The protection of privacy and the safeguarding personal information is our highest priority.
Please view the following Privacy Statement which clearly explains how we, at Stepbystep Services Limited (“the Company”), collect, process, store and protect information.
While providing intermediary services, you (“the Intermediary”) will be exposed to End Users (as they defined in the Intermediary Agreement) personal information. The Company will be exposed to personal information of the Intermediary and the End Users during the course of the Intermediary Agreement (“the Agreement”). Therefore the Intermediary is hereby to confirm that while providing services the Intermediary will strictly comply with the standards hereunder. The Intermediary also gives The Company its consent to such collection, processing, storage and use of personal information by The Company as explained below. Please be advised that the Company has limited access to End Users information possessed by the Brokers (as they defined in the Agreement) and that in any way End User information held by the Company or the Brokers will not be disclose to the Intermediary, unless required by law.
The Brokers collects the necessary information required to open, transact and safeguard End users assets and to provide the End User with the services they require. To this end, The Brokers gathers information from the End users and may, in certain circumstances, gather information from relevant banks and/or credit agencies, and/or other sources which help the Brokers profile the End Users requirements and preferences in an effort to provide better services. The Company may run similar checks on the Intermediary, in order to assess the business relationship between the party, serve Fee (as its defined in the Agreement) settlement and meet its legal constraints in practicing the intermediary business.
The information The Company collects includes information required to communicate with and identify the Intermediary. This information may be of certain demographic information about the Intermediary individuals, including birth date, banking details, domiciliation, education, occupation, etc.
The Company uses personal information only as required to provide quality service and security to the Intermediary. This information helps improve services, customize browsing experience and enables the Company to inform the Intermediary of additional products, services or promotions and the Intermediary hereby agree using this data for such purposes by the Company.
Should the Intermediary do not want to receive information of this nature for any reason, it shall contact the Company at the following address: email@example.com
The Company may share information with affiliates in the event such information is reasonably required by such affiliate in order to provide the products or services to the Intermediary. The Company may share information with partners, affiliates and alliances in order to offer additional similar products and services that meet the Intermediary needs and which are delivered in a manner that is useful and relevant only where the Intermediary have authorized the Company to do so.
The Company does not sell, license, lease or otherwise disclose personal information to third parties, except as described in this policy.
The Company reserves the right to disclose personal information to third parties where required by law, regulatory, law enforcement or other government authority. The Company may also disclose information as necessary to credit reporting or collection agencies as reasonably required in order to provide the services to the Intermediary.
To help the Company improve its services, The Company may engage third parties to help carry out certain internal functions such as Fee processing, support service, Intermediary satisfaction surveys or other data collection activities relevant to the Company’s business. Use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. All third parties with which The Company shares personal information are required to protect such personal information in accordance with all relevant legislation and in a manner similar to the way The Company protects the same. The Company will not share personal information with third parties which it considers will not afford the required level of protection.
Where the Intermediary has been introduced to the Company by another Intermediary (“Master Intermediary”), such Master Intermediary may have access to the Intermediary’s information. The Intermediary hereby unambiguously and unequivocally consents to the sharing of information with such Master Intermediary.
The Intermediary acknowledge that in order to provide services to the Intermediary, it may be necessary for information to be transferred outside of the European Economic Area or any other jurisdiction the Company or the Intermediary act in, and the Intermediary consent to such transfer.
The Company may share web site usage statistics with reputable advertising companies and with its affiliated marketing companies. The information collected by the advertising company is not personally identifiable.
From time to time, The Company may update this policy. In the event The Company materially changes this policy including how the Company collects, process or use the Intermediary’s personal information, the revised policy will be posted to the Company’s websites. The Intermediary agrees to accept posting of a revised policy electronically on the Company’s websites as actual notice to the Intermediary. Any dispute over this policy is subject to this notice, the Agreement and the code of conduct the Company practice with the Intermediary. The Company encourages the Intermediary to periodically check back and review this policy so that it will always know what information The Company collects, how The Company uses it, and to whom The Company may disclose it.
The Intermediary have read, understood and agree to this policy and hereby to confirm that it has the full power and authority to practice it.