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Privacy policy

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StepChange srl (hereinafter, «Stepchange» and «We»)
Hive 5, Cours St Michel 30
1040 Etterbeek
Brussels / Belgium
BE0741.421.676
info@stepchange.be

1. Why this Privacy Policy?

Any person (hereinafter referred to as the «Customer») visiting and/or using the website www.stepchange.be or www.stepchangemodel.com/stepchange or www.step.stepchange.be (hereinafter jointly referred to as the «Site») or using our services, discloses a certain amount of personal data. Personal data is information that enables us to
identify you directly or indirectly as a natural person.

We collect and process your personal data in accordance with the Belgian Law of 30 July 2018 on the protection of privacy with regard to the processing of personal data («Privacy Law») and the European Regulation of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data («Regulation» or «GDPR»).

By using the Site or our services, the User declares that he/she has read this Privacy Policy and expressly agrees to the collection and processing of your personal data in the manner described in this document.

We reserve the right to make changes to our Privacy Policy at any time.

2. Who processes your personal data?

2.1. The data controller

Stepchange is the data controller and determines the personal data collected, the purposes and the means of processing.

2.2. The subcontractor(s)

Stepchange is free to use sub-contractors. The processor is the natural or legal person who processes your personal data at the request and on behalf of the data controller. The processor is obliged to ensure the security and confidentiality of your data and always acts on the instructions of the data controller.
Stepchange uses the following subcontractors: Learnybox, Facebook, Google, Sendinblue.

3. On what basis is my data processed?

In accordance with the Privacy Act and the RGPD, we process your personal data on the following legal grounds:

- On the basis of the performance of the contract to which you are a party or contractual measures taken at your request for the use of our Site and the supply of our services and/or products.


- On the basis of our legal obligations for everything relating to the management of the contractual relationship, in particular invoicing.


- On the basis of our legitimate interest in sending information and newsletters to our customers.
- On the basis of your express consent for the sending of promotional offers (direct marketing).

4. What personal data is collected?

The processing of your personal data is limited to what is strictly necessary to achieve the purposes pursued by Stepchange. The categories of data concerned by the processing are listed below:

  • Personal identification data (surname, first name, address, login details)
  • Contact details (telephone number and e-mail address)
  • Financial identification data (bank details)
  • Electronic identification data (IP address, location, cookies)
  • Personal details (gender, age, date and place of birth, nationality)
  • Details of professional activity (position, company, field)
  • Details of professional values and skills (skills, activities, priorities)
  • Details linked to private values (intuition, hobbies, feelings)

 

All this information enables us to provide the best possible coaching and to offer a high-quality personalised service. We leave you the option of not answering certain questions if you feel they are too personal or not necessary for the coaching, but this may alter the quality of the coaching if you do not answer all the questions.


In addition, we use cookies to recognise Users and offer them a personalised user experience, to remember their technical choices and to detect and correct any errors on the Site. For more information on our use of cookies, please consult our Cookie Policy.

5. What are the objectives?

Stepchange collects your personal data for the sole purpose of providing you with an optimal, personalised and secure user experience. The processing of your personal data is therefore essential for the proper functioning of the Site and the provision of our services. If data is missing, incorrect or incomplete, Stepchange reserves the right to suspend or cancel certain operations.
Stepchange undertakes to process your personal data exclusively for the following purposes:

  • Customer management: customer administration, order management, coaching management, invoicing, monitoring creditworthiness, providing support, following up complaints and sending out newsletters.
  • Litigation management.
  • Protection against fraud and offences.
  • Personalised marketing and advertising if you have given your express consent. In this case, you are free to withdraw your consent at any time.

 

When you visit our Site, certain data is collected for statistical purposes. This data enables us to optimise your user experience. This data includes your IP address, the geographical area visited, the day and time of the visit and the pages visited. By visiting the Site, you expressly agree to the collection of this data for statistical purposes.


By collecting your data, we also want to produce general statistics about the world.
of work. These trends include both personal and non-anonymised data.

6. Who receives your personal data?

Your personal data will be used exclusively for internal purposes. However, your personal data may be transferred to third parties. In this case, Stepchange undertakes to make every effort to ensure that the partner complies with the RGPD.

7. How long will your data be kept?

Your data will be kept for as long as is necessary for the purposes for which it was collected. It will be deleted from our database as soon as it is no longer required for the purpose or if you have validly exercised your right to erasure.

8. What are your rights?

8.1. Guarantee of fair and lawful processing

Your personal data will always be processed in accordance with the legitimate purposes set out in point 5. It will be collected and processed in an appropriate, relevant and non-excessive manner and will not be kept for longer than is necessary to achieve the purposes for which it was collected.

8.2. Right of access

If you are able to prove your identity, you have the right to obtain information about the processing of your data. You have the right to know the purposes of the processing, the categories of data concerned, the categories of recipients to whom the data is transmitted, the criteria used to determine how long the data is kept, and the rights you can exercise over your data.

8.3. Right of rectification

Inaccurate or incomplete personal data may be corrected. Either directly by the User or by sending us a written request.

8.4. Right to erasure (or «right to be forgotten»)

You have the right to obtain the deletion of your personal data in the following cases:
- Your personal data are no longer required for the purposes for which they were collected; ;
- You withdraw your consent to the processing and there is no other legal basis for doing so
treatment ;
- You have validly exercised your right to object; ;
- Your data has been processed unlawfully; ;
- Your data must be deleted to comply with a legal obligation.

8.5. Right to limit processing

In certain circumstances, you have the right to request that the processing of your personal data be restricted, in particular if the accuracy of the data is contested, if the data is
necessary in the context of legal proceedings or for the time necessary for StepChange to verify that you can validly exercise your right to erasure.

8.6. Right to object

You have the right to object at any time to the processing of your personal data for the purposes of direct marketing, profiling or the legitimate interests of the controller. StepChange will cease processing your personal data unless it can demonstrate compelling legitimate grounds for the processing which override your right to object.

8.7. Right to data portability

You have the right to obtain all the personal data you have provided to us in a structured, commonly used and machine-readable format. At your request, this data may be transferred to another service provider, unless this is technically impossible.

8.8. Right to withdraw your consent

You may withdraw your consent to the processing of your personal data at any time, for example for direct marketing purposes.

9. How to exercise your rights

To exercise your rights, you must send us a written request and proof of identity, by e-mail to info@stepchange.be. We will reply as soon as possible, and no later than one (1) month after receipt of the request.

10. Possibility of lodging a complaint

If you are dissatisfied with StepChange's processing of your personal data, you have the right to lodge a complaint with the Data Protection Authority (https://www.autoriteprotectiondonnees.be/).