What is the purpose of this document?
We are committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you or your company (It applies to all customers) during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).
Steptoes is the “data controller”. This means that we are responsible for deciding how we hold and use personal information about you or your company. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to current and former customers. This notice does not form part of any contract of sale or other contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you or your company, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law (GDPR) which states that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have informed you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have informed you about.
- Kept securely.
The kind of information we hold 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, store, and use the following categories of personal information about you:
- Telephone numbers
- Personal email addresses
How is your personal information collected?
We will collect personal information in the course of customer-related activities with you through our interaction via direct contact at a place of work, contact via phone enquires and contact via online contact forms on our website.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
How do we protect your data
All data provided is collected, stored and maintained in accordance with documented security measures and procedures.
Change of purpose
We will only use your personal information 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.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
No third-party providers have direct access to your data, we do not share your data with third parties, third-party service providers and other entities unless specifically required by law or under an agreement we may have with you.
We may transfer your personal information outside the EU for any of the purposes described in this notice..
If we do, you can expect a similar degree of protection in respect of your personal information.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
If you want to review, verify, correct or request erasure of your personal information, or object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us in writing. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you have any questions about this privacy notice or how we handle your personal information, please contact us. You have the right to make a complaint at any time to the Cyprus supervisory authority for data protection issues.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact firstname.lastname@example.org .