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(A) This Notice

Summary: This Notice explains how we may Process your Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates.
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(B) Collection of Personal Data

Summary: We may collect or obtain Personal Data about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a public post about us on social media); when you visit our Sites; when you register to use BlueSteps or any of our other services; or when you interact with any third party content or advertising on a Site. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).
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(C) Creation of Personal Data

Summary: We may create Personal Data about you (e.g., records of your interactions with us).
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(D) Categories of Personal Data we may Process

Summary: We may Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); qualifications; employment history; diversity reporting details; recordso f your consents; information about our Sites (e.g., the type of device you are using); information about your interactions with out content or advertising; and any views or opinions you provide to us.
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(E) Lawful basis for Processing Personal Data

Summary: We may Process your Personal Data where: you have given your prior, express consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.
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(F) Sensitive Personal Data

Summary: We do not seek to collect or otherwise Process your Sensitive Personal Data. Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
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(G) Purposes for which we may Process your Personal Data

Summary: We may Process your Personal Data for the following purposes: providing BlueSteps, our Sites and our other services to you; operating BlueSteps, our Sites and our other services; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; and improving our Sites, and services.
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(H) Disclosure of Personal Data to third parties

Summary: We may disclose your Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites.
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(I) International transfer of Personal Data

Summary: We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so because it is necessary to provide services to you under the contract entered into when you signed up to the BlueSteps service.
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(J) Data security

Summary: We implement appropriate technical and organisational security measures protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.
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(K) Data accuracy

Summary: We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
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(L) Data minimisation

Summary: We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.
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(M) Data retention

Summary: We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed.
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(N) Your legal rights

Summary: Under applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.
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(O) Cookies and similar technologies

Summary: We may Process your Personal Data by placing or reading Cookies and similar technologies. For more information, please see our Cookie Notice.
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(P) Terms of Use

Summary: Our Terms and Conditions govern all use of BlueSteps, our Sites and our other services.
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(Q) Direct marketing

Summary: We may Process your Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
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(R) Contact details

Summary: You may contact us at by phone, email or through our Sites.
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(S) Definitions

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