Privacy Policy

This Privacy Policy was last updated on 03th of July 2024.

By using this website and downloading, installing, and/or using the app and making in-app purchases, you agree to this privacy statement. If you do not agree to this privacy statement, please stop using the website, app, uninstall it, and refrain from making any in-app purchases.

Who We Are 

___________ is a private company limited by shares, incorporated under the laws of the Republic of Cyprus, and is duly registered in the Companies Register maintained by the Department of Registrar of Companies and Official Receiver of the Republic of Cyprus with registration number ________ (referred to as «the Company,» «we,» or «us,» unless otherwise stated herein). We are the controller and entity responsible for your personal data.

Applicability of this Privacy Statement This Privacy Statement applies to information collected about:

  • Visitors to the Company’s website («Website»);
  • Individuals who use mobile applications developed or owned by the Company («App» or «Apps»).

Applicable Regulatory Framework 

We strive to adhere to and comply with the privacy laws of the jurisdictions where the users of our Apps are located. As a company registered and operating in an EU country, we follow the EU regulatory framework, including the General Data Protection Regulation (GDPR).

How do I submit a request?

If you wish to exercise your rights described above, please send a request via email to support@sobersteps.app

Can I use an authorized agent?

Yes, you may use an authorized agent to submit a request to opt-out on your behalf if you provide written permission to the authorized agent. Please send us a copy of this permission as instructed in Section 18 of this policy below. We may deny a request from an authorized agent if they do not provide proof that they are authorized by you to act on your behalf. You can also make a request on behalf of your minor child.

Do you engage in automated individual decision-making, including profiling?

No, we do not make decisions based solely on automated processing, including profiling, that would produce legal effects concerning you.

Do you use cookies?

Yes, the following cookies may be used on our website:

  • Strictly Necessary Cookies: These cookies enable essential functions and ensure the proper functioning of the website (e.g., page navigation and access to secure areas). These cookies are mandatory and do not require your consent as the website would not function properly without them.
  • Statistics Cookies: These cookies collect and report anonymous information that helps the website manager understand how visitors use the website. Your consent is required for the use of these cookies, which you can withdraw at any time.
  • Targeting Cookies: These cookies track user actions to identify visitors across different websites. Using the information collected by these cookies, you can see personalized ads that match your interests. Your consent is required for the use of these cookies, which you can withdraw at any time.
  • Marketing Cookies: These cookies are used to display personalized content and promotional information. Your consent is required for the use of these cookies, which you can withdraw at any time.

How can I manage cookies?

You can set your browser to refuse some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies, you may not be able to access certain areas or features of our website. You can manage the use of functionality cookies, targeting cookies, or advertising cookies by adjusting your browser settings. To learn how to manage cookies in your browser, please visit one of the following links:

How can I contact your DPOs?

If you have any questions, comments, or complaints about how we collect, use, and store your personal information, our data protection officers are here to help. You can contact them at any time at: E-mail address: support@sobersteps.app

Third Party Links

Our website and app may contain links to third-party websites, plug-ins, and applications. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We do not control these third-party websites and apps and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the privacy notice of every website or app you visit.

Persons Below the Age of 16 and COPPA

Where required by applicable data protection laws, we will always seek your express permission before asking you to submit your personal information on our website or via our apps. For individuals under the age of 16, or below the age limit determined by applicable local laws, please note that we do not knowingly collect information about the age of our users. Furthermore, we commit to immediately erasing and deleting any personal information related to any child under the age of 16, or below such age limit as determined by applicable local laws, that was inadvertently collected, kept, or stored by us, and we will ask our partners to do the same.

We take the privacy rights of users of our website and apps very seriously, including all rights granted to children under the age of 13 by the US Children’s Online Privacy Protection Act (COPPA).

Insofar as COPPA is applicable in your country of residence, and in safeguarding the rights of children under the age of 13, we do not knowingly collect or store any personal information related to children under the age of 13 residing in the United States. Furthermore, we commit to immediately erasing and deleting any personal information related to any child under the age of 13 that was inadvertently collected, kept, or stored by us, and we will ask our partners to do the same.

Changes to Our Privacy Statement

We keep our Privacy Statement under regular review. If we make changes to our Privacy Statement, we will post the updates on this page. Additionally, we may place notices on other pages of our website or inform you via the app, so that you are always aware of the information we collect and how we use it.