Effective Date: August 16, 2022
- Your use of the Site;
- Your signing up for a freebie and/or our email list through the Site (the “Email List”); and/or
- Your creation of an account through the Site, if/when we make that feature available.
I. Information We Collect
We collect information that falls into two categories: information you voluntarily provide, and information that your computer, mobile phone, tablet, or other device (all referred to as “Device”) or browser provides automatically.
A. Information You Voluntarily Provide.
When you interact with our Site, we, or our service providers (acting on our behalf), collect “Personal Information” — information that relates to you as an identifiable individual — that you intentionally and actively provide to us, such as your first and last name, address, email address, and when necessary, credit card or bank information. We collect this information when you:
- Inquire about our Site;
- Create an account on our Site;
- Send a communication through our Site;
- Make a purchase through our Site; or
- Sign up for an Email List or to receive our newsletter and/or advertisements or marketing emails from us.
We may collect content you make available through social media accounts or memberships with third parties if you choose to create an account using a social media login.
You can always choose not to provide us with information. However, if you do withhold information, we may deny you access to some or all of our website’s services and features.
Some transactions between you and our website may involve payment by credit card, debit card, checks, money orders, and/or third party online payment services. In such transactions, we will collect information related to the transaction as part of the course of doing business with you, including your billing address, telephone number, and other information related to the transaction.
List of Personal Information We May Collect From You:
Depending on how you communicate with us, we may collect the following information:
- Your email address
- Your first name
- Your last name
- Your phone number
- Your payment information (if you make a purchase through the Website)
B. Information About You That Is Provided Automatically.
Like most places on the Internet, simply by visiting our Website you or your Device automatically tell us certain information. This includes basic information such as your IP address, when you visited, the website from where you came prior to visiting us, the website where you go when you leave our website, your computer’s operating system, and the type of web browser that you are using. Our website automatically records this basic information about you.
Usage Information We Collect From You:
List of Usage Information includes:
- Your IP address;
- Your Device type,
- Your unique Device identifier,
- Your location, and
- The type of browser software and operating system you are using.
If you download or use mobile software applications (“Mobile Apps”) from our website, we may know your location. In addition, your Device using our Mobile Apps may provide us information about the device, including its unique identifier, make and model, operating system, mobile network carrier, and your telephone number. Your Device may have the ability to disable location services as well as deny us access to other information described in this paragraph. To learn more, check your Device’s user manual and/or contact your mobile device’s manufacturer or service carrier.
The Site may also feature social buttons from networks such as Facebook, Twitter, YouTube, Pinterest, and Instagram. To do so we embed code that they provide. We do not control that code ourselves. In order to function, their buttons generally know if you’re logged in. We do not have any access to that information, nor can we control how those networks use it.
If you access the Site via a mobile app, we use additional identifiers, such as the advertising ID provided by Apple or Android, for similar purposes.
C. Cookies and Other Data Tools.
For example, we may use a tool called Google Analytics to collect information about visitors’ use of this Site. Google Analytics collects information such as how often users visit this Site, how users find the Site, and what pages they visit. We use the information we get from Google Analytics to improve this Site. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. To opt-out of Google Analytics, please use Google’s opt-out tool: https://tools.google.com/dlpage/gaoptout.
Remarketing Tags and Pixels
Web Beacons or clear GIFs
The Site also may contain web beacons or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
When you visit our website, you may view advertisements posted on the site by Google or other companies. These advertising companies may collect information about you while you are visiting this website and other websites. They may use this data to show you advertisements on this website and elsewhere on the Internet about products and services you might like.
This website does not collect the information or control the content of the advertisements that you will see. You may be able to opt out of such advertising.
If you are in the United States, you may opt out of some advertising via the Digital Advertising Alliance at http://www.aboutads.info/choices/
If you are in Canada, you may opt out of some advertising via the Digital Advertising Alliance of Canada at http://youradchoices.ca/
If you are in the Europe Union or the United Kingdom, you may opt out of some advertising via the European Interactive Digital Advertising Alliance at http://www.youronlinechoices.com/
To find out more about Google privacy policies and its DoubleClick DART cookie used to generate interest-based advertising, go to https://policies.google.com/technologies/ads.
Dynamic Ad Serving
Our Site may use Google’s Dynamic Ad Serving Feature. To opt out of interest-based ads by Google, follow Google’s opt-out instructions located at https://support.google.com/ads/answer/2662922?hl=en.
Your use of this website without opting out means that you understand and agree to data collection to provide you with interest-based advertising.
Opting Out of Cookies; Do-Not-Track
You can opt out of cookies, but if you do, some features of the Site may not work correctly. To learn how to reduce the number of cookies you receive or delete cookies that have already been installed in your browser’s cookie folder, you can check your browser’s help menu or other instructions related to your browser. (For example, Safari has a help article entitled Manage cookies and website data in Safari on Mac, and Firefox currently has a variety of optional security features, including blocking cross-site tracking cookies and sending websites a Do Not Track signal that you don’t want to be tracked.) We try and honor any Do-Not-Track signals you send through your web browser when visiting the Site.
If you are using Google’s Chrome Browser and would like to opt out of tracking by FLoC, adjust your browser settings to block third party cookies. You can find instructions on how to block such cookies at https://support.google.com/chrome/answer/95647
II. How We Use Your Information and What We Do With It
We use the Personal Information we collect about and from you:
- To perform our responsibilities under a contract we have with you. For example:
- To communicate with you about changes to the Website; and
- If you submit a support ticket or make an inquiry through the Site, we will need to use your Personal Information in order to respond or troubleshoot.
- When we have a legitimate interest to do so – in other words, when it supports and achieves the aims of the Company. For example:
- To prevent fraud and protect the security of our Site;
- To communicate updates and improvements;
- To develop and optimize our Site;
- To resolve disputes;
- To help us provide and operate the Site;
- To advertise and market to you, which includes displaying targeted ads, offers and content made available to you based on your interests and usage of the Site;
- To analyze the performance of the ads, offers and content on or originating from the Website, as well as your interaction with them; and
- To comply with our legal obligations.
- With your consent. For example:
- We send marketing communications to you only if you consent to receive them; and
- We do not share your Personal Information with third parties for their direct marketing purposes without your consent.
- As otherwise required by applicable law. For example:
- Protecting someone’s rights;
- When necessary to perform a legal obligation or request from a governmental authority or similar body.
Some government intelligence agencies have the technological ability to access data from our website without our cooperation, knowledge, or consent. Even if we were to learn of such access, we may not be able to tell you because of national security laws. Please take this risk into account before supplying information to us or any other website owner.
Although we do not disclose individually identifiable information, we may disclose aggregate data about our website’s visitors to advertisers or other third parties for marketing and promotional purposes.
While we rely on your consent as a legal basis for collecting and processing your information, if you consent to a particular use of your information and you ultimately change your mind, you may withdraw your consent at any time by contacting us at info[at]smallstepsgoplaces.com or sending us physical mail at the address below.
If you no longer wish to receive email marketing communications, you may use the unsubscribe tool located at the bottom of that communication. If you withdraw your consent, we will not use your information going forward.
III. How We May Share Your Information
A. Service Providers. We share your Personal Information with other service providers that we have engaged to perform business-related functions for us (“Service Providers”). This includes service providers that:
- conduct research and analytics;
- create content for Company;
- provide customer, technical or operational support;
- conduct or support marketing (such as email marketing platforms);
- host the Site;
- maintain databases;
- send or support online advertising;
- process payments and/or fulfill purchases;
- otherwise support or help us provide the Site.
These Service Providers may use your Personal Information to help us perform necessary actions that support those activities. If a supplier wants to collect information about you, you will be notified. However, you will never be required to give information to a third party supplier. We restrict the way third party suppliers can use your information. They are not allowed to sell or give your information to others.
Appointments made through our Site are processed by Calendly, which may collect credit card information and other Personal Information. If you make payment through Calendly, Calendly stores your credit card data, and we do not have access to your full credit card information. You can read more about how Calendly uses your Personal Information here: https://calendly.com/privacy
D. Autoresponders. We may use your information with autoresponders in order to communicate with you by email. To protect your privacy, we use a verified opt-in system for such communications and you can always opt-out of such communications using the links contained in each autoresponder message. If you have difficulties opting out, you may contact us by sending an email to EMAIL ADDRESS, or sending us mail to the address listed below.
IV. Your Privacy Choices, Rights, and Access
A. In General.
You may always direct us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, to delete information we have collected and maintained about you, or not to send you emails or other communications by:
- sending us an email at info[at]smallstepsgoplaces.com; or
- following the removal or unsubscribe instructions in the communication that you receive.
If you wish to verify, correct, or update any of your Personal Information collected through the Site, or request access to all information that we have collected and maintain about you, you may contact us at the email or address included in the Contact Us section below. In accordance with our routine record keeping, we may delete certain records that contain Personal Information that you have submitted through the Site. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups or other technology-related reasons.
B. For Individuals in the European Economic Area
If you are in the European Economic Area, you have certain rights related to the Personal Information we hold about you:
- Access. You have the right to access the Personal Information we hold about you. If you wish to obtain a copy or description of the Personal Information we hold about you, please contact us using the contact details set out below. We may ask you to verify your identity and to provide further details about your request.
- Accuracy/Rectification. We will do our best to ensure the Personal Information we retain about you is accurate. We may from time to time send you an email update to remind you to tell us about any updates or changes to your Personal Information. You have the right to request that any inaccurate Personal Information is corrected and any incomplete information is completed by contacting us using the contact details set out below.
- Deletion/Erasure and Processing Restriction Requests. You have the right to request that we delete Personal Information that we hold about you. You also have the right to ask us to stop processing your Personal Information, subject to certain exceptions. If you would like us to erase or stop processing the Personal Information that we hold about you, please contact us using the contact details set out below.
- Portability Requests. You have the right to request that we provide certain parts of your Personal Information to you or transmit it directly to another company that processes Personal Information. If you would like us to transfer your Personal Information, please contact us using the contact details set out below.
- Withdrawing Your Consent to Receive Marketing Messages. You may ask us to stop using your Personal Information for advertising or marketing purposes at any time. If you wish to do this, please follow the removal instructions in any communication you receive or send us an email to info[at]smallstepsgoplaces.com with “UNSUBSCRIBE” in the subject line.
- Damages. You may have the right to claim compensation for damages caused by our breach of any data protection laws.
In addition, if you are in the European Economic Area and you have any complaints about how we use your Personal Information, you have the right to lodge a complaint with the data protection authority in your country. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
For further information on each of the above-mentioned rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.
C. Rights of California Residents
California residents are entitled once a year, free of charge, to request and obtain a list of all third parties to whom their personally identifiable information was provided for their direct marketing purposes in the preceding calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). Company does not disclose any user information to third parties for third party marketing purposes, so we are not required to comply with this law.
The California Consumer Protection Act (or “CCPA”) has additional protections for California residents. Though Company does not buy or sell Personal Information of any of its users, Company will honor the request of any California resident that makes any of the following requests:
- An inquiry as to what Personal Information Company has about the user and what Company does with that information;
- A request to delete the user’s Personal Information; or
- A request not to sell the user’s Personal Information.
Please end any such request via email to info[at]smallstepsgoplaces.com or write us at the following address:
Small Steps Go Places Inc.
440 Riverside Drive
New York, New York 10027
Even though we do not have a legal obligation to do so, we may respond to your requests made per the CCPA. However, these voluntary responses are not a waiver of our legal rights and obligations under the laws of California and USA or the arbitration provisions found within our website’s Terms and Conditions of Use.
D. Brazil Residents
If you reside in the Federative Republic of Brazil, you may have certain privacy rights under Brazil’s General Law on Protection of Personal Data, Lei Geral de Protecão de Dados Pessoais, Law No. 13,709/2018 (LGPD), to the extent the LGPD does not conflict with the laws of the USA. Even if we do not have a legal obligation to do so, we may respond to your requests made per the LGPD. However, voluntary responses are not a waiver of our legal rights and obligations under applicable United States laws or the arbitration provisions found within our website’s Terms and Conditions of Use.
V. A Note on Links to Other Websites and Your Voluntary Disclosure of Information to Third Parties
VII. Storage of Your Information
We will generally store information associated with your account until it is no longer necessary to provide services to you, until you ask us to delete it, or until your account is deleted, whichever comes first; but there are some exceptions to this general rule. We will retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our agreements, and take other actions permitted by law.
VIII. Request to Access or Delete
If we grant your request to access personal data, we will: (1) confirm whether or not we are processing your personal data; (2) provide you with a copy of any of your personal data that we possess; and (3) provide you with information about how we process such data (e.g. purposes, categories, recipients, etc.).
If you request that we delete your personal data that we possess, we will do so unless: (1) the data is needed to exercise the right of freedom of expression; (2) we have a legal obligation to keep the data; (3) we must keep the data for reasons of public interest; or (4) the data has been processed so that it is anonymized.
Any personal data we processed unlawfully will be deleted. If you were a minor when we collected the personal data, we will delete the data upon request.
If we believe any third parties have acquired your personal data through us, we will take reasonable steps to inform them that you have requested erasure of such data.
If your request is an objection to the processing of your personal data for directing marketing purposes, we will cease using your data for such purposes.
As a general rule, we will comply with objections to processing personal data except: (1) where it is not technically or commercially feasible to do so; or (2) we have a legal obligation that overrides your individual rights and freedoms.
If we collected personal data from you because of a contract between us or based on your consent, and we processed that data by automated means (in structured machine-readable format), you can request that data be transmitted by us to another company or organization.
We will provide such data to the recipient third party in a commonly used open format electronic file (e.g. CSV, JSON, XML, etc.).
Note: If you request that data we maintain about you be deleted or erased, no one (neither us nor you) will be able to recover that information later.
Data-Related Decisions and Processing
If we reject your request, we will provide you with the reason(s) for doing so. You may then choose to file a complaint with the Data Protection Authority and request a judicial remedy to the extent such a request is not in conflict with the laws of laws of California and USA or the arbitration provisions of our website’s Terms and Conditions of Use).
As a general rule, there is no fee for processing your request. However, we reserve the right to refuse your request or charge a reasonable fee for processing it if the request is manifestly unfounded or excessive. For example, it would be excessive to make a repetitive second request to access your personal data one month after we provided you with the data from a prior request.
We may make decisions through automated processing (e.g. algorithms) of personal data that are legally binding or significantly affect you.
Any such automated decision-making is done per your express consent or because it is necessary for reasons of substantial public interest under applicable law.
Such an automated decision may be made based on relevant law. However, if the decision is made for other reasons, we will inform you of the process’ logic and potential consequences of the decision. To the extent that the laws where you reside do not conflict with applicable United States law or the arbitration provisions found within our website’s Terms and Conditions of Use, you may also have a right to obtain human intervention and contest the automated decision.
IX. Security: We Cannot Guarantee the Security of the Site
We take seriously our obligation to safeguard the confidentiality, security and integrity of personal information collected from our users. As you can see, the Site uses an SSL (or secure sockets layer) certificate, which provides secure, encrypted communications between a website and internet browser. We also have appropriate security measures in place to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way, such as two-way authentication and use of encryption where possible. We limit access to your Personal Information to those who have a genuine business need to know it. You should be aware, however, that no system is completely secure from hackers and network failure and error, and we cannot guarantee the confidentiality, security and integrity of information maintained on our Site for that reason.
In other words, although we will use all reasonable efforts to safeguard the confidentiality of your Personal Information, we cannot guarantee that your information will always be secure.
Email is not a secure form of communication. Please do not send us your credit card number, social security number or other Personal Information via email.
We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
XI. Contact Us
Small Steps Go Places Inc.
440 Riverside Drive
New York, New York 10027
XII. This Policy and Customer Agreements
If you are our customer, any customer agreement between us supersedes this policy to the extent there is any conflict with the terms and conditions of the customer agreement.