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PRIVACY POLICY

Welcome aboard!

So, you have downloaded our Steppi platform and are starting to use the Steppi APP and all its functionalities! Any information you share with us (e.g. for creating a Steppi Account) will help us to provide you with services related to Steppi platform and to improve them to make them even better. We explain here our ways of collecting and using information, and how we protect your privacy. In this privacy policy, "personal data" means information that can be used to identify an individual, either from that information alone or from that information and other information we have access to about that individual. We collect both personal and non-personal data to enable and facilitate the best user experience possible.

What information is collected and how do we use it?

Types of Personal Data Collected

  • In order to provide our services to you, we will ask you to provide the necessary personal data that is required to provide those services. If you do not provide your personal data, we may not be able to provide you with access to our platform.
  • Set up and log in of Steppi Account. Personal data that are collected for creating a Steppi Account may include your personal email address, work email address or mobile phone number, device-related information (e.g. IMEI number) and various location related information (e.g. location area code, mobile network and country codes).
  • Activating your Steppi account. When you activate the Steppi platform, we may collect your age, height, weight and gender. We may also collect other details you provide as part of your profile such as your birthday, picture and signature.
  • Sharing your content. When you share content or send information to family and friends, we may collect personal information of those people, such as their names, email addresses, telephone numbers, and mailing addresses (if we need to send a product to them). You hereby represent and warrant that you have obtained necessary consent for use of third parties' personal data if you choose to provide them to us. When you share content or invite users to use Mi Fit, please note that other users may see the personal data you share.

How Personal Data is used

  • To develop the Steppi platform, together with general and statistical information
  • To communicate with you, including providing you with notifications on the platform that are updated or launched.
  • To provide marketing and promotional materials to you on our platform. (please note that you may unsubscribe anytime)
  • To personalize product design and to provide you with services tailored for you, for example, recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in challenges.
  • To conduct investigations regarding our platforms.
  • If you participate in our challenges, we may use your personal data to manage such activities.

Other Information

We use statistical data that does not specifically identify you (non-personal data) to help in our platform and provide a better user experience for you. Here are some of the non-personal data we may collect and how we use them:

  • When you create a Steppi Account, download our platform, participate in online surveys or interact with us in other ways, we may collect your language preferences, in the platform
  • When you opt-in to participate in our Challenges, we may gather statistics relating to your use of our challenge, on an anonymous basis. If there is an abnormal shutdown or breakdown, we may collect information relating to your mobile device to diagnose the problem.
  • When you use our services or functions that are based on location information, e.g. carry out a location search, take advantage of advertising, use weather functions, access information based on maps, etc., we may collect your geographical information.
  • When you use our platform, email messages and advertising, we may use cookies and other technical elements (e.g. pixel labels) to collect and store non-personal data. These enable us to provide you with a better experience and improve our overall service quality, e.g. in saving your preferred language settings, sending emails in a readable format, to determine whether the emails have been opened or not, etc.

You have control over your information!

We recognize that privacy concerns differ from person to person. Therefore, we provide examples of ways we make available for you to choose to restrict the collection, use, disclosure or processing of your personal data and control your privacy settings.

Who do we share your information with?

Unless we tell you in this privacy policy, we will keep your personal information confidential. We may disclose your personal data on occasion to third parties in order to provide the products or services that you have requested. Some of these third parties may be located outside your home country.

Disclosure may include the scenarios listed in this section below. In each case described in this section, you can be assured that Steppi will only share your personal data in accordance with your consent. You should know that when Steppi shares your personal data with a third party under any circumstance described in this section, Steppi will ensure that the third party is subject to practises and obligations to comply with the relevant data protection and privacy laws of your country. Steppi will contractually ensure compliance by any foreign Third-Party Service Providers with the privacy standards that apply in your home jurisdiction.

Information Not Requiring Consent

We may share anonymized information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, or we may tell our business partners the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

For the avoidance of doubt, if we are permitted by law to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.

Information Safety Safeguards

We are committed to ensuring that your personal data is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect. We have put in place the following security procedures and technical and organizational measures to safeguard your personal data:

  • Your personal data is stored on secure servers that are protected in controlled facilities.
  • All data saved in the back end is classified into different levels based on the importance and sensitivity of the data, e.g. whether the data contains personal data.
  • In the data centres, clusters that contain sensitive data are grouped together in the network topology and will be placed in rooms with additional physical security protection.
  • Data exchanged between Steppi platform and servers are encrypted using Secure Sockets Layer ("SSL").
  • There is a regular review of information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
  • Access is restricted to Steppi employees and Third-Party Service Providers who need to know that the information in order to process it, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations.
  • There are also access controls for all server clusters used for cloud-based data storage and process.
  • Most data used for Steppi platform is stored in a storage system.
  • Please note also that for the above, Steppi may use overseas facilities operated and controlled by Steppi to process or back up your personal data. However, this does not change any of our commitments to safeguard your personal data in accordance with this Privacy Policy.
  • Information safety is very important to us. We will take all practicable steps to safeguard your personal data. Through our protective measures above, especially encrypted storage and transmission, your data is as secure as it can be. Certain details of encrypted data cannot be accessed by anyone except by you.

When this Privacy Policy applies

Our Privacy Policy does not apply to services offered by a third party. The Steppi platform may include a third party's products or services. When you use such services, they may collect your information too. For this reason, we strongly suggest you read the third party's privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal data which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

Minors

We consider it the responsibility of parents to monitor their children's use of our products and services. Nevertheless, it is our policy not to require personal data from minors or offer to send any promotional materials to persons in that category. Steppi does not seek or intend to seek to receive any personal data from minors. Should a parent or guardian have reasons to believe that a minor has provided Steppi platform with personal data without their prior consent, please contact us to ensure that the personal data is removed and unsubscribe them from the Steppi platform.

Updates to the Privacy Policy

We keep our Privacy Policy under regular review. If we change our Privacy Policy, we will post the changes on the platform, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the time that we post the same on the platform. Your continued use of the platform on mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal data from you or when we wish to use or disclose your personal data for new purposes.