PRIVACY POLICY

Last updated [October 7th , 2021]

This document is an electronic record in terms of Information Technology Act, 2000 and rules made thereunder and as the same may be amended from time to time.

Our Privacy Policy forms part of and must be read in conjunction with, website Terms and Conditions. We reserve the right to change this Privacy Policy at any time.

We respect the privacy of our users and every person who visits our Web Application STREADS App. Here, STEPS AND TREADS PVT. LTD. refers to as (“we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy under General Data Protection Regulation (GDPR). If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at info@stepsandtreads.com.

When you visit our Web Application STREADS (“Web Application”) and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have concerning it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue the use of our Web Application and our services.

This privacy policy applies to all information collected through our Web Application, and/or any related services, sales, marketing, or events (we refer to them collectively in this privacy policy as the “Web Application“).

“Web Application“ shall collectively mean the fitness program including but not limited to online website under the domain name https://stepsandtreads.com/ and mobile applications under the brand name ‘STREADS’

ABOUT US

STREADS is a fitness app, which rewards its users for walking. It records the user’s steps through mobile’s pedometer and based on such recorded steps, coins or points get added to such user’s App account .This app is free of cost.

Based on the minimum number of coins/points (as mentioned in the App) collected in the user’s account, the user can redeem the same either against products and/or services offered on or through the App, whether they are offered by Us or by our partners. Further, the said coins/points can also be used to avail various discount offers that may be made available on or through the App, whether by Us or by our partners.

Currently, this App is not applicable for any cycling or any other activity except for walking and running/jogging.

We are located in India.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

At the outset, You are free to refrain from sharing Your information with Us. When You use the Web application, We may collect two basic types of information – Your personal and anonymous information and we may use personal and anonymous information to create a third type of information, aggregate information. We may also collect information which may be Sensitive Personal Information.

We collect personal information that you voluntarily provide to us when registering with us, expressing an interest in obtaining information about us or our services, when participating in activities on the Web Application, or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Web Application, the choices you make, and the services and features you use. The personal information we collect can include the following:

  1. Registration information-You provide when you create an account, including your first name and surname, country of residence, gender, date of birth, email address, username and password.

  2. Contact List – As part of the Services, we are functionality allowing you to search for friends by using your mobile Contact list and when you elect to do this, you will be asked to allow the STREADS App to access information of Contact list of your mobile phone . Provided you consent to this, contact list of your mobile will be processed by us in order to identify who are users of STREADS App and to allow you to invite others to install the STREADS App.

  3. You provide when you use our Web application and refer our Web application to others.

  4. Transaction information- You provide when You request information or purchase a product or service from Us, whether on our Web application, including your postal address, telephone number and payment information.

  5. Information You provide in public forums on Our Web application.

  6. Information sent either one-to-one or within a limited group using Our message, chat, post or similar functionality, where We are permitted by law to collect this information.

  7. Information You provide to Us when You use Our Web application, Our Web application on third-party sites or Web applications such as social networking sites or link Your profile on a third-party site or Web application with Your registration account.

  8. Location information when You visit Our Web application, including location information either provided by a mobile device interacting with one of Our Web application, website or Application, or associated with your IP address, where We are permitted by law to process this information.

  9. Usage, viewing and technical data, including Your device identifier or IP address, when You visit Our Web application on third-party sites or Web applications or open emails we send.

2. HOW WE COLLECT YOUR INFORMATION?

  1. In order to register as a user with the Web application, You can either create an account on Our Web application. Alternatively, You can sign in using Your Facebook/Google/ any other social networking website login. If You do so, You authorize Us to access certain Facebook/Google or any other social networking website account information, such as Your public Facebook/Google or any other social networking website profile (consistent with your privacy settings in Facebook/Google or any other social networking website). You will also be asked to allow Us to collect Your location and movement, Fitness information from the device when You use the Web application.

  2. We collect information You provide to Us when You request products, services or information from Us, register with Us, participate in public forums or other activities on Our Web application, respond to customer surveys, or otherwise interact with Us. Please keep in mind that when You provide information to Us on a third-party site or Web application (for example, via Our Web application), the information You provide may be separately collected by the third-party site or Web application. The information We collect is covered by this privacy policy and the information the third-party site or Web application collects is subject to the third-party site or Web application’s privacy practices. Privacy choices You have made on the third-party site or Web application will not apply to Our use of the information We have collected directly through Our Web application.

  3. You provide while using Our Web application or in some other manner. You may also provide Us photos, a personal description and information about Your gender and preferences. In case any chat facility is provided through the Web application and if You chat with other Web application users, You provide Us the content of Your chats, and If You contact Us for customer service or other inquiry, You provide Us with the content of that communication.

  4. We neither knowingly collect any information nor promote Our Web application to any minor under the age of 18 (eighteen) years. If You are less than 18 (eighteen) years old or a minor in any other jurisdiction from where You access Our Web application, We request that You do not submit information to Us. If We become aware that a minor has registered with Us and provided Us with personal information, We may take steps to terminate such person’s registration and delete their account with Us.

  5. We use various tools and technologies, such as cookies, cookies and Web beacons, including when you visit Our Web application or use Our Web application on third-party sites or Web applications, to collect Your personal information and non-personal information from the device from which You access the Web application and learn about Your activities taking place under Your account when You use Our Web application. Such non-personal information could include Your IP address, device ID and type, Your browser type and language, operating system used by Your device, access times, Your device geographic location and the referring website address. We may use web beacons and other similar technologies to track Your use of Our Web application and to deliver or communicate with cookies.

  6. Advertising networks service providers, web traffic analysis service providers, Our business partners and vendors and other third parties may also use cookies, which is beyond Our control. These would most likely be analytical/performance cookies or targeting cookies. Blocking such cookies is possible by activating the appropriate settings on Your device browser. However, this may affect the functionality of the Web application.

  7. We acquire information from other trusted sources to update or supplement the information You provided, or We collected automatically. Local law may require that you authorize the third party to share Your information with Us before We can acquire it.

These informations are primarily needed to maintain the security and operation of our Web Application, and for our internal analytics and reporting purposes.

3. HOW DO WE USE YOUR INFORMATION WE COLLECT?

We use your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is under your marketing preferences. You can opt-out of our marketing emails at any time (see below).

  • To send administrative information to you related to your account, our business purposes, and/or for legal reasons. We may use your personal information to send you a product, service, and new feature information and/or information about changes to our terms, conditions, and policies.

  • Deliver targeted advertising to you for our Business Purposes and/or with your Consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. [For more information, see our Cookie Policy.]

  • Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Web Application.

  • To protect our Web Application for Business Purposes and/or Legal Reasons. We may use your information as part of our efforts to keep our Web Application safe and secure (for example, for fraud monitoring and prevention).

  • To enable user-to-user communicationswith your consent. We may use your information to enable user-to-user communications with each user’s consent.

  • To enforce our terms, conditions, and policies for our business purposes and as legally required.

  • To respond to legal requests and prevent harm as legally required. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Web Application, products, services, marketing, and your experience.

  • Resolve disputes, diagnose errors, troubleshoot problems, detect and protect Us against any activity not expressly authorized under the Terms & Conditions as available at the link.

  • Tracking of Your physical movement, Fitness and location for step count and coin conversion.

4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share and disclose your information in the following situations:

  • Compliance with Laws.We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

  • Vital Interests and Legal Rights.We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, and illegal activities, or as evidence in litigation in which we are involved.

  • Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • Third-Party Advertisers. We may use third-party advertising companies to serve ads when you use the Web Application. These companies may use information about your usage of our Web Application and other websites that are contained in web cookies and other tracking technologies to provide advertisements about goods and services of interest to you.

  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

  • With your Consent. We may disclose your personal information for any other purpose with your consent.

  • Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Web Application) or otherwise interact with public areas of the Web Application, such personal information may be viewed by all users and may be publicly distributed outside the Web Application in perpetuity.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

COOKIES

A cookie is a small text file that a website or Web Application saves on your computer or device when you access the Web Application. In general, cookies have two main purposes: to improve your browsing experience by remembering your actions and preferences and to help us analyze our website traffic.

We use cookies to help us analyze traffic to the Web Application, to help us improve the website or Web Application performance and usability, and to make the Web Application more secure. Third-party cookies help us use Google Analytics to count, track, and analyze visits/use to the Website or Web Application. This helps us understand how people are using our Web Application and where we need to make improvements. These third-party cookies do not specifically identify you.

Control cookies

You are always free to delete cookies that are already on your device through your application settings, and you can set them to prevent them from being added to your device.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in India. We will not transfer your personal information to an overseas recipient.

7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

The Web Application may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services, or Web Applications. We cannot guarantee the safety and privacy of the data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Web Application. You should review the policies of such third parties and contact them directly to respond to your questions.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our Web Application is at your own risk. You should only access the services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Web Application, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Web Application. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at info@stepsandtreads.com.

11. GDPR ENTITLEMENT

EU General Data Protection Regulation (GDPR) has provided the below rights to the EU residents:

Right to information – The purposes for processing Personal Information and the rights of the individual.

Right to access the Personal Information that is processed.

Right to erasure (”Right to be forgotten”).

Right to rectification.

Right to restriction of the processing.

Right to object (opt-out) to processing.

EU residents can exercise these rights by raising a request directly at info@stepsandtreads.com.

12. WHAT ARE YOUR PRIVACY RIGHTS?

Account Information

You may at any time review or change the information in your account or terminate your account by:

  • Contacting us using the contact information provided below

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with legal requirements.

Opt-Out (RIGHT TO RESTRICT PROCESSING)
General

You have the right to opt-out of certain uses and disclosures of your Personal Information. Where you have consented to us for Processing of your Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting info@stepsandtreads.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Services and/or information from the advertisements on Third-Party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.

Telephone Communications

We may also send you certain non-promotional communications regarding our Services and you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

Cookies and Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on Web Applications, including our App. However, on many devices, App users may opt-out of certain ads via their device settings.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration. You can also opt-out by:

  • Contacting us using the contact information provided below.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Web Application.

13. DATA PROTECTION OFFICER

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions concerning this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Data Protection Officer,

Name- Miss.Divyansha Dixit ,

e-mail- info@stepsandtreads.com.

14. DO WE MAKE UPDATES TO THIS POLICY?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, email us at info@stepsandtreads.com.