Privacy Policy

Information regarding the processing of data in accordance with Article 13 of Regulation (EU) 2016/679

Pursuant to and for the purposes of Article 13 of Regulation (EU) 2016/679 of the Commission of the European Parliament and of the Council of April 27, 2016 (GDPR), we inform you that the personal data you voluntarily made available to Every Software Solutions Srl (hereinafter also the “Company” or “STEP”), with registered office in BEKALTA, info@step.com.tn, which operates as Data Controller, will be processed in compliance with current legislation on the protection of personal data.

1. Purpose and legal basis of the treatment

The personal data you provide to STEP will be processed within the limits necessary to achieve the following purposes:

Contractual purposes
a) Satisfy your requests for information, also through the simple compilation of a Form on the Site;
b) To provide the service and, in general, to fulfill the obligations arising from the contract;

The legal basis of data processing is the execution of the contract that involves you.

Fulfillment of administrative obligations purposes

c) Perform activities closely related and instrumental to the fulfillment of any contractual obligations, such as internal administration, financial management, collection of receivables, execution of payments, tax and accounting obligations.

The legal basis for the processing of data is the need to fulfill an obligation imposed by law.

Marketing purposes

d) To send information or promotions, such as, for example, invitations to seminars and conferences, newsletters, advertising material and to publicize products and services, including personalized and carry out studies, statistical and market analysis, both with traditional methods of contact (paper mail, operator calls) and automated (e-mail) by STEP.

The legal basis for the processing of data is the need to fulfill an obligation imposed by law.

2. Period of retention

Data collected to fulfill your request for information will be stored for a maximum period of 24 months.

Data collected to provide the requested Service and to fulfill obligations imposed by law will be kept for the duration of the contract and, after termination, for the ordinary prescription period of 10 years.

For marketing purposes, the data collected relating to purchases will be kept for a maximum period of 24 months.

Personal data, without reference to purchases, may be retained for a period not exceeding 24 months and until the person concerned requests its deletion. After this period of conservation, the data will be destroyed or made anonymous, compatibly with the technical procedures of cancellation and backup.

3. Provision of data and consequences of a refusal

With reference to the purposes referred to in paragraph 1, contractual purposes, letters a) and b), and the purpose of fulfilling administrative obligations, letter c), the provision of your personal data is necessary. Any refusal and/or the provision of incorrect and/or incomplete data may make it impossible to provide the planned activities.

With reference to the further purposes of point 1, Marketing purposes, letter d), the conferment of your personal data is optional. However, your refusal and/or the provision of inaccurate and/or incomplete data may prevent the execution of so-called marketing activities, including the performance of studies, statistical analysis and market research, but not the response to your request and the provision of the Service, which will still be provided.

4. Communication of data

Your data may be processed by STEP’s employees who are in charge of the above mentioned activities and have been authorized to process the data and have received adequate operational instructions. Your personal data may be processed to third parties who provide the Company with assistance and services used for the purposes referred to in point 1 above (such as, by way of example, suppliers, partners, consultants of STEP or other persons and/or entities, including Licensees and Agents contractually bound to STEP) who have been appointed as data processors and who, on behalf of STEP, ensure:

(i) the operation and/or maintenance of the websites and electronic and/or telematic tools used by STEP;
(ii) the management of the Service;
(iii) the elaboration of studies, statistical analysis and market research;
(iv) sending information or promotions, such as, for example, invitations to seminars and conferences, newsletters, advertising material and/or offers of goods and services in the manner indicated in paragraph 1 letter d) above;
(v) support activities regarding legal, fiscal, insurance, accounting, organizational aspects;

Your personal data may also be disclosed to third parties acting as data controllers, such as supervisory and regulatory authorities and, more generally, public or private entities legally authorized to request the data.

Such data will not be transferred abroad to non-EU countries.

5. Rights of the interested party and complaint to the Control Authority

By contacting the Company by e-mail sent to INFO@STEP.COM.TN the interested parties may ask the
data controller for access to personal data, or the rectification or erasure of personal data, and also have the right to restrict the processing of data in the cases provided for in Article 18 GDPR, and to object to the processing in case of legitimate interests of the data controller.

In addition, where the processing is based on consent or a contract and carried out by automated means, data subjects have the right to receive personal data in a structured, commonly used and machine-readable format, and to transmit the data to another data controller without
hindrance.

Data subjects have the right to revoke at any time their consent given for marketing purposes, and they may also object to processing for marketing purposes. It is understood that the interested parties who prefer to be contacted for the above-mentioned purpose through traditional forms of
communications, to express their objections only to automated communications.

Data subjects have the right to lodge a complaint with the competent supervisory authority in the Member State in which they reside or work, or in the Member State in which the alleged infringement took place.

Last updated: April 2022