My Steps: Walking Counter Privacy Policy

 

This Privacy Policy describes our policies and procedures for collecting, using, and disclosing your information when you use the Service, and informs you of your privacy rights and how the law protects you. We use your personal data to provide and improve the Service. By using the Service, you consent to our collection and use of your information in accordance with this Privacy Policy.

 

For the purposes of this Privacy Policy:

 

Service refers to the step counting and reward redemption functions provided by My Steps: Walking Counter.

 

Device refers to any device that can access the Service.

 

Personal data refers to any information relating to an identified or identifiable individual.

 

Service provider refers to a third-party company or individual employed by the Company to assist in the use of the Service, provide services on behalf of the Company, perform services related to the Service, or assist the Company in analyzing the use of the Service.

 

Usage data refers to data that is automatically collected, which may be generated during the use of the Service or may come from the Service infrastructure itself.

 

You refer to the individual who accesses or uses the Service.

 

Collection and Use of Your Data

 

Types of Information Collected

During your use of this service, we may collect relevant information and data for the following purposes, including but not limited to:

 

Usage Data: When you access or use our services, we may automatically receive and record relevant information, such as your device's Internet Protocol address (IP address), the service page accessed, the access date and time, the page dwell time, a unique device identifier, and other technical diagnostic data.

 

Device Data: We may collect your mobile device model, operating system version, device settings, mobile network information, device IP address, a unique device identifier, and other diagnostic information related to device performance.

 

Information You Voluntarily Provide: In addition to automatically collected information, you may also voluntarily provide us with personal information when providing feedback, participating in activities, or applying for rewards.

 

Google Account Information: If you choose to sign in with Google, we may receive information that you authorize Google to provide to us, such as your name, email address, profile photo, and a unique Google account identifier. We use this information to create or authenticate your account, maintain your login status, associate your activity and rewards with your account, and provide account-related services. We do not receive or store your Google password.

 

Withdrawal and Reward Redemption Information: When you request to withdraw earnings or redeem rewards, we may collect information necessary to process and verify the transaction, such as your user or account identifier, withdrawal or redemption amount, payout account identifier or other payout information required by the selected withdrawal method, transaction status, redemption history, and information reasonably necessary for eligibility verification, fraud prevention, and abuse prevention. The specific information collected depends on the withdrawal method you choose.

 

Exercise Information You Authorize: To ensure the normal operation of the pedometer function and to verify valid exercise for reward distribution, we will collect your body movement data and location information with your consent. You can enable or disable this permission at any time through your device's system settings, but if disabled, we will be unable to provide pedometer and reward services.

 

Purpose of Information Use

 

We may use the information we collect for the following purposes:

 

Service Provision and Maintenance: To ensure the normal operation, maintenance, and improvement of our services, monitor service usage, and identify and resolve technical issues.

 

Account Authentication and Management: To enable Google sign-in, authenticate your identity, maintain account access, associate your activity and reward records with your account, and provide account-related support.

 

Withdrawal and Payment Processing: To review and process withdrawal or redemption requests, deliver earnings or rewards, maintain transaction records, resolve payment-related issues, and prevent fraudulent or abusive activity.

 

Reward Distribution and Management: To distribute rewards based on your step count data according to in-app rules and to verify the compliance of reward acquisition behavior.

 

Management and Processing of User Requests: To promptly respond to and process your inquiries, complaints, feedback, or other requests during your use of the service.

 

Service Optimization and Personalized Experience: To continuously improve service quality by analyzing user habits and preferences, optimizing feature settings and interface design.

 

Legal and Compliance Uses: To comply with applicable laws and regulations, cooperate with regulatory requirements, exercise the rights granted by this policy or law, and for dispute resolution and enforcement.

 

We promise that your information will only be used for the purposes described in this Privacy Policy and will not be used beyond the relevant scope or provided to third parties, except as otherwise provided by laws and regulations.

 

Sharing Your Information

 

Subject to strict compliance with relevant laws and regulations and this Privacy Policy, we may share your personal information with third parties in the following circumstances:

 

Sharing with Service Providers: For service operation and analysis purposes, we may share necessary personal information with service providers who provide us with technical, consulting, or operational support, such as for monitoring and analyzing service usage and providing customer support. These service providers will process your personal information only to the extent necessary to perform their services and will be bound by contractual terms to protect your information security and legitimate rights.

 

Google Sign-In: When you use Google Sign-In, authentication is provided by Google. Information exchanged as part of the sign-in process is processed in accordance with Google's privacy terms and the permissions you grant. We request and use only the information necessary to provide login and account-related functions.

 

Payment and Payout Service Providers: To process a withdrawal or reward redemption, we may share the minimum information necessary with payment, payout, or financial service providers involved in completing the transaction. These providers may process such information in accordance with their own privacy policies and applicable legal obligations.

 

Due to Business Transfer or Merger: In the event of a merger, acquisition, asset transfer, financing, or other similar corporate restructuring, we may transfer your personal information as part of the transaction assets during the relevant transaction process or negotiations. We will ensure that such transactions comply with this policy and require the new entity holding your information to continue to be bound by this policy; otherwise, we will require it to obtain your authorization and consent again.

 

Sharing with Affiliated Companies: We may share your personal information with affiliated companies that belong to the same group or have a common control relationship. In this case, we will ensure that the affiliated company complies with the provisions of this Privacy Policy and uses your information to achieve the purposes described in this policy.

 

Sharing with Business Partners and Advertisers: We may share necessary device information (such as IP address, device ID) and anonymized usage data with trusted third-party advertisers and analytics service providers for personalized advertising, user trend analysis, and statistical evaluation. We will only share information necessary to achieve these functions and will contractually bind our partners to their information protection obligations and the scope of their use. You can opt out of personalized advertising through the "Restrict Ad Tracking" function on your device system.

 

With Your Consent: Except as stated above, if we need to share or disclose your personal information in other scenarios, we will obtain your explicit consent in advance and inform you of the type of recipient and the purpose of use.

 

We promise to strictly take technical and management measures to protect the security of your personal information in accordance with the law, and will strive to ensure that the recipient has sufficient data protection capabilities during the sharing process.

 

Retention and Transfer of Information

 

Retention Period of Information: We will retain your personal information only for the shortest period necessary to achieve the purposes described in this Privacy Policy. We may extend the retention period for personal information in accordance with the law in the following circumstances:

 

To complete transactions, prevent fraud, resolve disputes, and comply with applicable financial, tax, accounting, or legal requirements

 

To comply with applicable laws and regulations;

 

To safeguard public interests or perform major public tasks;

 

As necessary for litigation, arbitration, or administrative enforcement proceedings;

 

To fulfill the User Agreement, handle disputes, or enforce this policy and platform rules.

 

Even after the retention period expires, we may still anonymize some information for internal analysis, service optimization, or model training purposes. This information will no longer be able to identify a specific natural person.

 

Cross-border Transfer of Information

 

Because we operate in multiple jurisdictions worldwide and may use servers and service providers located in different countries or regions, your personal information may be transferred to computer systems outside your country/region for processing and storage. Data protection legislation in such destinations may differ from that of your jurisdiction.

 

You understand and agree that by using our services, you acknowledge the possibility of such cross-border transfers and consent to our lawful conduct of such operations.

 

Data Disclosure

 

We may disclose your personal data in the following specific circumstances in accordance with the law:

 

Commercial Transactions: Your personal data may be transferred as part of the transaction if the company engages in commercial transactions such as mergers, acquisitions, or asset transfers.

 

Responding to Law Enforcement Requests: Based on legal requirements, or in response to valid requests from courts, government agencies, or other competent authorities, we may be required to disclose your relevant personal data.

 

Other Legal Circumstances: We may disclose your personal information in good faith, provided it is reasonable, necessary, and in compliance with laws and regulations, for purposes including but not limited to:

 

Fulfilling the company's legal obligations;

 

Protecting and defending the company's legitimate rights and property;

 

Preventing, identifying, or investigating fraud, abuse, or other misconduct related to the service;

 

Protecting the personal safety and life of users, employees, or the general public;

 

Other circumstances necessary to avoid or assume legal liability.

 

We will always carefully assess the legality, necessity, and proportionality of any disclosure and will strive to ensure that your personal information remains adequately protected after disclosure.

 

Your Information Security

 

Protecting your personal information is of paramount importance to us, but please remember that no form of internet transmission or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

 

Children's Privacy

 

Our services are not intended for anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we discover that we have collected personal information from anyone under the age of 13 without parental consent, we will take steps to remove that information from our servers.

 

Advertising and Third-Party Services

 

We may display advertisements in our app and use third-party advertising and analytics services. These service providers collect and use certain device and usage information to serve more relevant ads (including personalized ads), evaluate ad performance, and conduct general statistical analysis.

 

The third-party advertising and analytics services we use may include (but are not limited to):

 

Google Play Services: https://policies.google.com/privacy?hl=en

 

Firebase: https://firebase.google.com/support/privacy/

 

Google AdMob: https://transparency.google/our-policies/product-terms/google-admob/

 

Facebook: https://www.facebook.com/about/privacy

 

Pangle: https://www.pangleglobal.com/privacy

 

Topon: https://www.toponad.com/en/privacy-policy

 

You have the right to opt out of interest-based personalized advertising. Here are how to manage your ad preferences:

 

You can enable "Limit Ad Tracking" (iOS devices) or "Oppose Personalized Advertising" (Android devices) on your mobile device.

 

Please note that opting out of personalized advertising does not mean you will no longer see ads, but rather that the ads you see will no longer be relevant to your interests, and their number may not decrease.

 

Other Website Links

 

Our services may contain links to websites not operated by us. If you click on a third-party link, you will be redirected to that third-party website. We strongly encourage you to review the privacy policy of each website you visit.

 

We have no control over the content, privacy policies, or practices of any third-party websites or services, and assume no responsibility for them.

 

Changes to this Privacy Policy

 

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new privacy policy on this page. We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy will take effect from the date of posting on this page.

 

Your Rights under GDPR

 

If you are located in the European Union, you have the following legal rights under the General Data Protection Regulation (GDPR). We are committed to respecting and protecting your right to exercise these rights in accordance with the law:

 

Right of Access: You have the right to confirmation that we are processing your personal data, and if so, you have the right to access such data and related information such as the purpose of processing, data type, and recipient.

 

Right of Correction: If your personal data is inaccurate or incomplete, you have the right to request that we correct or supplement it promptly.

 

Right to Erasure (Right to Be Forgotten): Under certain circumstances (such as when the data is no longer necessary, you withdraw your consent, or the data has been illegally processed), you have the right to request that we delete your personal data.

 

Right to Restrict Processing: Under legally permissible conditions (such as when you object to the accuracy of the data, or when the processing is illegal but you object to deletion), you have the right to request that we temporarily restrict the processing of your personal data.

 

Right to Data Portability: For personal data you provide to us based on your consent or contractual agreement, and where the processing is automated, you have the right to access this data in a structured, universal, and machine-readable format, or, where technically feasible, to request that we transfer it directly to another controller.

 

Right to Object: You have the right to object to the processing of your personal data for purposes of public or legitimate interest, based on your specific circumstances. If you object to processing for direct marketing purposes, we will immediately cease the relevant processing.

 

Right to Withdraw Consent: If data processing is based on your consent, you have the right to withdraw your consent at any time, but this does not affect the legality of processing carried out based on your consent before the withdrawal.

 

To exercise the above rights, you can contact us using the contact information at the end. We may require you to verify your identity for security reasons.

 

Account Deletion: You may request deletion of your account and associated personal data by contacting us using the contact information below. We will process the request in accordance with applicable law, subject to information that we may be required or permitted to retain for transaction records, fraud prevention, dispute resolution, security, or legal compliance.

 

Contact Us

 

If you have any questions about this Privacy Policy, you can contact us through the following methods:

 

By email: [email protected]