Tredstep Privacy Statement

This is the Privacy Statement of Tredstep Ireland Ltd.

Tredstep respects the privacy of all users of our website (i.e. our desktop and mobile sites) and Tredstep social media pages. This Privacy Statement outlines our policy concerning the collection and use of personal information which is gathered by Tredstep from users of this website and Tredstep social media pages.

The aim of this privacy policy is to explain how Tredstep collects and uses the personal information it gathers in this way. Tredstep will ensure that it keeps all personal information you provide to us in accordance with our obligations under current Data Protection legislation.

We may update our Privacy Statement from time to time to reflect any changes in technology, legislation or our data use practices which may affect the way in which we process your personal information.

Tredstep is not responsible for the privacy practices of any external websites and platforms which may be accessed or used in connection with your use of our website or Tredstep social media pages and so we would advise that you review the privacy statements of those websites and platforms as they may be subject to different privacy requirements.

Any processing of personal information gathered by Tredstep as a result of your use of this website, Tredstep social media pages or our apps is governed by the provisions of the Irish Data Protection Acts 1988 and 2003.

What personal information does Tredstep collect and use?

Competitions: When you enter a competition, Tredstep may collect and use your name, and your contact details (e.g. postal or email address / mobile number) in connection with the competition.
Tredstep Newsletter Sign In: If you create an Tredstep Sign In account, we may collect and use your name, contact details, gender, IP address, browser, operating system and device (including its location) you used and details regarding your website, Tredstep social media pages (e.g. pages time / date of pages visited / actions taken) to provide you with extra benefits like personalisation of Tredstep News content, email updates on content relevant to you, and exclusive competitions.  We may also sometimes track who opened and clicked the links in the communications that we send so that we can measure a campaign’s success. If you’ve signed up to Tredstep, we may combine your account information with information we collect about you using cookies, web beacons, device identifiers etc.  If you want to control the use of cookies etc., see the Tredstep Cookie Policy. See our specific Tredstep Privacy Statement for more info.
Marketing: If you sign up for marketing communications we may also collect, use and combine similar information for the purposes of marketing, including through the use of cookies, etc. For example, we may combine your account information with information we collect about you using cookies, web beacons, device identifiers etc. (including your device’s location). We may also sometimes track who opened and clicked the links in the communications that we send using technologies so that we can measure a campaign’s success. See “How do you use my information for marketing purposes?” below and our Tredstep Cookie Policy for more information in this regard. If you want to control the use of cookies etc., see the Tredstep Cookie Policy.

Purchases: If you purchase anything from Tredstep retailer, we may collect and use details of your method of payment and your address, in addition to your contact details to process your purchase.

Social media pages: If you post content on social media pages controlled by Tredstep, this information may be made publically available and used in connection with the operation and promotion of our social media pages and Tredstep.  Your posted content may be removed.

Cookies and Web Beacons etc.: Tredstep.com uses cookies, web beacons and similar technologies: these are small text files placed in your computer, tablet, mobile or other device. These technologies may collect your device identifier (IDFA), play data (e.g. how long you spend streaming), app usage, IP address or other information. They may also be used to recognise when your device visits a particular website or app or clicks on a particular link on Tredstep and others’ websites and apps or when you open emails we send you, or links in them. Tredstep’s policy concerning the use of cookies etc on Tredstep.com is outlined in the Tredstep Cookie Policy. This explains how you can control the use of cookies etc.

We will ensure that all personal information supplied is held securely, in accordance with the Data Protection Acts 1988 and 2003.

How do you use my information for marketing purposes?

We and our trusted partners will not use your information to contact you by email, phone or SMS for direct marketing or promotional purposes unless you specifically agree to be contacted for such purposes at the time you submit your information to us, or at a later time if you sign up specifically to receive such promotional information. We will not provide your information to third parties who may contact you for direct marketing or promotional purposes unless you have consented to us giving them your information for that purpose.

If you sign up to marketing communications from Tredstep, we may send you information about our products and services which we think may be of interest to you including our monthly newsletter.  In this case, we may build up a profile of you based upon what we infer from your usage of the different pages of our website, e.g. by using your Tredstep Sign In account information and combining it with information we collect using your IP address, cookies, web beacons, SDKs, device identifier, and play data (e.g. what you stream and how long you spend streaming) etc., including the location of your device.  For instance, we may use some categories of information (including interest groups, year of birth, gender and region) to tailor the information we send to you. We do this so that we send you content you’re interested in, instead of unwanted and irrelevant stuff.

We carefully selected iContact to help us deliver email marketing communications.  iContact has the TRUSTe’s Privacy Seal – TRUSTe is an independent third party that operates a globally recognized privacy trustmark. It is also registered with the Safe Harbor Framework which is overseen by the US Department of Commerce. You should read iContact’s privacy policy for more information as you agree to this, and the transfer of your information to iConatct, when you sign up to marketing communications from us.

When you sign up to marketing communications, we’ll normally contact you by email, but we may send you marketing texts also if you’ve given us your mobile number for this purpose. If you have just signed up to in-app push notifications, we’ll only send you in-app push notifications.

If you sign up to marketing communications from our trusted partners, we may provide your name and contact details you gave us for marketing (e.g. email or mobile number) to our trusted partners (such as relevant retailers) so that they can send you marketing communications.

If you opt-out from communications from our trusted partners, we won’t share your contact details with them any more. However, you’ll still need to directly opt-out from communications from the trusted partners to whom we have already given your information. You can stop us sending you in-app push notifications through your device settings.

What if I am under 18?

If you are aged 18 or under please ask your parent or guardian for their permission to provide us with your contact information.

Do you pass any personal information to third parties?

We use a service provider for email marketing communications.  When people use Tredstep website, the order may be processed by a service provider who is contracted to Tredstep. The service provider is under a contractual obligation to keep personal information for the purpose for which it is intended and not to pass on any personal information to any third parties.

Equally when members of the public vote in competitions the processing of the vote is contracted out to service providers. We may also use other services providers in some cases.  These service providers are also under a similar contractual obligation.

We will not provide your information to third parties who may contact you for direct marketing or promotional purposes unless you have consented to us giving them your information for that purpose.

Do you transfer any of the information collected abroad for other purposes?

Tredstep does not generally transfer any personal information abroad.

However, in some cases we may use carefully selected service providers to perform certain functions which may be located outside of Ireland. For instance, where you have signed up for marketing communications, you have agreed to the transfer of your information to our email service provider which is located in the US.   These service providers are bound by a contract with us.

How can I request a copy of my personal information held by Tredstep?

Any individual has a right to make an access request, in writing, under Section 4 of the Data Protection Acts for a copy of their personal data held by Tredstep.  We will clarify in response to your request the exact Tredstep entity that is the data controller in respect of your personal data.

Tredstep may ask for further identification information before the information is released to you.

Tredstep has 40 days to comply with the access request, subject to the provisions of the Data Protection Acts. It should be noted that under section 21 of the Data Protection (Amendment) Act 2003 there are specific exemptions relating to personal information held for journalistic, artistic and literary purposes.

If members of the public wish to see what personal information Tredstep may hold on them, please write to:

General Manager,

Tredstep Ireland Ltd.

Spruce Lodge, Kilternan,

Dublin 18, D18 K004

Ireland.

General information on Data Protection is available from the Office of the Data Protection Commissioner’s website to you.