Privacy Policy
Date of Last Revision: 05 March 2024.
Privacy and security are very important to us at StepUp Agency. This Privacy Notice (“Notice”) is meant to help you (the “end user”) understand how we at StepUp Agency collect, use, and share your data when you use our products or services on which we make this Notice available (collectively, the “StepUp Agency Services”).
This Policy applies to STEPUP AGENCY LTD. (collectively, “StepUp Agency” “we”, “our” and “us”). (Please see the “Contacting StepUp Agency” section below for which of these entities is responsible for processing your data.) You should read this Policy carefully, it contains important information about your privacy rights and choices.
StepUp is a full-service digital marketing agency. StepUp team through their years of experience, consistently delivered proven results aiding clients in achieving success and establishing a distinct market presence.
Before you use or submit any information through or in connection with the Services, please carefully review this Notice. By using any part of the Services, you acknowledge that you have read, understood and agree to the collection, use, and disclosure of your information as outlined in this Notice. To the extent allowed by law, the English version of this Notice is binding and its translations in other languages are for convenience only; in case of discrepancies between the English version of this Notice and its translations, the English version shall prevail.
If you are in the European Economic Area (“EEA”), the United Kingdom or Switzerland (collectively “Europe”) and have used the STEPUP AGENCY Services under a contractual relationship under the Terms of Service with STEPUP AGENCY UK, then for the purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”), the UK GDPR, and the Swiss Federal Act of 19 June 1992 on Data Protection (FADP), the data controller is STEPUP AGENCY LTD. and can be reached at the address set out at “Contacting Stepup Agency” below; and
- For the Users in the EEA that do not fall under the previous paragraph, and to the extent that this would be required by GDPR
If you are a resident of California, the California Consumer Privacy Act of 2018 provides you with additional rights. Please view our “California Privacy Notice” to learn more.
If you are a resident of Colorado, Connecticut, Utah or Virginia, the respective laws in your states provide you with additional rights. Please view our “Privacy Notice of certain other states in the United States” to learn more.
INFORMATION WE COLLECT
As further described below, when you use or otherwise access the Services, we collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from your browser or device (e.g. by logging how you interact with our Services).
A. Information That You Provide Directly to Us:
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
a- Email address
b- First name and last name
c- Phone number
d- Address, State, Province, ZIP/Postal code, City
e- Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies or Browser Cookies.
A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.</li>
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be Persistent or Session; Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies</p>
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account:to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract:the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.
V. Public Communications:
You can post comments, leave feedback, send thank-you notes or otherwise communicate with other users through our Services. Any content, including such comments, feedback, and notes that you choose to post on publicly available campaign pages through our Services are available to the public by default.
Please remember that any information that is disclosed in these areas becomes public information for both us and other users to use and share. Take care not to disclose personal data unless you intend for that data to become public. Please also be considerate and respectful of others while using the community to publish your opinions. We reserve the right, but do not have the obligation, to review and monitor such posting or any other content on our Services, and to remove postings or content that may be viewed as inappropriate or offensive to others.
VI. Communications to StepUp Agency:
If you have questions about how StepUp Agency handles information about you, you may contact us via a contact form, email, by chat services or by other means (for example, with questions about our Services, for customer support, or to let us know your ideas for new products or modifications to existing products). You may also choose to respond to surveys that we send out or requests for user interviews, or queries about your fundraisers. If you respond to our requests for surveys or interviews, we will collect any information you provide to us and use that information in the manner set forth herein. When you do so, we collect the information you choose to provide us, such as your contact details, any images you choose to upload and the contents and nature of your message.
We may engage vendors to provide certain interactive features on our Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on the Services for customer service purposes. When you participate in the interactive chat, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that we and our vendors on our behalf may on a real-time basis collect and process the information obtained through the feature. We would ask that you take care not to send financial information or other sensitive personal data to us through our chat services or other means, unless we ask you specifically for that data as part of providing the Services to you. When you provide such information to us directly, you consent to the processing of this data by StepUp Agency and/or our vendors. We collect the information listed in this section for the purposes described below in the sections “Our Use of Information Collected” and “Our Disclosure of Information Collected Through the Services”.
VII. Information relating to other parties:
You can choose to provide us with information relating to other parties. For example, if you choose to provide personal information about someone on your fundraiser, you confirm that you have the consent of such person to share their personal information with us.
VIII. Sensitive information:
You can also provide us with information about yourself or other parties that are considered sensitive, such as political opinions, race, ethnicity, health information or religious beliefs. If you post this information in a fundraiser, you choose to provide such information to be published publicly in relation to your fundraiser, donation or otherwise. Subject to applicable law, StepUp Agency may use any information which has manifestly been made public, including processing information about you that reveals sensitive information.
When you provide such information to us you consent to the processing of this data by StepUp Agency and/or its service providers. We collect the information listed in this section for the purposes described below in the sections “Our Use of Information Collected” and “Our Disclosure of Information Collected Through the Services.
X. Information Collected by Our Payment Processors
We use Stripe, and PayPal for payments, analytics, and other business services. These payment processors may collect personal data including via cookies and similar technologies. The personal data they collect may include transactional data and identifying information about devices that connect to its services. They use this information to operate and improve the services it provides to us, including for fraud detection, loss prevention, authentication, and analytics related to the performance of its services. They operate both as processors for us and independent controllers for the information they collect directly from our users.
You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy. You can learn more about PayPal and read its privacy policy at https://www.paypal.com/us/legalhub/privacy-full
B. Information That is Passively or Automatically Collected:
I. Device & Usage Information:
When you interact with StepUp Agency through the Services, we automatically receive and store certain information from devices that you use to access the Services. This information is collected passively by using various technologies, and includes the type of geolocation information, Internet browser or mobile device you use, any website from which you have come to the Services, your operating system, and location data through an IP address that identifies the city and state where you logged into the Services . StepUp Agency either stores such information itself or such information is included in databases owned and maintained by StepUp Agency, and/or its agents or vendors.
II. Location Information:
When you use the Services to organise a fundraiser, the Services may require that you provide your postcode, city or town, and state or province of residence. Please keep in mind that other users of the Services can view your postcode, city or town, and country or region of residence in connection with the fundraiser. We also use your location information as described in this Notice, such as described above under “Device & Usage Information”, and in an aggregate way, as described below in the “Aggregated Data” section.
III. Cookies and Other Electronic Technologies:
When you interact with the Services, we try to make that experience simple and meaningful. When you visit our Services, our web server, business providers, and/or the Social Networking Services (defined below) are integrated into the Services, we use cookies or other electronic technologies (such as web beacons or pixel tags) for various purposes. Cookies are small pieces of information that are issued to your computer or mobile device when you visit a website, or access or use a mobile application. That information regarding your use of the Services is stored and sometimes tracked. Web beacons are transparent image files, which enable the Services to track website usage information. Pixel tags are tiny graphic images with unique identifiers that track online movements of our users. We will refer to the cookies and other technologies identified here collectively as “Cookies” for purposes of this Notice.
i. Type of Cookies
Some Cookies are strictly necessary to make our Services available to you (“Essential Cookies”). We cannot provide our Services without these Essential Cookies.
We also use Cookies for functional purposes in order to maintain and improve our Services or your experiences, and for marketing purposes (collectively, “Non-Essential Cookies”). Some of the Non-Essential Cookies used are set by us to collect and process certain data on our behalf and some are set by third parties and/or our Social Networking Services.
Information to and from Social Networking Services Non-Essential Cookies include Cookies we use in conjunction with the Social Networking Services. One of the special features of the Services is that it allows you to enable or log into the Services via various social media applications/services, like Facebook or X, or to upload videos using YouTube APIs (“Social Networking Service(s)”). By directly integrating these services, we aim to make your online experiences richer and more personalised. To take advantage of these features, we will ask you to provide your credentials for the applicable Social Networking Service in order to log in to our Services. When you add a Social Networking Services account to the Services or log into the Services using your Social Networking Services account, we will collect relevant information necessary to enable the Services to access that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service (for example, your name and photograph, as well as other information that you permit the Social Networking Service to share with us).
We will use, store, and disclose such information in accordance with this Notice. However, please remember that the manner in which Social Networking Services use, store, and disclose your information is governed by the policies of such third parties, and StepUp Agency shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Services. For example, if you upload a video onto your fundraiser using the mobile application for the Services, your video will be uploaded using YouTube and subject to Google’s Privacy Policy and Google’s Security Settings. You further acknowledge that if you choose to use this feature, your friends, followers, and subscribers on any Social Networking Services you have enabled will be able to view such activity. For example, if you sign on using Meta, Meta’s privacy policy and terms of service would apply to the data Meta might obtain from your activities on StepUp Agency. Please visit the terms of use and privacy policy of the relevant Social Networking Service to learn more about your rights and choices, and to exercise your choice about those technologies.
ii. Analytics
We use web analytics vendors on our Services, such as those of Google Analytics, to help us analyse how users use the Services, including by noting the website from which you arrive, and providing certain features to you including Google Signal features such as user id tracking, dynamic remarketing, interest-based advertising, audience targeting, behavioural reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, and video ads reporting. The information collected by the technology will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services. This may result in you seeing advertisements for our Services when you visit other websites. To limit Google Analytics from using your information for analytics, you can install the Google Analytics Opt-out Browser Add-on by clicking here. You can also adjust your advertising settings by clicking here.
We use vendors to help us understand and analyse how visitors use our services, and to improve the Services. They may collect the following types of information from users of our Services: device IP Address, device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Services, and details about your use of the Services .
iii. Why We Use Cookies
We use Cookies to collect information about your access to and use of the Services, including to: (1) allow you to navigate and use all the features provided by our Services; (2) customise elements of the layout and/or content within the Services and remember that you have visited us before; (3) identify the number of unique visitors we receive; (4) improve the Services and learn which functions of the Services are most popular with users; (5) understand how you use the Services (e.g. by learning how long you spend on the Services and where you have come to the Platform from) and (6) marketing our Services to you. As we adopt additional technologies, we may gather additional information through other methods. We will notify you of such changes with updates to this Notice.
iv. Your Cookie Preferences
Most web and mobile device browsers automatically accept Cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set.
If you are located in the EU, you will be requested to opt-in to all Cookies other than essential cookies. If you are located in California, Colorado, Connecticut, Utah or Virginia, you can learn more about how we use cookies in our “California Privacy Notice” or the or the “Privacy Notice of certain other states in the United States”. You can also learn more about Cookies by visiting www.allaboutcookies.org, which includes additional useful information on Cookies and how to block Cookies using different types of browsers or mobile devices.
You can also consult the “Help” section of your browser for more information (e.g. Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). If you receive tailored advertising on your computer, you can generally control Cookies from being put on your computer by visiting the following:
- or advertising based in the United States either the Network Advertising Initiative’s Consumer opt-out link, the Digital Advertising Alliance’s Consumer opt-out link or the Your Ad Choices for App tool; or
- for advertising in Europe, the Digital Advertising Alliance Consumer Ad Choices opt-out link.
We do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit these opt-out pages, or you subsequently erase your cookies, use a different computer or change web browsers, your opt-out may no longer be effective.
If you are accessing our Services through a mobile device, you can also update your privacy settings on your device by setting the “Limit Ad Tracking” and Diagnostics and Usage setting property located in the settings screen of your Apple iPhone or iPad, or by resetting your Android ID through apps that are available in the Play Store. You can also limit information collection by uninstalling the App on your device and you can use the standard uninstall process available as part of your device for this purpose. Finally, and in connection with the Social Networking Services, you can visit your settings with each of the Social Networking Services to exercise your choice about those technologies. Please note that we do not control these mechanisms maintained by other parties and thus cannot be responsible for their functionality.
OUR USE OF INFORMATION COLLECTED
StepUp Agency uses the information collected from the Services in a manner that is consistent with this Notice. We may use the information that you provide (or otherwise permit the Services to access) for the following purposes:
A. Communicating With You
We use the information we collect to contact you for administrative purposes (e.g. to provide services and information that you request or to respond to comments and questions). For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem. In addition, we may call you if you are not responding to email and your fundraiser is subject to refunds.
We also use the information we collect to send you communications relating to the Services, such as updates on events, communications relating to products and services offered by us and by third parties, request your feedback on our Services and communications about services we believe will be of interest to you. For example, we can send periodic emails to registered users of the Services relating to their recent interactions with the Services, such as donating to a fundraiser.
B. Customisation and Marketing
We may use the information we collect for customisation and marketing purposes. For example, we may use device identifiers to learn how users interact with our Services in order to personalise the content of our Services, such as customising the language and fundraisers on our homepage based on your location.
C. Legal
We use information we collect to defend our legal rights, comply with state, local, federal or international laws, and to enforce our Terms of Service and this Notice.
CHILDREN
Our Services are not designed for use by individuals under the age of 13 (or 16 for children located in Europe). If you are under the age of 13 (or 16 for children located in Europe), please do not use the Services and/or submit any information through the Services. If you have reason to believe that a child under the age of 13 (or 16 for children located in Europe) has provided personal information to StepUp Agency through the Services, please contact us at hello@step-upagency.com, and we will delete that information from our databases to the extent required by law.
SECURITY
While no organisation can guarantee perfect security, StepUp Agency has implemented and seeks to continuously improve technical and organisational security measures to protect the information provided via the Services from loss, misuse, unauthorised access, disclosure, alteration, or destruction.
DO-NOT-TRACK SIGNALS
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here. If you are a California consumer, you can view our “California Privacy Notice” to learn more about our recognition of other signals.
RETENTION OF YOUR INFORMATION
We retain your information for as long as we deem necessary for the purpose for which that information was collected and for our legitimate business operations; provided, however, that your information is only retained to the extent permitted or required by applicable laws. When we no longer need to retain your information, we will take reasonable steps to remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it in accordance with our internal document retention policies. When determining the retention period for your information, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the Services we provide to you if we delete some information about you, mandatory retention periods provided by law and the statute of limitations.
ou, we can still send you emails about your account or any Services you have requested or received from us.
OTHER TERMS
Your access to and use of the Services is subject to STEPUP AGENCY’s Terms of Service and such other terms, which may be made available to you in connection with your use of the Services.
CHANGES TO STEPUP AGENCY’S PRIVACY NOTICE
STEPUP AGENCY reserves the right to update or modify this Notice at any time and from time to time. We will notify you of any material updates or changes we make to this Notice. If you disagree with our revisions to the Notice, you can deactivate your account or discontinue the use of our Services. Please review this Notice periodically for any updates or changes to this Notice.
By using our Platform and Services after any such update or modification, you acknowledge that you have read and understood the terms of the Notice as updated or modified.
CONTACTING STEPUP AGENCY
You can contact our Data Protection Officer by emailing hello@step-upagency.com.
You can also contact us via mail as follows:
7 Coronation Road, Dephna House, LAUNCHESE
London
NW10 7PQ
UNITED KINGDOM