Stepes (referred to below as “Company”, “we”, “us”, and “our”), is committed to protecting your privacy and will carefully handle and protect the Personal Information (defined below) which you provide to us or we obtain during your use of this website (“Website”).

By accessing, browsing or using this Website, or by providing your Personal Information to us, you agree and consent to our handling and processing of your Personal Information in accordance with this Privacy Policy. If you do not so consent, please stop accessing, browsing or using this Website and do not provide any Personal Information to us.

Please remember that third-party websites you may access through our Website will have different privacy policies to ours and you should review those policies if you use those websites.

COLLECTION OF YOUR PERSONAL INFORMATION

When you visit this Website or register, order products or services, or communicate with us, we may ask you to provide certain personal information, such as your name, gender, nationality, country of origin, languages, work history, job title, company name, e-mail address, address, telephone number, and various others. We may also collect information about the areas of products or services that you are interested in. If you choose to order products or services, we will ask for additional information, such as your credit card information and billing address, which is used to create a billing account. You may be asked to provide information to us (e.g. your resume and voice sample) for recruitment purposes. Such information may be retained by us for future use and reference unless you specifically request us not to do so. You agree to only provide Personal Information which you have consent to supply to us for use in accordance with this Privacy Policy. If you do not provide us with the Personal Information we need we may not be able to provide the products or services you request.

We may collect information about your visit, including the pages you view, the links you click and other actions taken in connection with the Website. We also collect the standard information that your browser sends to every website you visit, such as your IP address, domain name, browser type and language, access times and referring website addresses.

All of the information referred to in the above section is collectively referred to as “Personal Information”.

USE OF PERSONAL INFORMATION

The Personal Information you provide will be used by the Company and those third parties mentioned here only for purposes specified in this Privacy Policy.

We collect and use your Personal Information to operate and improve our Website and deliver the products and services, or carry out the transactions, you have requested. These uses may include providing you with better customer service; making the Website easier to use; improving our products, services and technologies; and displaying content and advertising customized to your preferences. We also use your Personal Information to communicate with you. We may send certain service communications such as welcome letters, billing reminders, information on technical or service issues, and security announcements.

We may also use your Personal Information to provide you with marketing communications about goods, services and promotions which may be of interest to you, and we may contact you about these by fax, SMS, email, post or telephone. We may also permit selected third party partners to use your Personal Information for such purposes with your prior consent.

We occasionally hire other companies to provide particular services for us, such as processing transactions and taking payment, performing background checks, processing and delivering communications, providing customer support, hosting the Website and performing statistical analysis of our services. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. Whilst the Company has taken reasonable precautions to ensure that third parties to whom you consent to your Personal Information being transferred use it properly, you agree that the Company cannot be held responsible for the failure by any such parties to deal with your Personal Information in accordance with their legal obligations.

We may also access and/or disclose your Personal Information to third parties if we believe such action is necessary to comply with applicable laws or regulations and/or protect and defend our rights or property (including the enforcement of our agreements).

Personal Information collected on the Website or otherwise by us may be transferred outside of your country and stored and processed in any other country in which the Company, or its partners or agents, operate. Personal information protection laws or rules in these countries may not be similar to those in your country.

You consent to the use and transfer of your Personal Information as detailed in this Privacy Policy.

SECURITY OF PERSONAL INFORMATION

We are committed to protecting the security of your Personal Information and take reasonable commercial measures to help protect it from unauthorized access, use, disclosure, alteration or destruction.

If a username and a password are used to help protect your accounts and Personal Information, it is your responsibility to keep them confidential and not share them with anyone. If you are sharing a computer with anyone you should always log out before leaving to protect access to your information from subsequent users.

COLLECTION AND USE OF MINORS’ PERSONAL INFORMATION

The Website is intended for users that are eighteen years of age or older. We do not knowingly collect any Personal Information from anyone below this age.

USE OF COOKIES

The Website uses “cookies” to enable you to sign in and to help personalize your online experience. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies contain information that can later be read by our web server. The Website uses cookies to store your preferences and other information on your computer to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content and appropriate advertising on your later visits to this Website.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Website that depend on them.

ACCESSING AND UPDATING PERSONAL INFORMATION

We take all reasonable steps to ensure all Personal Information retained by us is accurate, complete, and up-to-date but it is your obligation to provide correct and accurate Personal Information to us and update us in case of any changes to your Personal Information. We reserve the right to correct, rectify or delete any inaccurate Personal Information or cease to rely on it until rectification is complete.

Your right of access – If you submit a request to us, we’ll confirm whether we’re processing your Personal Information and, if necessary, provide you with a copy of that Personal Information. If you require additional copies, we may need to charge a reasonable fee. You can make this request by sending an email to support@stepes.com There may be circumstances where we have the right under applicable laws and regulations to refuse to do so.

Your right to rectification – If the Personal Information we store about you is inaccurate or incomplete, you’re entitled to have it corrected. If you are entitled to rectification, and if we’ve shared your Personal Information with others, we’ll let them know about the modification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your Personal Information with so that you can contact them directly.

Your right to erasure – You can ask us to erase or remove your Personal Information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your Personal Information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also share with whom we’ve shared your Personal Information with so that you can contact them directly.

Your right to restrict processing – You can ask us to ‘block’ or suppress the processing of your Personal Information in certain circumstances such as where you contest the accuracy of that Personal Information or you object to us. If you are entitled to restriction and if we’ve shared your Personal Information with others, we’ll let them know about the restriction where it is possible for us to do so. If you request it, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your Personal Information with so that you can contact them directly.

Your right to data portability – As of 25 May 2018, you have the right, in certain circumstances and regions, to obtain Personal Information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object – You can ask us to stop processing your Personal Information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your Personal Information, except if we can establish compelling legal grounds for the processing; or
• processing your Personal Information for direct marketing.

• Your right to withdraw consent – If we rely on your consent as our legal basis for processing your Personal Information, you have the right to withdraw that consent at any time.

CHANGES TO PRIVACY POLICY

We will occasionally update this Privacy Policy to reflect changes in our services and customer feedback. When we post changes to this Privacy Policy, we will revise the “Last Updated” date at the top. If there are material changes to this Privacy Policy or in how we will use your Personal Information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notice. We encourage you to periodically review this Privacy Policy so that you know how we are handling and protecting your information.

This Privacy Policy is written in English only, and there is no other language version available.