Last updated: 12/28/2020
The categories of Personal Information we collect include:
- Identification Information you provide to us
- Communication Information you share when you voluntarily reach out to us
- Technical Information we automatically collect
- Third Party Personal Information
When you interact with our Site or mobile app, we collect Identification Information that you choose to share with us. For example, when you set up an account with us, we need to collect a few important details about you, such as your name, address, Social Security number, a unique username you would like to go by, your phone number, your email address, and your date of birth. We may also collect location data you choose to share with us, so we can help protect against fraud. When you use the Service, we may prompt you to share information about contacts you have on your phone, and that is optional to provide.
We may also collect other information such as a copy of your government-issued identification and a selfie image for verification purposes. Please ensure that you only send us an image of yourself. Do not include any images of others.
When you contact customer support or communicate with us in any other way, including by voluntarily responding to questionnaires, surveys or requests for market research seeking your opinion and feedback, we’ll collect whatever information you volunteer, in addition to your name and email address.
When you visit our Site or use our Services, we collect information about which of the Services you’ve used and how you’ve used them. Examples of this information include:
- Usage information on our Site or mobile app (e.g., pages you visit on the Site, webpage from which you linked to our Site);
- Time and date of your activities;
- Your IP address;
- Location Information:
- When you browse the Site, we collect an estimate of your location through your IP address
- When you use the app, we collect your Location Information through your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g. latitude/longitude) of your mobile device. If you have given the app permission to access your location, we will collect your device’s location as permitted by the settings you choose, and store your location history. If you want to opt-out of the collection of your Location Information, please adjust your settings in your mobile device to limit the app’s access to your Location Information.
- Device ID;
- The kind of browser and computer you use;
- Name of your internet service provider; and
- Operating system version.
We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law, as follows:
- Identity Verification Information. We may collect Personal Information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources to verify your identity. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.
- Social Media Information. We have pages on social media sites like Instagram, Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
To provide the Services:
Step may use your Personal Information to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Manage individual information and accounts;
- Respond to questions, comments, and other requests;
- Verify an individual’s identity by comparing your selfie image against your government-issued identification;
- Process payment for products or Services purchased;
- Process applications and transactions;
- Provide access to certain areas, functionalities, and features of our Services; and
- Allow you to register for events.
For internal business purposes:
Step may use Personal Information for its internal business purposes, including to:
- Measure interest in Step’s Services;
- Develop new products and Services or improve existing products and Services;
- Ensure internal quality control;
- Communicate about individual accounts and activities on Step’s Services and systems, and, in Step’s discretion, changes to any Step policy;
- Comply with regulatory requirements;
- Prevent potentially prohibited or illegal activities;
- Protect the safety of any person, to address fraud, security or technical issues, or to protect the Company’s rights or property;
- Comply with applicable laws, rules and regulations or court orders; and
- For any other purpose for which you have given express permission or consent to Step.
For marketing purposes:
Step may analyze and use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Step may provide you with these materials by phone, postal mail, email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time you provide Personal Information; and
- Otherwise with your consent.
We may share Personal Information about you in the following ways:
- To verify your identity. For example, we may share information about you with credit reporting agencies to verify your Social Security number.
- With vendors and service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities; (v) know-your customer services and fraud and anti-money laundering prevention; (vi) analytics services; and (vii) in connection with the provision of the Services. These service providers have contracted with us to only use the Personal Information for the purpose(s) for which the data were originally collected or may otherwise be lawfully processed.
- Business partners. We may share Personal Information with our business partners, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested. For example, we partner with Evolve Bank & Trust (“Evolve”) to provide you with the Services. We may share your Personal Information with Evolve to enable Evolve to provide banking services to you in connection with our Services.
We may also share Personal Information with business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you.
- With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
- comply with any valid legal process, governmental request, or applicable law, rule, or regulation;
- investigate, remedy, or enforce potential Terms of Service violations;
- protect the rights, property, and safety of us, our users, or others; or
- detect and resolve any fraud or security concerns.
- With third parties as part of a merger or acquisition. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of Step or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share your Personal Information in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy.
In operating the Services, we may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
We may also use analytics tools such as Google Analytics to collect information regarding visitor behavior and visitor demographics on our Site, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.
We may employ a software technology called clear gifs (a.k.a. Web Beacons) that help us better manage content on our Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements and actions of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ Personal Information. We may use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
We will retain your information for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws.
Our Services may contain links to other websites and other websites may reference or link to our Services. These websites are operated by third parties not controlled by us, and by linking to them or being linked from them Step does not endorse, approve or make any representations about Third-Party websites or domains. We encourage you to read the privacy policies of each and every website and domain that you interact with. We are not responsible for the privacy practices or content of such other websites or domains and you visit them at your own risk.
Our Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform, blog, or chat room, or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, forums or otherwise online and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.
Step takes commercially-reasonable steps to protect the data you have given us from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. However, please be aware that no transmission of Personal Information over the Internet or the electronic storage of this information can be absolutely guaranteed to be free from unauthorized use or access. Before submitting any Personal Information via the Site or Services, please keep in mind these risks and know that you do so at your own risk.
We may give you choices regarding the sharing of your information with affiliates and third parties. Choices you have about the sharing of your information will be described in the privacy policies or notices you receive in connection with the products or Services you obtain from us.
Where provided for by law and subject to any applicable exceptions, California residents may have the right:
- To know the categories of Personal Information that Step has collected about you, the business purpose for collecting your Personal Information, and the categories of sources from which the Personal Information was collected;
- To access the specific pieces of Personal Information that Step has collected about you;
- To know whether Step has disclosed your Personal Information for business purposes, the categories of Personal Information so disclosed, and the categories of third parties to whom we have disclosed your Personal Information;
- To have Step, under certain circumstances, delete your Personal Information;
- To instruct businesses that sell Personal Information to stop doing so – Step, however, does not sell Personal Information; and
- To be free from discrimination related to the exercise of these rights.
If you would like to exercise any or all of these rights, you may do so by calling 1-888-378-6023 or contacting us. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
In addition, parents or guardians can contact us to:
- request copies of the Personal Information we collected about their child;
- direct us to delete the Personal Information we collected about their child;
- direct us to stop collecting or using Personal Information regarding their child; and
- prohibit the disclosure of Personal Information regarding their child to third parties not needed to provide the Service.