Privacy Policy

Information by Steam-A Private Limited regarding personal data processing

Your privacy is important to us. We have taken all the necessary organizational and technical measures in order to process your personal data in a manner that is lawful, appropriate, and transparent. In this privacy statement by “STEAM-A” Private Limited Company, we explain which of your personal data we will process, for what purposes and on what grounds, to whom we could provide them, and for how long we will store them.

We recommend that you read this information carefully so that you know more about the manner of processing of your personal data as a client, potential client, related party to a client of ours, counter party, contact person, representative of a legal entity, or any other interested party. Regardless of what are the purposes and the grounds on which we process your personal data, STEAM-A will treat your data with equal care. This document also contains information about your rights and the manners in which you can exercise them.

STEAM-A may update this privacy statement and its most recent version will be available at steam-a.com. “STEAM-A” Private Limited Company will inform you of all material changes to its terms via its website or other communication channels.

1. About the company

Steam-A Private Limited have their registered office at 2/92 A-6 Thennampalayam-Annur Road, Arasur (PO), Coimbatore, Tamil Nadu 641407.

For questions related to the processing of personal data, please contact us by e-mail at talkto@steam-a.com.

Steam-A in its capacity of a Personal Data Controller conducts its activities in strict adherence to prevailing industry best practices and legal requirements on personal data collection and management.

Steam-A is a controller with respect to the personal data of its clients but also a personal data processor of data provided by its counter agents for the purpose of execution of respective contractual obligations, whereas in the second case Steam-A strictly follows the controller’s instructions in carrying out this activity.

2. Definitions

“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, a personal identification number, location data, gender, address, telephone number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing of personal data” is any operation or set of operations which is performed on personal data whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

3. Rights of data subjects

In the cases when you are exercising your rights as a data subject, it would be necessary for you to make a detailed description of your request in the application submitted to Steam-A. When exercising your rights, Steam-A will need to verify your identity so as to avoid anyone else trying to impersonate you. For this purpose, we may require an ID card or other identification document when providing you with the information you request.

You may ask in writing various questions about the processing of your personal data by Steam-A, electronically at the e-mail indicated above. We answer requests within one month.

If you are not satisfied with our response, you have the right to complain to the data protection authority where you live or work:

• United Kingdom – Information Commissioner’s Office (ICO), ico.org.uk
• Netherlands – Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl
• Elsewhere in the EU – the supervisory authority of your country.
• India – the Data Protection Board of India, once it is established under the Digital Personal Data Protection Act, 2023. In the meantime, write to us at the address above.

In the cases when Steam-A has received your personal data from third parties, e.g. your employer is processing them for its own purposes, you may file a complaint against the actions of these third parties directly to them.

The exercise of your rights can not be opposed to the provision of your personal data to the competent authorities for the prevention, investigation, and detection of criminal offences.

If you are a person whose personal data is processed by STEAM-A under the General Data Protection Regulation, effective since 25.05.2018, you have the following rights:

• Right to access – Upon your request, as the data subject, STEAM-A shall provide information about the categories of the personal data relating to you, which are being collected and processed by us, and information about the purposes of the processing, the recipients, or categories of recipients to whom your data are disclosed and the sources of this data, except the cases when the data was collected directly from you.
• Right of rectification, blocking (restriction of processing), and/or erasure (deletion) – Upon your request, STEAM-A shall correct, erase or cease the processing of your personal data. In such cases, STEAM-A shall notify all third parties to whom your personal data has been disclosed regarding all rectifications and erasures that have been made or all cases of restriction of processing of your personal data.
• Right to data portability – As a data subject, you have the right to request to receive the personal data concerning you, which you have provided to STEAM-A, in a structured and commonly used and machine-readable format and you have the right to transmit/transfer those data to another Controller without hindrance from STEAM-A as personal data controller, to whom the data was provided, where the processing is based on consent or on a contract or the processing of your personal data is carried out by automated means.
• Right to object – As a data subject, you have the right to object to the processing of your personal data when the processing of personal data is based on Steam-A’s legitimate interest. Steam-A shall review your objection and shall provide its opinion in writing within 30 days unless this term needs to be extended, for which we will notify you in due time. After reviewing the objection, Steam-A will generally discontinue the processing of your personal data and will notify all interested parties to whom the personal data has been submitted of the objection received and of the measures taken in this regard. In some cases, however, Steam-A has an indisputable legal basis to continue the processing of your personal data even after receiving your objection (for example, in cases of unsettled contractual relations, lawsuits etc.). In such cases, Steam-A will contact you to clarify the reasons why it will continue to process your personal data. If your objection concerns the processing of personal data for direct marketing, Steam-A will suspend unconditionally the processing of your personal data for that purpose.

4. Types of processed personal data

Steam-A may process different types of personal data related to your physical, social or economic identity. Such data may be obtained from you as the data subject or from third parties.

Steam-A may process some or all of the data categories listed below in order to achieve the purposes described below, only if it has a good reason to do so.

• To identify you: full name; permanent address (street, number, post code, city, country); current address (street, number, post code, city, country).
• To contact you: phone number (mobile/fixed); email address; address (street, number, post code, city, country).

Steam-A sometimes processes public information such as from official public registers, which are responsible for keeping this information legally, or purchases it from companies that are responsible for the lawful collection of personal data.

Such public data may be processed for the purposes listed by Steam-A in this document.

5. Recipients of personal data

Personal data is generally processed by the employees of Steam-A. The processing of personal data may also be carried out by personal data processors with whom Steam-A has signed a contract for this purpose. Where there is a legitimate reason, personal data may be provided to other administrators to use for their legitimate purposes.

6. Purposes of personal data processing

Steam-A collects personal data for the following purposes:

• To provide, personalise, maintain and improve our products and services, and enable features to personalise your Steam-A account;
• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the relevant information and services;
• To administer and enhance the security of our platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To provide you with information about services we consider similar to those that you are already using, or have enquired about, or may interest you. If you are a registered user, we will contact you by electronic means (e-mail or SMS or telephone or other internet based instant messaging systems) with information about these services;
• To understand our users (what they do on our Services, what features they like, how they use them, etc.), improve the content and features of our Services (such as by personalizing content to your interests), process and complete your transactions, make special offers, provide customer support, process and respond to your queries;
• To generate and review reports and data about, and to conduct research on, our user base and Service usage patterns;
• To allow you to participate in interactive features of our Services, if any; or
• To carry out research with our partners.

7. Legal bases for processing

Under the UK and EU General Data Protection Regulation we process personal data only where one of the following applies:

• Your consent – for analytics cookies and campaign measurement (section 9), and for marketing emails where you ticked the box on one of our forms. You can withdraw consent at any time, and withdrawing it does not affect processing carried out beforehand.
• Steps taken at your request before entering into a contract – when you ask us for a demo, a white paper or a quotation, we use your details to respond.
• Performance of a contract – to deliver and support the Iris platform for our customers.
• Our legitimate interests – to run and secure our website, to understand how it is used, and to contact business representatives about products related to those they enquired about. We balance those interests against your rights, and you can object at any time (section 3).
• Legal obligation – where the law requires us to keep or disclose records.

8. Term of storage of personal data

Steam-A shall use your personal data only when Steam-A has a clear purpose in mind. Personal data cannot be kept for longer than it is necessary for the purpose(s) for which such personal data is used.

• Enquiries and white paper downloads – kept in our CRM while we are in contact with you and for up to 24 months after our last contact, unless you ask us to erase them sooner.
• Marketing consent and unsubscribe records – kept for as long as we send you marketing, and afterwards only as a record that you opted out.
• Customer and contract records – kept for the duration of the contract and for as long as the law requires afterwards, typically for accounting and tax purposes.
• Website analytics – as set out in section 9.

The term may be longer where this is necessary for us to establish, exercise or defend legal claims.

9. Where your data is processed

Steam-A operates from India, the United Kingdom and the Netherlands, and our staff in those countries may access your data. Our CRM (Freshworks) and our website hosting (Amazon Web Services) also process data outside your country.

Where personal data is transferred out of the United Kingdom or the European Economic Area, we rely on the transfer mechanisms permitted by the UK and EU GDPR, such as the European Commission’s standard contractual clauses together with the UK addendum. You can ask us for details of the safeguards that apply by writing to talkto@steam-a.com.

10. Cookies and similar technologies

This website stores a small amount of information in your browser. Analytics cookies and campaign attribution are only used if you accept them in the cookie banner. You can change your choice at any time: open cookie settings. If you withdraw consent, we delete the analytics cookies and stored attribution from your browser.

Without consent, Google Analytics may receive cookieless signals (such as a page view) that do not identify your browser. We do not use advertising or remarketing cookies.

11. Services used on this website

• Freshworks (Freshsales CRM) – the contact and white paper forms send the details you enter, the page you submitted from and, if you accepted cookies, the campaign that brought you to the site, to our CRM so we can respond to you.
• Google Analytics – website usage statistics, as described in section 10.
• Amazon Web Services – hosts this website and our downloadable white papers.
• Content delivery – some files are loaded from other providers: blog images (Sanity), map tiles (CARTO), animations (LottieFiles) and the software behind the phone number field in our forms (jsDelivr). Like any web server, they receive your IP address when your browser loads their files. We do not use them to track you.