Privacy Policy

The Step Inititiative - Always stay informed

In the context of our professional activities, Solving the E-Waste Problem (StEP) Initiative – Association to support sustainable solutions for the global e-waste problem (hereinafter "we", "us" or "our") processes – as the controller within the meaning of Article 4(7) of the General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter "GDPR") – your personal data and the personal data of your employees and/or members of corporate bodies (hereinafter "you" or "your"). This privacy notice informs you of the details of the processing of your personal data. Personal data is all information which relates to an identified or identifiable person, such as his/her name, date of birth, address etc. (hereinafter "data").

(A) DATA PROCESSING IN CONNECTION WITH YOUR MEMBERSHIP IN THE StEP INITIATIVE


(1) For what purposes do we process your data and on which legal basis?

We process your data for the following purposes and on the following legal bases:

(a) Performance of the StEP Initiative

We process the data of our members for the purpose of the performance of the initiative, i.e. to provide our services as defined in our constitution. Such processing is lawful on the basis of Article 6(1)(b) GDPR (performance of a contract).

(b) Compliance with legal obligations

Furthermore, we process personal data in order to comply with the legal obligations to which we are subject (e.g. retention periods established under the Federal Fiscal Code). Such processing is lawful on the basis of Article 6(1)(c) GDPR (compliance with a legal obligation).

(c) Marketing

We process the personal data of current, former and potential members and their employees for the purposes of marketing, i.e. sending regular newsletters informing about recent developments. Such processing is conducted on the grounds of your explicit consent and thus is lawful on the basis of Article 6(1)(a) GDPR (consent).


(2) Who receives your data?

Your personal data will be disclosed by us only if there is a valid legal basis for such disclosure. In any case, we only disclose your data to the extent necessary for each specific purpose, or as required under the relevant legal provision, in line with any legitimate interest or, in the case of consent, as specified by you.

Where necessary, your data will be disclosed in particular to our tax consultant and auditor Rogy & Rogy Wirtschaftsprüfungs- und Steuerberatungs GmbH, Geusaugasse 39/8, 1030 Vienna, Austria.

Furthermore, we sometimes use service providers (data processors) for data processing (in particular for technical support). These processors have agreed to maintain the confidentiality of your data, are carefully selected by us, and are bound by our instructions. In particular, we employ the services of the following processors:

  • Wir&Medien | Tobias Bialdyga & Saskia Molewicz GbR
    Im Zukunfts Zentrum Zollverein, Katernberger Str. 107, 45329 Essen, Germany

  • Mittwald CM Service GmbH & Co. KG
    Königsberger Straße, 4-6;32339 Espelkamp, Germany


(3) How long will your personal data be retained?

In principle, we retain your data until your StEP membership has ended. Furthermore, we are subject to multiple retention obligations, in accordance with which data are also required to be retained beyond the term of the contract, as stipulated for instance on the basis of retention periods provided under tax law or professional rules of conduct. We also retain your data, where appropriate, as long as legal claims can be made in connection with your agreement. In the case of pending administrative or judicial proceedings, your data will be retained until termination of the respective proceedings.

Moreover, we retain your data beyond the term of the membership as part of our database of contract partners and for the purposes of members management. We delete your data if you object to such data processing or if there has been no contact with you for business purposes over a period of three years.

(B) DATA PROCESSING IN CONNECTION WITH OUR WEBSITE


(1) Provision of the website and creation of log files

(a) Description and scope of data processing

Each time our internet site is accessed, our system collects automated data and information from the computer system accessing our site.
The following data is collected:

  • User’s IP address
  • Access status / HTTP status code
  • Date and time of access and time zone difference to Greenwich Mean Time (GMT)
  • Operating system and interface used
  • Volume of data transmitted
  • Websites from which the user's system accesses our website
  • Websites accessed by the user's system via our website
  • Information on the type of browser and the version being used
  • Protocols
  • Used Hostname
  • User agent

The data are likewise stored in our system's log files.

(b) Legal basis for data processing

The temporary storage of data and log files is lawful under Article 6(1)(f) GDPR.

(c) Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the user's computer to retrieve and display the website. For this purpose, the user's IP address must be stored for the duration of the session.

The data is stored in log files to guarantee the functionality of the website. Furthermore, the data help us optimise the website and guarantee the security of our information technology systems.

Our legitimate interest in processing data as provided for under Article 6(1)(f) GDPR also consists in achieving these objectives.

(d) Duration of storage

The data are deleted or anonymized at the end of each session.

In the event the data are stored in log files, these files will be deleted after 60 days. Data are not stored for a period exceeding this in any format which would make it possible for the persons concerned to be identified.

(e) Recipients

Your data will be transferred to:

  • Mittwald CM Service GmbH & Co. KG
    Königsberger Straße 4-6;32339 Espelkamp; Germany


(2) Use of cookies

(a) Definition of cookies

Cookies are small text files stored in your browser. They are downloaded by your browser the first time you visit our website. The next time this website is visited using the same terminal or browser, the cookie and the information stored in it will be sent either to the respective website which set it (first party cookie) or to another website to which it belongs (third party cookie). In this way, the cookie recognises that the website was requested using the respective browser and this changes the way in which content is displayed. For instance, cookies "remember" your preferences, how you use a site, and to some degree they adapt the offers shown to the individual.

(b) Functionally necessary cookies

We use the following cookies for the purpose of transmitting messages and providing the services requested by you. The data processing activities undertaken by employing the use of cookies are based on our legitimate interests in providing a fully functioning website and the services requested by you (Article 6(1)(f) GDPR, Section 96 para. 3 of the Telecommunications Act).

Cookie Types of data Purposes Storage period Recipients
PHPSESSID Hash (a sequence of randomly generated numbers) (no personal data involved) Recognition of the user during the sessing Session x
cookieconsent_status Boolean ("dismiss" or "allow") (no personal data involved) Saves if the user has agreed to the cookie banner 1 year x


(3) Newsletter

(a) Purpose

We store and processes your email address for the purpose of sending to you emails that contain useful information about out activities.

Furthermore, we store your IP address and the times of registration respectively for the purpose of proving your registration and, where appropriate, investigating and clarifying any possible misuse of your personal data.

Furthermore, we measure the performance of the newsletter by processing data on whether the newsletter was opened (yes/no) ("opening rate"), information on which sections of the newsletter were clicked ("click behaviour"), as well as information on the technical deliverability of the newsletter ("bounces", e.g. whether the newsletter could not be delivered due to an incorrect email address). Such data are generated by the system.

(b) Legal Basis

Your email address is processed on the basis of the consent you have given in accordance with Section 107 of the Telecommunications Act and Article 6(1)(a) GDPR. You have the right to revoke your consent at any time free of charge.

You can revoke your consent at any time by clicking on the link in any email providing information or by sending an email to info@step-initiative.com.

Your IP address, the times of registration and confirmation from the confirmation link are processed on the basis of our legitimate interest under Article 6(1)(f) GDPR. Our legitimate interest consists in proving your registration and, where appropriate, investigating and clarifying any possible misuse of your personal data.

We base our processing of the information you provide to us on a voluntarily basis and the collection of data in order to measure performance on our legitimate interests (marketing purposes; Article 6(1)(f) GDPR).fd

You provide your data to us on a voluntarily basis without being under a statutory or contractual obligation to do so. However, the processing of your email address is necessary in order to be able to send you the respective newsletter. Failure to provide an email address means that we cannot send the newsletter to you.

(c) Storage / deletion

When you unsubscribe from the newsletter, this is automatically noted in the newsletter database. This ensures you do not receive the newsletter from the time you unsubscribe.

Email address data are stored in our system so long as the newsletter subscription is active. If the user decides to unsubscribe from the newsletter, the data on our servers will be deleted. For statistical purposes, only anonymized data and data that cannot be used to identify the user are retained.

(d) Recipients

We use the services of a processor to distribute the newsletter and manage our newsletter subscriptions:

  • MailChimp
    The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA.

We provide the company with your email address and name. Find out more about the Privacy Policy of MailChimp at https://mailchimp.com/legal/privacy/


(4) Contact Form and Webinar Application

(a) Purposes

We store and processes your personal data (i.e. Company name, Name, E-Mail address, Phone) provided in the contact form for the purpose of administration of requests sent in the contact form.

We store and processes your personal data (i.e. First name, Last name, E-Mail address) provided in the webinar application form for the purpose of administration of your webinar application.

We store and processes your personal data (i.e. Name of company / institution, Description of organization’s activities, main topics of interest, E-Mail address) provided in the application form for organisaitons form for the purpose of administration of your membership application.

We store and processes your personal data (i.e. Name, Description of professional background, topics of main interest, E-Mail address) provided in the application form for individuals for the purpose of administration of your membership application.

(b) Legal basis

Your data provided in the contact form is processed on the basis of Article 6(1)(f) GDPR (legitimate interest).

Your data provided in the webinar application form is processed on the basis of Article 6(1)(c) GDPR (performance of the contract).

(c) Storage / deletion

Data provided in the webinar application form are stored in our system 3 month after the webinar.

Furthermore, we are subject to multiple retention obligations, in accordance with which data are also required to be retained beyond the term of the contract, as stipulated for instance on the basis of retention periods provided under tax law or professional rules of conduct. We also retain your data, where appropriate, as long as legal claims can be made in connection with your agreement. In the case of pending administrative or judicial proceedings, your data will be retained until termination of the respective proceedings.

(d) Recipients

Your data is not disclosed to any recipients.


(5) Processors

In some instances, we engage the services of external service providers (so-called processors) to process personal data. They were carefully selected and commissioned by us, are bound by our instructions and are regularly monitored.

The following processors act on our behalf:

  • Mail Chimp
    The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA

  • Wir & Medien
    Im Zukunfts Zentrum Zollverein, Katernberger Str. 107, 45329 Essen, GERMANY

  • Mittwald
    Königsberger Straße 4-6;32339 Espelkamp; GERMANY