For the purpose of the Data Protection Legislation, the data controller is Stepex Limited of Step House, North Farm Road, Tunbridge Wells, United Kingdom in respect of any Personal Information that you provide to us or we otherwise obtain about you.
1.What information does Stepex hold about you and how is it collected?
If you, for example:
- search for a service;
- place an order for a brochure or other materials;
- enter a survey;
- post content;
- communicate with any third party; or
- report a problem with any of the Websites,
on or via any of the Websites, some or all of your personal information (including your name, job title, job function, company’s name, telephone, fax and mobile numbers, postal and email address, the industry you work in and your area of interest) may be collected by Stepex. We also collect personal information from you when you contact us (by email or otherwise).
A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Websites and the data you choose to share with us (including data you automatically share with us by way of your browser settings). We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our Websites. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Websites when they are using it. This helps us to improve the way the Websites work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to the Websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to the Websites, the pages you have visited and the links you have followed. We will use this information to make the Websites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|Cookie||Cookie Type||Purpose||More information|
|Google Analytics / Adwords||Analytical/ Performance / Targeting||
Google Analytics is a web analytics service provided by Google, Inc. Google Analytics sets cookies in order to allow us to evaluate and report on the use of our website. It is widely used across the web and all data is anonymised meaning the cookies carry no personally identifiable information. These cookies help us to understand our visitor’s behaviour and allow us to make improvements to better our user’s experience. Stepex may use Google Analytics for the following purposes:
· Google Analytics Demographics and Interest Reporting. Stepex use information from Google’s Interest-based advertising or 3rd-party audience data (such as interests) with Google Analytics to influence our marketing strategy. Personal information is not captured unless expressly provided by the user.
|You may opt out of the Google Analytics Display Advertiser Features through Ads Settings in your Google Account. You may also opt out of Google Analytics using this browser ad-on|
With regard to each of your visits to the Websites we may automatically collect the following information:
- your browser type and version;
- time zone setting;
- browser plug-in types; and
- versions, operating system and platform.
We may also collect information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the Websites (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
You may opt out of the Google Analytics Display Advertiser Features through Ads Settings in your Google Account. You may also opt out of Google Analytics using this browser ad-on
2. Personal Information that we receive from other sources
We may collect Personal Information about you from publically available sources (either ourselves or via third parties) in connection with our legitimate business interests.
We may also receive information from third parties who collect Personal Information from you and pass it on to us. To the extent necessary, the third party collecting this data is responsible for obtaining the relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used.
3. What does Stepex do with your personal information?
We will only use your Personal Information (including information we receive from other sources) in the following ways (depending on the types of information): (i) so that we can perform a contract with you; (ii) for the purposes of legal compliance; and (iii) for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of our Websites and services and support our customers and Website users).
All of the Personal Information described above will be stored on Stepex’s user database (unless you notify us that you no longer wish us to retain such information, in which case it will be deleted). Stepex will only use your Personal Information in order to contact you (for example by email, mail or telephone) for those purposes to which you have previously consented on the site or where we otherwise have a right to do so. For example, if you register on one of our Websites, Stepex will email to you Stepex’s information about that event and, contact you about relevant products and services offered by Stepex or by reputable third parties. Stepex will also contact you in order to secure your permission to market its products and/or services where it has obtained your details in the course of a sale of any of its products or services. If you do not wish to receive information about Stepex’s and/or third parties’ products and services, please leave the relevant box on the registration form unticked when you register or, subsequently, via the “subscription preferences” link which will be sent to you during this process. You may cancel your subscription to Stepex’s marketing material at any time by clicking on the Unsubscribe Button link at the foot of any marketing communication.
Should you request us to amend or suppress records containing your information we will endeavor to do so as promptly as practical, however you may receive communications for a transitional period while we process the records.
Stepex will also use the information which you provide in aggregate form (i.e. so that no individual users are identifiable) to determine demographic profiles and browsing patterns in order to
- develop marketing profiles and assist strategic development;
- manage Stepex’s relationship with its sponsors and advertisers;
- enable site audits to be performed; and
- enable Stepex to review, develop and improve the services which it offers.
In addition, Stepex will use your information to notify you about changes to our services.
Stepex will also use the Personal Information collected from your use of the Websites to administer the Websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to improve our site to ensure that content is presented in the most effective manner for you and for your computer, to allow you to participate in interactive features of our service, when you choose to do so, as part of our efforts to keep the Websites safe and secure, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, and to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
4.Keeping your personal information up to date
We take all reasonable action to ensure that the information we collect and use is accurate, complete and up-to-date.
However, the accuracy of the information depends to a large extent on the information you provide. That’s why we recommend that you
- Keep us up-to-date with changes to your information such as your name and address; and
- Let us know if there are any errors in the information
You have the right to see the Personal Information we hold about you and to ask us to: (a) make any changes to ensure that any Personal Information we hold about you is accurate and up to date; (b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or (c) transfer any information we hold about you to a specified third party. If you wish to do this, please contact us using the contact details set out at section 9 below.
5.To whom is your personal information disclosed?
Stepex will not share your Personal Information with the other members of its group and (provided that you consented to receiving marketing from such third parties) will make your name and postal address available to reputable third parties so that they can send you details of their products and services.
In supplying Stepex with your Personal Information, you agree that Stepex may transfer that information (to the extent that it is still held on our database at the relevant time) to a third party who acquires all or substantially all of any Stepex entity’s assets or stock or our Website services, or to a third party which we purchase or from which we acquire substantially all of its assets or stock, in each case whether by merger, acquisition, reorganisation or otherwise.
Stepex will also share your Personal Information with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract it enters into with them or you, and/or, to the extent you have expressly consented (by ticking the relevant box on the registration form), to advertisers and advertising networks that require your data to select and serve relevant adverts to you and others.
In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation, enforce our terms and conditions and any other agreement, or protect the rights, property, or safety of Stepex, Stepex’s group companies and our contractors, directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.
6.Transfers of personal information overseas
8.How do we protect your information?
Stepex is committed to data security and will take the appropriate technical and organisational measures to ensure that your Personal Information is treated securely. Stepex offers the use of a secure server. The secure server software encrypts all information which you input before it is sent to Stepex.
Stepex takes steps to guard against unauthorised access to the Personal Information of the users of the Websites. Although it makes every effort to create a secure environment for your Personal Information, Stepex cannot guarantee the safety of any Personal Information which is transmitted to us on-line and/or via email as, unfortunately, the transmission of information via the internet is not completely secure. Although Stepex will take appropriate technical and organisational measures to protect your Personal Information, any transmission is at your own risk. Once we have received your information, we will use appropriate technical and organisational measures to try to prevent unauthorised access.
We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation allows (This is 3 years, given our current procedures).
Where Stepex has given you (or where you have chosen) a password which enables you to access certain parts of the Websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone
If you have any questions or concerns about Stepex’s use of your Personal Information, please email Hugh Robinson at firstname.lastname@example.org or write to him at
Mr Hugh Robinson
North Farm Road
Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.