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We are based in London. Following the development of our platform’s technology, we incorporated on 21st October 2022. Our company number is 14433954, and you can find us on Companies House here.

 

NB A previous record of Steppr Ltd appears on companies house from some time ago, although this was always dormant and has been dissolved.

 

For any press & media enquiries, please contact us here.

 

 

17th January 2023: Company launch press release

Last updated 09/01/2023

 

1. Our Company Details

 

Steppr Limited is incorporated and registered in England and Wales, with company number 14433954. Our registered office is 128 City Road, London, United Kingdom, EC1V 2NX. “Steppr” is our trading name, and is a registered trademark owned by Steppr Limited. We are the data controller of the personal information you provide to us. Please contact us here if you have any questions. Words used in this User Privacy Policy have the same attributed meanings as those in our User Terms & Conditions.

 

2. We Respect Your Privacy

 

Please read this document carefully as it details our approach to protecting your privacy in relation to data we collect and process about you through our website (steppr.com, steppr.uk, steppr.co.uk, collectively “Website”) and App (together with Website referred to as our “Platform”). By using our Service in any way, you are confirming that you have read and agree to this User Privacy Policy and our User Terms & Conditions. If you disagree with any of this, please do not interact with our Service or Platform in any way and reach out to us to discuss the matter immediately (don’t worry, we won’t be hurt!).

 

3. Collecting Your Information

 

Personal information/data includes any information that can be used to identify you, whether directly or indirectly. The information we collect directly from you (whether through post, email, phone or your use of the Platform to perform actions such as User Account creation, Voucher purchase, greetings card personalisation) or indirectly from you (pertaining to automated collection of technical data about your equipment, browsing and purchasing activity and patterns) can often fall into that category, and may include the following:

 

• Identifying Information: Information you give us about yourself to create or update your personal account on our Platform (“User Account”). This may include your name, email address and a password;

 

• Order information: Information you give us to create an Order for a Product on our Platform, including payment information and data like the name and address of the End-Recipient if the Product is a Gift;

 

• Personalisation information: Information you give us that is necessary to personalise a greetings card (for a Gift). By this, we are referring to any images you upload or text you write;

 

• Usage information: Information we may collect about your use of our Service (including your use of the Platform), such as the date of creation of your User Account, account use timings and which specific Vouchers you have bought;

 

• Communication information: Information we may collect about you from the e-mails or physical letters you send us, or through any other communication, including mobile phone numbers to contact you on;

 

• Technical information: Information we may collect about your use of a mobile or other device to access our Platform. This may include device-specific information such as device type, device identifiers, operating system, browser and connection information, IP address and other types of technical information such as mobile payment methods, performance and other characteristics data, other information from cookies and other similar technologies; and

 

• Special information: Please note that we do not collect or use any special classes of data (which includes data such as health information and political opinions).

 

Please note that if you decide to save a payment method during a purchase on your User Account, that information is not stored by us. The payment service provider used (Stripe) will store the information and is required to comply with the Payment Card Industry Data Security Standard (PCI DSS) to securely store and protect your data. During the payment process you may be asked to authenticate a payment following a prompt from your card issuer.

 

4. Using Your Information

 

 

• User Account management: Administer and manage your User Account on our Platform, including registering your account, tracking your redemptions where we are able in order to update your purchase history categories and Voucher statuses;

 

• Provision of Products: Facilitate your ability to browse Vouchers, purchase them from Partners and receive order confirmations/receipts;

 

• Purchase history display: While you are emailed about your Product purchases, we also display them to you in three categories in your User Account (these categories may change): (1) Vouchers you have bought for yourself that have not yet been redeemed; (2) Vouchers you have bought as gifts for other End-Recipients; and (3) Vouchers you have bought that have been redeemed.

 

• Voucher eligibility: We display Vouchers to you that you are eligible for. For example, you may be eligible to buy Vouchers similar to those you have already purchased, at greater discounts, and this depends on your purchase history. Please note, ‘eligibility’ as stated here is at our sole discretion and is not a guarantee in any way;

 

• Gifts personalisation: You can create greetings cards on our App, with features you add such as text and images, which we then transmit to the third party printing service to fulfil the order;

 

• Order management: Facilitation and fulfilment of our obligations regarding Orders;

 

• Customer validation and support: This includes user authentication, customer support and administrative messages;

 

• Monitoring and analysis of data: We may investigate and perform tests on data we have gathered for our internal operations and audit requirements, observing and understanding trends, general customer analytics and research, and troubleshooting;

 

• Legal obligations: This includes operations such as analysing data to prevent fraud and other abuses;

 

• Platform maintenance and improvement: We may use your information to help us create and design product updates, personalisation of your and general User experience, to research and develop new features, and to maintain security of the Platform;

 

• Reminders: We may display in-app notifications, push notifications and send emails to you, or other reminders using information agreed upon, often based off your purchase history, for reasons including but not limited to reminding you to use a Voucher, or that a Partner you previously purchased from is selling more Vouchers; and

 

• Customer communication: This includes emailing you about updates or changes to our Service, User Terms & Conditions, this User Privacy Policy, or other important documents, asking you to partake in a survey or review or competition, marketing information (only if you consent beforehand and you will be able to opt-out) and about our Service features that you may be interested in, as well as answering questions you may have and responding to your queries.

 

5. Legal Basis

 

 

• Consent: You have given us clear content, which can be withdrawn by emailing us at any time, to process your personal data for a specific purpose;

 

• Contract: The processing by us is required for a contract we have with you, or because we have been asked by you to take specific steps before entering into a contract;

 

• Legal obligation: The processing is required by law;

 

• Vital interests: We need to process the data to protect someone’s life;

 

• Public task: The processing is necessary in relation to if we perform a task in the public interest or for our official functions, and the task or function has a clear basis in law; and

 

• Legitimate interests: The processing is necessary for our or a third parties’ legitimate interests unless a good reason to protect your data overrides those legitimate interests. These legitimate interests include: (a) monitoring the use of our intellectual property; (b) complying with our internal procedures and policies; (c) enabling us to carry out our Service in respect to you both effectively and efficiently; and (d) ensuring our Platform components, and other related systems and services, are secure.

 

 

6. Disclosure of Your Information

 

 

• When you purchase a Voucher from a Partner (facilitated by our Platform), they have access to the relevant Order information that is required for the Voucher creation and management processes, which includes your name and email address. There may also be an exchange of information between Steppr and the Partner when Vouchers are redeemed at their Checkout (although redemption is an arrangement between you and the Partner that does not require Steppr), for monitoring and accounting purposes. We urge you to contact or read the privacy policies of any Partners before purchasing Vouchers from them;

 

• When you have purchased a Gift, third party suppliers such as the printing service we use to fulfil the Order will require certain information, such as the greetings card content, recipient name and address, to print and send the physical greetings cards;

 

• Technology and IT service providers for technical support, search engine providers and analytics services (such as Firebase Google analytics – which makes use of cookies, IDs and other technologies to collect and store user personal data, which you can read more about here: policies.google.com/technologies/partner-sites) that may help us improve and optimise the Platform;

 

• Payment service providers (such as Stripe) who process credit card and debit card payments, and carry out the required security checks;

 

• If we are acquired or purchased by, merged with, sold to, or enter into a partnership or joint venture with another business entity (or are involved in negotiations for any of these cases), or create a subsidiary of Steppr, then your information may be correspondingly transferred or disclosed to that business entity, its partners, owners or advisors; and

 

• Our User Terms & Conditions, provision of our Service and business operations, or other agreements may require it; protection of our own rights, or those of other parties related to us, may require it; other legal obligations may require us to share your information in certain circumstances (such as to prevent and protect against fraud).

 

7. Where Do We Store and Process Personal Data?

 

 

8. Information Security

 

 

 

• Keep the password for your User Account for our Platform safe;

 

• Do not use the same password for our Platform as you use for other services;

 

• Do not remain signed in to our Platform when you are not using it; and

 

• Do not allow any other parties to use your User Account.

 

9. Information Retention

 

 

10. Your Rights in Relation to Personal Data

 

 

• The right to be informed: You have the right to be provided with concise, transparent, intelligible and easily accessible information about our collection and use of your personal data, explained in clear and plain language. This is the intention of this User Privacy Policy, as well as your ability to contact us here if you have any concerns;

 

• The right of access: You have the right to request and obtain a copy of your personal data and other supplementary information from us, free of charge;

 

• The right to rectification: You have the right to have inaccurate personal data that we hold about you corrected, or completed if it is incomplete;

 

• ‘The right to be forgotten’: You have the right to request for us to erase your personal data, although certain situations may not allow us to do this, including if we need to comply with a legal obligation to keep the specified data;

 

• The right to object and right to restriction of processing: You have the right to request the restriction or suppression of your personal data and its processing by us;

 

• The right to data portability: You have the right to obtain your personal data from us in an accessible and transferrable format, and reuse it for your own purposes across different services; and

 

• The right to make a complaint: You have the right to lodge a complaint about us in relation to our treatment of your information with the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection (www.ico.org.uk/concerns; 0303 123 1113). We would appreciate you giving us the opportunity to deal with your concerns first!

 

 

11. Linking to External Websites and Third Party Content

 

 

12. Use of cookies

 

 

 

13. Changes to User Privacy Policy

 

 

14. Contact Us

 

If you have any questions, comments or requests about our User Privacy Policy, please email us at here. Alternatively, you can also send us physical correspondence at Steppr Limited, 128 City Road, London, United Kingdom, EC1V 2NX.