Last Updated: 2025.3.13

At SmallStep, we deeply value your privacy and are committed to handling your personal information responsibly and in compliance with applicable data protection laws. Our privacy practices are founded on the principles of necessity, transparency, security, and user control.

Your privacy is of the utmost importance to us at "SmallStep" We commit to:

▪️ Store your personal information only for as long as necessary.

▪️ Be cautious and intentional about the personal information we collect.

▪️ Allow you easy control over your public and private information.

▪️ Be transparent about our data collection and usage practices.

We are "SmallStep", a software company specializing in mobile applications. In this policy, "us," "we," and "our" refer to "SmallStep" and its affiliated entities.

We prioritize your privacy and aim to be transparent, fair, and accountable in our data practices. This policy outlines what you can expect regarding your personal information.

This policy applies to users of our mobile applications and those who interact with our customer support channels.

This document covers:

1. Data collection and usage

2. Legal basis for data usage

3. Third-party sharing

4. Data retention

5. Your rights

6. Child users

7. International data transfers

8. Security measures

9. Cookie policy

10. In-app purchases

11. User-generated content

12. Policy updates

13. Contact and complaints

You have the right to:

1. Object to our use of your data for direct marketing.

2. Raise valid objections to our processing of your data based on legitimate interests.

For more details, see the "Your Rights" section.

By using our app, you confirm that you have read and understood this privacy policy in its entirety.

When utilizing the Service, Usage Data is gathered automatically. This may involve details like:

Internet Protocol address (IP address) of your device

Type of browser you use and its version

Pages of our Service you visit

Visiting time, date, and duration

Unique device identifiers

Diagnostic information

Should you use a mobile device to access the Service, we automatically gather specific data, including but not limited to:

Type of mobile device

Device unique ID

IP address of your mobile device

Mobile operating system

Mobile internet browser

Unique device identifiers (such as IDFA/AAID for advertising)

Other diagnostic data

Each time you visit our Service or access it using a mobile device, your browser may transmit certain information to us, including:

Model of hardware

Operating system details and version

IP address of your mobile device

Screen dimensions and pixel density

Language and country setting

Time zone setting

Status of device sound settings (pertinent to reminder functionalities)

For enhanced user experience, we have incorporated tools for data analytics within the App. These tools do not gather health or private data of users. They are solely utilized for pinpointing CRASH issues and conducting AB tests for new features and designs. The information collected includes:

Screen Size

Manufacturer

Model

OS Name

OS Version

OS Build

Time Zone

System Language

Carrier's country and name

Locale

Country and regional area

App Name

Build of the App

Version number of the App

SDK Name

SDK Version

Our app may request the following permissions based on functionality needs:

Media Library/Storage: To save and retrieve files you create or modify within the app

Camera: To enable photo capture features within the app

Location: To provide location-based services and relevant local information

File Management: To help you organize and manage files within the app

You can manage these permissions at any time through your device settings.

We use your data to:

Provide and maintain our Services

Show personalized and non-personalized advertisements

Analyze usage patterns to improve user experience

Detect and prevent technical issues

Respond to customer support inquiries

Fulfill legal obligations

We rely on the following legal grounds to process your personal data:

Contractual obligations: Processing necessary for performance of our contract with you

Your explicit consent: For specific data processing activities, particularly regarding personalized advertising

Legitimate interests: For business operations, security, and improving our services

Legal compliance: To comply with applicable laws and regulations

We may share data with the following categories of third parties:

Google AdMob: Receives device identifiers, IP address, and usage data to serve relevant ads

Facebook Meta Ads: Receives device identifiers and usage data for ad targeting

Mintegral: Receives device identifiers and usage data for ad serving

Pangle: Receives device identifiers and usage data for ad delivery

Applovin: Receives device identifiers and usage data for ad optimization

Firebase: Receives usage and crash data to improve app performance

Google Analytics: Receives anonymized usage data for statistical analysis

Service Providers: Who perform services on our behalf (hosting, payment processing)

Legal Authorities: When required by law, court order, or governmental regulation

Business Partners: In connection with a merger, sale, or acquisition

We ensure all third-party partners comply with applicable data protection laws. Your privacy is important to us, and we will only share your personal information when absolutely necessary.

We retain your personal data for specific timeframes based on the type of data:

Account information: For as long as your account is active plus 30 days after deletion

Usage data: For 26 months from collection

Customer support communications: For 2 years after resolution of your inquiry

Device information: For 13 months from your last app usage

After these periods expire, your data will be securely deleted or anonymized.

In accordance with the laws of your region, you may have certain rights related to your personal information. These rights might include (if applicable):

To exercise any of these rights:

Email: Send a request to usersupport@smallstep.fun

In-App: Use the feedback option within our app

Response Time: We will respond to all legitimate requests within 30 days

Our app is not directed at children under the age of 16, and we do not knowingly collect data from them. If we discover we have collected personal information from a child under 16, we will promptly delete this information. If you believe we might have any data from or about a child under 16, please contact us at usersupport@smallstep.fun.

We operate globally and may transfer your data to servers and third parties located outside your country of residence, including outside the European Economic Area (EEA). When we transfer personal data outside the EEA, we implement appropriate safeguards including:

Standard Contractual Clauses approved by the European Commission

Adequacy decisions where applicable

Data Protection Agreements with our partners

We employ industry-standard security measures to protect your data, including:

Encryption of data in transit and at rest

Firewalls and secure server infrastructure

Regular security assessments and penetration testing

Access controls and authentication requirements

Employee training on data protection

Secure data disposal procedures

While we implement these safeguards, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Our app and website may use cookies and similar tracking technologies to enhance your experience. These technologies may collect information such as your IP address, browser type, and usage patterns. You can control cookie settings through your browser or device settings.

We use the following types of cookies:

Essential cookies: Required for basic functionality

Preference cookies: Remember your settings and preferences

Analytics cookies: Help us understand how our services are used

Advertising cookies: Used to serve relevant advertisements

If you make in-app purchases, payment information is processed by third-party payment processors and is not stored by us. We receive only confirmation of successful transactions without storing payment details.

If our app allows you to create, upload, or share content:

You retain ownership of your content

We may use this content only as needed to provide our services

You are responsible for ensuring your content does not violate others' rights

We may update this policy periodically to reflect changes in our practices or legal requirements. We will notify you of any significant changes through:

In-app notifications

Email communications (if you've provided your email)

Notice on our website

The updated policy will be effective upon posting, unless otherwise stated.

If you have any questions, concerns, or complaints about our privacy practices:

Email: usersupport@smallstep.fun

You also have the right to lodge a complaint with your local data protection authority.

We may occasionally update or revise our privacy policy due to our operational needs or changes in relevant laws and regulations. These updates will become part of this policy and have the same effect.

▪️ If we make significant changes that affect the purpose, method, or scope of how we collect your personal information, we will notify you through a pop-up notification within the app. This ensures you're aware of the updates.

▪️ By continuing to use Smallstep's products and services, you acknowledge that you understand and agree to the entire privacy policy, including any future updates.