Privacy

PRIVACY STATEMENT

LAST UPDATED:  March 22, 2021

Steady Platform, Inc. ("Steady" or "we") has developed this statement to provide you with information on how we collect, use and share information from you and other users (“Users”) of the website steadyapp.com (“Site”) and Steady Service.

Steady collects information about you when you use our mobile applications, Sites and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. The Services are provided by Steady.


COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us, such as when you create or modify your account, contact customer support, use the Services or otherwise communicate with us. This information may include: name, email, phone number, postal address, interests, skills, employment experience, education background, job preferences, bank information, payment method and other information you choose to provide.

Information We Collect Through Your Use of Our Services

When you use our Services, we collect information about you in the following general categories:


IMPORTANT INFORMATION ABOUT PLATFORM PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Steady app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Steady app seeks before you first use the app, and your use of the app constitutes your consent.

Information We Collect from Other Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example:


USE OF INFORMATION

We may use the information we collect about you to:

SHARING OF INFORMATION

We may share the information we collect about you as described in this Statement or as described at the time of collection or sharing, including as follows:

Through Our Services

We may share your information:

OTHER IMPORTANT SHARING

We may share your information:

We do not sell personal information, and we will not sell personal information except as described in this Statement or if we provide you with notice and a right to opt-out of such sale.


PROTECTION OF INFORMATION


We implement a variety of security measures intended to maintain the safety of your personal information. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. When you access your personal information, we offer the use of a secure server. All sensitive/credit information you supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases to be only accessed as stated above. Unfortunately, the transmission of information via the internet is not completely secure, thus, despite these efforts, we cannot guarantee the security of your personal information transmitted through our website. Any transmission of personal information is at your own risk.

To protect the security of your information, we may require you to authenticate your identity to conduct certain transactions using the Services. If you believe that information that you have submitted through the Services has been used without your permission, email us at help@steadyapp.com to report unauthorized access. If you fail to notify us, you may be liable for all unauthorized activity on your account.


SOCIAL SHARING FEATURES


The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.


ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our Services, as well as when you visit other online sites and services. Third-party vendors may collect personal information about your online activities over time and across different websites when you use our Site.

Please refer to our Cookie Statement for more information about your choices around cookies and related technologies.


YOUR CHOICES


Account Information

You may correct your account information at any time by logging into your online or in-app account. If you wish to cancel your account, please email us at Help@SteadyApp.com.  Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.

Access Rights

Individuals may update any personal data by logging in to their profile on either the Steady website or through the Steady app.  Steady will also comply with individual's requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law.


Promotional Communications

You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.

Third party links

In an attempt to provide you with increased value, we may include third party links on our site. By including a link to a third-party website, Steady does not endorse or recommend any products or services offered or information contained at the third-party website. These linked sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Such third party may have a privacy policy different from that of Steady and the third-party website may provide less security protection than our website. If you decide to visit a third-party website via a link contained on the Site and/or the Services, you do so at your risk. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these linked sites (including if a specific link does not work).

Children Under the Age of 13

Our website is not directed to or intended for access or use by, and we do not knowingly collect personal information from, children under 13 years of age. If you are under 13 years of age, do not access, use or provide any information on our website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 years of age, we will delete that information. If you believe we might have any information from or about a child under 13 years of age, please contact us at Help@SteadyApp.com.

We do not sell the personal information of California consumers if we have actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information.


COOKIES AND ADVERTISING

Please refer to our Cookie Statement for more information about your choices around cookies and related technologies.

This website does not respond to browser “Do Not Track” signals.

CHANGES TO THE STATEMENT

We may change this Statement from time to time. If we make significant changes in the way we treat your personal information, or to the Statement, we will provide you notice through the Services or by some other means, such as email. Unless otherwise stated, any modifications to this Statement will go into immediate effect after they have been posted. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review the Statement for the latest information on our privacy practices.


YOUR CONSENT

By using our Site, you consent to our privacy policy.

CONTACT US


If you have any questions about this Privacy Statement, please contact us at privacy@SteadyApp.com.

NOTICE OF PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

Rights Under the California Consumer Privacy Act

Steady’s Privacy Statement includes this California Privacy Notice (“Notice”), which contains information pursuant to the requirements of the California Consumer Privacy Act (“CCPA”). For individuals who are California residents, the CCPA requires certain disclosures about the categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it. You have also the right to exercise certain rights regarding your personal information.

Requests

Subject to certain exceptions, if you are a California resident who has provided personal information to Steady, or a California resident that reasonably believes that Steady has collected or stored your personal information, you have the right to make the following requests, at no charge, up to twice every 12 months.


Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.


We may disclose your personal information to the following categories of other parties for an operational purpose, or for a business purpose or commercial purpose, as those terms are defined in the CCPA. Details are provided in the CCPA notice below, but we may disclose your personal information as described in this Notice and our Privacy Policy, including:

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Notice along with our Privacy Policy.


In response to a verified consumer request to know what personal information was collected or sold, we will investigate and provide an individualized response to the consumer, which will include the business or commercial purpose for collecting and/or sharing that information. We will not merely refer the consumer to our general practices outlined in this Notice or Privacy Policy unless our response would be the same for all consumers and this Notice or our Privacy Policy discloses all the information that is otherwise required for the response to such a consumer request.

Methods for Submitting Request

You may submit Requests to Know and Requests to Delete in one of the following methods: (1) emailing privacy@steadyapp.com or (2) sending your request via physical mail to 10735 Jefferson Blvd. #1061 Culver City, CA 90230.


Verification of Requests

We will need to verify your identity, including your residency in California, to respond to Requests to Delete and Requests to Know. If you have an account with us that is password-protected, we may also verify your identity through our existing authentication practices for your account.


If you do not have an account with us, and your request concerns “categories” of personal information collected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific pieces of personal information, we can request from you at least three data points of personal information as well as a signed declaration with penalty of perjury to verify your identity.

If a request concerns household information, and the household does not have a password-protected account with us, we will not comply with a Request to Know specific pieces of personal information about the household or a request to delete household personal information unless all of the following conditions are satisfied: (1) All consumers of the household jointly request access to specific pieces of information for the household or the deletion of household personal information; (2) we have individually verified all the Users of the household under the CCPA; and (3) we have verified that each User making the request is currently a member of the household.


Time for Response

Please note that once you have submitted a Request to Know or Request to Delete, we will send you a receipt, acknowledging your request, within 10 business days.


We use good faith efforts to respond to a verifiable consumer request within 45 days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing. If we cannot verify you within the 45-day time period, we may deny the request. If necessary, we may take up to an additional 45 calendar days to respond to the consumer’s request, for a maximum total of 90 calendar days from the day the request is received, provided that we will provides you with notice and an explanation of the reason that we will take more than 45 days to respond to the request.


In the case of a Request to Delete, we may use a two-step process for online requests to delete where you must first, submit the Request to Delete and then second, separately confirm that you want your personal information deleted.


Authorized Agent


As a California resident, you have the right to designate an agent to exercise these rights on your behalf using the procedures set forth herein. The authorized agent must specify the individual on whose behalf it is making the request. Before acting on this request, we may require that you provide signed permission to act on your behalf (or provided a Power of Attorney under Probate Codes sections 5000 to 4465), verify your own identity directly with us, and directly confirm that you have provided the authorized agent permission to submit the request. We may deny the request from an authorized person that does not provide proof that they are authorized to act on your behalf.


Exercising your CCPA Rights.

To request (a) information about your Personally Identifiable Information collected or (b) deletion of your Personally Identifiable Information, please send a request to privacy@steadyapp.com or via physical mail to 10735 Jefferson Blvd. #1061 Culver City, CA 90230. We will only respond to verifiable consumer requests. A verifiable consumer request means a request that is made by consumer, by a consumer on behalf of a consumer’s minor child, or a person registered with the California Secretary of State that is authorized to act on your behalf. Your verifiable consumer request must include (1) sufficient information that allows us to verify your identity and California residency or provides sufficient authority to make the request; and (2) describes your request with enough detail to evaluate and respond to your request. We will not respond to any requests if we cannot verify your identity or authority to make the request and confirm that the personal information belongs to you. You are not required to create an account in order to make a verifiable consumer request. We are not required to comply with more than two verifiable requests from the same consumer in a 12-month period of time. Please allow 45 days to complete your request. We will inform you if more time is required to complete, but it should take no longer than 90 days. If you have an account, we may provide our response to your account. If you do not have an account, we will provide our response according to your requested format, namely, electronically or by mail.

Non-Discrimination.

We will not discriminate against you because you exercised your rights under the CCPA including: (1) denying goods or services; (2) charging different prices or rates for goods or services through discounts, benefits, or imposing penalties; (3) providing different level of quality of goods or services; or (4) suggesting that you will receive a different price, rate, quality, or level of goods or services.

CCPA Notice Notice at Collection Pursuant to California Civil Section 1798.100(b), this section serves as notice to California residents of (A) the categories of personal information that we collect through the Site and Services, (B) the categories of sources of such personal information, (C) the business or commercial purposes for which such personal information was collected, and (D) the categories of third parties to whom such information was or could be disclosed in the past twelve (12) months. This notice supplements and is subject to our Privacy Policy.

A. Types of Personal Information Collected


B. Business or Commercial Purposes and/or Uses

Please refer to our above Privacy Policy for a list of all the ways we may use the

C. With Whom We May Share Your Information

For each of the above categories, we may disclose your personal information to third parties as described in this Notice and our Privacy Policy, including:


COOKIE NOTICE

Last updated: March 22, 2021/strong>

This Cookie Notice explains how Steady Platform, Inc. and its subsidiaries (collectively “Steady”, “we”, “us”, and “ours”) use cookies and similar technologies to recognize you when you visit our websites and use our mobile applications (“Site”). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information. Cookies set by the website owner (in this case, Steady) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

We use first party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Sites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites. Third parties serve cookies through our Sites for advertising, analytics and other purposes. This is described in more detail below.

First and third-party cookies served through our Sites and the purposes they perform are described below:


What about other tracking technologies?

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Sites to another, to deliver or communicate with cookies, to understand whether you have come to our Sites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Our mobile applications may include third-party application software development kits that provide mobile performance and analytics data, bug reporting features, and APIs to third parties that help provide the Site, for social media functionality, and for marketing and advertising.

Does Steady serve targeted advertising?

As described above, third parties may serve cookies on your computer or mobile device through the Sites to serve advertising. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences for certain third-party cookies by clicking on the appropriate opt-out links provided above. You can also set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Site though your access to some functionality and areas of our website may be restricted, you may worsen your overall user experience, since it will no longer be personalized to you and it may also stop you from saving customized settings like login information. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. To revoke consent, users may disable cookies by modifying their browser settings. The links listed below provide more information about what cookies are installed, how to allow, block or remove installation from your computer. Depending on which browser you use, the user may follow these links:

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/https://www.networkadvertising.org/, or http://www.youronlinechoices.com. Please bear in mind that there are many more networks listed on that site than those that we use on our Website.

We use Google cookies for analytics and marketing purposes. You can opt-out of Google tracking through Google Ads Settings, Ad Settings for mobile apps, or any other available means. Google also provides a Google Analytics opt-out plug-in for the web.

What is Do Not Track (DNT)?

DNT is a concept that has been promoted by regulatory agencies such as the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites by using browser settings. The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a DNT technology standard. While some progress has been made, it has been slow. No standard has been adopted to this date. As such, Steady does not generally respond to "do not track" signals.

How often will this Cookie Notice be updated?

We may update this Cookie Notice from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore revisit this Cookie Notice regularly to stay informed about our use of cookies and related technologies.


The date at the top of this Cookie Notice indicates when it was last updated.