Effective date: December 03, 2018
10029519 Manitoba Ltd (Operating as "ONTHESTEP SERVICES"). ("us", "we", or "our") operates the OnTheStep mobile
application (hereinafter referred to as the "Service").
This page informs you of our policies regarding the collection, use and
disclosure of personal data when you use our Service and the choices you have
associated with that data.
We use your data to provide and improve the Service. By using the Service, you
agree to the collection and use of information in accordance with this policy.
Service is the OnTheStep mobile application operated by 10029519 Manitoba
* Personal Data
Personal Data means data about a living individual who can be identified
from those data (or from those and other information either in our
possession or likely to come into our possession).
* Usage Data
Usage Data is data collected automatically either generated by the use of
the Service or from the Service infrastructure itself (for example, the
duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
* Data Controller
Data Controller means the natural or legal person who (either alone or
jointly or in common with other persons) determines the purposes for which
and the manner in which any personal information are, or are to be,
* Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who
processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process
your data more effectively.
* Data Subject (or User)
Data Subject is any living individual who is using our Service and is the
subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to
provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you
("Personal Data"). Personally identifiable information may include, but is not
* Email address
* First name and last name
* Address, State, Province, ZIP/Postal code, City
* Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or
promotional materials and other information that may be of interest to you.
You may opt out of receiving any, or all, of these communications from us by
following the unsubscribe link or the instructions provided in any email we
When you access the Service with a mobile device, we may collect certain
information automatically, including, but not limited to, the type of mobile
device you use, your mobile device unique ID, the IP address of your mobile
device, your mobile operating system, the type of mobile Internet browser you
use, unique device identifiers and other diagnostic data ("Usage Data").
We may use and store information about your location if you give us permission
to do so ("Location Data"). We use this data to provide features of our
Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any
time by way of your device settings.
Tracking & Cookies Data
Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website and stored
on your device. Other tracking technologies are also used such as beacons,
tags and scripts to collect and track information and to improve and analyse
You can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may not be
able to use some portions of our Service.
Examples of Cookies we use:
* Session Cookies. We use Session Cookies to operate our Service.
* Preference Cookies. We use Preference Cookies to remember your preferences
and various settings.
* Security Cookies. We use Security Cookies for security purposes.
Use of Data
10029519 Manitoba Ltd. uses the collected data for various purposes:
* To provide and maintain our Service
* To notify you about changes to our Service
* To allow you to participate in interactive features of our Service when
you choose to do so
* To provide customer support
* To gather analysis or valuable information so that we can improve our
* To monitor the usage of our Service
* To detect, prevent and address technical issues
* To provide you with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about unless you have opted
not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection
If you are from the European Economic Area (EEA), 10029519 Manitoba Ltd.
legal basis for collecting and using the personal information described in
context in which we collect it.
100229519 Manitoba Ltd. may process your Personal Data because:
* We need to perform a contract with you
* You have given us permission to do so
* The processing is in our legitimate interests and it is not overridden by
* For payment processing purposes
* To comply with the law
Retention of Data
10029519 Manitoba Ltd. will retain your Personal Data only for as long as is
use your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply
with applicable laws), resolve disputes and enforce our legal agreements and
10029519 Manitoba Ltd. will also retain Usage Data for internal analysis
purposes. Usage Data is generally retained for a shorter period of time,
except when this data is used to strengthen the security or to improve the
functionality of our Service, or we are legally obligated to retain this data
for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and
maintained on — computers located outside of your state, province, country or
other governmental jurisdiction where the data protection laws may differ from
those of your jurisdiction.
If you are located outside Canada and choose to provide information to us,
please note that we transfer the data, including Personal Data, to Canada and
process it there.
information represents your agreement to that transfer.
10029519 Manitoba Ltd. will take all the steps reasonably necessary to ensure
and no transfer of your Personal Data will take place to an organisation or a
country unless there are adequate controls in place including the security of
your data and other personal information.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, 10029519 Manitoba Ltd. may be required to
disclose your Personal Data if required to do so by law or in response to
valid requests by public authorities (e.g. a court or a government agency).
10029519 Manitoba Ltd. may disclose your Personal Data in the good faith
belief that such action is necessary to:
* To comply with a legal obligation
* To protect and defend the rights or property of 10029519 Manitoba Ltd.
* To prevent or investigate possible wrongdoing in connection with the
* To protect the personal safety of users of the Service or the public
* To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of
transmission over the Internet or method of electronic storage is 100% secure.
While we strive to use commercially acceptable means to protect your Personal
Data, we cannot guarantee its absolute security.
Our Policy on "Do Not Track" Signals under the California Online Protection
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can
set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings
page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation
If you are a resident of the European Economic Area (EEA), you have certain
data protection rights. 10029519 Manitoba Ltd. aims to take reasonable steps
to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if
you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
* The right to access, update or delete the information we have on you.
Whenever made possible, you can access, update or request deletion of your
Personal Data directly within your account settings section. If you are
unable to perform these actions yourself, please contact us to assist you.
* The right of rectification. You have the right to have your information
rectified if that information is inaccurate or incomplete.
* The right to object. You have the right to object to our processing of
your Personal Data.
* The right of restriction. You have the right to request that we restrict
the processing of your personal information.
* The right to data portability. You have the right to be provided with a
copy of the information we have on you in a structured, machine-readable
and commonly used format.
* The right to withdraw consent. You also have the right to withdraw your
consent at any time where 10029519 Manitoba Ltd. relied on your consent
to process your personal information.
Please note that we may ask you to verify your identity before responding to
You have the right to complain to a Data Protection Authority about our
collection and use of your Personal Data. For more information, please contact
your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service
("Service Providers"), provide the Service on our behalf, perform Service-
related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these
tasks on our behalf and are obligated not to disclose or use it for any other
We may provide paid products and/or services within the Service. In that case,
we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is
provided directly to our third-party payment processors whose use of your
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
MasterCard, American Express and Discover. PCI-DSS requirements help ensure
the secure handling of payment information.
The payment processors we work with are:
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If
you click a third party link, you will be directed to that third party's site.
We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone
under the age of 18. If you are a parent or guardian and you are aware that
your Child has provided us with Personal Data, please contact us. If we become
aware that we have collected Personal Data from children without verification
of parental consent, we take steps to remove that information from our
We will let you know via email and/or a prominent notice on our Service, prior
to the change becoming effective and update the "effective date" at the top of
* By email: email@example.com