Privacy Policy

What is this Privacy Policy for?

Step Function is committed to ensuring your privacy is protected. This Privacy Policy sets out details of the information that we may collect from you and how we may use that information. Please take your time to read this Privacy Policy carefully.

 

The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.

 

About Us

In this Privacy Policy references to “we” or “us” or “Step Function” are to Step Function.

We are the data controller of any personal information you provide to us. This means that we are responsible for complying with data protection laws. This Privacy Policy describes what personal information we may collect from you, why we use your personal information and more generally the practices we maintain and ways in which we use and protect your personal information.

If you have any questions about how we collect, store or use your information, you can contact us using the details set out below.

 

Who Do We Collect Information About?

We collect information about:

  • Previous, current and prospective clients
  • Step Function website users
  • Business contacts and suppliers

 

When Do We Collect Personal Information?

We collect information about you:

  • When you apply for one of our courses
  • Whenever you use the Step Function website
  • When you sign up to our newsletter
  • If you respond to a customer survey, questionnaire or marketing campaign
  • If you contact us for any other reason

 

What Personal Information Do We Collect And Use?

In order for us to provide training courses, we need to collect and process personal data about you.

The personal information that we collect will depend on your relationship with us.

If you provide personal information to us about other individuals you agree: (a) to inform the individual about the content of this Privacy Policy; and (b) to obtain any consent where we indicate that it is required for the processing of that individual’s personal data in accordance with this Privacy Policy.

Personal information:

  • General information such as your name, email address, phone number
  • Information captured during our telephone calls
  • Your marketing preferences

 

How Do We Collect Your Information?

We collect personal information from a number of different sources, including:

  • Directly from you
  • Through customer surveys and responses to marketing campaigns
  • From your use of our website

 

What Are Our Purposes For Using Your Information
  1. To fulfil a contract, or take steps linked to a contract.
  2. Providing you with services described on the website;
  3. Responding to communication;
  4. Carrying out technical analysis to determine how to improve the website and services we provide;
  5. Monitoring activity on the website, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the website;
  6. Managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the website or asking for your feedback or whether you want to participate in a survey;
  7. Managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
  8. Improving our products and services;
  9. Providing general administrative and performance functions and activities;
  10. Processing your job application (if you are applying for a job at Step Function);
  11. Where you give us consent, providing you with marketing information about products and services which we feel may interest you;
  12. For purposes which are required by law;
  13. For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

 

Who Do We Share Your  Information With?

Disclosures to third parties

We may disclose your information to the third parties listed below for the purposes described in this Privacy Policy. These might include:

  • other third parties who assist in administration e.g. accountants, lawyers and other experts
  • fraud detection agencies and other third parties who operate and maintain fraud detection registers
  • the police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime
  • online search engines
  • social media platforms
  • our third party service providers such as IT suppliers, lawyers, marketing agencies, payment processing agencies, document management providers and tax advisers
  • third parties who undertake analysis for the purposes of product improvement
  • selected third parties in connection with the sale, transfer or disposal of our business. We will ensure that such third parties have the appropriate technical and organisational measures in place to safeguard your data

 

What Marketing Activities Do We Carry Out?

Email marketing (Newsletter)

If you have consented, we may use your personal information to provide you with information by emailed Newsletter about our products or services or those of our partners which may be of interest to you. You have the option to opt out at any time.

If you wish to unsubscribe from newsletters sent by us, you may do so at any time by clicking on the “unsubscribe” link.

Email marketing (Other)

If you have contacted us directly and provided your email address, we may use your personal information to provide you with information via email about our products or services you have expressed an interest in. You have the option to opt out at any time by contacting us using the details provided below.

SMS marketing

If you have contacted us directly and provided your phone details, we may use your personal information to provide you with information by text message about our products or services you have expressed an interest in. You have the option to opt out at any time by contacting us using the details provided below.

Telephone marketing

If you have contacted directly us and provided your phone details, we may use your personal information to call you regarding products and services you have expressed an interest in. You can opt out of receiving these calls at any point by contacting us using the details provided below.

 

How Long Do We Keep Your Information For?

We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply with our legal and regulatory obligations. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim, or where we are required to keep your personal data due to legal or regulatory reasons.

 

Your Rights

Under data protection law you have certain legal rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details provided below.

 

Please note:

  • in some cases we may not be able to comply with your request (e.g. we might not be able to delete your data) for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can’t comply with your request, we will tell you why.

 

Your rights include:

  1. The right to access your personal information. You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your information will usually be provided to you via email, unless otherwise requested.
  2. The right to rectification. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.
  3. The right to be forgotten. In certain circumstances, you have the right to ask us to erase your personal information. Examples would include where the data is no longer required for the original purpose, consent has been withdrawn and there no overriding ground for continuing the processing, or for compliance with the national law.
  4. The right to restriction or suspension of processing. In certain circumstances, such as a question over its accuracy, you are entitled to ask us to stop using your personal information or to suspend its use.
  5. The right to data portability. In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice.
  6. The right to object to marketing. You can ask us to stop sending you marketing messages at any time.
  7. The right to object to processing. For certain uses of your personal information, we will ask for your consent. This consent can take the form of an action or affirmative instruction. Where we do this, you have the right to withdraw your consent to further use of your personal information. In other circumstances we may process your data using legitimate interest, and again you have the right to withdraw this right of processing, unless it is necessary in connection with our legal rights.
  8. The right to lodge a complaint with the ICO. We would hope that you will always raise any issues with us first, and that we will be able to resolve them to your satisfaction. However, if this isn’t possible then you always have a right to complain directly to the Information Commissioner’s Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations.

 

Please see below for contact details of the ICO:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Email: casework@ico.org.uk

Making a complaint will not affect any other legal rights or remedies that you have.

 

How We Protect Your Information?

We use a range of organisational and technical security measures to protect your information.

We restrict access to your information as appropriate within Step Function to only those who need to know that information for the purposes set out above.

Firewalls are used to block unauthorised traffic to the servers. Our internal procedures cover the storage, access and disclosure of your information.

 

Contacting Us

If you have any questions about how we collect, store or use your personal information, you may contact us at:

Email: enquiries@stepfunctioncoaching.co.uk

 

Updates To This Policy

From time to time we will make changes to this Privacy Policy, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. You should check our website periodically to view the most up-to-date Privacy Policy.