Privacy Policy

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PRIVACY POLICY

1. Introduction
1.1 Small Steps Consultants Ltd (“We”, “Our”, “Us”) are committed to safeguarding and respecting the privacy of our website visitors. This policy (together with our terms of use and any documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.2 By visiting and using our website you are accepting and consenting to the practices described in this policy.
1.3 Please contact for any data protection queries or visit the Information Commissioner’s Office (ICO) via www.ico.org.uk to lodge a complaint.

2. What personal information is collected
Information we collect about you. With regard to each of your visits to our site, we will automatically collect information including (without limitation) the following:
(a) the internet protocol address used to connect your computer to the internet, time zone setting, geographical location, browser type and version, operating system and platform, referral source, length of visit, page views and website navigation paths;
(b) information about your visit, including the full Uniform Resource Identifiers (URI), clickstream to, through and from our site, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs, methods used to browse away from the page) and any ‘phone number used to call us.

3. Using personal information
3.1 Our lawful basis for processing your data is consent, legitimate interest or public interest. We use analytic tools on your data in a way you would reasonably expect. This helps us to improve the website and enhance your web experience. You can find more information on this in paragraph 10.
3.2 Your privacy settings can be used to limit the publication of your information on our website, although it may affect functionality, and you may adjust the privacy controls on the internet browser that you use to access our website.
3.3 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

4. Disclosing personal information
4.1 You agree that we have the right to share your personal information with:-
(a) any member of our group, which means our subsidiaries as defined in section 1159 of the UK Companies Act 2006;
(b) selected third parties including but not limited to:-

• business partners, suppliers and sub-contractors for the performance of any contract that we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and optimization of our site.

4.2 We will disclose your personal information to third parties:
(a) to the extent that we are under a duty to disclose or share your personal data in order to comply with any legal obligation;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to enforce or apply our terms of use and other agreements or to protect our rights, property or safety and that of our customers or others (including exchanging information with other companies and organisations for the purposes of fraud prevention and reducing credit risk);
(d) in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; and (e) if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.

5. International data transfers
5.1 Information that we collect will be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. It will also be processed by staff engaged in, among other things, the provision of support services. Information that we collect may be transferred to and stored in the United States of America under the Privacy Shield Framework or under Standard Contractual Clauses for data transfers between EU and non-EU countries. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
5.2 Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorized access.

6. Data Subject’s Rights
The Data Protection Act 2018 and the General Data Protection Regulation (EU 2016/679) (GDPR) (collectively, the Act) gives you control of your data. It states you have a right to request a copy of your information and ask us to correct your information that is wrong, delete it or restrict the use of it for specific purposes. To access your information, you will need to send us a Subject Access Request and two pieces of identification:
(a) A government issued photo identification, such as a passport or driving licence; and
(b) A document dated within the last 3 months showing your current address, such as a utility bill.
We will then respond within 1 month of receipt of your request. There is no cost to access your data, but we have the right to charge you a reasonable fee if we believe your request is manifestly unfound or excessive.

7. Amendments
We may update this policy from time to time by publishing a new version on our website. Please check this page occasionally to see any updates or changes to our privacy policy.

8. Cookies
8.1. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
8.2 By continuing to browse our website, you are agreeing to our use of cookies.
8.3 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.4 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.5 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
8.6 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

9. Our cookies
9.1 We only use session cookies.
9.2 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below. We use a session cookie to:
(a) track how users interact with the website;
(b) improve the website's usability;
(c) prevent fraud and improve the security of the website;
(d) facilitate the use of our website search engine.

10. Analytics cookies
10.1 We use Google Analytics to gather and analyse traffic which accesses our website.
10.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
10.3 The analytics cookies used by our website have the following names: _ga, _gat, _gid, __utma, __utmt, __utmb, __utmc, __utmz and __utmv.
10.4 The information generated relating to our website is used to create reports about the use of our website.
10.5 Our analytics service provider's privacy policy is available at: http://www.google.com/policies/privacy/.

11. Third party cookies
11.1 Our website also uses third party cookies over which we have no control.
11.2 You can view, delete or add interest categories associated with your browser by visiting: http://www.google.com/settings/ads. You can also opt out of the AdSense partner network cookie using those settings or using the NAI's (Network Advertising Initiative's) multi-cookie opt-out mechanism at: http://www.networkadvertising.org/choices. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-in available at:  https://www.google.com/settings/ads/plugin.

12. Blocking cookies
12.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
(b) in Firefox (version 47) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
(c) in Chrome (version 52), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.

13. Deleting cookies
13.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internetexplorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 47), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and
(c) in Chrome (version 52), you can delete all cookies by accessing the "Customise and Control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".
13.2 Deleting cookies will have a negative impact on the usability of many websites.

14. Our details
You can contact us by email using info@smallsteps.ltd