Right to Know

 

PRIVACY STATEMENT

LAST UPDATED / EFFECTIVE DATE: February 8, 2023

 

Steady Platform, Inc., including all Steady businesses and affiliates (“Steady,” “us,” or “we”), has developed this statement (“Privacy Statement”) to provide you with information on how we collect, use, and disclose information from you and other users (“Users”) of our websites, such as steadyapp.com or steadyiq.com, where this Privacy Statement is posted (collectively, the “Site”) and Steady Services.

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, gross income, business expenses, 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:

  • Job Information: When you use the Services to seek a job, we collect information concerning your employment history, educational and other background, and job preferences including the type of job requested, the specific job that you obtained, and your compensation.
  • Transaction and Bank Information: For those users who have linked their bank account information with us, we collect bank account transaction details, purchase history, and other related transaction details.
  • Usage and Preference Information: We collect information about how you and site visitors interact with our Services, preferences expressed, and settings chosen. In some cases, we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers.
  • Device Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
  • Log Information: When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, geolocation information about where you might be, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.
  • Sensitive Personal Information:  We may collect your driver’s license, state identification card, account log-in, precise geolocation, or racial or ethnic origin.

 

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

  • Consumer data platforms
  • Credit reporting agencies
  • Operating systems and platforms
  • Data brokers 

 

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

  1. If you choose to link, create, or log in to your account with a bank (e.g., Capital One), payment provider (e.g., Google Wallet) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app. For retrieving bank account transaction information, we use Plaid.  Plaid’s privacy policy is available here.
  2. If your Employer uses one of our enterprise solutions, we may receive information about you from your Employer.
  3. When you request on demand services, our Employers may provide us with a rating related to your job performance.
  4. If you also interact with our Services in another capacity, for instance, as an Employer or user of other apps we provide, we may combine or associate that information with information we have collected from you in your capacity as a User or rider.
  5. If you choose to link, create, or log in to your account with a gig platform (e.g., Uber) and/or payroll provider (e.g., ADP) using our data aggregators, we may receive information about you from that site or app. 

USE OF INFORMATION

We may use the information we collect about you to:

  1. Provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users and Employers, develop safety features, authenticate users, and send product updates and administrative messages;
  2. Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
  3. Send or facilitate communications (i) between you and an Employer, or (ii) between you and a contact of yours, at your direction, in connection with your use of certain features, such as referrals;
  4. Send information, at your request, to agencies or institutions to verify information you have provided them in a request or application for financial support or services;
  5. Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Steady and other companies, where permissible and according to local applicable laws; and to process contest, sweepstakes, or other promotion entries and fulfill any related awards;
  6. Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements;
  7. We may transfer the information described in this Privacy Statement to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Privacy Statement;
  8. Audit related to our current interactions with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
  9. Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes. Including to detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  10. Debug to identify and repair errors that impair existing intended functionality;
  11. Short-term, transient uses, but your personal information will not be disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  12. Perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
  13. Undertake internal research for technological development and demonstration;
  14. Undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance our services or devices; and
  15. Any commercial purposes, including any purpose to advance your commercial or economic interests, such as by inducing you to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

 

DISCLOSURES OF INFORMATION

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

Through Our Services

We may disclose your information:

  1. With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us;
  2. With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public; and
  3. With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate.

 

OTHER IMPORTANT DISCLOSURES

We may disclose your information:

  1. With Steady subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and / or logistics purposes;
  2. With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
  3. In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
  4. With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Steady or others;
  5. In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, liquidation, or acquisition of all or a portion of our business by or into another company;
  6. If we otherwise notify you and you consent to the disclosure;
  7. In an aggregated and/or anonymous form which cannot reasonably be used to identify you; and
  8. To conduct any other legitimate business activities.

 

We do not sell personal information, and we will not sell personal information, except as described in this Privacy 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 who 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 personal information that we collect about you as required by law, or for legitimate business purposes to the extent permitted by law Or as described in this Privacy Statement for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws. For instance, if you have a standing credit or debit card 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.

 

Retention of Personal Information

We retain the personal information we collect as described in this Privacy Statement for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve dispute, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

 

Access Rights

Individuals may update any personal information by logging in to their profile on either the Steady website or through the Steady app.  Steady will also comply with an individual's requests regarding access, correction, and/or deletion of the personal information we store 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 Site. 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 Site and Services are 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 Site or provide any personal 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 that 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 PRIVACY STATEMENT

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

YOUR CONSENT

By using our Site or Services, you consent to our Privacy Statement.

 

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 disclose 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.

 

Right to Know

You have the right to request that Steady disclose certain information about how we have handled your personal information in the prior 12 months, including:

  • categories of personal information collected
  • categories of sources of personal information

business and commercial purposes for collecting and selling your personal information

  • categories of third parties with whom we have disclosed your personal information
  • categories of personal information that we have disclosed with a third party for a business purpose; and
  • categories of third parties to whom the consumer’s personal information has been sold and the specific categories of personal information sold to each category of third party.

 

Right to Request Deletion

Subject to certain exceptions, you may request that your personal information that you have provided to us (as defined specifically by the CCPA) be deleted. We will comply with this request once we are able to confirm that we received a verified consumer request. Please be advised that we may deny your request to delete your personal information if we need to maintain your personal information in order to (1) complete a transaction, provide a service or goods, or perform a contract for which the personal information is collected; (2) help to ensure security and integrity; (3) debug products and to identify and repair errors that impair functionality of the Service or Site; (4) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law; (5) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.); (6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) comply with a legal obligation; or (9) otherwise use your personal information, for internal use only, that is compatible with the context in which you provide the personal information.

 

Right to Request Copies

You have the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months.

 

Right to Opt-Out

You have the right to opt-out of the sale, disclosure, release, transfer, or dissemination (collectively, “sale”) of your personal information. While we do not sell your personal information, we will disclose such information with third parties with your explicit consent as set forth in our Terms of Service and Privacy Statement. We will respect and honor your request to opt-out of the sale of your personally information, but please be advised that you may not be eligible to utilize certain aspects of the Services.

 

Right to Correct 

You have the right to request that we correct inaccurate personal information.

 

Right to Limit

You have the right to limit the use and disclosure of sensitive personal information.

 

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.

  • Performing Services. For example, creating, maintaining, customizing, and securing your account with us. Any personal information you provide us may be used to verify your identity.
  • Communications. For example, to communicate with you about the content and services or other products, content, or services in which you may be interested, or to respond to your inquiries or comments, or to periodically send notifications related to the services, such as notifications of changes to the services or policies.
  • Security. For example, maintaining the safety, security, and integrity of our website, products and services, databases, and other technology assets, and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests or court orders, and to comply with any applicable laws and regulations.
  • Debugging/Repair. For example, identifying and repairing errors in our websites' functionality.
  • Short-term, Transient Use. For example, nonpersonalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
  • Internal Research. For example, undertaking internal research for technological development and demonstration.

 

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 Statement, including:

  • With identified entities whose products or services you specifically use or request to receive while you use our Services, with disclosure only to specific partners with your explicit consent.
  • With entities conducting an audit on our behalf.
  • With your consent, such as with other selected third parties so that they may send you promotional materials about goods and services that they offer.
  • In response to legal process and when we believe that doing so is required by law (including laws applicable to our Affiliates and service providers), may be necessary to protect any person’s property, rights, or safety, or to investigate a potential violation of law, will help to enforce any terms of use or other legal agreement, or in the event of a corporate transaction, such as a divestiture, merger, consolidation, bankruptcy, or asset sale.

 

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 Privacy Statement.

 

In response to a verified consumer request to know what personal information was collected, disclosed, 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 disclosing that information. We will not merely refer the consumer to our general practices outlined in this Privacy Statement unless our response would be the same for all consumers and this Privacy Statement discloses all the information that is otherwise required for the response to such a consumer request.

 

Methods for Submitting Requests

You may submit Requests to Know, Requests to Correct, Requests to Opt-Out of Sale/Sharing, Requests to Limit, and Requests to Delete through 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 your requests. 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, correction of household personal information,  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, 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 provide 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 exercise any of your rights outlined above, 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 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

Identifiers

What We May Collect

  • Name
  • Alias
  • Postal address
  • Unique personal identifier
  • Online identifier (in the form of a universally unique identifier)
  • Internet Protocol Address
  • Email address
  • Date of birth
  • Phone number

 

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

What We May Collect

  • Name
  • Alias
  • Postal address
  • Unique personal identifier
  • Online identifier (in the form of a universally unique identifier)
  • Internet Protocol Address
  • Email address
  • Date of birth
  • Phone number

 

Protected classification characteristics under California or federal law

What We May Collect

  • Gender
  • Military/veteran status
  • Inferred citizenship (based on passport information you provide us)

 

Inferences drawn from other personal information

What We May Collect

  • Information to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

 

Biometric information

  • We do not collect information from this category

 

Geolocation data

What We May Collect

  • Internet Protocol Address
  • Precise Geolocation data

 

Professional or employment-related information

What We May Collect

  • Documents and/or information you choose to provide us related to your current or prospective employment

 

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

What We May Collect

  • Information you choose to provide us

 

Internet or other similar network activity

What We May Collect

  • Internet traffic’s country of origin and related information

 

Sensory data

  • We do not collect information in this category

 

Commercial information

  • We do not collect information in this category

 

Sensitive Personal Information

What We May Collect

  • Social Security, driver’s license, state identification card, or passport number
  • Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
  • Precise geolocation
  • Facial or ethnic origin, religious or philosophical beliefs, or union membership

 

We do not sell or share your sensitive personal information.

 

B. Business or Commercial Purposes and/or Uses

Please refer to our above Privacy Statement for a list of all the ways we may use the personal information.     

 

C. With Whom We May Disclose 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 Statement, including:

  • With identified entities or agencies whose products, services, or benefits you specifically use or request to receive while you use our services, with disclosure only to specific entities or agencies with your consent
  • With entities conducting an audit of our business on our behalf
  • With entities performing accounting, legal and regulatory compliance, security, and handling other internal functions, such as internal investigations on our behalf
  • With data analytics providers
  • With operating systems and platforms
  • With your consent, such as with other selected third parties so that they may send you promotional materials about goods and services that they offer
  • When we believe that doing so:
  • is required by law
  • is required to comply with a civil, criminal or regulatory inquiry, investigation, subpoena, or summons by federal, state of local authorities
  • is necessary to cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state or local law
  • may be necessary to protect any person’s property, rights, or safety
  • is necessary to investigate a potential violation of law
  • will help to enforce any terms of use or other legal agreement
  • is necessary in the event of a corporate transaction, such as a divestiture, merger, consolidation, bankruptcy, or asset sale. 

 

Additional State Privacy Rights

We will process data in accordance with applicable state laws and regulations based on your state of residence. To protect your privacy, we will respond to your privacy requests as required by any such applicable laws.  

 

For Virginia residents, you can appeal a decision we make related to your privacy requests by utilizing additional options for appeal that we may provide in our response or by contacting us at privacy@steadyapp.com or 10735 Jefferson Blvd. #1061, Culver City, CA 90230.

 

COOKIE NOTICE

Last updated: January 1, 2023

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 Sites. 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:

  • Essential website cookies: These cookies are strictly necessary to provide you with services available through our Sites and to use some of its features, such as access to secure areas.
  • Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Sites but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
  • Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Sites are being used or how effective our marketing campaigns are, or to help us customize our Sites for you.
  • Advertising cookies: These cookies are used to make advertising messages more relevant to you and they perform functions like preventing the same ad from continuously reappearing and in some cases selecting and displaying advertisements to you across the internet that are based on your interests.
  • Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Sites through third party social networking and other websites. These cookies may also be used for advertising purposes too.

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 Site.

 

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.