STEPS4SS.COM AND STEPSFUNDRASING.COM

PRIVACY STATEMENT


Steps 4 Success Inc. “Steps 4 Success”, “we”, “our” or “us”) values the trust you have placed in us. As part of our relationship, we recognize and respect your privacy. That is why Steps 4 Success is committed to protecting your privacy and using the information you share with us responsibly.

This Privacy Statement (“Privacy Statement”) is designed to explain: (i) how Steps 4 Success collects, uses, processes, secures, shares and transfers information; (ii) what type(s) of information we collect; (iii) how you can edit and/or delete certain information and change preferences; and (iv) covers your access and/or use of our website. This Privacy Statement does not apply to the practices of companies that Steps 4 Success Inc. does not own or control, or to people that Steps 4 Success does not employ or manage.

This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our personal information practices or relevant laws. When we make changes, we will post them here. If we make material changes to this Privacy Statement we will place a notice on our website. You may wish to check this section of our website from time to time, because by visiting our website, you agree to accept any such changes to this Privacy Statement. Except as otherwise mentioned herein, this Privacy Statement only addresses the use and disclosure of information we collect from you on our website.

This Privacy Statement is incorporated into, and part of our Terms of Use, which governs your access to and use of our website in general. This Privacy Statement shall be interpreted under the laws of the United States, regardless of the location, residence or nationality of individual users.
We updated our Privacy Statement on April 29, 2019 which is this Privacy Statement’s effective date.


TYPES OF INFORMATION WE COLLECT

Steps 4 Success may collect personal information from you when you enter a contest or sweepstake, participate in a survey or poll, shop online, check the status of an order or review order history, join our mailing list or our social networking sites, purchase and send a gift card or utilize our technical support or customer services. Categories of personal information collected include: your name, e-mail address, postal, billing and shipping address, phone number and credit card number. In addition, we may maintain a record of your purchases from STEPSFUNDRAISING.COM and our and our affiliated companies’ stores and authorized distributors, retailers and dealers.

We obtain certain information by automated means when you visit our website, such as the IP address of the device you use to connect to the Internet, domain type, browser version, service provider and the pages accessed. By collecting this information, we learn how to best tailor our website to our visitors and understand what products and services you might prefer. We and certain of our trusted third party providers collect this information through various means, such as "cookies" and "web beacons," each of which are discussed in more detail below.

We also collect information from third-party sources, including from social media and other websites that display authorized STEPS 4 SUCCESS branding. For example, if you post a comment on our Facebook page or send us a message on Twitter, we may collect that information as described in this Privacy Statement. We also may collect information about you from commercially available sources (such as data aggregators and public databases). Please note that we may combine this information with other information that we collect about you and use it as described in the Privacy Statement.


HOW WE USE INFORMATION

STEPS 4 SUCCESS uses the information we collect from you for the following purposes:
• To process your order and answer your questions about the status of your order.
• To provide you with periodic e-mails and mailings about STEPS 4 SUCCESS merchandise, services and promotions.
• To pre-fill fields.
• Showing you and/or providing to you content that we think might be of interest to you, and displaying content according to your preferences and our terms.
• To send you e-mails to help us learn more about your shopping preferences.
• To help us improve our online store and your shopping experience.
• To provide advertisements to you about our products and services on this and other websites.
• To analyze user traffic patterns.
• To protect the security or integrity of our websites and our business.
• To contact or notify you if necessary.
• To develop new services and products.
• To provide services to you.

• To comply with our legal obligations, policies and procedures.
• As otherwise indicated in our Terms of Use.

Please note that if you use the share feature on our website to share any products with a friend, we will use your friend's name and email address to send the forwarding email. Your friend's information will not be saved in our customer or marketing databases. On occasion, we may combine information you provide with other demographic information available to us.


DATA INTEGRITY

STEPS 4 SUCCESS processes personally identifiably information only for the purposes for which it was collected and in accordance with this Privacy Statement. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personally identifiably information needed to provide or improve our website, services and products or as otherwise permitted under this Privacy Statement. Notwithstanding the foregoing, we depend on you to update or correct your personally identifiable information whenever necessary.


MOBILE MARKETING

You may be able to sign up to receive communications about our products and services through your mobile device by submitting your mobile telephone number on this website. If you use this feature, we will send you communications about our products, services and promotions to such email address and/or by text message and voice message. You may, at any time, opt out of receiving these communications by contacting us as specified in the "How to Contact Us" section below. Depending on the terms of your mobile phone contract, you may incur charges for receiving and sending email and text messages on your mobile device. STEPS 4 SUCCESS is not responsible for these charges.


INFORMATION WE SHARE

STEPS 4 SUCCESS will not sell or rent the personal information you provide to us online to any third party. STEPS 4 SUCCESS shares information about our customers and subscribers with affiliated companies and reputable third parties to provide better service to you. These third party providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. These services may include gathering, maintaining and managing customer information; providing customer services; taking and fulfilling orders; conducting STEPS 4 SUCCESS promotions, contests, sweepstakes and surveys; and communicating effectively with our subscribers, visitors and customers. We do not authorize these third parties to make any other use of your information. In addition, STEPS 4 SUCCESS may share information that our subscribers and customers provide with specially chosen marketing partners. We also may share aggregated statistical or demographic information about you with third party companies in a manner that does not reveal your personal identity.

When STEPS 4 SUCCESS conducts contests, sweepstakes, promotions, and surveys, or joins with other companies to do so, customers who choose to participate may be asked to provide personal information. STEPS 4 SUCCESS and the other participating companies may use this information for such purposes as notifying winners and fulfilling promotional obligations, and may also cross reference customer databases to identify common customers. Information from these activities may also be used to explore future promotional opportunities or fulfill contractual obligations.

STEPS 4 SUCCESS may disclose your personal information to third parties (i) if we are required to do so by law, regulation or legal process (such as a court order), (ii) in response to a request by government or law enforcement authorities, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; (iv) enforce our Terms of Use or the terms of any of our statements or policies; or (v) protect the rights, property or safety of STEPS 4 SUCCESS, our associates or our visitors, users, subscribers or customers. In addition, we may share your information in connection with a substantial corporate transaction, such as a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.


LINKS TO OTHER WEBSITES

This website may contain links and conduits to other websites (“Linked Sites”) for your convenience and information. These websites may be operated by companies not affiliated with STEPS 4 SUCCESS. These Linked Sites may have their own privacy policies, which we strongly suggest you review if you visit any Linked Site. We are not responsible for the content of any websites that are not affiliated with STEPS 4 SUCCESS, any Linked Site, any use of those websites, or the privacy practices of those websites.


HOW WE PROTECT YOUR PERSONAL INFORMATION

We maintain appropriate administrative, technical and physical safeguards to protect the personal information you provide on this website against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing. For online payment transaction we use Paypal. They use the latest in data encryption and anti-fraud technology to keep your information secure, reducing the risk of online fraud. We encourage you to read the Policy of Privacy of Paypal.

You can check the security of your connection by looking at the URL line of your browser. When accessing a secure website, the first characters of the website address change from "http" to "https. If you are using a web browser or firewall that does not permit communications through secure websites, you will not be able to make purchases on our website. If you cannot access the secure server for any reason, you can place your order by calling 1-305-213-5155.

While we implement the above and other security measures to protect your information, please note that no data transmitted over the Internet or any other public network can be guaranteed to be 100% secure.


YOUR SECURITY OBLIGATIONS

You must protect against unauthorized access to your password and to your computer. Please sign off when finished using a shared computer. Your emails to us are not necessarily secure against interception so do not include sensitive information in them. We generally will not ask for passwords in an email and you should assume that if you get such a request, it might be fraudulent. YOU MUST DO WHAT YOU REASONABLY CAN TO ENSURE THE SECURITY OF YOUR PERSONAL INFORMATION.


SERVICES AND PRODUCTS ON OTHER WEBSITES

We may offer some of our products and services or authorized STEPS 4 SUCCESS branding on or through other websites. Information, including personally identifiably information, that you provide to those websites may be sent to us in order to deliver our products and services or collected and used by us as described in this Privacy Statement. We process, use, share and secure such information under this Privacy Statement. The affiliated websites through which our products and services and authorized STEPS 4 SUCCESS branding are offered may have different privacy practices and we encourage you to read their privacy policies. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their websites.


THIRD-PARTY APPLICATIONS

Our website may include Widgets, which are interactive mini-programs that run on our website to provide specific services from another company (e.g. allowing you to share a profile with your FaceBook or Twitter account). Personal information, such as your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it. We have no responsibility or liability for the practices, policies and security measures implemented by such parties.


PUBLIC FORUMS

When you contribute to a public area or feature, such as a chat room, bulletin board, list serve, wall, blog, wiki or other open forum that we may make available on or through our website or an authorized third-party website, the information that you submit may be made available to the general public. We do not restrict the distribution of personal information that you voluntarily disclose in these public forums, and so that information can be collected and used by others. For this reason, we recommend that you do not submit any sensitive information, including your full name, home address, phone number, other information that would enable other users to locate you, or financial information on these areas. We cannot prevent such information from being used in a manner that may violate this Privacy Statement or applicable law.


ACCESS AND CORRECTION

Subject to applicable law, we provide you with access to personal information we have retained about you and the ability to review, correct, update, block or delete the information where it is inaccurate. Subject to applicable law, we may limit or deny access to personal information where providing such access is unreasonably burdensome or expensive under the circumstances. Please submit your request to the address specified in the "How to Contact Us" section below. Please include your name, email address and postal address in your request.


YOUR CHOICES

We offer you certain choices about how we communicate with you and what information we collect from you. You may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences within a reasonable time going forward. You can choose not to receive marketing communications from us by clicking on the unsubscribe link in our marketing emails or contacting us as specified in the "How to Contact Us" section below. Please include your name, email address and postal address if you send us your request by email or postal mail.


COOKIES

Like many companies, we use "cookies" on this website. Cookies are bits of text that are placed on your computer's hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. We use cookies, for example, to preserve the contents of your virtual shopping cart between visits. We also use cookies to measure activity on the website and determine which areas and features of the website are the most popular. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie and how to disable existing cookies. Without cookies, however, you may not be able to take full advantage of all our website features. For example, if you turn off cookies or refuse them, you will not be able to make purchases on the website. If you cannot access the secure server for any reason, you can place your order by calling 1-305-213-5155.


WEB BEACONS

Certain pages on this website contain "web beacons" (also known as Internet tags, pixel tags and clear GIFs). Web beacons are used for internal purposes, such as to obtain the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, and the type of browser used to view the page. We also retain service providers who use web beacons to assess the effectiveness of our email communications and learn what pages our visitors viewed.


THIRD-PARTY USE OF COOKIES AND OTHER TECHNOLOGIES

STEPS 4 SUCCESS also may allow reputable third parties to collect information about your online activities through cookies and other technologies so that these third parties can provide services to us. These selected companies may use information about your activities on our website and other websites and combine such information with other information (such as an email address) to provide advertisements about our products and services on this and other websites. These third parties have their own policies regarding privacy, and their information practices are not covered by this Privacy Statement. Some of these third parties are members of the Network Advertising Initiative(“NAI”), a cooperative of online marketing companies that offers a centralized tool for opting out of behavioral advertising delivered by each of its member companies. We encourage you to read these businesses' privacy policies if you should have any concerns about how they will care for your personal information. If you would like more information about this practice and to know your choices about not having this information used by these companies, see the Network Advertising Initiative’s consumer Web site located at. Please note that opting out of the use of your information by an NAI member company does not mean that you will no longer receive online advertising or that data about your activities on our website will not be collected by third parties. It does mean that a NAI member company from which you opted out will no longer deliver advertisements tailored to your online activities as long as the company's opt-out cookie resides on your browser. You also may configure your browser settings to reject all third-party cookies.


TRANSMIT AND TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES

If you are unsure whether this Privacy Statement is in conflict with the applicable local rules where you are located, you should not submit your or any other persons personally identifiably information to us. Anyone who accesses, uses or interacts with us, our third party providers or this website who submits personally identifiably information or provides any other information does thereby consent to: (i) the international transmission, transfer, processing and/or storage of all such information, including personally identifiably information, to a country which may be deemed to have inadequate data protection and (ii) the collection, using and sharing of such information, including personally identifiably information, as provided in this Privacy Statement.


PHISHING

"Phishing" is a scam designed to steal your personal information. If you receive an email that looks like it is from us asking you for your personal information, do not respond. We will never request your password, user name, credit card information or other personal information through email.


VISITING STEPS4SS.COM OR STEPSFUNDRAISING.COM FROM THIRD-PARTY SITES

If you are visiting STEPS4SS.COM OR STEPSFUNDRAISING.COM through a link from another website or search engine, information about your visit to STEPS4SS.COM and STEPSFUNDRAISING.COM may be collected by the provider of the other website or search engine. We encourage you to review the privacy policies of these other websites or search engines. You may avoid disclosing your information to these other websites or search engines by entering STEPS4SS.COM or STEPSFUNDRAISING.COM directly into the address field of your Internet browser.


CHILDREN'S PRIVACY

This website is not directed to children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen on the website. If we become aware that we have inadvertently received personal information from a visitor under the age of thirteen on this website, we will delete the information from our records. We recommend that prospective users between the ages of 13 and 17 ask their parents or other legal guardians for permission before sending any information about themselves to anyone over the Internet.


HOW TO CONTACT US

If you have any questions or comments about this Privacy Statement or if you would like us to update information we have about you or your preferences, please contact us as indicated below:

Steps 4 Success Inc.
PO Box 366552
San Juan PR 00936-6552


Effective Date: July 4, 2010
Last Updated: April 29, 2019