Privacy Policy

This Privacy Policy explains how 100 Steps 2 Startup Inc. (“us” or “we”) collects, uses, discloses, stores, safeguards and retains your Personal Information. If you do not agree to the terms of this Privacy Policy, you may not use our website, services or products.

Personal Information

“Personal Information” means information, other than business contact information, about an identifiable individual. You should exercise discretion when disclosing your Personal Information to us, and should not disclose sensitive or confidential information that you wish to remain private. We will keep Personal Information that you provide to us private, and will disclose such Personal Information only in accordance with this Privacy Policy.


This Privacy Policy applies to Personal Information that we collect when you use our website or services, and to public Personal Information that we collect from third party websites. This Privacy Policy does not apply to the practices of companies or other entities that we do not own or control, or to people that we do not employ or manage. Any Personal Information you supply, or authorize us, implicitly or explicitly, to supply to any third parties is governed by the privacy policies of those third parties.

Collection and Use:

We will collect and use your Personal Information in connection with the provision of products and services from our website including: (i) delivery of the services, (ii) carrying out the transactions you have requested, (iii) for billing purposes, (iv) in order to communicate with you about new products and services, promotional offers, and surveys to improve the services, and (v) to prevent fraud and other prohibited or illegal activities. We may use your Personal Information, in conjunction with information available from third parties, to provide the complete functionality of our services.

When you access the Internet, the computers that host websites you visit (“servers”) automatically receive some anonymous information. This “usage data” may include a record of which web pages a web browser has visited. We may use usage data to provide advertising about goods and services that may be of interest to our customers, or to provide customized features and services.

We and our advertisers may use various kinds of software devices to collect information about Internet use. Small files called “cookies” may be attached to your web browser. These files identify your browser and save information such as user IDs so that we servers can track web browsers. We use cookies to enable you to sign in to our services and to store your preferences and other information on your computer. You can set your browser to disable cookies, but our website may not work properly if you disable cookies.

We may elect to use third party advertising companies to advertise on our website, and in these instances may use a software technology called clear gifs (a.k.a. web beacons/web bugs/action tags/pixel tags) to better manage advertising on our website. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. Clear gifs may ping or alert the advertiser’s server about the online movements of web users. Web beacons help us measure the effectiveness of our website and our advertising. Web beacons also help us measure the effectiveness of our e-mail campaigns. The information collected may include some limited Personal Information, and web beacons allow us to recognize users by accessing cookies. We may also combine the information that we collect through web beacons with other Personal Information that has been collected from you. All this information is used to better tailor our advertising and promotions to you. We also use web beacons in conjunction with one-to-one marketing e-mails sent by our users to enable them to better track the effectiveness of such e-mails.

We may permit third parties to compile individual information or aggregated statistics from our use of web beacons to enable such third parties to determine the effectiveness of online marketing and to allow such third parties to develop purchasing or other statistics on the advertiser’s site. All aggregate statistical information is anonymous. We do not share any Personal Information with such third parties. We do not allow web beacons on our Website to be used by third parties to access your Personal Information.


We may share your Personal Information with our corporate affiliates to carry out transactions that you request or to make our business, or that of our corporate affiliates, more responsive to your needs. We will not sell, trade, or disclose to third parties any Personal Information derived from the registration for, or use of, our online service — including customer names and addresses — without the consent of the customer.

We may share your Personal Information with third parties we engage to provide products and services on our behalf, or to third parties on whose behalf we collect your Personal Information. However, we will not sell or loan your Personal Information to third parties unless we ask for your prior permission. We will also not disclose your Personal Information to third parties for the purposes of the third party marketing products to you.

We may disclose your Personal Information: (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule or regulation (including privacy laws, rules and regulations); (b) in response to a court order, subpoena, discovery request or other lawful judicial or administrative proceeding; (c) as otherwise required by any applicable law, rule or regulation; and (d) in good faith, to protect or defend our rights or property, or the rights or property of other customers or users.


We have implemented reasonable technology and security features and policy guidelines appropriate to the sensitivity of the information to safeguard the privacy of your Personal Information from unauthorized access or improper use.

E-mail Contents:

We will not read or disclose to third parties private e-mail communications that are transmitted using our services except as required to operate the service or as otherwise authorized by law.

Account Information:

Your Personal Information is available to you in your profile that you created when registering as a user. Such information is available to you at any time to validate or correct errors. It is your responsibility to maintain the accuracy of your Personal Information. Any inaccuracies should be immediately corrected on your profile or reported to our Privacy Officer.

Data Retention

We will keep and retain your Personal Information for as long as your account is active with us or as long as required to provide services to you. We will also retain Personal Information in compliance with our legal obligations. Your Personal Information will be retained only as long as necessary for the purposes for which it was collected.

Withdrawal of Consent

You may withdraw your consent to the collection, use and disclosure of Personal Information about you at any time. To do this, please contact our Privacy Officer. Withdrawal of your consent to the collection, use and disclosure of your Personal Information will result in you being unable to continue use of our website or services.

Privacy Officer:

If you have any concerns about our on-line Privacy Policy or its implementation, you may contact our Privacy Officer at

Changes in Practices:

We may change the terms of this Privacy Policy at any time. We will inform you of any changes that we make by e-mail.

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