Privacy Policy

1. What does this Privacy Notice provide?

This Privacy Notice (“Notice”) provides wpsteer.com personal data processing steps. It applies to any personal information you provide to us and any personal information we receive from other sources. This Notice describes our actions and your rights related to your personal information. This Notice is not a contract and does not create rights and obligations for any of the parties, except for those provided in the legal acts regulating the protection of personal data.

2. Who is responsible for your personal information?

The term “WP steer” used in this Notice refers to the website www.wpsteer.com including related websites (“we”, “us” or “our” words are also used). Wpsteer.com is responsible for your personal information (and is the data controller in terms of data protection legislation) that we collect from you or about you.

You can contact us regarding data protection by e-mail: info@wpsteer.com

3. When and how do we collect your information?

We collect personal information in the following cases:

  • When we provide services to customers.
  • When you order services from us.
  • When you use our website www.wpsteer.com
  • When you contact us with a complaint or enquiry.
  • When you contact us on social media.

4. What kind of information do we collect?

Information you provide to us
When you order our services, we ask that you provide accurate and necessary information that is necessary to respond to your request. When you provide your personal information to us, we use it for the purposes specified at the time of collection or for purposes that are obvious from the context of the collection, such as making a commercial offer to us.

In providing the above services to our customers, we may collect personal information such as:

  • Contact data, e.g., first name, last name, e-mail postal address, residential address, telephone number.
  • Communication preferences, such as information about which newsletters you wish to receive.
  • Other relevant information such as your job title, language, zip code, location, and time zone where you live.

More information about what information we collect for each service we provide, as well as information about the purpose and legal basis for data collection, is provided below.

We do not collect any special personal data. Special personal data includes data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life. If you provide us with personal information about other individuals, such as your employees or dependents, you must obtain their consent before providing this information to us.

Information we collect on our website and social media networks
We may collect all or some of the information below when you order our services, use access to content or connect to the site. Without limiting the categories of information below, this information may include:

  • Contact information, e.g., first name, last name, e-mail, postal address, residential address, telephone number.
  • User account name, password, password reminder questions, and answers to those questions.
  • Communication preferences, such as information about which newsletters you wish to receive.
  • Information about the searches being performed.
  • Contact information of the friends you have invited (used only for desired communication).
  • Information posted online, such as in our community discussions.

In some cases, we automatically collect information when you visit our website or email correspondence. during letters. Automated technologies include cookies and other technologies used on computers or other devices. For additional information on how we use cookies, please read our Cookie Policy.

Social media networks
You can contact us using social networks or based on the integration of social media networks on our website. When you connect with us on third-party social networks or use the social network features integrated on the website, you give us access to certain information about your social network account (such as name, email address, photo, gender, date of birth, messages or pages that you liked).

If you post information while communicating with us on social networks or using social network integration, depending on the privacy settings you choose, the posted information may be publicly posted on the Internet. In some social media networks, you can control what information you post is made public. To learn more about how to control your privacy settings and how third-party social networks handle your personal information, please refer to the social networks’ privacy policies and terms of use.

Mobile devices
If you access our website using a mobile device, we may collect information about your mobile device’s unique identification number and the device’s IP address, as well as information about the device’s operating system, communication service provider and location information. In certain cases, we may ask for your consent to use your phone number (e.g., for the purpose of providing pop-up messages).

5. How do we use your personal information?

Below is a summary of the purposes for processing your personal information. More information about what information we collect for each service we provide, as well as information about the purpose and legal basis for data collection, is provided below.

By providing services to our customers
We process the personal information provided by customers to provide our professional services. The specific purpose for which your personal information is processed depends on the type and scope of services provided, as well as applicable laws, regulatory guidelines, and professional standards. We can also process your data in cases where we are approached as a client by a legal entity, in cases where you are an employee of the client or otherwise related to the client. In this case, the customer must ensure that you are informed about the transfer of your personal information to us or to our service providers and business partners.

Administration of customer requests
We process the personal information of our customers and their representatives to:

  • Carry out identity identification and verification procedures before starting the provision of services.
  • Communicate with the client, provide services, and administer them, and ensure payment for services.
  • Handle customer complaints and inquiries.

Communicating with customers and potential customers and sending promotional messages
We process the personal information of our customers and their representatives to:

  • Communicate with clients regarding ongoing, planned or proposed services.
  • Send newsletters, useful information, promotional messages, and other forms of marketing communication to customers.
  • Invite customers to events (or organize and administer such events).

Data analysis
Our business is innovative, so we create new high-quality products and services based on the foundation of previous customer relationships. We use measures designed to summarize and anonymize data, thereby ensuring your rights and the legality of our actions.

In order to use your personal information for other purposes that are not compatible with the purposes for which your personal information was collected, we will ask for your consent. In all cases, based on the applicable legal acts, we seek proportionality between our interest in processing your personal information and your rights, freedom, and other interests as a data subject, in order to ensure the security of your personal information.

Legal basis
All processing of your personal information is based on a lawful basis for processing this information. In most cases, processing is based on the following grounds:

  • Processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter a contract (e.g., by us assisting an employer to fulfil an obligation to you).
  • Processing is necessary to ensure compliance with legal requirements (for example, when we are required to collect certain information about our customers for accounting or tax obligations, or when we are required to provide information to courts or other authorities).
  • The processing is based on our legitimate commercial interests, considering your interests and fundamental rights (for example, when we use personal information provided by customers to us to provide services, but when the information used is not necessary to perform a contract to which you are a party).

In limited cases, we base the processing on your consent, for example, when we need to obtain your consent to send you promotional messages.

Before collecting and/or processing your personal information or criminal record information, we will determine the lawful basis for using this information. Typically, this basis will be:

  • Your express consent.
  • Establishing, enforcing, or defending against legal claims by us or third parties.

6. Do we collect data from children?

We never provide our services to children directly, and we never knowingly collect personal information from children.

7. How long do we store personal information?

The period for which we store your personal information depends on the purpose of obtaining the data and the categories of data. We store your personal information for no longer than is necessary for the purposes provided for in this Notice, except in cases where a longer storage period is provided in legal acts. We have implemented appropriate measures to destroy your personal information in a timely, secure, and consistent manner when this information is no longer required.

In certain cases, we may store your personal information for a longer period in order to have accurate information about your relationship with us, to resolve potential complaints and disputes, or if we reasonably believe that there is a threat of litigation related to your personal information or relationship with us.

8. Do we disclose your personal information?

Business partners
We transfer your personal information to business partners who provide specialized services or in the case of cooperation with us. These business partners act as independent data controllers and are themselves responsible for compliance with data protection requirements. See their privacy notices for more information on their privacy policies. Business partners primarily include providers of various IT and related services.

Service providers
We may disclose your information to our service providers so that they can provide services and process your information on our behalf (for example, to provide services to our customers or to use the information for our own purposes, such as marketing). These service providers are obliged by the contracts concluded with us not to use or disclose your personal information in any other way than is necessary to provide services on our behalf or to fulfil legal requirements. These actions by service providers may include any of the processing actions described in the section “How do we use your personal information?”. These service providers properly store your data, and the actions performed with the data are limited to the purposes for which the data were collected. Service providers include, for example, IT service providers who maintain our systems; automated marketing service providers, contact centre service providers; and so on.

Legal requirements and transfer of business
We may disclose your personal information if: (i) required by laws, regulations, orders, standards, or other lawful legal requirements; (ii) in response to official requests or requests from public authorities; (iii) when we believe disclosure is necessary to prevent financial or other harm; (iv) investigating illegal activities; or (v) transferring all or part of our business. Disclosure may also be required for company audits or investigations of complaints and security risks.

9. Do we transfer your personal information to other countries?

In certain cases, we may transfer your personal information to service providers or business partners operating in other countries. Our related companies, business partners, service providers and other third parties may be in countries that are not recognized by the European Commission as providing an adequate level of data protection.

When we transfer data, we ensure that:

  • The transfer of data is based on contracts drawn up in accordance with standard contract provisions approved by the European Commission, which oblige each party to process data ensuring an adequate level of security.
  • When we receive inquiries from institutions, we always check them thoroughly and only then pass on personal information.

If you want more information about the transfer of your personal information outside the European Economic Area, you can contact us in the ways indicated in this Notice. You also have the right to request information about the security measures we take to ensure information security (including copies of relevant data transfer agreements).

10. What security measures do we use when processing your personal information?

The security of your personal information is very important to us, so we have implemented technical and organizational measures to protect your personal information from loss, misuse, alteration, and destruction. We protect your personal information from unauthorized access, use and disclosure by using security technologies and procedures such as data encryption and access restrictions. Only properly authorized people have access to your personal information, and these people are properly informed on how to ensure the security of personal information. Our service providers and business partners are obliged to ensure the confidentiality of personal information and not to use this information other than intended.

11. What actions can you take with your personal information?

We provide our customers with certain types of choices regarding the personal information we process. When you provide us with your personal information, we give you the opportunity to choose whether you want to receive marketing communication (emails, SMS messages). You can opt-out of marketing communications at any time by using the link in the notification, by visiting the page or by contacting us using the contacts provided in this Notice.

You also can exercise the data subject rights listed below. In certain cases, the exercise of these rights may be limited, or we may refuse to comply with your request, for example, when your request is contrary to legal regulation. We may also ask you to provide additional information to verify your identity and for other security reasons.

You can exercise these rights by contacting us using the contacts provided in this Notice. As far as possible, we always try to respond as soon as possible to requests and inquiries or inform you of the need to provide additional information.

The right to access personal data
You have the right to access your personal information that we process. You can access some of the information by logging in to your user account.

The right to correct personal data
You have the right to request that we correct your personal information that is inaccurate or out of date.

The right to be forgotten
In certain cases, you have the right to request that your personal information would be deleted. If we delete your personal information, all, or some of the services we provide may become unusable.

The right to restrict data processing
In some cases, such as when there are questions about the accuracy of personal information, you can request to restrict the processing of personal information.

Right to data portability
You have the right to request that we provide personal information about you in a structured, commonly used and computer-readable format, but only if the processing of the information is based on consent and the processing is carried out by automated means.

The right to object to processing

You have the right to object to the processing of your personal information, but only in cases where the processing is based on our legitimate interests. In this case, we can provide arguments why our legitimate interests take precedence over your rights.

Automated decision making
You have the right not to be subject to a decision based solely on automated data processing that has legal consequences for you or that has a significant impact on you in a similar way, except when: (i) the decision is necessary for the performance of a contract to which you are a party; (ii) the decision is permitted by law; and (iii) the decision is based on your express consent.

12. Contact us

If you have requests, complaints, or other questions, please contact our e-mail address: info@wpsteer.com

13. Changes

This notice may change from time to time. After changes are made, the most recent version of the Notice will be posted on our website and updated with the date of the last change. We recommend that you read this Notice regularly to keep up to date with our personal information handling practices.

The message was last updated on 21/09/2023

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