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Welcome to StepsConnect privacy policy. We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we process your personal data when you visit our website or use our services and tells you about your privacy rights and how the law protects you.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Steps SRL, trading as StepsConnect is the data controller and is responsible for your personal data (collectively referred to as "StepsConnect", "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us by using the details set out below.
Full name of legal entity: Steps SRL, trading as StepsConnect.
E-mail address: info@stepsconnect.com
Postal address: StepsConnect, Via Galvani 24, 15121 Alessandria, Italy
We keep our privacy policy under regular review and may update this policy from time to time without notice. If we materially change the ways in which we use or share personal data previously collected from you through the website and services, we will notify you through the website and services, by email, or by other communication.
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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
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 may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
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:
We have set out below a description of the ways we may 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose / Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer and allow you to access our website and services, including our job matching service.
Identity, Contact, Engagement, Profile, Usage, Marketing and Communications, Special Categories
Performance of a contract with you; Consent (Special Categories only)
To manage our relationship with you which may include contacting you with updates or information about our service (but excluding marketing)
Identity, Contact, Profile
Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to keep our records updated and provide relevant information to our customers)
To operate, administer and protect our business and this website (including dealing with our customers, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Identity, Contact, Technical, Engagement, Profile, Usage, Special Categories
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, to enforce our Terms and Conditions or other legal rights, and in the context of a business reorganisation or group restructuring exercise), Necessary to comply with a legal obligation, Consent (Special Categories only)
To deliver relevant website content and advertisements to you, and measure or understand the effectiveness of the information we serve to you.
Identity, Contact, Engagement, Profile, Usage, Marketing and Communications, Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Technical, Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about roles and companies that may be of interest to you, and to allow companies to reach out to you about roles that may be of interest.
Identity, Contact, Engagement, Profile, Usage, Marketing and Communications, Technical, Special Categories
Necessary for our legitimate interests (to develop our products / services and grow our business), Consent (Special Categories only)
We may use your Identity, Engagement, Profile, Technical, Usage and Special Categories of Data to form a view on jobs or services that you may be interested in, or that may be suitable for you and may display relevant content on our website, or send it to you by email. You may also receive marketing communications from us if you have opted in to receive marketing, or if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing or job notification messages at any time by following the opt-out links on any marketing message sent to you.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
We will only use your personal data for the purposes 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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, in compliance with the above rules, where this is required or permitted by law.
When processing your personal data as described above, we may share your personal data with the parties set out below:
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.
Some of your Personal Data are shared with Recipients who could be found outside the European Economic Area. The data controller ensures that the processing of your Personal Data by these Recipients takes place in compliance with the Regulations. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis. More information is available from the Data Controller at the following addresses: info@StepsConnectconnect.com
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 know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have internal 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.
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including 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 with 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 unauthorized 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 we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are to:
If you wish to exercise any of the rights set out above, please contact us or our representative using the contact details set out above.
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.
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 30 days. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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Last updated: 25 January 2024