Our Commitment to Your Privacy
This privacy policy applies to http://www.screensteps.com (the "Site"), a website operated by ScreenSteps, Inc., (the “Company,” “us,””we” or “our”).
The Site also includes our Chrome extension and customer subdomains, e.g. company-name.screenstepslive.com.
The Site provides the "Service" as defined in the Terms of Use.
We respect and protect the privacy of our users. This Privacy Policy explains how we collect and use your information and is part of our Terms of Use when you use our Site or Service.
Your Consent
By using our Site or Service, you consent to our Privacy Policy. If you don’t agree, please don’t use our Site or Service.
What information do we collect?
Personal Data
“Personal Data’ means any information relating to an identified or identifiable natural person. We collect Personal Data from two classes of users of the Services: Administrators for entities that contract with us or that might be interested in contracting with us (“Customers”) and the persons that Customer desire to use the Services to provide information or training to them (“End Users”).
For Customers, we will collect Personal Data such as the names, e-mail addresses, name of the entity they represent and phone numbers and IP Address you access the Site or Service from. We also will collect content such as knowledge-base articles, checklists and courses (“Program Information) and a history of the Program Information posted (“Program History”). We may also collect credit card information from the account owner for a Customer account.
For End Users, we collect Personal Data such as names, user names and email addresses. We also collect End User IP addresses, search history within the ScreenSteps knowledge base and history of access to the Program Information.
Finally if an End User or Customer submits a comment, we will collect it, and the time and place the comment was posted.
Tracking Data
We and our third-party service providers may collect certain tracking information about your use of our Site and Service. For example, we collect;
- Log information (including your IP address, browser type, Internet service provider, referring and exit pages, operating system, dates/time of access, and related data)
- Information collected by cookies and tracking pixels (as discussed below)
- Web beacons (also called "Internet tags" or "clear gifs"; used to count visitors to our Site and which pages were viewed and links clicked)
- Embedded scripts (code temporarily downloaded onto your device to collect information about your interactions with the Service and thereafter deleted or deactivated)
Cookie Information
We use cookies and similar technologies in our Site or Service. The Site or Service may also include cookies and similar tracking technologies of third parties, which may collect additional information about you via the Site or Service and across other websites and online services. For more details about how we uses these technologies, and your opt-out opportunities and other options, please see our Cookie Policy.
How do we use your data?
Analytics: Company utilizes Tracking Information to access anonymous data to help us understand how our Services are used. We use Tracking Information to customize content for you and improve our Services. Google Analytics and Keen.io provide reports to Company with website trends without identifying individual visitors.
Providing the Services. We use your Personal Data to provide the Services, provide customer service/support and communicate with you regarding the Services and new features. If you are a Customer, it enables us to track your use for customer service purposes. We use the Programming Information created by Customers to provide the Services to End Users connected to the Customers. If you are an End User, we use your Personal Data and history of access to identify you, enable you to establish feedback using comments and track your use of the Services for customers.
Validating Access to Content. For Customers, we use the Personal Data of customers tied to Programming Information and Program History to validate your right to use our Services. We use the Program History and history of access by End Users tied to their Personal Data to validate the identities of End Users and track their use to report to Customers as a part of our Services. These are essential components of our Services.
Direct Marketing. We use Customer Personal Data to communicate with you regarding the provision of the Services, but also to let you know about additional features and services we provide that may be of interest to you. If you do not wish to receive marketing communications, you may opt out at any time by sending a request to privacy@screensteps.com.
How Do We Share Your Data
We will not sell, rent, or share Personal Data with third parties outside of our company without your consent, except in the following ways:
Customers. Our service involves providing a platform to present knowledge base and course content from Customers to End Users. This involves presenting the content and ensuring that certain End Users have accessed and reviewed the content for the benefit of both the Customer and End User. As such, we share End User contact information and applicable End User search history and End User Program Information access history with Customers to confirm End User attendance and review of the content.
Comments. If you post a comment, it will be shared with other End Users accessing the Programming Information and the Customer that posted the Programming Information. Once posted, comments cannot be edited, but may be deleted by contacting the Customer that is providing the Programming Information.
Charging for Services. When you enter your credit card information, we transmit your information to Chargebee for processing, but Company does not store any credit card data associated with any purchases processed on the Site. Company utilizes ChargeBee’s APIs to process payments and utilizes Stripe as a payment gateway for those payments. You should review Stripe's Privacy Policy and ChargeBee, Inc. Privacy Policy for more detail about how your information is collected, stored and maintained by these third party payment processors
Law Enforcement and Internal Operations
Personal Data may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against Company or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (iv) to protect the rights, property or safety of Company, its users or members of the general public. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third party request to compel disclosure of your information.
Business Transfer
Company may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Under such circumstances, Company will use commercially reasonable efforts to notify its users if their personal information is to be disclosed or transferred and/or becomes subject to a different privacy policy.
Third Parties
We sometimes contract with other companies and individuals to perform functions or services on our behalf. Our categories of service providers includes software maintenance, data hosting, sending email messages, project management and customer service. We necessarily have to share your Personal Data with such third parties as may be required to perform their functions. We take steps to ensure that these parties take protecting your privacy as seriously as we do, including entering into Data Processing Addendum, EU Model Clauses and/or ensuring they have EU-U.S. and Swiss-US Privacy Shield certification since all of our service providers are in the United States.
Third Party Service Providers
Third Parties that collect and share Personal Data with us regarding End Users or Customers. Additional information about the subprocessors we use to support delivery of our Service is set forth in our list of Subprocessors.
How is My Data Protected?
We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example:
- SSL encryption (https) everywhere where we deal with personal data.
- Password protection on your account.
- Data is kept on secure, encrypted servers, located in the US.
- Restricting staff access to Personal Data protected by password logins.
- Regular staff privacy and security training
- Payment services are tokenized
However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we store, process or transmit.
Payments Encryption: Company utilizes only PCI-DSS compliant third party payment processors to ensure the security of your personal information.
Your Choices?
Right to Review and Rectify Your Personal Data.
Customers can see a history of what articles and courses they have viewed or complete on their account as well as your Account Information.
You can update most of your Account Information by logging on to your account. However, if additional assistance is required to change or delete inaccuracies within other Personal Data or would like to know what other information about you was collected, please contact us at privacy@screensteps.com.
Right to Remove or Withdraw Consent.
You have the right to withdraw consent where such consent is required to share or use data and you may request that we delete your Personal Data.
If you would like to delete comments posted, please contact your employer or entity that has provided the Programming Information.
If you receive newsletter or marketing communications from us and no longer wish to receive them, please follow the removal instructions in the email or change your account settings. You can delete your Account Information by logging into your account and canceling your account. However, since your Account Information and Account History is required for us to provide the Services to you, deleting it will also terminate your access to the services. Deleting your Personal Data does not mean that all of it will be removed. We take steps to delete Personal Data that is no longer necessary in relation to provide the Services by deleting it within 120 days of your terminating your account or if the account remains unused for more than one year. Account data will be deleted within 90 days. Account images will be deleted within 120 days and will be permanently removed from our backup systems within 140 days. We may be required by law, to retain it to exercise or defend legal claims, or contractual obligations with our customers to retain some information in connection with our obligation to provide the Services. We may de-identify and anonymize some data for purposes of retaining it.
Data Portability
If you would like us to transmit your Personal Data to another company providing similar services, we will work with them to do so upon request and verification of such request with both the requestor and the company receiving the Personal Data.
Right to Redress
If you are a subject of the European Union or European Economic Area and Switzerland and you believe we have violated any data protection laws that apply to you, you have a right to file a complaint. Please contact the Information Commissioner’s Office in the United Kingdom.
Processing End User Data for Customers
Our Services may involve the processing of Personal Data on behalf of our customers. When we do so, we are acting as processors for the controllers of such data. As such, we take steps to ensure that Personal Data subject to GDPR is processed in accordance with controller instructions and GDPR such as entering into a Data Processing Addendum incorporating EU Standard Contractual Clauses governing the processing, transmission and use of such End User Personal Data. If you wish to exercise your data subject rights to review, rectify, delete or port your End User Personal Data please contact the controller to make such request. If you make the request to us, we will work with the controller to process and evaluate such request to confirm whether deletion is required by GDPR.
Your data will be stored only for as long as strictly necessary to provide our services to our clients, to meet our obligations to you, and to meet our legal obligations.
Transnational Transfer of Data
If you are providing your Personal Data to us directly to use our Site or Services, we will transmit your data, including your Personal Data, to the United States in order to fulfill our contractual obligations to you.
Your California Privacy Rights
The California Privacy Rights Act states that residents have the following rights:
- The right to know about the personal information a business collects about them and how it is used and shared;
- The right to delete personal information collected from them (with some exceptions);
- The right to opt-out of the sale or sharing of their personal information; and
- The right to non-discrimination for exercising their CCPA rights.
In November of 2020, California voters approved Proposition 24, the CPRA, which amended the CCPA and added new additional privacy protections that began on January 1, 2023. As of January 1, 2023, consumers have new rights in addition to those above, such as:
- The right to correct inaccurate personal information that a business has about them; and
- The right to limit the use and disclosure of sensitive personal information collected about them
California residents who have an established business relationship with ScreenSteps may make a written request to Company about whether Company has disclosed any Personal Information to any third parties for the third parties' direct marketing purposes during the prior calendar year. To make such a request, please send an email at privacy@screensteps.com or write us:
ScreenSteps Privacy
PO Box 801
McLean, VA 22101
866-275-7865
Third Party Websites
We may link to other websites. If you click on any of the links in this Privacy Policy, you will be directed to another website. Company does not control the data collection or privacy practices of such third party sites. We encourage you to read the privacy policies of any third party sites, as their collection, use and storage practices and policies may differ from ours.
Data Retention
Your data will be stored only for as long as strictly necessary to provide our services to our clients, meet our obligations to you, and fulfill our legal obligations.
Minors Under 16 Years of Age
Company does not knowingly collect or store any personal information from or about children under the age of 16.
If you believe a child under the age of 16 has under any circumstances provided us with personal information and data, a parent or legal guardian can email us at privacy@screensteps.com to request that their children’s information be deleted from our records.
Do Not Track
Do Not Track” or DNT is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. At present, our Site does not respond to or alter its practices when a DNT signal is received.
Changes to our Privacy Policy
Company reserves the right to amend this Privacy Policy at any time. If Company makes material changes to its Privacy Policy, we will notify you by (1) changing the Effective Date on our Privacy Policy and provide additional notification either (1) via email or other means as we may deem commercially reasonable.
Questions?
If you ever have any questions about our online Privacy Policy, please contact us. We respect your rights and privacy, and will be happy to answer any questions or concerns you might have. You may direct any such questions to our Data Protection Team at privacy@screensteps.com.
Our EU Representative:
Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is :
Instant EU GDPR Representative Ltd.
Adam Brogden contact@gdprlocal.com
Tel +35315549700
INSTANT EU GDPR REPRESENTATIVE LTD
Office 2,
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8
Ireland
Our UK Representative:
Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is: GDPR Local Ltd.Adam Brogden contact@gdprlocal.com
Tel +44 1772 217800
1st Floor Front Suite
27-29 North Street, Brighton
England
Last Updated: August 27, 2024
