StepsLife Privacy Policy

 

Last Updated: 5th January, 2017

Welcome to the StepsLife Privacy Policy ("Policy").  This describes how we collect, store, use, protect and share your information and with whom we share it.  We suggest you read this in conjunction with our Terms of Use for our mobile application ("App") of which this Policy is part. 

This Policy applies to persons anywhere in the world who use our App and the Service (as defined in our Terms of Use).  You agree that we can collect, transfer, store, disclose and use your information as described in this Policy. StepsLife is owned and operated by STEPS LIFE, S.L. You as User are solely responsible for use of the App and the StepsLife service and the processing of personal data associated with your account, which includes, among others, collecting, storing and sharing personal data uploaded by you and your Invited Users. StepsLife automatically implements the instructions given by you and you are solely responsible for those instructions (such as recording or sharing images).

You warrant that (a) you have informed any third party whose image or voice or other personally identifiable data is recorded through the App who is 14 years old or more that the StepsLife App and Service processes his/her data and that you have obtained authorisation from such persons for this kind of activity, as provided herein or (b) there are mandatory rules in your country would exempt you from the aforementioned obligations. You agree to fully comply with this Privacy Policy.

 

I.      Information We Collect.

There are four basic categories of information we collect:

á       Information you give us.

á       Information obtained from your use our Service.

á       Information obtained when making payments

á       User Content

HereÕs a little more detail on each of these categories.

A.      Information You Give Us (Registration Data)

We collect information that you provide us when you register for an Account and use the App.  For example, most of our services require you to set up a basic account, so we will need to collect a few details about you. We collect certain information about you:

á     Name;

á     Email address;

á     Password

á     Gender;

á      Login information as well as other information you identify on our App.

 

The aforementioned data is obligatory in creating an account and you will not be able to register for an account or access and use the Services if you do not provide us with such Registration Data.

 

B.      Information Obtained From Your Use of Our Services (Usage Data)

We collect additional information in connection with your use of StepsLife.  We record the data analytics regarding your use of the Service, e.g. whether you looked at a certain content, shared content, or saw a specific video for a period of time.  This is a more complete picture of the types of information we obtain:

á       Traffic Data.  When you visit our App, we automatically track and collect the following categories of information: (1) your Internet protocol address and domain server address; (2) the date and time of your visit our App; (3) the type of system you used to access the App; and (4) the pages that you accessed during your use of the App; (collectively, "Traffic Data").

á       Usage Information.  Such as how you interact with the services and other users, which videos you watch, or which questions you submit; how you communicate with other users, such as their usernames, the time and date of your communications, the number of questions you post, which videos are being answered, your interactions with messages (such as when you open a message or capture a screenshot).

á       Information Collected by Cookies and Other Technologies. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with services we offer through one of our partners. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our services. For more details on our cookie usage, please see our cookie policy at http://steps.life/cookie-policy

C.    Payments 

Your data relating to your payment by credit for the use and access of the Service is collected as follow:

1.     App Stores: payment data collected through in-app purchase are collected by the applicable app store (iTunes Store or Google Play) and according to its applicable terms of use.

a.     iTunes Store: http://www.apple.com/legal/internet-services/itunes/us/terms.html

b.     Google Play: https://play.google.com/about/play-terms.html

2.     Online Payment: Your payment data is not collected by us but processed by our payment provider Stripe Inc., and this data is processed according to their terms of use, which are available at: https://stripe.com/es/legal

 

We do not have access to your full credit card data (only abbreviated data to verify payment), which will be processed by the payment gateway provider in accordance with its terms. You warrant that the credit card data is yours and that you have the authorisation to provide this data and use the credit card for making payments.

 

D. User Content (User Data)

On your behalf, as a principal function of the service, we collect and process personal data relating to you and your family provided by you and/or your Invited Users as Content (as defined in the Terms) in accordance with the provisions set out below.

 

II.     Uses Of Information Collected (other than User Content).

A. We use the Registration Data to:

-       Provide, maintain, and improve our Service, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to users, authenticate users, and send product updates and administrative messages;

-       Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to test, analyze, conduct data analysis, and to monitor and analyze usage and activity trends;

-       Send you commercial communications we think will be of interest to you Ð you may opt out of these by sending us an email to help@steps.life with heading Ònewsletter opt outÓ or the unsubscribe feature on each communication;

-       We may share Registration Data with third parties, particularly public authorities, to comply with laws.  We may share this information to respond to lawful requests and legal processes, and also for emergency purposes and we will notify you unless otherwise prevented by law.

-       We may share Registration Data when necessary protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use. We will previously notify you of this (including the recipient) unless otherwise prevented by law.

 

B. Usage Data

We use Usage Data to evaluate and improve the content of the App and Service and to make the App and Service more useful to users. We also use it to diagnose problems with our server, to keep our server running smoothly, and to monitor the number of users and visitors to the App / Service and the type of technology they use.

We use cookie data to as set out in our cookie policy.

C. Payment Data

This data is only collected to process payment for subscriptions.

D. User Data

We process User Data on your behalf in accordance with your instructions and the service configuration and features as set out hereunder in Section VIII.

III.        Information Choices and Changes.

A.    Our marketing emails tell you how to Òopt-out.Ó If you opt out, we may still send you emails regarding management of the Service. Non-marketing emails include emails about your accounts and our business dealings with you.

 

B.    You may send requests about personal information to our contact email below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.

 

C.    The services may also contain third-party links and search results, include third-party integrations, or offer a co-branded or third-party-branded service. By going to those links, using the third-party integration, or using a co-branded or third-party-branded service, you may be providing information (including personal information) directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. As always, we encourage you to review the privacy policies of every third-party website or service that you visit or use, including those third parties you interact with through our services.

 

IV.       Messages from Us.

We may send you periodic announcements including the details of our existing and new programs.  You may opt out of these announcements by contacting help@steps.life or by clicking the opt-out link at the bottom of these emails. If you opt out of these marketing emails, you may still receive system notices and other information that is specifically related to your account. 

 

 

 

V.         Our Commitment to Data Security. 

 

We take certain measures to protect the transmission of sensitive end-user information.  We make reasonable efforts to ensure the integrity and security of our network and systems in accordance with applicable law. Nevertheless, we cannot guarantee that our security measures will prevent hackers from illegally obtaining this information.  Given the resourcefulness of cyber-criminals we are unable to guarantee that our security is completely without security holes. 

 

In the event of any security breach affecting your data, we will notify you in accordance with applicable law.

 

VI.        How to Access or Modify Your Information And Privacy Updates.

 

A.    We offer our Users the opportunity to access or modify information provided during registration.  To access or modify such information, please configure your account. If you have any problems, please contact us at help@steps.life.

 

B.    We may change this privacy policy. If we make any changes, we will notify you and change the Last Updated date above. If you do not accept these modifications, you may cancel your account and retrieve your Content within 30 days, in accordance with our Terms and Conditions. Modifications will take effect once you use the Service after being notified of the change or you otherwise accept the changes.

 

 

VII.       Where to Direct Questions About Our Privacy Policy.

 

A.    If you have any questions about this Policy or the practices described herein, you may contact us at help@steps.life.

 

B.    We welcome your comments or questions about this privacy policy. You may also contact us at our address:

 

STEPS LIFE, S.L.

Carrer Vallespir 19, 4-1

08173 Sant Cugat del Valles (Barcelona)

SPAIN

 

 

VIII.      Data Processing on your Behalf: StepsLife as Data Processor.

 

  1. User Data. Once you have created an Account, you and your invited Users may start to upload content to the Services, which may include personal data relating to you, or to third parties (User Data). In accordance with applicable privacy law, to the extent that it applies to the Services, you are the Data Controller of this User Data and you appoint us as a Data Processor of such data for the purpose of providing the Services.

 

  1. Your use of User Data. As Data Controller, you warrant that you have the appropriate authority to collect and process the User Data and you agree to record and process and use the User Data in accordance with this Privacy Policy, the Terms and applicable law, and only for the explicit purposes of the Services. You will not submit to the Services any personal data relating to any individual that has not authorized such processing, when such authorization is required. Through the Services, you may also access the User Data collected by us on your behalf. You will inform us within 24 hours about any problem arising in relation with management of your Account and/or User Data. You and your Invited Users will be responsible for any illegal use of other personÕs data (personal or not) through the Services, including any use contrary to applicable data protection laws and/or in violation this Privacy Policy.

 

  1. Data Processor Obligations. To the extent that we are Data Processor on your behalf, we shall (a) implement appropriate technical and organizational measures to safeguard any User Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to User Data only to those employees who need to know it to enable the Processor to perform the Services; (c) only process the User data as specified by this Policy and in accordance with your instructions, and (d) will not use the User Data for any purposes other than those related to the performance of the Services or pursuant to your written instructions.  Upon the expiry or termination of this Agreement by way of de-registration, or upon your request, we will cease any and all use of the third party Data and will destroy or return it to you except as provided above with respect to backed-up data and termination. We will not disclose User Data to any third party without your prior written consent or pursuant to court or administrative order.

 

  1. Subcontracting. As Data Processor we contract in your name the services of Google Ireland Limited for the hosting of the data on servers within the European Union. You specifically authorize us to do this.

 

  1. Data removal. Through the Service, you may delete all User Data that is stored there. This data will no longer be accessible and will be fully removed from our systems on the next back-up, except as indicated below. If you wish to remove all the User Data in your Account, please, uninstall the App from your devices, and send us an email (as set out below), with a digital copy of your ID or other identification document to prove your identity. Once your identity confirmed, we will immediately remove all Data from our active systems and back-ups within fifteen (15) days from confirmation of identity (except as indicated below).

 

 

IX         Analytics and other Anonymous Data Use. 

 

For the purpose of improving our services, we anonymise User Data and store and process this data on an anonymous basis, even if your Account has been closed. The principal purpose is to analyze how our Services are used, measuring their effectiveness, providing customer service, and facilitating payments.

 

X.         User Rights.

 

You have the right to access, rectify, erase, block and oppose any processing of your personal data that we may have. Moreover, you may at any time withdraw your consent to the processing of your personal data and information. This withdrawal will not have retroactive effects but may prevent providing the Services. The above is without prejudice to provisions of Spanish applicable law enabling conservation of data for the purpose of defending our responsibility and complying with mandatory legal obligations. The aforementioned rights may be effective by contacting us at help@steps.life or at:

 

STEPS LIFE, S.L.

Carrer Vallespir 19, 4-1

08173 Sant Cugat del Valles (Barcelona)

SPAIN

 

We will assist you in accordance with the functionalities of the Services and the Term of this agreement to attend any User request with regard to the processing of their personal data.

 

XI.        Consent

 

By completing the forms of the Services and registering for an Account, you declare to have read and accepted the terms of this Policy. Without prejudice to the generality of the foregoing, you expressly and unequivocally consent to:

á       the collection and processing of your personal data by us in accordance with the indicated purposes and this Policy;

á       the collection and processing of User Data on your behalf, as indicated herein.

á       the processing of all personal data stated in this Privacy Policy by the following subcontractors: Google Cloud Platform, in the European Union.

 

Your consent to personal data collection and processing may be revoked, without retroactive effects.