User Consent/Legal Basis
Other legal basis for collecting Personal Information are: (i) where we need the Personal Information for performance of a contract or requested service; or (ii) where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collect your Personal Information with your consent, you may withdraw your consent at any time as provided below. You understand and agree that we may collect, use, disclose and otherwise process the Personal Information you provide even if you are located outside the United Arab Emirates.
- Name, username, password, email address, and other contact information.
- Billing and shipping addresses, credit card number, and expiration date.
- We or our third-party service providers may also gather information relating to your devices, including: device model, operating system, browser type, unique device identifier, IP address, mobile phone number, mobile network carrier, and location (such as application installations).
- Other Personal Information you choose to provide such as your preferences, etc.
Use of Information
- To fulfill or respond to your inquiries.
- To address administrative needs and communications.
- To improve our products and services.
- To contact you for internal business purposes.
- To provide you with newsletters, surveys, promotions, and notices on changes and upgrades to our products and services.
We use Anonymous Information such as web or mobile pages you have viewed, in order to analyze request and usage patterns so that we may improve our products and services, enhance our user experience, and gather broad demographic information for aggregate use. Anonymous Information consists of data that would not identify you personally; these records exclude information (such as your name) that makes them personally identifiable to you. We may disclose Anonymous Information to third parties that promote our products and services. We reserve the right to use and disclose Anonymous Information to third parties in our discretion.
We may share your Personal Information with third party vendor and suppliers to provide you with the products and services that we offer you through the Website and to send you the Newsletters. You expressly consent to the sharing of your Personal Information with our contractors and third-party service providers (for the sole purpose of providing products and services to you. These service providers are contractually obligated to ensure the confidentiality of Personal Information and implement appropriate security measures.
We may participate in co-branding or co-promotional agreements with third parties pursuant to which we may share Personal Information with such third parties (“Partner Companies”). For example, we may participate in agreements with Partner Companies pursuant to which we provide the Partner Companies with a URL and a customer registration page co-branded with, or private labeled by, the Partner Companies, and the Partner Companies distributes and promotes the URL to its customers. A Partner Company may have access to Personal Information that we collect from their customers. As a result, if you register on the Website through a Partner Company, we may provide your Personal Information to the Partner Company. We do not control the privacy practices of these Partner Companies.
We may offer you the chance to participate in drawings, contests, giveaways, and promotions (“Special Promotions”) through our Website. By registering for a Special Promotion, you agree to the official rules that govern that Special Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Special Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Special Promotion. If you choose to enter a drawing, contest or other promotion, personally identifiable information may be disclosed to third parties or the public in connection with the administration of such Special Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Special Promotion’s official rules, such as on a winners list.
We may use your Personal Information in order to provide to third parties non-personal aggregated information about you that does not allow you to be identified or contacted and that is combined with the Personal Information of other users ("Aggregate Information"). For example, we might inform third parties regarding the number of users of our Website and the activities they conduct while on our Website. We might also inform a company that performs services or that provides products and/or services to us (that may or may not be a business partner or an advertiser on our Website) that 70% of our users live in the Middle East" or that "45% of our users have purchased products and/or services which can be downloaded from our Website." Depending on the circumstances, we may or may not charge third parties for this Aggregate Information. We may not limit the third parties' use of the Aggregate Information.
Under the following scenarios, we may be required to share your Personal Information:
- If we respond to subpoenas, court orders or legal process, or if we need to establish or exercise our legal rights or defend against legal claims.
- If we believe it is necessary to restrict or inhibit any user from using any of our Websites, including, without limitation, by means of “hacking” or defacing any portion thereof.
Unsubscribe from Our Newsletters
Should you no longer wish to receive our any of our Newsletters to your inbox, you may click on the unsubscribe link located at the bottom of each message received, and/or contact us at [email protected] and we will immediately remove you from our distribution list.
Located in the United Arab Emirates
Step Feed and the Website are located in the United Arab Emirates and governed by Dubai law. If you are outside the United Arab Emirates when you visit Website or engage in communications with us via mail, e-mail or telephone, please be aware that your Personal Information may be transferred to, stored and processed in the United States of America where our servers are located. Any information you provide to us, or that we collect through your use of the Website and will be stored, processed, and transferred within, or to, the United States of America. Please be aware that the United States of America and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country.
Note that your Personal Information may be available to the United Arab Emirates Government or its agencies under legal process in the United Arab Emirates.
Google User Data
The Website may use third party services to access your Google user data, only upon your verification and consent to do so. You will be notified prior to accessing your Google user data, and must authorize your account credentials before you are capable of accessing your Google user data. The Google user data you use will not be stored or shared by us. The Google user data accessed by the Website is limited to user contacts, and are used solely to allow you to email those contacts directly from the Website.
Users in the European Economic Area (EEA), United Kingdom and Switzerland
The Legal Basis for Using EEA, UK and Swiss Personal Information
For residents of the European Economic Area (EEA), United Kingdom and Switzerland, we advise that your Personal Information will be transferred to and processed in the United Arab Emirates which has data protection laws that are different than those in your country and may not be as protective. Our legal basis for collecting and using your Personal Information is to do so with your consent; where we need the Personal Information for performance of a contract or requested service, including to provide you with our daily Newsletter, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collected your Personal Information with your consent, you may withdraw your consent at any time.
Our retention of your Personal Information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.
To the extent that we transfer Personal Information from the EEA, UK or Switzerland to a jurisdiction outside the EEA, UK or Switzerland that has not been adduced by the European Commission as providing adequate data protections, we will ensure that such Personal Information is safeguarded through appropriate contractual terms or other approved mechanisms.
Rights for EEA.UK or Swiss Residents
In addition, if you are a resident of the EEA, UK or Switzerland, you have the right to:
- Find out if we use your Personal Information, to access your Personal Information, and receive copies of your Personal Information.
- Withdraw any express consent that you have provided to the processing of your Personal Information at any time without penalty.
- Access your Personal Information and have it corrected or amended if it is inaccurate or incomplete.
- Obtain a transferable copy of some of your Personal information which can be transferred to another provider when the Personal Information was processed based on your consent.
- If you believe your Personal Information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
- Request your Personal Information be deleted or restricted under certain circumstances. For example, if is using your Personal Information on the basis of your consent and has no other legal basis to use such, you may request your Personal Information be deleted when you withdraw your consent.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide Personal Information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal Information is required and if not, the consequences of not sharing your Personal Information with us.
Similarly, if we collect and use your Personal Information in reliance on our or a third party's legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.
To withdraw consent or exercise these rights, please contact us via email at [email protected]
Step Feed has implemented technical, administrative and physical security measures to protect your information from unauthorized access and use as described. While we strive to protect your information, no data transmission over the Internet is 100% secure and, consequently, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any information you transmit you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.
We will retain your information for the time necessary to provide a requested service, realize our legitimate business purposes and to comply with the law. We will only retain personal information for the longer of the period if: (a) required by law, or (b) there is a time-bound determination business need.
Our Website is not intended to be used by children under the age of 13, and we will not knowingly collect Personal Information from children under this age. We do not use an application or other mechanism to determine the age of users of the Website. All information provided to Step Feed will be treated as if it was provided by an adult. If, however, we learn that a child has submitted information about himself/herself to us, we will delete the information as soon as possible.
Google User Data
The Website may use third party services to access your Google user data, but only upon your verification and consent to do so. You will be notified prior to accessing your Google user data and must authorize your account credentials before you are capable of accessing your Google user data via the Website. The Google user data you use will not be stored or shared by us. The Google user data accessed by the Website is limited to user contacts and are used solely to allow you to email those contacts directly from the Website to, for example, invite your contacts to sign up for the Newsletters. We do not have access to your contacts.
Links to Third-Party Websites
The Website may contain links to and from third party websites of our business partners and various contact management services and other service providers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check their individual privacy policies before you submit any Personal Information to those websites.
Cookies and Similar Technologies
We may use pixel tags, cookies, and/or other similar technologies to collect visitor information.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse most areas of the Website, but some features may not function. You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org .