If you are based in Europe for the purposes of European data protection legislation, the controller of your personal information is Next Step Pro with offices at 4660 La Jolla Village Drive, Suite 875, San Diego, CA 92122.
We receive and store any information you knowingly provide to us. For example, if you tag a page in our repository, we’ll record the keywords that you provided. Also, when you purchase a Service subscription, we will collect payment related information. Certain information may be required to register with us or to take advantage of some of our features. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description. If you do not provide us with such information, your access to or use of the Service may be limited.
Whenever you interact with our Service, we may automatically receive and record information on our server logs from your browser or device, which may include your IP address, device identification, “cookie” information, the type of browser and/or device you’re using to access our Service, and the page or feature you requested. The data that we collect can tell us how often users use a particular feature of the Service, and we can use that knowledge to make the Service better and more useful to as many users as possible. We do not track information about your online activity after you leave our Services.
“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Service are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.
We may collect Personal Information from third parties we reasonably believe have the right to provide such information to us (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). In addition, we may collect Personal Information with your consent or as required by law or regulation.
We process Personal Information for certain legitimate business purposes, which include some or all of the following:
“Legitimate Interests” means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience.
When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can object to our use of your Personal Information for our legitimate interests. See the “Your Rights” section below.
We neither rent nor sell your Personal Information in personally identifiable form to anyone. However, we may share your Personal Information with third parties as described in this section:
We may share your personal information with third parties with your express consent.
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing service to charge your Card. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
We may choose to buy or sell the assets of Next Step Pro In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
U.S. Federal Trade Commission enforcement: Next Step Pro, Inc’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
We may anonymize your Personal Information so that you are not individually identified, and provide that information to our partners. We may also provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate information to any third party in a manner that would identify you personally, as an individual.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to email@example.com.
We will retain personal information for as long as it is needed for legitimate business purposes to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We keep such servers to help protect the stability and availability of the Service (such as protecting it from viruses and malfunctions).
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal information are available in our retention policy which you can request from us by contacting us. See the “Contacting Us” section below.
You can delete your account by emailing firstname.lastname@example.org. Subject to the “Limitations on Deletion” section below, when you request for us to delete your account for the Service, your data will be permanently deleted from our servers and access to your account will be disabled.
We may retain your Personal Information in accordance with our retention policy (see the “How Long We Keep Your Information For” section) and to the extent required to comply with (or we deem it reasonable in light of) any laws or regulations.
If you are based in the European Union you can also do the following:
Even if you have accepted the processing of your personal information for marketing purposes, you have the right to ask us to stop processing your personal information for such purposes. Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
You can request a copy of your information which we hold (in Europe this is known as a subject access request). If you would like a copy of some or all of it, please contact us and let us know the information you want a copy of, including any account or reference numbers, if you have them. Any subject access request may be subject to a reasonable fee to cover the cost of providing you with details of the information we hold about you.
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please contact us and let us know the information that is incorrect and the information you want it replaced with.
You may request that we cease processing your personal information. If you make such a request, we shall retain only the amount of personal information pertaining you that is necessary to ensure that no further processing of your personal information takes place.
You have rights to obtain a copy of some of the Personal Information that we hold on you and reuse or share it for your own purposes (“right to data portability”).
We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the Personal Information concerns more than one individual, we may not be able to transfer the information to you if doing so would prejudice the other person’s rights.
While your Personal Information is in our possession, it will be primarily stored at hosting facilities located in the USA (for North American & Global customers and in the EU (Germany for European Customers, including UK & Switzerland). These facilities are either operated by Next Step Pro or our third-party providers. By using the Service, you are consenting to have your Personal Information stored, transferred and processed in the USA or in Europe (for European customers, including the UK & Switzerland).
Whenever we transfer your personal information out of the European Union, we ensure a similar degree of protection is afforded to it by ensuring that the organization to which it is transferred is E.U.-U.S. Privacy Shield Framework certified or alternatively that at least one of the other safeguards listed below is implemented.
Next Step Pro, Inc complies with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Next Step Pro, Inc complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland, including the onward transfer liability provisions.
If there will be a transfer of personal information to a third party acting as a controller, Next Step Pro will “enter into a contract with the third party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual.” If the third party is acting as an agent rather than a controller, the Privacy Shield participant (Next Step Pro) itself will ensure that the transfer of data is only for limited and specific purposes. Whether the data transferee is a controller or an agent, the data must be provided the same level of protection as is required under the Privacy Shield principles.
Next Step Pro remains liable if its agent processes personal data in a manner inconsistent with the Privacy Shield principles, unless Next Step Pro proves that it is not responsible for the event giving rise to the damage.
Next Step Pro commits to cooperate with EU / Swiss data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of employment relationship.
To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.
If you have a concern about the way your data has been handled when it was collected by Next Step Pro, Inc in the United States using the Privacy Shield Framework, please refer to the “Complaints” and “Dispute Resolution” sections below.
Adequacy: the transfer is made only to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission webpage on Adequacy: https://ec.europa.eu/info/law/law-topic/data-protection_en, or
EU Model Contracts/Standard Contractual Clauses: where the party is outside of the European Union, not in a country subject to an adequacy decision and not privacy shield certified, we enter into specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission webpage on Model Contract Clauses: https://ec.europa.eu/info/law/law-topic/data-protection_en
Next Step Pro takes certain precautions to protect your Personal Information and to limit the risk that it will be accessed without authorization, including use of certain industry standard technologies and practices. That said, we cannot guarantee the security of such information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. No security system is perfect, so your use of the Service is at your own risk.
In addition to the security measures referenced above, your Service account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Service or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at email@example.com.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact: https://www.jamsadr.com/about/submit-a-case
For residual complaints not fully or partially resolved by other means, you may be able to invoke a binding arbitration mechanism.
If you have any questions or concerns regarding our privacy policies, please send us a detailed message at firstname.lastname@example.org, or: 4660 La Jolla Village Drive, San Diego, CA 92122, USA
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over other websites and their content. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.