This privacy policy (“Policy”) describes how StepTribe (“StepTribe”, “we”, “us” or “our”) collects, protects and uses the information (“User Information”) you (“User”, “you” or “your”) may provide in the StepTribe mobile application and any of its services (collectively, “Mobile Application” or “Services”).
It also describes the choices available to you regarding our use of your User Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
Automatic collection of non-personal information
When you open and use the Mobile Application it automatically records the information which your device provides. This data may include information such as your device name and version, operating system type and version, language and region preferences, the information about your user-behavior in the app including access times and dates, and other statistics.
When it’s online, Mobile Application may send the collected data to our servers from time to time. Information collected automatically is used only to establish statistical information regarding Mobile Application work and usage. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
Collection of personal information
You can use the Mobile Application without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual.
We have no intention of collecting any personal data from our users. Nevertheless, we may receive some of your personal data through the app or other channels when you contact us with requests or share feedback about the app. In this case, we shall use your personal data only to respond to your messages and to fulfill your requests.
Storing information
We will retain and use your User Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your User Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, User Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
Use and processing of collected information
We use the collected information for our internal purposes only. We do not sell, lease, or otherwise share any data of our users to any third parties. The information we collect from you may be used for the following purposes:
- fulfilling your requests;
- work with your feedback on Mobile Application and Services;
- research and analytics;
- personalization of the app and improving user experience;
- ensuring the proper operation of Mobile Application and Services;
- further app development.
Processing your User Information depends on how you interact with our Mobile Application, where you are located in the world and if one of the following applies: (i) You have given your consent for one or more specific purposes; (ii) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) Processing is necessary for compliance with a legal obligation to which you are subject; (iv) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own.
The rights of users
You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your personal information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if personal information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your personal information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your personal information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your personal information from us; (vii) you have the right to receive your personal information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
How to exercise these rights
You can request to receive an exported copy of all the collected data about you as well as a request to delete all the collected data about you directly through Mobile Application by selecting the appropriate option in the settings menu. Any other legitimate requests to exercise User rights can be directed to StepTribe through the contact details provided in this document. These requests will be exercised by StepTribe free of charge as early as possible but not longer than in 30 days.
Privacy of children
We do not knowingly collect any User Information from children under the age of 13. If you are under the age of 13, please do not submit any User Information through our Mobile Application or Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide User Information through our Mobile Application or Service without their permission.
If you have reason to believe that a child under the age of 13 has provided User Information to us through our Mobile Application or Service, please contact us. You must also be at least 16 years of age to consent to the processing of your User Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).
Third-party vendors and links to other mobile applications
We use third-party vendors to perform certain services on behalf of us, such as hosting, analytical or other services, and such third-party vendors may collect or have access to information about you. Within the foregoing, we use Google Firebase and Google Analytics to collect and analyze some parts of User Information, so you should be aware that your data may be collected by Google who may combine it with other information you’ve provided to them or they’ve collected from your use of their services.
Our Mobile Application may contain links to other mobile applications that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other mobile applications or third-parties. We encourage you to be aware when you leave our Mobile Application and to read the privacy statements of each and every mobile application that may collect User Information.
Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of User Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your User Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Mobile Application cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.
Data breach
In the event we become aware that the security of the Mobile Application has been compromised or User Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice in the Mobile Application.
Legal disclosure
We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Changes and amendments
We may update this Privacy Policy from time to time in our discretion and will notify you of any material changes to the way in which we treat User Information. When changes are made, we will post a notification in our Mobile Application. We may also provide notice to you in other ways in our discretion. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Mobile Application or Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your data in a manner materially different than what was stated at the time your data was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Mobile Application or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Mobile Application and its Services.
Contacting us
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your User Information, you may send an email to info@steptribe.io
This document was last updated on July 15 2020.