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INTRODUCTION

We (Step Communications Ltd, Step House, North Farm Road, Tunbridge Wells TN2
3DR, United Kingdom), as the data controller are committed to protecting your
privacy and endeavour to collect, process and share your data in accordance with
the latest regulations that apply. This privacy policy explains how we do this
and what your rights are.


PRIVACY POLICY


PERSONAL DATA

We collect and process personally identifying information from you including
your name, company address and email when you register for services offered by
any of our websites, which include access to restricted content, subscriptions
to newsletters and other site-related mailings as well as to receive the printed
version of the magazine. We may also use the data that you provide to send you
information about other products or services offered by the Step Group of
companies that we believe to be of interest to you. In addition, we may send you
information that we believe to be relevant to your profession on behalf of third
party commercial partners.

When you register and create an account with our websites, you will have
consented to us processing your personal information as described above.

We may also collect personally identifying information as a result of other
activities such as market research where no prior consent has been obtained. In
these cases, we process your data because we have a legitimate commercial
interest in doing so. The processing is necessary so that we can send you
business or professional information that is relevant to your identified role or
information about our products and services electronically or by post. We take
care to ensure that you meet the profile of our target audiences and that we use
your data in ways that you would reasonably expect and that our use of your data
has minimal privacy impact on you. You have the right to object to our use of
your data in these circumstances, using the opt-out mechanisms that accompany
each communication, by contacting the Data Controller at the address above or by
email to data@stepcomms.com or securely via our dedicated preference management
tool at privacy.stepcomms.com.

We also collect and process personal information when we enter into commercial
negotiations or agreements with you. In these cases, the processing is necessary
for the performance of a contract to which you are party or in order to take
steps at your request prior to entering into a contract.

We will not process your data in a manner that is incompatible with the purposes
outlined above.


OTHER DATA

We record and store your IP Address and information provided by your user agent
(browser) such as its type and version and your operating system when you visit
our websites. This information does not identify you personally, and we use it
for aggregate reporting on user activity which we may provide to advertisers,
and for system administration, site improvement and security purposes. We also
use your IP Address to obtain your general location (at country level) to
improve the registration process if you visit the registration page on any of
our websites where they exist.


SECURITY

Keeping information about you secure is very important to us so we store and
process your personal information in accordance with the high standards required
under data protection legislation. When we collect your personal information, we
do our best to keep the information you disclose to us secure. We do this by
ensuring that all information transmitted between us and you via a web browser
is encrypted. Your browser should display a padlock icon to indicate that the
site is secure, and the protocol used for transmission is https instead of http.
Despite this, we can't guarantee your data security. By using our websites you
accept the inherent risks of providing information online and will not hold us
responsible for any breach of security.


DISCLOSURE TO OTHER ORGANISATIONS

The personal information that we collect when you use our websites is
confidential. We may only disclose your personal information to a third party in
the following circumstances:

 * To third party technical partners, for example companies who undertake
   automated addressing of mailings on our behalf. Such companies are not
   permitted to use your personal information for any other purpose and are only
   permitted to keep a copy of the information for as long as is necessary to
   provide the service;
 * If required or permitted to do so by law;
 * If required to do so by any court or any other applicable regulatory,
   compliance, governmental or law enforcement agency;
 * If necessary in connection with legal proceedings or potential legal
   proceedings;
 * If ownership of all or part of our websites is transferred, in which case any
   purchaser would only be entitled to use that information in a way consistent
   with this Privacy Policy;

We will not share your personal information with third party commercial partners
under any circumstances.


HOW LONG WE STORE YOUR DATA FOR

We will continue to store your personal data as long as necessary in order to
provide you with the service that you requested. We periodically review data to
ensure that the services that we provide are still relevant, and we will remove
or anonymise data when we deem this not to be the case.


YOUR RIGHT TO ERASURE

Under certain circumstances, you have the right to request removal of your
personal data from our systems. We may request evidence of identity before we
can comply with erasure requests. Requests should be made in writing to the Data
Controller at the address above, by email to data@stepcomms.com, or securely via
our dedicated preference management tool at privacy.stepcomms.com.


YOUR RIGHT TO ACCESS AND RECTIFICATION

You have the right to access a copy of your personal data. You also have the
right to have any errors corrected. Requests for access and rectification should
be made in writing to the Data Controller at the address above, by email to
data@stepcomms.com, or securely via our dedicated preference management tool at
privacy.stepcomms.com. Access will be subject to verification of your identity.


YOUR RIGHT TO OPT OUT

Every newsletter and third party mailer we send includes a working unsubscribe
link enabling you to opt out of receiving further newsletters or mailers. If you
have registered for newsletters at more than one of our websites and you no
longer wish to receive those newsletters, you must unsubscribe from each one
individually. All third party mailers provide you with the option to select
which suppliers you no longer want to hear from, or to opt out of receiving
third party mailings altogether. If you wish to stop receiving printed copies of
the magazine, each copy includes instructions on how to let us know. You can
also specify the activities that you would like to opt in and out of securely
via our dedicated preference management tool at privacy.stepcomms.com

In all cases, the opt-out request is processed as soon as we have received your
instructions. In practice, this takes immediate effect in respect of digital
communications, but you may receive a further edition of the printed magazine if
the mailing labels have already been processed prior to your opt out request.


COOKIES AND OTHER TRACKING ACTIVITY

Our websites use cookies to track visitor activity anonymously for analytics
purposes; to provide certain social networking features; to personalise content;
and to manage your access to restricted content if you register with the site
and log in.

Our websites make use of some third party services who also store cookies (Third
party cookies) on your machine. These services are

 * Google Analytics

The links above will take you to specific information about controlling cookies
from these third parties.

If you would like more general information on controlling cookies, please visit
www.aboutcookies.org.

If you register for access to restricted content on our websites and then log
in, we may track your activity in order to analyse how we may improve the site
or its services based on visitor behaviour.


LINKS TO OTHER WEBSITES

Our websites include links to third party websites. The inclusion of these links
should in no way be considered endorcements of the content of the websites and
they are not governed by this Privacy Policy. We do not pass any identifying
data to third party websites when you follow links. Any data you provide to
third party websites is subject to their own privacy policies.

© Step Communications Ltd, Registration Number 3893025.
Step House, North Farm Road, Tunbridge Wells, Kent TN2 3DR, United Kingdom Tel:
+44 (0) 1892 779999