PRIVACY POLICY
1.
The following entity acts as the data controller of the personal data collected and processed through the 2Steps App: PSP PROSOCIALPLATFORM LTD (No. HE 402871), a company registered on October 09th, 2018, having its address at Amathountos, 202 MARINA GARDENS A, Flat/Office 8-9 Parekklisia, 4533, Limassol, Cyprus (hereinafter – “2Steps”, “we” or “us”).
2Steps has designated a Data Protection Officer that can be reached by sending a letter to the e-mail address: support@2steps.online or to 2Steps’s address mentioned above.
Before we explain why, when, how and what personal data 2Steps collects and processes about users, let explain some basic concepts related to the protection of personal data. We believe that this way you, either as a user or non-user of the App, will gain a better understanding and awareness of why 2Steps processes the chosen data in the processing of personal data.
2Steps has designated a Data Protection Officer that can be reached by sending a letter to the e-mail address: support@2steps.online or to 2Steps’s address mentioned above.
Before we explain why, when, how and what personal data 2Steps collects and processes about users, let explain some basic concepts related to the protection of personal data. We believe that this way you, either as a user or non-user of the App, will gain a better understanding and awareness of why 2Steps processes the chosen data in the processing of personal data.
| Personal data | Personal data is any information about an identified or identifiable individual (data subject). An identifiable individual is an individual that can be directly or indirectly identified, in particular by referring to a specific identifier (name, number, network identifier) or to one or more specific elements of a physical, physiological, genetic, psychological, economic, cultural or social identity of the individual. |
| Subject of personal data | This is an individual to which the personal data relates and which can be identified by personal data or which is identifiable. |
| Special categories of personal data (sensitive personal data) | This is a new designation of confidential personal data. It is about such personal data that the data subject alone can cause harm in society, at work, at the university or may lead to its discrimination. Such personal data usually reflects racial or ethnic origin, political views, religious or philosophical beliefs, membership in trade unions, or the processing of genetic and biometric data for the purpose of unique identification of a natural person and data on his health, sexual life or sexual orientation of an individual. By choosing to provide this information, the user consents to the processing of that information. |
| Administrator | The administrator is an individual or legal entity that determines the purposes and means for processing personal data and bears the primary responsibility for processing. If these terms and conditions are not specified for a particular service, the personal data administrator is 2Steps. |
| Processor | This is a natural or legal person who, on the basis of administrator instructions, processes personal data for the administrator. |
| Processing of personal data | Processing is any operation or set of operations that are performed with personal data or personal data sets using or without using automatic procedures, such as collection, recording, systematization, structuring, storage, updating or modification, search, viewing, use, access with transfer, distribution or any other provision of access, ordering or combining, limiting, deleting or destroying. |
2.
What Information Do We Collect?
2Steps is a service for people who have reached the age of majority, whose main goal is to meet and communicate with other people. You can use 2Steps’s service through a mobile application for the Android platform or iOS platform. By registering with 2Steps, you enter into a legal agreement with us and we process your data for providing the service in accordance with the terms of this Privacy Policy.
To become a 2Steps user, you need to create a profile. During registration, we ask you to provide the following information:
To become a 2Steps user, you need to create a profile. During registration, we ask you to provide the following information:
- name,
- email address,
- gender, date of birth,
- your location data.
You can also provide with other information about yourself by specifying in your profile, but this is optional. You control your profile and have constant access to this data in the "Profile" section on 2Steps, where all data can be corrected or updated (except for the name and email address).
Please be careful when placing in your profile such personal information as your health information or sexual orientation. Remember that the photos or videos that you post in 2Steps can disclose that kind of personal information. If you provide or upload personal information about yourself, you consent to its processing and publication in public.
In the interests of security and to improve the user experience, all users must undergo verification of the account. For verification, we send a letter to your e-mail address. This is necessary only to make sure that the e-mail address belongs to you. In addition, we are struggling with the creation of fake accounts that can be used to harm other users, as well as to commit cybercrimes - such accounts pose a threat to the 2Steps’s community and prevent other users from enjoying communication. We use your e-mail address based on the above legitimate interests and to prevent fraud and cybercrime.
To provide users with a free, non-premium service, we process a series of data (demographics and location) to attract targeted advertising for their legitimate interests, including the transfer of such data to advertisers. You can limit the transfer of such data in the settings, but you will still see advertisements, although they will be less relevant to you. In the security settings of your device, you also have the ability to prevent or restrict device IDs that will be passed on to third-party advertisers, as well as how to use these identifiers.
If you have geolocation enabled and want to turn it off, follow these instructions:
iPhone - Settings, Privacy, Geolocation Services, 2Steps
Android - Settings, Apps, 2Steps, Permissions, Location
We also want to keep in touch with you to inform you about our promotions and offers. If you agree with this, we will use your e-mail address to send you this information. You can change your decision at any time in the Settings app.
Please be careful when placing in your profile such personal information as your health information or sexual orientation. Remember that the photos or videos that you post in 2Steps can disclose that kind of personal information. If you provide or upload personal information about yourself, you consent to its processing and publication in public.
In the interests of security and to improve the user experience, all users must undergo verification of the account. For verification, we send a letter to your e-mail address. This is necessary only to make sure that the e-mail address belongs to you. In addition, we are struggling with the creation of fake accounts that can be used to harm other users, as well as to commit cybercrimes - such accounts pose a threat to the 2Steps’s community and prevent other users from enjoying communication. We use your e-mail address based on the above legitimate interests and to prevent fraud and cybercrime.
To provide users with a free, non-premium service, we process a series of data (demographics and location) to attract targeted advertising for their legitimate interests, including the transfer of such data to advertisers. You can limit the transfer of such data in the settings, but you will still see advertisements, although they will be less relevant to you. In the security settings of your device, you also have the ability to prevent or restrict device IDs that will be passed on to third-party advertisers, as well as how to use these identifiers.
If you have geolocation enabled and want to turn it off, follow these instructions:
iPhone - Settings, Privacy, Geolocation Services, 2Steps
Android - Settings, Apps, 2Steps, Permissions, Location
We also want to keep in touch with you to inform you about our promotions and offers. If you agree with this, we will use your e-mail address to send you this information. You can change your decision at any time in the Settings app.
3.
Legal Basis
Under the EU and the UK data protection laws (and other applicable data protection laws), we are required to inform you of our legal basis for using your personal data.
To the extent that we are provided with the consent of the person involved for the processing of personal data, the legal basis for processing is a Consent.
The legal basis for the processing of personal data necessary for the execution of an agreement, the provision of services, in which the User is one of the parties involved, is the Contractual Necessity. This also applies to processing operations that are required for the performance of pre-contractual activities.
If the processing of personal data is necessary to fulfill a statutory obligation that 2Steps must comply with, the legal basis is Legitimate Interests.
If there are vital interests of the User or another natural person that require the processing of personal data, the Legal Interest of the User is the legal basis.
If data processing is necessary to protect the legitimate interests of 2Steps or a third party, and the interests, fundamental rights and freedoms of the person involved do not override the previously mentioned interests, the Legitimate Interests of 2Steps and the third party shall be the legal basis for data processing.
To the extent that we are provided with the consent of the person involved for the processing of personal data, the legal basis for processing is a Consent.
The legal basis for the processing of personal data necessary for the execution of an agreement, the provision of services, in which the User is one of the parties involved, is the Contractual Necessity. This also applies to processing operations that are required for the performance of pre-contractual activities.
If the processing of personal data is necessary to fulfill a statutory obligation that 2Steps must comply with, the legal basis is Legitimate Interests.
If there are vital interests of the User or another natural person that require the processing of personal data, the Legal Interest of the User is the legal basis.
If data processing is necessary to protect the legitimate interests of 2Steps or a third party, and the interests, fundamental rights and freedoms of the person involved do not override the previously mentioned interests, the Legitimate Interests of 2Steps and the third party shall be the legal basis for data processing.
4.
What Data Is Going About Me If I Use The Mobile Application?
Wherever you are, with 2Steps you have the opportunity to communicate with your friends, make new acquaintances, and stay in touch with your contacts that you have purchased with our service. You can do this using a mobile application.
When you use a mobile application we collect information about your language, as well as your location (latitude and longitude). This information helps us determine your physical location so that we can determine the language of your region and provide an opportunity to communicate with people near you.
If you have enabled the location function, but you want to turn it off, you can do this in your device system settings.
2Steps and advertisers who are our partners can also store and use the identifier of your device to provide you with targeted advertising inside the application. You can opt out of targeted advertising by setting the appropriate settings in your profile. You can also refuse to provide data to third parties, but you will still see general ads in the application.
When you use a mobile application we collect information about your language, as well as your location (latitude and longitude). This information helps us determine your physical location so that we can determine the language of your region and provide an opportunity to communicate with people near you.
If you have enabled the location function, but you want to turn it off, you can do this in your device system settings.
2Steps and advertisers who are our partners can also store and use the identifier of your device to provide you with targeted advertising inside the application. You can opt out of targeted advertising by setting the appropriate settings in your profile. You can also refuse to provide data to third parties, but you will still see general ads in the application.
5.
How Long Does 2STEPS Keep My Data?
We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. If you do not use your account for 24 months, your profile and any associated data will be deleted. When you request the removal of your profile via an application, it, and all associated personal data immediately becomes unavailable and completely deleted within 30 days.
Our correspondence with our support team will be kept longer so that we can use it for any subsequent requests that may arise. Such correspondence deleted after 3 years in the absence of requests.
Anonymous information about activity on 2Steps persists longer for statistical data and marketing research, but it does not correlate with you after deleting the profile, that is, becomes anonymous. This is because 2Steps seeks to develop its services and opportunities for more convenient communication and this period is justified by our legitimate interest.
Information such as IP addresses, mobile numbers and e-mail addresses is retained to combat fraud and spam as long as it is relevant.
Our correspondence with our support team will be kept longer so that we can use it for any subsequent requests that may arise. Such correspondence deleted after 3 years in the absence of requests.
Anonymous information about activity on 2Steps persists longer for statistical data and marketing research, but it does not correlate with you after deleting the profile, that is, becomes anonymous. This is because 2Steps seeks to develop its services and opportunities for more convenient communication and this period is justified by our legitimate interest.
Information such as IP addresses, mobile numbers and e-mail addresses is retained to combat fraud and spam as long as it is relevant.
6.
What Information 2STEPS Collects About Me, If I Still Have No 18 Years?
2Steps deliberately does not collect any information about minors. We do not engage or encourage the use of our service by persons under the age of majority. If we become aware of the registration of a user under the age of majority, the statutory residence of an EU citizen and the provision of their personal data, we will take measures to remove such profile and any information about it from 2Steps.
If we deleted your profile because you violated our minimum age rule, we can save your email and IP addresses so you do not try to bypass our rules by creating a new profile.
If we deleted your profile because you violated our minimum age rule, we can save your email and IP addresses so you do not try to bypass our rules by creating a new profile.
7.
With Whom 2STEPS Shares My Data?
We can provide third parties, such as payment systems, advertisers, postal services, aggregate information that includes your personal data (but does not directly identify you) together with other information, including third-party data, for market analysis and demographic data to show relevant ads about other products and services.
We share your data with the following categories of third parties:
We share your data with the following categories of third parties:
Categories of persons: |
Disclosable data: |
|---|---|
| Moderators who track activity in content review apps. | Name and registration details, profile details, messages and photos |
| Advertising partners and targeted advertising providers. | Ad identifier linked to your device (device ID), age, gender and IP address (and your assumed location based on your IP address) |
| Law enforcement agencies | Any personal information provided by you, depending on the nature of the request or concern, when required by law, when a potential crime is being investigated, or when it is necessary to protect someone's vital interests |
| Fraud prevention and anti-spam services to protect the service from criminal activity | Email address, phone number, IP address and IP session information, social network identifier, username, user agent string |
We may use third party Service Providers to monitor and analyze the use of our Service: Firebase, Amplitude, Branch
Firebase is analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Amplitude is an analytics service provided by Amplitude, Inc.
For more information on the privacy practices of Amplitude, please visit the Amplitude Privacy & Terms web page: https://amplitude.com/privacy
Branch is a linking and analytics platform for app and website developers provided by Branch Metrics, Inc.
For more information on the privacy practices of Branch, please visit the Branch Privacy & Terms web page: https://branch.io/policies/privacy-policy/
We may also use the following third party service providers:
Qonversion is a service for automating and optimizing the marketing and monetization of the app by
For more information on the privacy practices of Qonversion, please visit the Privacy & Terms web page: https://qonversion.io/page/privacy.
Applovin is a service for automating and optimizing the marketing and monetization of the app by Qonversion Inc.
For more information on the privacy practices, please visit the Applovin Privacy & Terms web page: https://www.applovin.com/privacy
OneSignal is a customer engagement platform provided by OneSignal for companies around the world to enable relationships for them and their customers. This is primarily done by leveraging first party data to personalize and automate messaging through first party channels, such as email, mobile push notifications, web push notifications, and in-app messaging.
For more information on the privacy practices of OneSignal, please visit the OneSignal web page: https://onesignal.com/privacy_policy.
We guarantee that these parties act in accordance with the data protection and confidentiality provisions of this Privacy Policy. We do our best to ensure that all data remains as anonymous, in hashed, non-human readable form.
In the event that 2Steps or any of our partners who own your data legally transfers business or changes ownership, for example, due to the takeover by another company or the merger, reorganization or sale of all or part of the assets, as well as in case of insolvency, we can be required to disclose your personal information.
Firebase is analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Amplitude is an analytics service provided by Amplitude, Inc.
For more information on the privacy practices of Amplitude, please visit the Amplitude Privacy & Terms web page: https://amplitude.com/privacy
Branch is a linking and analytics platform for app and website developers provided by Branch Metrics, Inc.
For more information on the privacy practices of Branch, please visit the Branch Privacy & Terms web page: https://branch.io/policies/privacy-policy/
We may also use the following third party service providers:
Qonversion is a service for automating and optimizing the marketing and monetization of the app by
For more information on the privacy practices of Qonversion, please visit the Privacy & Terms web page: https://qonversion.io/page/privacy.
Applovin is a service for automating and optimizing the marketing and monetization of the app by Qonversion Inc.
For more information on the privacy practices, please visit the Applovin Privacy & Terms web page: https://www.applovin.com/privacy
OneSignal is a customer engagement platform provided by OneSignal for companies around the world to enable relationships for them and their customers. This is primarily done by leveraging first party data to personalize and automate messaging through first party channels, such as email, mobile push notifications, web push notifications, and in-app messaging.
For more information on the privacy practices of OneSignal, please visit the OneSignal web page: https://onesignal.com/privacy_policy.
We guarantee that these parties act in accordance with the data protection and confidentiality provisions of this Privacy Policy. We do our best to ensure that all data remains as anonymous, in hashed, non-human readable form.
In the event that 2Steps or any of our partners who own your data legally transfers business or changes ownership, for example, due to the takeover by another company or the merger, reorganization or sale of all or part of the assets, as well as in case of insolvency, we can be required to disclose your personal information.
8.
What Data Others Can See About You
When using the app, keep in mind that any data you post or send in the app may be available to both app users and others. Users should be careful about what information they post, as it can become publicly available.
The information in your profile, as well as other information you disclose in the app, including certain data added to your profile through other accounts, can be viewed by others. They may also share this information with individuals who are not users of the app. For example, someone might suggest that one of their friends meets you by taking a screenshot of your profile picture and sending it, regardless of whether their friend is a user of the app.
The information in your profile, as well as other information you disclose in the app, including certain data added to your profile through other accounts, can be viewed by others. They may also share this information with individuals who are not users of the app. For example, someone might suggest that one of their friends meets you by taking a screenshot of your profile picture and sending it, regardless of whether their friend is a user of the app.
9.
Your Rights
You have the right to lodge a complaint with data protection regulators. 2Steps has its main office at Amathountos, 202 MARINA GARDENS A, Flat/Office 8-9 Parekklisia, 4533, Limassol, Cyprus. and the Information Commissioners’ Office (ICO) is our lead regulator. You can find out how to make a request to the ICO. If you are in the EU, you can also contact the local data protection authority who can communicate with the information authority on your behalf.
You have a number of rights under the European Data Protection law if you are an EU citizen.
You have a number of rights under the European Data Protection law if you are an EU citizen.
| 1. | Right to be informed: what personal data an organisation is processing and why (this notice). |
| 2. | Right of access: you can request a copy of your data. |
| 3. | Right of rectification: if the data held is inaccurate, you have the right to have it corrected. |
| 4. | Right to erasure: you have the right to have your data deleted in certain circumstances. |
| 5. | Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained. |
| 6. | Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider. |
| 7. | Right to object: in certain circumstances (including where data is processed on he basis of legitimate interests or for the purposes of marketing) you may object to that processing. |
| 8. | Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process. |
If you want to exercise any of your rights listed above please visit Feedback Page or email us at support@2steps.online. For your protection and the protection of our users, we may request certain information to verify your identity before processing your request.
If you do not agree with the way we have handled your request or your personal information, contact the first order authority using the contact information listed above.
If you feel we have not resolved your concern, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you live in a country or territory located in the European Union (EU) or the European Economic Area (EEA), you may also get in touch with your local Data Protection Regulator. If you live in a country outside the EU, you may have the right to lodge a complaint with your local privacy or data protection regulator.
If you do not agree with the way we have handled your request or your personal information, contact the first order authority using the contact information listed above.
If you feel we have not resolved your concern, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you live in a country or territory located in the European Union (EU) or the European Economic Area (EEA), you may also get in touch with your local Data Protection Regulator. If you live in a country outside the EU, you may have the right to lodge a complaint with your local privacy or data protection regulator.
10.
How Does 2STEPS Protect My Personal Data?
2Steps takes the necessary security measures to protect and prevent loss, misuse and alteration of information under our control, including your personal data. Our technical specialists are constantly working to ensure that 2Steps remains safe and secure.
While we take reasonable precautions against possible security breaches of our member database and records internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with 2Steps, your personal data may be compromised. If that happens, please report it to Support via Feedback page.
In order to prevent misuse of 2Steps by a user whose profile/account has expired or been deleted, we will retain information we deem necessary to prevent that user from creating a new account in violation of our Terms of Service and to ensure compliance with all laws and legal regulations.
Please note: Even after your account is deleted or after you delete information from your profile, other users and non-users will be able to see copies of that information to the extent that it was previously disclosed to them, or to the extent that other users have saved or copied it. We have no control over this and assume no obligation to do so. If you have given third-party applications or sites access to your personal information, they may retain that information in accordance with their terms of service and privacy policy
While we take reasonable precautions against possible security breaches of our member database and records internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with 2Steps, your personal data may be compromised. If that happens, please report it to Support via Feedback page.
In order to prevent misuse of 2Steps by a user whose profile/account has expired or been deleted, we will retain information we deem necessary to prevent that user from creating a new account in violation of our Terms of Service and to ensure compliance with all laws and legal regulations.
Please note: Even after your account is deleted or after you delete information from your profile, other users and non-users will be able to see copies of that information to the extent that it was previously disclosed to them, or to the extent that other users have saved or copied it. We have no control over this and assume no obligation to do so. If you have given third-party applications or sites access to your personal information, they may retain that information in accordance with their terms of service and privacy policy
11.
Where Is My Personal Information Keeping?
To ensure the smooth operation of our service and you can always stay in touch with your friends, we use a network of servers including outside the European Union and (for Users located in Russia) Russia. This hardware is located in third-party data centers that are located in territories offering necessary legal protection, that comply with all relevant personal data protection legislation and with which we have signed the relevant agreements concerning personal data of the users.. The data collected by our advertising partners can also be stored outside the European Economic Area. We guarantee that the data will be adequately protected and that existing legal schemes such as those approved by the EU (EU approved model clauses (which can be found here) and the countries hosting the software and hardware for confidentiality will be respected, and reliable contractual standards will be implemented. If you want more information about our security measures, please write to us at support@2steps.online.
12.
What Data 2STEPS Receives If I Would Contact The Support Team?
If you contact our support team by writing to support@2steps.online or, we will receive your e-mail address, and we can track your IP address and the information you receive from us to help solve your problem. We will keep records of our correspondence with you, including any complaints that we receive from you about other users (and from other users about you) within 3 years after the deletion of your account.
13.
For What Goals 2STEPS Uses My Personal Data?
We can use the materials that you place in the public domain in 2Steps, for advertising purposes on the sites and in the applications of our partners. This meets our legitimate interests and allows us to improve the service and make it more attractive to users.
We use your personal data to resolve disputes, resolve problems and enforce our Terms of Service.
We use your personal data to resolve disputes, resolve problems and enforce our Terms of Service.
14.
Policy Amendments
2Steps may revise this Privacy Policy from time to time. The most current version of the policy always takes precedence when regulating our use of your information and can be found in application and on its designated page on the Play Market (Android) and App Store (iOS). If we make material changes to this policy, we will notify you, for example, by sending an email to the e-mail address associated with your account or by posting a notice on the 2Steps app.
The date this Privacy Policy was last modified: October 11, 2022. Effective from October 11, 2022.
The date this Privacy Policy was last modified: October 11, 2022. Effective from October 11, 2022.