At Striving Toward Excellence in Public Service (STEPS), Inc. and its affiliate organizations and programs, we are committed to protecting your privacy and your personal information. We do not sell or rent your personal information to others. Your privacy is very important to us and we want you to be assured that our privacy practices are held to the highest standard—we take every precaution to protect your information.
| STEPS, Inc. and its affiliate organizations and programs are permitted to use your personal information as stated below.
Our full details are:
Full name of legal entity: STRIVING TOWARD EXCELLENCE IN PUBLIC SERVICE, INC.
Email address: email@example.com
Postal address: 100 Centennial Avenue #1837, La Plata, MD 20646, USA
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org.
OUR COMMITMENT TO YOU
We appreciate your interest and support of STEPS, Inc. and its affiliate organizations and programs. We make an effort at all times to provide accurate information for your review while providing industry standard safeguards for any and all personal information you submit.
It is our policy to ethically and accurately share the needs and potential personal and professional impact so you can competently consider sharing financially if you desire to do so. As people of faith, we believe the desire for all giving comes from God as He moves in the hearts and minds of people who are prepared by the Holy Spirit. Our business process includes offering programs that inform and provide giving opportunities without imposing an undue obligation or pressure.
We assure you that your identity is kept confidential and we will not sell or rent your name to any other organization or corporation. We pledge to be responsible in our management, truthful in our advertising and cost-effective in our finances.
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymized data.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain backups of our website and/or databases and to enable publication and administration of our website, other online services, and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook advertisements or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
HOW WE COLLECT YOUR PERSONAL DATA
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook-based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
HOW WE USE YOUR INFORMATION
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at firstname.lastname@example.org at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors, and insurers.
Government bodies that require us to report processing activities.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
To use certain features of the Website or its Content, you may need a username and password. You are responsible for maintaining the confidentiality of the username and password, and you are responsible for all activities, whether by you or by others, that occur under your username or password and within your account. You agree to notify us immediately of any unauthorized or improper use of your username or password or any other breach of security. To help protect against unauthorized or improper use, make sure that you log out at the end of each session requiring your username and password.
It is your responsibility to protect your own username and password from disclosure to others. We cannot and will not be liable for any loss or damage arising from your failure to protect your username, password or account information. If you share your username or password with others, they may be able to obtain access to your personal information at your own risk.
By using our Website and its Content you agree to enter true and accurate information on the Website and its Content. If you enter a bogus email address, we have the right to immediately deactivate your account.
We will use our best efforts to keep your username and password(s) private and will not otherwise share your password(s) without your consent, except as necessary when the law requires it or in the good faith belief that such action is necessary, particularly when disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, the potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to the portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com.
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 or 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 one month. Occasionally it may 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
PURCHASES & DONATIONS
When you choose to purchase from or make a donation to STEPS, Inc. or one of our affiliate organizations and programs, we ask for your name, address, zip code and e-mail. We will use this information in order to correspond with you, provide gift receipts and other news of interest. When you sign up to receive information, coaching and/or mentoring services, broadcasts, e-books, or other products and publications, we need to know your e-mail address. This allows us to personalize our communications with you. When you make an online donation or create an M. Stanley Butler, STEPS, or Leadership Link account, we collect all necessary personal information through securely encrypted Web forms. This information includes your name, contact information, including email and street address, credit card type, number, security code and expiration date and unique identifiers such as your M. Stanley Butler, STEPS, or Leadership Link account number. Your contact information is used to contact you to resolve customer service issues. You can correct or update your personal information stored on our sites by completing the online contact form on the Contact page on our website.
When you subscribe to e-mails we collect any necessary contact information through securely encrypted Web forms. Upon registering you can request to receive e-mail communication from us. Our e-mail messages will contain instructions on how to unsubscribe or you may remove yourself from these mailing lists at any time by e-mailing firstname.lastname@example.org.
SURVEYS, POLLS, CONTESTS AND ACCOUNT INFORMATION
From time to time, we may collect information on our sites via market research, surveys, polls, and contests. Participation is completely voluntary. This information may include but is not limited to your name or address, demographic information such as your zip code or age. This information will be used for purposes of monitoring or improving the use and satisfaction of our sites. Information collected through surveys and polls will be used to analyze the use of our sites and improve the content and features. Contact information provided through contests will be used to notify winners and award prizes.
AGGREGATED TRACKING INFORMATION
M. Stanley Enterprise & Ventures, LLC and its affiliate organizations and programs collect several types of aggregated tracking information on its sites mainly by tracking page views to monitor visitor traffic patterns and site usage to help us further develop and improve the content and design of the site. This information includes, but is not limited to IP addresses, browser types and page views. This information is tracked in order to observe movement throughout the site to analyze trends and to improve the content and features to meet your needs. We may also collect your IP address to help diagnose problems with the server and to administer the site. This information is never linked to the personal identification information.
SHARING OF INFORMATION
To provide specific services, we may partner with third-party vendors, such as credit card processing companies and consultant organizations or another nonprofit organization and organizations and programs that may be of interest to you. We will share only the information necessary for these vendors to provide their services. STEPS, Inc. will make a reasonable effort to ensure any information shared with third-party vendors is not retained, shared or used for any secondary purposes.
We reserve the right to disclose your personal information to appropriate third parties if we are required to do so by law, or to comply with legal processes such as search warrants or subpoenas. We also reserve the right to disclose your personal information if we believe the information must be shared to:
| Address technical problems or perform network maintenance
| Investigate reports of users sending material using a false e-mail address, or of users sending harassing, threatening or abusive messages
| Protect against fraud, misuse or unauthorized use of our site or ministry
| Address emergencies, such as the risk of someone’s physical safety
STEPS, Inc. and its affiliate organizations and programs securely manage all customer data in accordance with consumer data protection laws enacted worldwide, including data handling, storage, and security. We take every precaution to protect your personal information, both online and offline. Our sites have been designed with security as a priority and we have physical, electronic and procedural safeguards to protect the information we collect by this site. We use encryption for all sensitive account portions of our sites including online donations and contact forms. The information you enter into any of these areas is protected with the strongest encryption supported by your browser. We cannot guarantee that unauthorized third parties will be unable to bypass these safeguards and access the information you provide by our sites. If you have any questions about the security of our sites, please submit your email to email@example.com.
We do not set any personally identifiable information in cookies, nor do we employ any data capture mechanisms on our Website other than cookies. You may choose to disable cookies through your own web browser’s settings. However, disabling this function may diminish your experience on the Website and some features may not work as intended. We have no access to or control over any information collected by other individuals, companies or entities whose website or materials may be linked to our Website or its Content.
LINKS TO EXTERNAL WEBSITES
Our sites contain links to external websites and STEPS, Inc. and its affiliate organizations and programs are not responsible for the content or privacy practices of these sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each website that collects personally identifiable information.
ASSIGNMENT OF RIGHTS