Updated: August 2022
|1.||Important information and who we are|
Steplab as Data Controller
Save as provided at paragraph 1.3, Steplab is the data controller of all of your personal data that we manage in connection with the provision of the Services.
Steplab as Data Processor
Steplab is entitled to enter into commercial relationships with other third parties pursuant to which it may act as processor or joint controller of specified personal data. We would notify you in advance if this was to take place.Contact details
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical information on how Steplab Users use action steps, interact with the development materials and development process, and how coaches use both the action step selector and deliberate practice tools. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not undertake any obligatory collection of any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. To the extent we do ever request any Special Category of Personal Data you will always be given the opportunity to decline to provide such information and this will not prevent you from accessing the Website or using the Services.If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of the Subscription Agreement, and you fail to provide that data when requested, we may not be able to perform the Services. In this case, we may have to suspend your access to the Services until this is resolved and we will notify you accordingly.
How is your personal data collected?
We collect data from you through direct interaction by you when you register an account to use the Services and when you interact with the Services to the extent that you offer feedback or contribute additional personal data.
As you interact with the Website and use the Services, we will automatically collect Aggregated Data about your browsing actions and patterns. We collect this data by using cookies and other similar technologies but this data does not identify you individually.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
You can find out more about the types of lawful basis that we will rely on to process your personal data in paragraph 10 below.
Steplab recognises the importance of protecting the privacy of children. We will not knowingly collect any personally identifiable information from children. Our Terms require that Users represent to us that they are an adult. If a child has provided Steplab with personally identifiable information, we ask that a parent or guardian e-mail us at [email protected] and we will delete the child's information from our records.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
If you opt-in, we may communicate with you occasionally about other Steplab opportunities or for important research purposes. If you consented to receive this additional information we will always do our best to provide information to you that is up-to-date and relevant, whether that is by email, post, text or phone. All our newsletter communications include the option to unsubscribe at any time. In the meantime, if you wish to change how we contact you, please email us at: [email protected]Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access the data for the purpose of the delivery of the Services.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data (see paragraph 10 below).
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:
If you wish to exercise any of the rights set out above, please contact us by email at [email protected]No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.