Table of Contents

Preamble

Step Global respects your privacy. This privacy policy provides information about how we collect and use your data on stepglobalgroup.com. By accessing the services provided by Step Global on our website, you agree to the collection and use of your data by Step Global in the manner provided in this privacy policy. Please read this privacy policy carefully.

The personal data we collect from you

While using this website, you may contact our lawyers and obtain information relating to the residence and/or citizenship programs or the services offered by Step Globa Group and start the process of obtaining any of the services in which you may be interested. You may also contact us if you are looking for a career opportunity or wish for us to provide you with further information to support your press or media work. You may also contact us for general enquiries or if you are planning to be our suppliers.

We will collect and process the following personal data about you:

1. The information you give us

These are personal details and include your first name, last name, e-mail address, and phone number. These details also include information on which services you are interested in or details about your enquiry.

Such information may be provided by you in the following circumstances:

  • Filling in an enquiry form on the website
  • Corresponding with us by post, phone, e-mail, or otherwise when you apply for our services
  • Subscribing to our services or publications
  • Requesting marketing to be sent to you
  • Giving us some feedback
  • Starting negotiations for or entering into a contract to supply goods and/or services to us

To the extent you engage our services or where you might apply for a job opportunity, you may be required to provide further information. Where you are a business user, we may also require further information before we enter into a commercial relationship with you.

Such additional information may include payment details such as banking information, VAT numbers, and/or tax IDs in order for us to process payments in relation to our services. We may also require you to provide us with information that might be needed to establish and serve as proof of your identification, such as copies of your passport or national ID card. Where you are a job applicant, you will be required to provide a copy of your up-to-date CV.

Where we are collecting or processing further information, we will provide you with separate privacy notices that further describe how and why we are using your personal data.

Where we are required to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the services as agreed or we may not be able to enter into a contract with you, but we will notify you if this is the case at the time. We may have to terminate that contract with you as a result.

2. The information we collect about you from our website

Whenever you visit our website, we will automatically collect the following:

  • Technical information: including the IP address used to connect your computer to the internet, your log-in information, the browser type and version, the full uniform resource locators (URL), and the clickstream to, through, and from our website (including date and time), as well as other information regarding your experience on our website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  • Location information: We may receive information about your location and may determine your location through your IP address and, when accessing the Website through a mobile device, by using the data that we collect from that device. This includes information about the wireless networks or cell towers near your mobile device at the time of access.

3. Information we receive from other sources

We may receive personal data about you from various third parties and publicly available sources as set out below:

  • Technical data from Google Analytics advertising features, including Google AdWords, Facebook Pixel’s, Google Tag Manager, LinkedIn, Gmail, and other ad hoc paid media partnerships.
  • Identity, contact, and background data from publicly available sources, compliance databases, and/or compliance and due diligence service providers within and outside the UAE so we can confirm that you are a suitable client of or supplier to us.
  • e providers within and outside the EU so we can confirm that you are a suitable client of or supplier to us.

How we use your information

1. The information you give us

We shall use this information:

  • To facilitate the provision of the services that you request and where we need to perform the contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests (or those of a third party), and where your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation
  • To resolve any issues that you have reported and to provide support-related services
  • To manage the supplier relationship you have with us

2. The information we collect about you from our Website

We shall use this information:

  • To administer our Website and for internal operations, including troubleshooting, and in order to keep our Website safe and secure
  • To improve our Website to ensure that content is presented most effectively for you
  • To ensure that content displayed on the Website is presented in a user-friendly manner

3. Information we receive from other sources

We will combine information we receive from other sources with information you provide to us and information that we collect from you. We will use your information only for purposes as described in the paragraphs above.

Legal Basis for processing

We shall only process your personal data insofar as this is necessary for us to be able to provide the services we offer and/or for the purposes indicated in this Privacy Policy (see section B., ‘How we use your information’).

We may also process your personal data based on any legitimate interest or in order to comply with any legal obligations. These interests and obligations may include the exercise or defense of legal claims or in order to comply with an order of any court, tribunal, or authority, or disclosure to a government or regulatory entity.

Generally, we do not rely on consent as a legal basis for processing your personal data. However, where your consent is required, we will provide you with a form requesting explicit consent to do so.

Marketing

You will receive marketing communication if you have requested such information from us by providing us with your details through this website. Where we have entered a business relationship (namely a consultation) with you, we may inform you about our activities, offers, or other information that we believe would be useful to you in accordance with our legitimate interest.

We share your personal data with third party for marketing purposes only with your explicit consent.  Third parties may collect data on our website for purposes such as (i) storing and accessing tracking technologies, (ii) conversion tracking, (iii) delivering targeted ads, and (iv) improving third-party products to optimize our marketing campaigns. The collected information may include details such as the URL address, types of device, browser, operating system information, and your IP address. 

Please note that you have the right to access, correct, erase, or transfer your personal data held by any third-party service providers. You may also have the right to object to, or request the restriction of, certain processing activities. To exercise these rights, please contact the respective service provider directly. You have the right to withdraw consent or to object to receiving marketing information at any time by contacting info@stepglobalgroup.com. Once you have withdrawn your consent or object to any one of the purposes listed herein, we will stop sending you any marketing communications. If you choose not to consent or to object to any one of the purposes listed herein or withdraw your consent at any time, we will still be able to provide our services; however, we would not be able to provide you with the full range of services that we offer, and it may affect the efficiency with which we provide the services you request.

Disclosure of your information

We may disclose your personal data to any of our business partners or legal partners working on your immigration application alongside with us. All Step Global Group partners respect and protect the security of your personal data.

We may need to share personal data with government agencies and authorities in the country where you seek to obtain residence or citizenship. We shall only provide the necessary information in order to perform services under our contract with you.

We may be required to share your data with local agents or other service suppliers (in their capacity as data processors), which is necessary for us to provide the services you request. These local agents and suppliers store and process your data based on strict confidentiality and subject to the appropriate security measures and safeguards in place as described in section H. below.

We may also share your data with other third parties in their capacity as data controllers such as legal, tax, real estate, immigration or other advisors and consultants, (international) banks for payment details, or third parties providing other or additional services or goods to you such as real estate agencies, owners, or developers who you might wish to engage with under separate terms and conditions between you and such third parties. These third parties will process your data in their own right as data controllers and their data protection policies and processes shall become applicable.

We may also disclose or share your data if we are under a duty to do so in order to comply with any legal obligation, judgment, or under an order from a court, tribunal, or authority. We may also disclose your data to enforce our terms of use, or to protect our rights, property, or safety, that of our partners or other users of our website. This includes exchanging information with other companies and organizations for the purposes of anti-money laundering or KYC checks, compliance with anti-bribery or corruption laws, and/or fraud protection.

Transfers of data to third countries

Where we share your personal data with internal or external third parties, this may involve transferring your data outside the UAE. We will transfer your personal data in accordance with standard contractual clauses to ensure that your personal data is protected and transferred securely.

Third party access to your personal data

We work closely with third parties to provide you with the services you request on our website. These third parties include cloud storage providers, analytics providers, and search engine information providers. We will only work with third-party providers that comply with applicable laws in the jurisdictions in which we operate and, if applicable, agree to be bound by the SCC (as defined in section F., ‘Transfers of data to third countries’) to adequately protect and safeguard your personal data.

Data security

We will ensure that appropriate security measures are taken against unlawful or unauthorized processing of personal data, and against the accidental loss of or damage to personal data.

No method of transmission of data is 100% secure, and absolute security cannot be guaranteed.

Complaints

We welcome any comments, complaints, and queries in relation to data protection. As indicated above, you may contact our data protection officer at info@stepglobalgroup.com, and we shall try our best to deal with any issue or concern you may have.

Changes to this Privacy Policy

Any changes we make to this Privacy Policy in the future will be posted on this page, and where appropriate, notified to you via e-mail.

How to contact us

If you have any questions regarding this Privacy Policy, or if you would like to send us your comments, please contact us today at info@stepglobalgroup.com.