Privacy Notice
Welcome to A Step Ahead (“we” or “us” or “our”). A Step Ahead respects and understands your privacy
(“you” or “your”). This Privacy Policy describes how we collect your information through our mobile
applications (the “App”) and other services (collectively referred to as the “services”). This privacy
policy should be read in conjunction with the A Step Ahead’s Terms of Use located here:
astepahead.app/termsofuse
This Privacy Policy complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms
defined in the CCPA have the same meaning when used in this Privacy Policy.
1. Personal Information
Personal Information includes other similar terms under applicable privacy laws—such as “personal data”
and “personally identifiable information.” In general, Personal Information includes any information that
identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a
particular individual. Types of Personal Information that may be collected include:
- Name
- Telephone Number
- Gender
- Race/Ethnicity
- Age
- IP Address
2. How Information Is Collected?
When registering on our App or filling out a form, as appropriate, you may be asked to enter your name,
e-mail address or phone number. You will be contacted in response to any information you request, but
you may prevent your contact information from being automatically saved for future contacts by checking
the appropriate box.
When you register or use our mobile apps, we may track your location to provide you with information
about other services or users. If you do not want this feature, Location Services can be disabled on your
device.
If you choose to link, create, or log in to one of our accounts through a personal social media platform
(e.g., Twitter, LinkedIn, Facebook, etc.), we may receive personal information about you, your
connections, and your preferences from your use of that social media platform.
Our Services may use first party and third-party cookies, pixel tags, plugins, and other tools to gather
device, usage and browsing information when you use our App or other services. We use the information
for security purposes, to facilitate navigation, to personalize and improve your experience.
- Cookies.
Cookies are small text files that a website or in some instances an app transfers to your hard drive to store
and sometimes collect information about your usage of websites or app, such as time spent on the
websites or app, pages visited, language preferences, and other anonymous traffic data. You can control
the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by
activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Services. Unless you have adjusted your browser setting so
that it will refuse cookies, our system will issue cookies when you access or log on to our Service.
- Pixel tags and other similar technologies.
Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some websites to,
among other things, track the actions of users of the websites (including email recipients), measure the
success of our marketing campaigns and compile statistics about usage of the websites and response rates.
3. How We Use Your Information
Any of the information we collect from you may be used in one of the following ways:
- To personalize your experience (your information helps us to better respond to your individual
needs). - To improve our App and other services (we continually strive to improve our App offerings based
on the information and feedback we receive from you). - To improve customer service (your information helps us to more effectively respond to your
customer service requests and support needs). - To process transactions: Your information, whether public or private, will not be sold, exchanged,
transferred, or given to any other company for any reason whatsoever, without your consent,
other than for the express purpose of delivering the product or service requested. - To send periodic emails, either at your or of a marketing nature, either of which you may opt-out
from receiving at any time. - To analyze user choices and preferences to produce data sets and reports for internal analytic
purposes and improve our service offerings.
We may also aggregate Personal Information in a manner that is anonymized, so that it is no longer
considered Personal Information, which may be used by us for various business purposes.
All Personal Information shall be purged from our App thirty (30) days upon your deletion, termination,
or closure of your User profile from the App. We may retain certain Personal Data of a User for the
following reasons:
- To comply with legal and tax data retention obligations, including records of financial
transactions. - To stop former user who was terminated by us from starting a new user account.
- For our own legitimate interests, especially in those instances where there may be an outstanding
claim, dispute, or issue that may obligate us to keep certain personal information data. - To cooperate with law enforcement, a court order, subpoena, or other legal reason.
4. Data Security
Our systems, applications, and procedures are all designed to secure and maintain the privacy and
security of your data in order to minimize the risks of theft, damage, loss of information, or the
unauthorized access or use of information. All measures meet the prevailing industry standards, however,
we cannot guarantee that our services, systems, and platforms will be always immune from any
malfunctions, unlawful access or interceptions, or other types of wrongdoing.
5. Disclosure of Personal Information
We may disclose Personal Information under the following circumstances:
- To our affiliates and subsidiaries for the purposes described in this Privacy Policy.
- To third parties in order to provide our services and meet our obligations to you for any services
we are providing to you. Note these third-party website or apps may have privacy policies
beyond our control which differ from this Privacy Policy. - To third parties with whom you choose to let us share information, for example other apps or
websites that integrate with the Services, or those with Services with which we integrate. - To cooperate with law enforcement, a court order, subpoena, or other legal reason
6. Children
Our Service is not intended for anyone under the age of 13.
- The Service Is Not for or Directed Towards Children. We do not intend to and will not knowingly
collect any personally identifiable information from children under the age of 13. Children under
the age of 13 are prohibited from using the Service. If we learn that we have collected
information from a child under the age of 13, we will remove that information immediately and
delete it from our servers. If you believe information from a child under the age of 13 has been
provided to the Service, please notify us at [email protected] - California Minors. While the Service is not intended for anyone under the age of 18, if you are a
California resident under age 18 and you believe your information has become publicly-available
through the Service and you are unable to remove it, you may request removal by contacting us at
[email protected]. When requesting removal, you must be specific about the information you
want removed and provide us with specific information, so that we can find it.
7. Opt-Out Choice
You may opt out from receiving marketing-related communications from us on a going-forward basis by
contacting us or by using the unsubscribe mechanism contained in each email.
Under applicable privacy laws, you may have the right to request to review, make amendments, have
deleted or otherwise exercise your rights over your personal information that we hold, subject to certain
legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to
us related to your personal information:
By submitting an email request to us at [email protected].
We will follow applicable law to keep your personal information accurate, complete and up-to-date. In
your request that is covered by an applicable privacy law, please specify the personal information you
would like to have changed, whether you would like to have your personal information suppressed from
our database or otherwise let us know what limitations you would like to put on our use of your personal
information. We may only follow such requests: (a) where required by applicable law; or (b) with respect
to the personal information associated with the particular e-mail address that you use to send us your
request (please note: we may need to verify your identity before implementing your request). We will
comply with your request as soon as possible.
Please see the Sections 11 and 12 for information about individual rights under California and GDPR.
8. Third Party Transfers or Services
This Privacy Policy does not apply to third-party services that operate any apps, website, or services
unrelated to our services but which we may link to on App. Any third-party app, website, or service has
their own privacy policy or terms of use that you will be responsible for reading and understanding.
9. Amendment of Privacy Policy
This Privacy Policy may be amended from time to time. Any material change to how we use, collect,
disclose or process Personal Information, we will make an explicit notice of such changes on our App.
10. Questions
If you have any questions or concerns about this Privacy Policy, please contact us at
[email protected].
11. Information for California Residents
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following
details regarding the categories of Personal Information that we collect, use, and disclose about California
residents. Under the CCPA, “Personal Information” is information that identifies, relates to, or could
reasonably be linked with a particular California resident or household.
Sources
We collect Personal Information from: Our interactions with you, such as when you use our App
contact us online or on the phone, sign up for a newsletter, register an account, purchase a product
or service, or attend one of our events; and
Our affiliates, third-party providers of software applications made available on the App and
publicly available online sources.
Categories
In the past 12 months, the following categories of Personal Information as listed in the CCPA
may have been collected by us:
In the past 12 months, the following categories of Personal Information as listed in the CCPA
may have been collected by us:
- Category A. Identifiers, such as name, contact information, IP address and other online
identifiers; - Category B. Personal information, as defined in the California customer records law, such as
name, contact information, payment card number, financial information, employment
information, insurance information, and government-issued ID numbers; - Category C. Characteristics of protected classifications under California or federal law, such
as marital status; - Category D. Commercial information, such as transaction information and purchase history;
- Category F. Internet or network activity information, such as browsing history and
interactions with our App; - Category H. Geolocation data, such as device location;
- Category G. Professional or employment-related information; and
- Category K. Inferences drawn from any of the Personal Information listed above to create a
profile about, for example, an individual’s preferences and characteristics.
How We Use Personal Information
We use these categories of Personal Information to:
- Meet our obligations to you with respect to our services and other products;
- Develop, improve, update, and maintain our products and services;
- Provide services to our employees and agents;
- Personalize, advertise, and market our products and services;
- Conduct research, analytics, and data analysis; and
- Perform general business transactions, record-keeping, and our day-to-day operations.
Disclosure
In the past 12 months, we have disclosed the following categories of Personal Information as listed in
the CCPA to third parties:
- Category A. Identifiers, such as name, contact information, IP address and other online
identifiers; - Category B. Personal information, as defined in the California customer records law, such as
name, contact information, payment card number, financial information, employment
information, - Category C. Characteristics of protected classifications under California or federal law, such as
marital status; - Category D. Commercial information, such as transaction information and purchase history;
- Category F. Internet or network activity information, such as browsing history and interactions
with our App; - Category G. Geolocation data, such as device location;
- Category I. Professional or employment-related information; and
- Category K. Inferences drawn from any of the Personal Information listed above to create a
profile about, for example, an individual’s preferences and characteristics.
We have not sold Personal Information, as “sale” is defined in the CCPA.
Rights as a California Resident
As a California resident, you may request that we provide to you the following information covering the
12 months preceding your request
- The categories of Personal Information we collected about you and the categories of sources from
which we collected such Personal Information; - The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting (if applicable) Personal Information about
you; and - The categories of Personal Information about you that we otherwise shared or disclosed, and the
categories of third parties with whom we shared or to whom we disclosed such Personal
Information (if applicable). - Delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please contact us at
[email protected].
As provided under the CCPA, you have:
- the right to know (request disclosure of) personal information collected by us about you, from
whom it was collected, why it was collected, and, if sold, to whom; - the right to delete personal information collected from you;
- the right to opt-out of the sale of personal information (if applicable);
- the right to non-discriminatory treatment for exercising any rights; and
- the right to initiate a private cause of action for data breaches. be free from unlawful or
discriminatory treatment for utilizing your rights.
In the event, that we engage in services that are considered “financial incentives” as defined under the
CCPA, we will give notice of the material terms and receive consent from the applicable individuals
before they are included in any such incentive.
12. GDPR
Under the EU General Data Protection Regulation (“GDPR”) and other laws, we are required to inform
you of the legal reasons for our use and processing of any Personal Information. The legal reasons for our
collection, use, and processing of Personal Information includes:
- To comply with applicable laws and obligations and in order to defend or respond to legal claims.
- To perform our services to you.
- Business purposes including marketing, advertising, IT and network support services, mergers
and acquisitions, and internal investigations
If you are a covered individual under the General Data Protection Regulation (“GDPR”) you have legal
rights in relation to the data that we hold about you. These rights include:
- Obtaining information regarding the processing of your data and access to the data that we
hold about you. Please note that there may be circumstances where we are entitled to refuse
requests for access to copies of data; - Requesting that we correct your data if it is inaccurate or incomplete;
- Requesting that we erase your data in certain circumstances. Please note that there may be
circumstances where you ask us to erase your data, but we are legally entitled to retain it; - Objecting to, and requesting that we restrict, our processing of your data in certain
circumstances. Again, there may be circumstances where you object to, or ask us to restrict,
our processing of your data but we are legally entitled to refuse that request; - Withdrawing your consent, although in certain circumstances it may be lawful for us to
continue processing without your consent if we have another legitimate reason (other than
consent) for doing so.
We may request that you prove your identity by providing us with a copy of a valid means of
identification to comply with our security obligations and to prevent unauthorized disclosure of data. We
reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive
requests concerning your access to your data and for any additional copies of the data you request from
us.
Individuals covered by the GDPR should contact us at [email protected] to request further
information.
Transferring Your Data Outside the EEA (If GDPR Applies)
The data that we collect from you is transferred to, and will be stored in, the United States that is not
subject to equivalent data Protection Law. For our purposes, the information we collect is processed and
stored in the US.
We may transfer your data outside the European Economic Area (“EEA”)
- In order to store it.
- In order to enable us to provide the Service.
- Where we are legally required to do so.
In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we
have concluded these are not overridden by your rights. Where your information is transferred outside the
EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate
safeguards and that it is treated securely and in accordance with this Privacy Policy.
You may contact us here at any time if you would like further information.
Questions or Revoking Consent
If you have questions regarding our Privacy Policy, or if you wish to update the personal information you
have provided to us, you may do so by contacting us here.
Should you wish to revoke your previously given consent to the Privacy Policy please email us at
[email protected]. If you have previously registered on our App and wish to un-register contact us at
[email protected]