via Google, Bing, or other free analytics services). This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area ("EEA"), the information referenced above in this paragraph may be considered personal information under applicable data protection laws.
Usage of our Services. When you use our Services, we may collect information about your engagement with and utilization of our Services, such as processor and memory usage, storage capacity, navigation of our Services, and system-level metrics.
Collected By Third Parties
Accounts. If you choose to link our Services to a third-party account, we may receive information about that account to authorize linking. If you wish to limit the information available to us, you should visit the privacy settings of your third-party account(s) to learn about your options.
Partners. We may also receive publicly available information about you from our third-party partners and combine it with data that we have about you.
How We Use Information
We use the information we collect in various ways, including to:
- Provide, operate, and maintain our Services
- Improve, personalize, and expand our Services
- Understand and analyze how you use our Services
- Develop new products, services, features, and functionality
- Communicate with you to provide you with updates and other information relating to the Service
- Process your transactions
- Send you text messages and push notifications
- Find and prevent fraud
- For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency
We may share the information we collect in various ways, including the following:
- Vendors and Service Providers. We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Services and to provide you with relevant information relating to STEP.
- Aggregate Information. Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can’t be used to identify you personally.
- Third-Party Partners. We may also share information about users with third-party partners in order to receive additional publicly-available information about you.
- With Your Consent. We may share information with your consent.
Legal Basis for Processing Personal Information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
You may access other third-party services through the Services, for example by clicking on links to those third-party services from within the Services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.
STEP is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please bear in mind that the Internet itself is not secure.
We retain personal information we collect from you where we have an ongoing, legitimate need to do so (for example, to provide you with a service you have requested or to comply with applicable legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If you are a registered user, you may access certain information associated with your Account by logging into our Services or by contacting us. If you terminate your Account, we will scrub all of your personal information from your Account profile, but any public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the public.
To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your personal information. The information you provide us may be archived or stored periodically by us according to backup processes for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit STEP's ability to comply with a legal obligation; inhibit STEP's ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to a third party (STEP has no trade secrets or protected information under the GNU license with the exception of our branding).
Your Data Protection Rights Under the General Data Protection Regulation (GDPR)
If you are a resident of the EEA, you have the following data protection rights:
- If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by contacting us.
- In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by contacting us.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by contacting us.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
You may opt-out of emails or notifications from us if you previously opted-in to these communications.
You can use some of the features of the Services without registering, thereby limiting the type of information that we collect.