Online Information Gathering and Purposes for Processing
In operating this Site and our services, STEP 1-2-3 MENTOR may process personal information about you in a number of ways. Personal information is information which relates to an identified or identifiable individual (i.e., a natural person) and lets us know the specifics of who they are, such as name, email address or postal address; it may also include their views and preferences as they relate to trademark issues and STEP 1-2-3 MENTOR’s services.
Types of information collected by STEP 1-2-3 MENTOR:
We mostly collect personal information when you use a personalized service, such as login to the Site, or you voluntarily disclose your information such as a credit card number, name, address, phone number, fax number, email address, demographic, and other personal and financial information when you register for membership with STEP 1-2-3 MENTOR, transact business at our Site, communicate by sending us an email, complete an STEP 1-2-3 MENTOR survey or fill in a form.
In some cases, such as on discussion boards, blogs or other public forums, any personal information you provide may become publicly available to employees of STEP 1-2-3 MENTOR member organizations and possibly the general public. Users should be aware that when they voluntarily disclose such personal information (e.g. email address as used in a signature line), that information can be collected and used by others and may result in unsolicited messages from other posters or parties.
Please note that if you are active in STEP 1-2-3 MENTOR, you may have been assigned or have created a username and password to be used for accessing the Site. This information is mentioned by STEP 1-2-3 MENTOR to allow you to access the Site.
Collection of IP addresses: When visiting any Internet site your unique address, called an “IP address,” is recorded. The amount of information about users made available from their IP addresses varies greatly, for instance depending on how they are connected to the Internet. STEP 1-2-3 MENTOR does not release any information about the collection of this address to any third party.
Survey Information: Occasionally, STEP 1-2-3 MENTOR conducts surveys to assist us in our strategic planning and development of our benefits and services. We may appoint third parties to do this on our behalf. Survey responses will only be shared with third parties, including the membership at large, in aggregate.
Communications with STEP 1-2-3 MENTOR: If you contact us with a complaint or query, we may keep a record of any phone number or email address used to get in touch with us as well as the correspondence and the period of time it took for us to deal with a query or any request you had.
Website Usage Information: STEP 1-2-3 MENTOR also collects and archives technical website information about how visitors interact with our Site. This may include Site statistics such as:
- The number of visitors to our Site;
- How long our visitors spend on our Site and how they navigate around our pages;
- How visitors interact with the search functionality on our Site;
- What browsers our visitors use and what country they are located in; and
- The referring URL of a Site visit and/or what search terms or results might have brought a visitor to our Site.
This information is mainly processed by STEP 1-2-3 MENTOR in an anonymized or depersonalized format and is primarily used internally to provide better service to STEP 1-2-3 MENTOR members.
In addition to the purposes noted above, we may process your personal information for the following purposes:
- to provide you with the information and membership services you have requested and send you marketing materials;
- to communicate with you about your account, changes in policies or transactions;
- to authenticate your access to our Site;
- for system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to distinguish you from other users (for example to remember your log-in details);
- to monitor your use of our Site to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
- to notify you of any changes to our services;
- to ensure that our Site is safe and secure; and
- to comply with applicable laws and regulations.
Legal basis for processing your personal information
We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:
- Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
- Our legitimate business interests: Where it is necessary for us to understand our members, promote our services and operate effectively as a professional organization, provided in each case that this is done in a legitimate way that does not unduly affect your privacy and other rights. For example, we will rely on this legal basis when we conduct certain analysis to understand our members in sufficient detail so we can tailor our resources to suit their needs.
- Performance of a contract with you (or in order to take steps prior to entering a contract with you): For example, where you have applied to become a member of STEP 1-2-3 MENTOR and we need to use your contact details and payment information in order to process your membership application.
- Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
We will not share your personal information with any third parties except where:
- You have consented or asked us to share your information with third parties;
- Our organization, or substantially all our organization’s assets are merged or acquired by a third party, in which case your personal information may form part of the transferred or merged assets;
- To provide anonymous statistical information about users of the Site and related usage information to reputable third parties;
- We are using a third-party service provider to provide services that involve data processing; or
- Where it is otherwise permitted by applicable law, or where we are required by law to do so.
Where we store your personal information
The personal information that we collect may be transferred to and stored at, a destination outside of your country which may have less strict data protection laws when compared to those in your country.
How we keep your personal information
We take steps to ensure that the personal information that you provide is retained only as long as it is necessary for the purpose for which it was collected. After this period, it will be deleted or in some cases anonymized. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.
Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in the future.
Applicable data protection may give certain rights in relation to your personal information, including the right to object to and/or withdraw consent to the processing of your personal information, the right to access your personal information, and the ability to erase, restrict, or receive a machine-readable copy of your personal information. We will handle any requests to exercise your rights in accordance with applicable law, and you can contact us about your rights at any time by emailing us at firstname.lastname@example.org.
In addition to the rights above, you may be able to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we request that you initially contact us (using the contact details above) so that we can investigate, and hopefully resolve, your concerns.
STEP 1-2-3 MENTOR provides links on our Site that will take the user to other sites or services. STEP 1-2-3 MENTOR does not control the content or links that appear on these other sites. In addition, these other sites or services, including their contents and links, may be constantly changing. The fact that we have made these links available to you is not an endorsement or recommendation to you by STEP 1-2-3 MENTOR. We provide these links only as a convenience. For more information please see the STEP 1-2-3 MENTOR
Other companies linked to this Site may collect information about you when you view or click on these sites. We cannot control this collection of information. You should contact these content providers directly if you have any questions about their use of the information they collect. These sites and services may have their own privacy policies or no policy at all. We encourage you to review the privacy policies of any third-party sites or services before providing any of them with your personal information.
STEP 1-2-3 MENTOR takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage and processing practices, and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.