Privacy Policy
Last updated on 03rd 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
AFTERMIND LAB LTD 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 HE 434274 (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).
To provide you with our online services and/or products
When is this relevant for me?
When you use / receive our online services and/or products
What information do you collect about me?
First name, last name, email address, password, other data that you provide while registering, date of account creation, date of user's most recent login, selected account settings, online services and/or products received by user, tests' results, games' scores
What is your legal basis to collect my information?
Contract (Art. 6 (1) (b) of GDPR)
Where do you collect the information from?
From yourself
Am I obliged to provide this information?
It is a requirement necessary to enter into a contract. If you do not provide this information, you will not be able to use / receive our online services and/or products
How long do you store information about me?
5 years from the last login to your account
To process your orders and receive payments
When is this relevant for me?
When you make a payment on our website
What information do you collect about me?
First name, last name, email, subscription plan, ordered services and/or products, paid amount, currency, payment information (card number, expiration date, CVC number, postal code)
What is your legal basis to collect my information?
Contract (Art. 6 (1) (b) of GDPR)
Where do you collect the information from?
From yourself
Am I obliged to provide this information?
It is a requirement necessary to enter into a contract. If you do not provide this information, you will not be able to use our services
How long do you store information about me?
10 years from the moment you made a purchase
To ensure security of our website/app and continuously improve it for you
When is this relevant for me?
When you use our website
What information do you collect about me?
IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the site, the pages you view on the site, your actions on the site, and the dates and times that you visit, access, or use the services. When you use the site on a mobile device, we may also collect the physical location of your device using satellite, cell phone tower, or wireless local area network signals
What is your legal basis to collect my information?
Consent (Art. 6 (1) (a) of GDPR)
Where do you collect the information from?
From yourself
Am I obliged to provide this information?
No
How long do you store information about me?
1 month after you visit our website
To provide you with customer support
When is this relevant for me?
When you submit an inquiry or file a complaint
What information do you collect about me?
First name, last name, email address, country, telephone number, subject of your inquiry, date of your inquiry, content of your inquiry, attachments to your inquiry, reply to your inquiry
What is your legal basis to collect my information?
Consent (Art. 6 (1) (a) of GDPR)
Where do you collect the information from?
From yourself
Am I obliged to provide this information?
No
How long do you store information about me?
3 years from the moment your last inquiry was received
To ensure and improve the performance of our website/app, to adapt its content and format to the needs of users and to show you relevant internet ads
When is this relevant for me?
When we want to inform you or ask your opinion about our products or show you internet ads
What information do you collect about me?
Full name, email, telephone number, IP address, order information, country, postback information, website that directed the company's website, your interaction with internet ads
What is your legal basis to collect my information?
Consent (Art. 6 (1) (a) of GDPR); Customer relationship (Art. 81 (2) of Lithuanian Law on Electronic Communications)
Where do you collect the information from?
From yourself, social media service providers, marketing service providers
Am I obliged to provide this information?
No
How long do you store information about me?
5 years after you use our services or after you give your consent, unless you withdraw your consent earlier
To interact with you via social media
When is this relevant for me?
If you interact with our social media profiles (e.g., send a message, follow our profiles, share a post, react to a post)
What information do you collect about me?
Name and surname, email address, gender, country, picture, message, time and date the message was received, content of the message, message attachments, response to the message, time of response, information about the company's rating, comments on a post, post shares, information about post reactions
What is your legal basis to collect my information?
Consent (Art. 6 (1) (a) of GDPR)
Where do you collect the information from?
From yourself and social media platforms
Am I obliged to provide this information?
No
How long do you store information about me?
10 years from the moment you interact with our social media profiles
How do I submit a request?
If you wish to exercise your rights described above, please send a request via e-mail: 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:
- Mozilla Firefox: Enable and disable cookies
- Google Chrome: Manage cookies in Chrome
- Opera: Opera privacy settings
- Microsoft Edge: Microsoft Edge privacy
- Safari: Manage cookies and website data in Safari
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: 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.