NUSTEP, LLC PRIVACY POLICY
Last updated on June 29, 2023
NuStep, LLC believes in your right to privacy, and protecting your private information is our priority. As such, NuStep, LLC and its affiliates (“NuStep”) have created this Privacy Policy in compliance with applicable law in order to demonstrate our firm commitment to privacy. This Privacy Policy describes how NuStep collects, uses, discloses, transfers, stores, retains or otherwise processes your information when you (whether in your individual or business capacity) access or use, in any manner, any content, products, services or related activities (collectively “Services”), through offline or online methods, including when you visit our website nustep.com.
When we refer to “we,” “us,” or “our,” we mean NuStep, or the specific division, subsidiary, or affiliate that operates a site, provides its content, or processes information received through it and/or through other offline or online methods as set forth herein, each as appropriate and applicable. When we refer to “you” or “your,” we mean the person accessing the site or Services and/or providing information in connection with the site or Services. If the person accessing the site or Services does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.
This Privacy Policy applies to your use of our Services, and covers information collected in connection with your access to and use of our Services. You should read this entire Privacy Policy before submitting information to us or using our Website. Whenever you submit information via the site or otherwise to us, whether online or offline, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy.
This Privacy Policy is subject to our Terms of Use located at https://www.nustep.com/legal/. We may update this Privacy Policy from time to time, as specified in the “Changes to This Privacy Policy” section below.
OUR PRIVACY POLICY INCLUDES:
- GENERAL DISCLOSURES
- WHAT INFORMATION WE COLLECT
- HOW WE USE YOUR INFORMATION
- BIOMETRIC DATA
- WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION
- COOKIES POLICY
- HOW TO RESTRICT COOKIES
- THIRD-PARTY ADVERTISING AND ANALYTICS
- LINKING SITES
- SOCIAL MEDIA
- HOW LONG WE RETAIN YOUR INFORMATION
- DO NOT TRACK
- MARKETING AND PROMOTIONAL COMMUNICATIONS
- CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION
- SECURITY
- CALIFORNIA PRIVACY RIGHTS
- CHANGES TO THIS PRIVACY POLICY
- CONTACT US
Each of the sites is hosted in the United States. If you are visiting the site from outside of the United States, please note that by providing your information it is being transferred to, stored or processed in the United States and other countries, where our data center and servers are located and operated. This section sets forth the general privacy policy for the United States and other jurisdictions not otherwise specifically covered by the jurisdiction-specific policies or jurisdiction-specific policies below. If you are outside the United States and do not wish to allow the transfer of your personal data to the United States, you should not use the site and opt-out of the collection of cookies. View our Cookies Policy.
We take your privacy and the protection of your personal data seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.
COLLECTION OF PERSONAL INFORMATION
Personal Information
We collect personal information about you in the following ways: 1) from you when you voluntarily submit information directly to us; 2) using automated technology, including when you visit our Website, social media, or interact with our electronic advertisements or communications; and 3) using third party sources, including our service providers, analytics providers, through social media and other websites or services we interact with. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. More information is given below in the “Cookies” section below.
All personal information may be used for the purposes stated in this Privacy Policy.
We collect, use, and disclose your personal information as described in the chart in Annex 1 below.
Sensitive Personal Information
We may collect Sensitive Personal Information from you including health information, biometric data, and geolocation. Access to your Sensitive Personal Information is strictly limited to those with a legitimate business reason for accessing this in line with the lawful basis described in Annex 1.
BIOMETRIC DATA
This section defines NuStep’s policies and practices with respect to Biometric Data, as defined below, and is implemented under applicable laws, including, but not limited to, the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. and as may be amended (“BIPA”) and other applicable laws.
As used in this Privacy Policy, “Biometric Data” includes “biometric identifiers” and “biometric information” as defined in BIPA, 740 ILCS § 14/10, or other applicable laws. A fingerprint is an example of a biometric identifier.
NuStep will collect your Biometric Data for the following purpose(s):
- NuStep and/or its vendors collect, store, and use your Biometric Data to identify you and verify your identity while using a Transitt.
- NuStep and/or its vendors will not sell, lease, trade, or otherwise profit from your Biometric Data.
NuStep will not collect, disclose, disseminate, or otherwise share your Biometric Data to or with anyone other than its service providers, who provide NuStep with products and services using Biometric Data, without/unless:
- First obtaining your written consent to such collection, disclosure or dissemination;
- The disclosure of Biometric Data is necessary to complete a financial transaction requested or authorized by you;
- Disclosure is required by state or federal law or municipal ordinance; or
- Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
NuStep shall use a reasonable standard of care to store, transmit, and protect from disclosure any Biometric Data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which NuStep stores, transmits, and protects from disclosure other confidential and sensitive information.
NuStep shall retain Biometric Data only until, and shall request that its vendors destroy such data when, the first of the following occurs:
- the initial purpose for collecting or obtaining such Biometric Data has been satisfied;
- within three (3) years of your last interaction with NuStep; or
- as otherwise may be required according to applicable law.
THIRD-PARTY ADVERTISING AND ANALYTICS
We may use third-party service providers to provide site metrics and other analytics services. These third parties may use cookies, web beacons and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our site and Services, webpages viewed, time spent on webpages, links clicked and conversion information (e.g., transactions entered into). This information may be used by NuStep and third-party service providers on behalf of NuStep to analyze and track usage of our site and Services, to determine the popularity of certain content and to better understand how you use our site and Services. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.
This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices.
LINKING SITES
The site contains links to other websites. NuStep is not responsible for the privacy practices or the content of such websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). We do not share information we gather with other websites or any other entities or individuals unless such sharing is disclosed to you in advance through this Privacy Policy. Other linked websites, however, may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the websites you may visit by linking from the site. Please note that this Privacy Policy applies only to our site, and not to other companies’ or organizations’ websites to which we link.
For instance, for processing credit card payments we use the external payment provider Paytrace. No credit card information is stored on NuStep’s systems. Paytrace will process personal data to handle payments on behalf of NuStep. Further information can be found in the Paytrace privacy policy at https://www.paytrace.net/privacy-policy/.
HOW LONG WE RETAIN YOUR INFORMATION
We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable law. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.
In some circumstances we may de-identify or aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. This allows the specific information collected (name, email, address, phone number, etc.) to become de-identified, but allows NuStep to keep the transaction or engagement data. For example, NuStep will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history. This will allow NuStep to maintain a level of information that helps us develop and improve our site and Services.
DO NOT TRACK
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. NuStep does not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available third-party tools, we offer you the choices described in this Privacy Policy to manage the collection and use of information about you.
NuStep does track some activity across websites (including your search terms, the website you visited before you visited or used the Services and other clickstream data) and we may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.
MARKETING AND PROMOTIONAL COMMUNICATIONS
You may opt-out of receiving marketing and promotional messages from NuStep, if those messages are powered by NuStep, by contacting us in writing and letting us know your specific opt-out request. If you decide to opt-out, you will still receive non-promotional communications relevant to your use of our Services.
SECURITY
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, no online or computer environment is 100% secure, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under Contact Us.
CALIFORNIA PRIVACY RIGHTS
California law permits residents of California to request certain details about our disclosure of your personal information by us to third-parties for direct marketing purposes during the immediate preceding calendar year. If you are a California resident please see the section titled “California Consumers Only” for an explanation of your rights.
This Privacy Policy may be revised from time to time as we add new features and Services, as laws change and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide advance notice on our site. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the site and Services constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the site immediately. If you have any questions about this Privacy Policy, the practices of the site or your dealings with the site, you can contact us by using the information provided under Contact Us.
CONTACT US
Please contact NuStep with any questions or concerns regarding this Privacy Notice.
NuStep, LLC
47700 Halyard Dr.
Plymouth, Michigan, USA 48170
833.687.8373
If you have any questions or concerns regarding our Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with NuStep using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.
CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights
Updated on June 29, 2023
This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose personal information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy. The terms “Website,” “online services,” and “Services” and any undefined terms will have the same meaning as defined in our Privacy Policy.
RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD AND SHARED
Information Collected
Within the past 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 to this Notice. To review these categories click here.
Business-to-Business (“B2B”) Information
If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, you have the same rights as other consumers set forth in this Notice with respect to the information we collect from you in that role. We collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information and communications consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. For more details see Annex 1.
Information Sold or Disclosed:
We share your data with third-party partners such as social networking sites and advertising companies in order to serve you with ads tailored to your preferences across various platforms. This type of sharing may be considered “selling” or “sharing” under the CPRA. You can control the information shared about you and request an opt-out as explained below.
We have sold or shared the following categories of personal information for a business or commercial purpose in the preceding 12 months.
- Internet Activity
We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding 12 months:
- Personal Identifiers
- Commercial Information
- Internet/Network Activity
- Biometric Information
- Financial Information
We do not knowingly sell the personal information of individuals under 16 years of age without affirmative authorization.
For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see Annex 1.
Requests to Know
You have the right to request that we disclose to you the following information about personal information we collect from you:
- categories of personal information collected;
- categories of sources of personal information collected;
- the business or commercial purpose for collecting or selling personal information;
- the categories of third parties with whom we share personal information; and
- the specific pieces of personal information we have collected about you over the past 12 months.
You also have a right to request that we disclose if we have sold or disclosed your personal information for a business purpose over the past 12 months and, if so, the categories of personal information sold or disclosed and the categories of third parties to whom personal information was sold or disclosed, along with the business or commercial purpose for which the personal information was sold or disclosed a (“Request to Know”).
To make a Request to Know, please submit a verifiable consumer request pursuant to the instructions below. You may only make a verifiable consumer Request to Know twice within a 12-month period. We will acknowledge your Request to Know within 10 days and will attempt to respond substantively within 45-90 days.
The Request to Know must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.
You can make a Request to Know what personal information we have about you in the following ways:
- You may make a request here: myprivacy@nustep.com
- You may make a request using this webform
- You may also make a request by phone by contacting us at 833.687.8373
Once we receive your Request to Know, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity.
RIGHT TO LIMIT USE OF SENSITIVE PERSONAL INFORMATION COLLECTED
We do not collect or process sensitive personal information for purposes of inferring characteristics or for any purposes other than those set forth in Regulations Section 7027(m). If you have questions about how we collect or use your sensitive personal information, please contact us at myprivacy@nustep.com.
RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION
Requests to Delete
You have the right to request the deletion of your Personal Information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.
To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below. You may only make a verifiable consumer Request to Delete twice within a 12-month period. We will acknowledge your Request to Delete within 10 days and will attempt to respond substantively within 45-90 days.
The verifiable consumer Request to Delete must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will notify you if this is the case.
A Request to Delete requires two steps: 1) making the Request to Delete and 2) confirming that you want your information to be deleted.
You can make a Request to Delete in the following ways:
- You may make a request here: myprivacy@nustep.com
- You may make a request using this webform
- You may also make a request by phone by contacting us at 833.687.8373
Once we receive your initial request to delete and your separate confirmation to delete, we will need to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. When making your request, you should be prepared to provide us with information that will help us to identify you.
We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.
RIGHT TO CORRECT
You have the right to request that we rectify inaccurate information about you.
To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below. We will acknowledge your Request to Correct within 10 business days and we will attempt to respond substantively within 45-90 days.
You can make a Request to Correct in the following ways:
- You may make a request here: myprivacy@nustep.com
- You may make a request using this webform
- You may also make a request by phone by contacting us at 833.687.8373
Once we receive your request to correct, we will need to verify that you are the person that is the subject of the request through the Verification Process.
We will review all information provided by you to us, to determine whether the information is inaccurate. We reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.
We will inform you of our decision to deny or grant your request.
We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.
RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION
You have the right to opt-out of the sale of your personal information. As explained in the chart in Annex 1 of this Policy, we and our third-party partners, such as social networking sites and advertising companies, share your data in order to serve you with ads tailored to your preferences across various platforms. This type of sharing may be considered a “sale” under the CCPA. You can control the information shared about you and request an opt-out. We will process your Request to Opt-Out within 15 days.
You can make a Request to Opt Out in the following ways:
- You may make a request using this webform
- You may make a request by contacting us at 833.687.8373
Opt-out Preference Signals
We honor opt-out preference signals that you enable, including a Global Privacy Control. Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use. If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal information without first seeking your explicit consent.
This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.
Cookies
As explained in our “Cookies” section, you can opt out of cookies using your browser.
Please Note:
- Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
- Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
- We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
- You may still receive ads from us that are not tailored to your interests.
ADDITIONAL OPTIONS TO OPT-OUT OF SALE
In addition to the above options to opt out of the “sale” of your information under the CCPA as described above, you have controls and choices with respect to collection and use of your information by third parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third party companies and are not responsible for their operation.
Advertising Opt-Out
You can opt out of sharing your information with third-party companies engaged in targeted advertising including social networking sites such as Google, Twitter and Facebook using the following tools: For websites: https://optout.aboutads.info. For mobile apps: http://www.aboutads.info/appchoices.
Google Opt-Out
You can opt out of Google Analytics by installing Google’s Opt Out browser add on: https://tools.google.com/dlpage/gaoptout. You can opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated.
Facebook Ad Preferences
To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.
RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS
You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act.
RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING
You can request access to information about automated decision making processes we use and you may request to opt out of certain automated decision making. We do not engage in automated processing.
RETENTION OF PERSONAL INFORMATION
Please see section above titled “How Long We Retain Your Information” for our retention policy.
AUTHORIZED AGENT INFORMATION
You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.
Authorized agents can make requests under the California Consumer Privacy Act by emailing us at email address: myprivacy@nustep.com. We will require authorized agents to provide proof of the consumer’s identity and proof of designation as an the authorized agent. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.
We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
Cal-OPPA COMPLIANCE STATEMENT
California Do Not Track Notice: Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow additional third parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above.
CALIFORNIA SHINE THE LIGHT DISCLOSURE INFORMATION
Although we do not disclose to any third parties for their direct marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:
Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the e-mail or mailing address specified below under “Contact Us.” If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.
CONTACT FOR MORE INFORMATION
For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at:
NuStep, LLC
47700 Halyard Dr
Plymouth, Michigan, USA 48170
833.687.8373
Changes to This Privacy Policy
This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.
SOCIAL MEDIA
We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by such third-party websites or to whom it is disclosed. You should review the privacy policies and settings on any social media website that you subscribe to so that you understand the information they collect and may be sharing. If you do not want your social media websites to share information about you, you must contact that website and determine whether it gives you the opportunity to opt-out of sharing such information. NuStep is not responsible for how these third-party websites may use information collected from or about you.
Further, our site may include social media features, such as the Facebook Like button. Our integration of these features may allow third-party social media to collect certain information, such as your IP address and which page(s) you are visiting when using our site and Services, and to set a cookie to enable that feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing it.