Privacy Policy

MRP24: Privacy Policy – Stepnell Group Issue Date: 01.09.2018 Rev 001

1.0 Introduction

The Stepnell Group, hereinafter referred to as the The Group, takes your privacy very seriously. This Privacy Policy is intended to set out your rights and answer any queries you may have about your personal data. The controller of your data will be Stepnell Ltd.

If you need more information, please contact: privacyteam@stepnell.co.uk

2.0 What information do we collect?

In addition to any personal data you voluntarily supply, The Group may also process:

● Information related to the browser or device you use to access our website

● Internet browser and operating system

● IP address.

3.0 How do we use this information and what is the legal basis for this use?

We process the personal data listed above for the following purposes:

● To comply with applicable law and regulations

● In accordance with our legitimate interests in protecting The Group’s business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation)

● With your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services

● We may use information you provide to personalise:

○ our communications to you

○ our website; and

○ products or services for you, in accordance with our legitimate interests.

● To monitor use of our website. We may use your information to help us check, improve and protect our products, content, services and website, both online and offline, in accordance with our legitimate interests

● In circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests.

4.0 With whom and where will we share your personal data?

We may share your personal data for the purposes of inter-Group administration and to deliver products or services where elements of these are provided by Group companies other than those with which you have directly contracted. We may also share your personal data with search engines, web analytics and service providers.

5.0 How long will you keep my personal data?

We will keep your personal information in line with our data retention process. For further information please contact our Privacy Team: privacyteam@stepnell.co.uk

6.0 Where is my data stored?

The data that we collect from you is stored within the European Economic Area (EEA). Further information may be obtained from our Privacy Team: privacyteam@stepnell.co.uk

7.0 What are my rights in relation to my personal data?

Your rights with regards to personal data are detailed on the ICO website: www.ico.org.uk

Should you have any queries regarding this Privacy Policy, about The Group’s processing of your personal data or should you wish to exercise your rights, you can contact The Group’s Privacy Team by emailing: privacyteam@stepnell.co.uk