LAST UPDATED: Apr 6, 2025
Privacy Notice
This Privacy Notice (“Notice”) is designed to help you understand how StepoAI Inc. (“StepoAI”, “we”, “us”, or “our”) collects, uses, and shares your personal information and help you understand and exercise your privacy rights. This Notice applies to StepoAI’s processing of personal information including on our website available at https://stepo.ai/ and our other online or offline offerings which link to, or are otherwise subject to, this Notice (collective, the “Services”).
Disclosure Regarding Client Data. This Privacy Notice does not apply to the personal information we process on behalf of our clients pursuant to a written agreement we have entered into with such clients (“Client Data”). Our clients’ respective privacy notices or policies govern their collection and use of Client Data. Our processing of Client Data is governed by the contracts that we have in place with our clients, not this Privacy Notice. Any questions or requests relating to Client Data should be directed to our client.
Disclosure Regarding International Data Processing. StepoAI is a global company headquartered in the United States. Many of our IT and other functions are administered centrally in the United States and any information you provide or we collect may be transmitted to a country other than your country of residence for processing or storage, and it may also be communicated to third parties hired by us to provide services such as website hosting, database management, or analytics. By using our Services, you voluntarily consent to the collection, control, creation, use, storage, and processing of your personal information in any country to which we may transfer your personal information in the course of our business operations including the United States. For more information, please see International Transfers of Personal Information. For information on our processing of personal information subject to applicable jurisdictional requirements (including the European Union or United Kingdom laws), please see Annex A – Supplemental Country/Regional Notices.
1. UPDATES TO THIS PRIVACY NOTICE
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE PERSONAL INFORMATION
4. HOW WE DISCLOSE PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
10. CHILDREN’S PERSONAL INFORMATION
11. THIRD-PARTY WEBSITES/APPLICATIONS
12. LANGUAGES OTHER THAN ENGLISH
ANNEX A: SUPPLEMENTAL COUNTRY/REGIONAL NOTICES
ANNEX B: SUPPLEMENTAL CONSUMER HEALTH DATA PRIVACY STATEMENT
We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website and/or we may also send other communications.
We collect personal information you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.
We may collect personal information that you provide to us.
We may collect personal information automatically when you use the Services.
Our uses of these Technologies fall into the following general categories:
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
We may collect personal information about you from third parties.
We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to market our products and Services, as described below.
We use personal information to fulfill our contract with you and provide the Services, such as:
We use personal information for various administrative purposes, such as:
We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law and such materials will include opt out instructions.
California Shine the Light: If you are a California resident, you may annually submit a request to us to find out whether we have shared your personal information with third parties for the third parties’ direct marketing purposes. If you would like to submit such a request, please “Contact Us.”
If you have any questions about our marketing practices or would like to modify your marketing preferences, please contact us at any time as set forth in “Contact Us” below.
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.
We may engage in automated decision making, including profiling. StepoAI’s processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making.
If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
We may disclose any of the personal information we collect to the categories of third parties described below.
Some of the service providers we may use include:
Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction as permitted by law and/or contract.
Your Privacy Choices. The privacy choices you may have about your personal information are described below and in the Annex A – Supplemental Country/Regional Notice, where relevant.
Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.
The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws. You may be entitled to additional rights depending on where you live. If you live in a country offering comprehensive privacy rights, please review Annex A – Supplemental Country/Regional Notice below.
Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.
To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.
Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
We employ reasonable physical, technical, and administrative safeguards designed to keep personal information secure; however, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
It is your responsibility to protect against unauthorized access to your password, phone, tablet, and computer by, among other things, signing off after using a shared device, choosing a robust password nobody else knows or can easily guess, and keeping log-in information and passwords private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. Where required by applicable law, you may request access to information about our security policies and procedures by contacting us as described in “Contact Us” below.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We comply with laws governing the international transfer of personal information typically through the execution of legally required data protection agreements incorporating, where applicable, standard contractual clauses approved for use by the European Union or regulators of other jurisdictions, or other instructions that may be specified, updated, amended, replaced, or superseded from time to time by the applicable regulatory authority. Where required by applicable law, you may request access to information about the transfer safeguards we use by contacting us as described in “Contact Us” below.
We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
The Services are not directed to children under 18 and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
StepAI is the controller of the personal information we process under this Privacy Notice. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:
StepoAI Inc.
12819 SE 38th St, 314,
Bellevue, WA 98006
privacy@stepo.ai
ANNEX A – SUPPLEMENTAL COUNTRY/REGIONAL PRIVACY NOTICES
This Supplemental Notice only applies to our processing of personal information subject to the European Union General Data Protection Regulation (“GDPR”) and the United Kingdom Data Protection Act (“DPA”).
A. LEGAL BASES
In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.
If we process personal information considered a “special” or “sensitive” category of personal information, then our processing of such personal information may be supported by one or more of the following conditions:
If your personal information is subject to the applicable data protection laws of the European Union or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.
If you are located within the European Union, you may find the contact details of the competent authorities in the following link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
If you are located within the United Kingdom, you may lodge a complaint with the Information Commissioner’s Office (ICO) by clicking here: https://ico.org.uk/make-a-complaint/.
B. CONTACT US
StepoAI is the controller of the personal information we process under this Privacy Notice. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact our Privacy and Data Protection Team at:
StepoAI Inc.
12819 SE 38th St, 314,
Bellevue, WA 98006
privacy@stepo.ai
If you wish to receive a response by email, please be sure to include your name, postal address, and email address. If we do not receive an email address, we will respond by postal mail.
ANNEX B – SUPPLEMENTAL CONSUMER HEALTH DATA PRIVACY STATEMENT
This Supplemental Consumer Health Data Privacy Statement (“Consumer Health Data Privacy Statement”) supplements StepoAI’s Privacy Notice.
This Supplemental Consumer Health Data Privacy Statement only applies to personal information that we process that is “consumer health data” subject to the Washington My Health My Data Act (“MHMDA”) or Nevada’s Consumer Health Data Privacy Law (“NVCHDPL”) (as applicable).
Terms used in this Supplemental Consumer Health Data Privacy Statement that are defined in MHMDA or NVCHDPL will have the meaning set forth in those laws to the extent such laws are applicable.
CONSUMER HEALTH DATA WE COLLECT
Under the MHMDA, “consumer health data” is defined as “personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status.”
Under NVCHDPL, “consumer health data” is defined as “personally identifiable information that is linked or reasonably capable of being linked to a consumer and that a regulated entity uses to identify the past, present or future health status of the consumer.”
Because consumer health data is defined very broadly, many of the categories of personal information that we collect under our Privacy Notice may also be considered consumer health data.
Examples of consumer health data that you may provide to us, or that we may otherwise collect, may include:
SOURCES OF CONSUMER HEALTH DATA
We collect consumer health data that you provide to us, consumer health data we collect automatically when you use the Site, and consumer health data from third-party sources, as described in our Privacy Notice and below.
WHY WE COLLECT AND USE CONSUMER HEALTH DATA
We collect and use consumer health data for the purposes and in the manner described in the “How We Use Personal Information” section of our Privacy Notice.
Primarily, we collect and use consumer health data as reasonably necessary to provide you with the products or Site you have requested or authorized. This may include delivering and operating the products or Site and their features, personalization of certain product or Site features, ensuring the secure and reliable operation of the products or Site and the systems that support them, troubleshooting and improving the products and Site, and other essential business operations that support the provision of the products and Site (such as analyzing our performance and meeting our legal obligations).
We may also use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law.
SHARING OF CONSUMER HEALTH DATA
We may share each of the categories of consumer health data described above for the purposes described above and in the “How We Use Personal Information” section of our Privacy Notice.
We only share or disclose your Consumer Health Data as needed to provide you with the products or services that you request, or with your explicit consent. We may share or disclose any or all the above categories of Consumer Health Data to the following entities, who shall use the data only as permitted for the purposes set forth above, and within the bounds of our contracts with them:
These general categories of third parties:
In addition, we may share or disclose Consumer Health Data as permitted or required by law, such as (i) to an acquiring organization if we are involved in a sale or a transfer of our business, (ii) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, (v) as needed to support external auditing, compliance and corporate governance functions, (vi) as needed to preserve the integrity or security of our systems, or (vii) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or Federal law.
HOW TO EXERCISE YOUR RIGHTS
MHMDA and NVCHDPL provide consumers with certain rights with respect to consumer health data.
Under MHMDA, consumers have the right to: (i) confirm whether StepoAI is collecting, sharing, or selling consumer health data and to access such data; (ii) withdraw consent from StepoAI’s collection and sharing of consumer health data; and (iii) request that StepoAI delete consumer health data.
Under NVCHDPL, consumers have the right to: (i) confirm whether StepoAI is collecting, sharing or selling consumer health data; (ii) have StepoAI provide the consumer with a list of all third parties with whom StepoAI has shared consumer health data relating to the consumer or to whom StepoAI has sold such consumer health data; (iii) request that StepoAI cease collecting, sharing, or selling consumer health data relating to the consumer; and (iv) request that StepoAI delete consumer health data.
The rights afforded to consumers under MHMDA and NVCHDPL are subject to certain exceptions.
Subject to certain legal limitations and exceptions, you have the following rights with respect to any Consumer Health Data we may collect about you:
You may submit a request pursuant to any of these rights by contacting us as described in “Contact Us.”
StepoAI will not discriminate against you for exercising any of your rights. We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. Please allow 45 days for a response. We may, after receiving your request, require additional information from you to authenticate your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.