2019-2020 Privacy Policy

We take good care of your data!

What this privacy policy covers

This policy describes how Stepback and other companies and brands in our group (also referred to as “we” or “us”) will make use of your data to avail services from our website (https://www.stepback.ph).

It also describes your data protection rights, including a right to object to some of the processing which Stepback carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

How we use your data

  • Stepback uses your personal data to manage your relationship with us, allow you to purchase services from us, deal with invoicing and ensure that we can communicate with you efficiently.
  • Data is shared with other members of the companies which are associated or affiliated to Stepback and third party agents who assist us with the sale and provision of our services.
  • Where we rely on your consent, such as for direct marketing, you can withdraw this consent at any time.

What information we collect

We collect and process personal data about you when you interact with us and our websites, and/or when you purchase services from us. This includes:
  • Your name;
  • Your email address;
  • Your phone number;
  • Your address;
  • Your payment details (including your billing address or PayPal account or bank details, as appropriate); and/or
  • Information related to the browser or device you use to access our website;

How do we use this information, and what is the legal basis for this use?

We process this personal data for the following purposes:

  • To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us. This includes:
    • verifying your identity;
    • taking payments;
    • communicating with you;
    • providing customer services and arranging the delivery or other provision of services;
  • Where we have a legitimate interest. This includes:
    • providing an enhanced online user experience such as “likebox”.
    • to conduct research, analysis and analytics.
  • Where you give us consent:
    • we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners.
    • we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used
    • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

What rights do you have?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

How do I get in touch with you?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data or would like to opt-out of direct marketing, you can get in touch at lloyd@stepback.ph.

How long do you retain my data?

Where we process registration data, we do this for as long as you are an active user of our sites and for 12 months after this.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.

Where we process personal data in connection with performing a contract, we keep the transactional data for six years from your last interaction with us (or such longer period as may be required by law).

Language

This policy is written in English with a reference translation in another language (if necessary). In the event of any conflict in interpreting or construing the terms of this policy, the English version shall prevail.

Stepback uses your personal data to manage your relationship with us, allow you to purchase services from us, deal with invoicing and ensure that we can communicate with you efficiently.