STAY ON TRACK PRIVACY POLICY

Please read this Privacy Policy carefully before using Stay on Track. 


This Privacy Policy is aimed to inform you (“You”) as a user of Stay on track (the “Application”, “App”, “Service”) about the information Mobilious Limited (“we”, “us”, “our”), having registered office at Karaiskaki 13, 3032, Limassol, Cyprus, as the Application developer, collects, how that information may be used, with whom it may be shared, and Your options about such use and disclosure. 


This Privacy Policy is incorporated into, and is subject to, the Application’s Terms of Use. By choosing to use our Service You: (i) agree to the collection and use of information in relation to this Privacy Policy, (ii) warrant and guarantee that You are over 16 years of age (or are a parent or guardian with such authority to agree to this Privacy Policy for the benefit of an individual under 16 years of age). Please do not use the Application or access the Service provided by it if You do not agree to this Privacy Policy.

What kind of information do we collect?

We may collect information that can identify You (“Personal Information”) and other information that does not directly identify You, as listed below.

Information You provide

age, height, weight, target weight, average physical activity level, goals for losing, maintaining or gaining weight, medical conditions, food preferences, images of Your food (if respective functionality is available) and preferences for daily calorie intake. We may collect and store the abovementioned information when You provide it to us in order to use the Service or in some other manner, for example by corresponding with us (by email or chat, for instance) when You report a problem with the Service or when You subscribe to any of our services, or search for a service.

Note: Information about a third party

When You provide us with information about a third party, You must have the consent of that third party before providing us with that information. By providing us with information regarding a third party You warrant that You have their permission to provide that information to us.


Information collected automatically

Device information: may include information specific to Your mobile device (e.g., OS Version, hardware model, unique device identifier, mobile network information); information about Your logging in, use of features, functions, or notifications on the device. We also collect and use Your Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID) to recognize Your device and support advertising activities on our Services. These number values are not permanently tied to Your device and, depending on Your operating system, You can reset it through Your device settings.

Usage information: information about the use of the App, such as frequency of use, engagement with particular features, which sections of the App user visits and common use patterns.

Location: IP address, time zone, mobile service provider.

UPON YOUR CONSENT, THE APP MAY ALSO HAVE ACCESS TO YOUR CAMERA ROLL AND/OR CAMERA, AND/OR MOTION AND FITNESS MODULE (THE “LIBRARIES AND UTILITIES”). IF YOU DO NOT ALLOW THE ACCESS TO YOUR LIBRARIES AND UTILITIES, YOU MAY NOT BE ABLE TO USE THE APP OR SOME OF ITS FEATURES.


For instance, for iOS devices, We will provide You with functionality allowing You to recognize the food You may eat and approximate calories in such food, by Your image of such food. We will not be able to provide the mentioned functionality unless You allow us access to Your camera roll and/or camera. We will not use any of Your images other than for the purpose of provision of food recognition functionality.


WE DO NOT HAVE ACCESS TO ANY MATERIAL, INCLUDING IMAGES, THAT YOU UPLOAD OR IMPORT TO THE SERVICE IN CONNECTION WITH YOUR USE OF THE APP. YOU CAN DELETE THE FILES YOU HAVE STORED IN THE APP BY USING THE AVAILABLE DELETION FUNCTIONS.

What do we collect this information for?

enhancing Your user experience on our Application by operating, maintaining, and providing You with all of the content and features of the Services ("maintaining Service functionality purposes");

providing You with customer support. We may use Your Personal Information to respond to Your requests for technical support, Service information or to any other communication You initiate (“customer support purposes”);

performing research and analysis about Your use of, or interest in, our products, services or content, or products, services or content offered by others (“analytics purposes”);

communicating with You via push notifications, reminders about the Service. You can opt out of receiving push notifications by changing the settings on Your device;

developing and providing content and advertising tailored to Your interests on our and other third-party services (“marketing purposes”);

detecting and resolving any fraud or other illegal or undesirable user behavior;

arranging advertising campaigns, analysis of advertising campaigns effectiveness ("marketing purposes") to the extent permitted by the law;

taking other legally-required actions.

As regards emails, during in-app registration/onboarding process we may ask you to login into the app based on the email in order to create account/save your progress. In this regard, we will process your email data because we need to perform a contract with you. 


In addition to above, we may also use your email address to verify whether such email is correct; let you know about important updates to our terms and policies; communicate with you about our Service or similar products that might be of interest for you, ask for your feedback. Should you opt-in (or we are allowed based on your country laws), we may also send you other marketing communications, such as product updates, offers, discounts, and provide news and information that we think will be of interest to you. All email communications are performed based on our legitimate interest.


In a very limited number of cases depending on application store’s requirements, we may also use your email for matching and attribution. Such marketing activities are also based on our legitimate interest. 


Please note that when we process your email data on the bases of legitimate interests for direct marketing purposes, you have an unrestricted right to object to the processing; this also applies to matching and attribution. Should you wish to exercise your right to object, please email us via any of the contact options available below.


With whom do we share this information and how may we disclose it?

Service Providers


We may share Your information with third parties that perform certain services on our behalf, such as our authorized service providers or analytics providers. In general, the third-party providers engaged by us will only collect, use and disclose Your information to the extent necessary to allow them to perform the services they provide to us, e.g. facilitating our Service and analyzing how our Service is used. 


You can learn more about main service providers with whom we may share Your information as described above hereunder, along with links to such service providers privacy policies, which we recommend You to read:


1) AppsFlyer

We use AppsFlyer for for the following purposes:

analytics purposes, specifically for research and analysis of users’ interaction with the Application.

Appsflyer helps us to understand, in particular, how users find our App (for example, which advertiser served an ad that led You to our App in application store). Appsflyer also provides us with different analytics tools that enable us to research and analyze Your use of the Service.

marketing purposes

Appsflyer helps us to tailor our and third parties’ ads to Your interests and show the relevant ads to You.

In order to receive these services from Appsflyer, we share such data as:

device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier (“technical information”);

information relating to Your actions in the App, such as: downloads and installations of Applications, and other interactions, events and actions, such as add to cart, in-app purchases made, clicks, engagement time etc. (“engagement information”).

IP address (which may also provide general location information), User agent, IDFA (Apple identifier for advertisers), Google Advertiser ID and other unique identifiers (“technical identifiers”).

You can learn more about the AppsFlyer Privacy Policy here: https://www.appsflyer.com/privacy-policy/. Please note that You may cancel collection of Your information for and sharing it with AppsFlyer here: https://www.appsflyer.com/optout.


2) Amplitude

We use Amplitude for analytics and customer support purposes, specifically to understand how customers use our App.

As for analytics purposes, Amplitude helps us to understand, in particular, how users find our App (for example, which advertiser had delivered an ad that led You to our App in the app store). Amplitude also provides us with different analytics tools that enable us to research and analyze Your use of the Service, which helps us to decide what Application features we should focus on.

As for customer support purposes, Amplitude helps us to respond to Your requests for technical support. For example, it enables us to track Your interaction with our App and in order to detect particular technical issues with the App.

In order to receive those services from Amplitude, we share such data as:

Platform, device type (phone or tablet), device family, country, city, region, carrier, OS, time zone, language, IP Address, locale, referral source (“technical information”);

Your interaction with the App (i.e. taps on the particular screens) and age (“user related information”);

Unique identifiers. (such as IDFA).

Amplitude is EU-US Privacy Shield certified, which You can verify and learn more about here: https://www.privacyshield.gov/participant?id=a2zt000000001XZAAY&status=Active.

You can learn more about the Amplitude Privacy Policy here: https://amplitude.com/privacy.


3) Firebase Cloud Messaging


We use Google-powered service Firebase Cloud Messaging in order to deliver in-app messages (notifications or data messages) which may be of interest for you, as well as analyse effectiveness of such in-app messages, check their delivery status so that such messages are as relevant as possible. 


Firebase Cloud Messaging collects your user-related data to process the delivery of in-app messages and allow us to assess their effectiveness. Such user-related data may include characteristics of your device, app store, advertizing identifier, device’s language, OS version, your age, interactions with notifications, data messages, status of messages delivery etc, subscription status and some other data. 


Please read Firebase Data Processing and Security Terms and Privacy and Security in Firebase for further information on Firebase privacy practices. 


4) Firebase Crashlytics


Firebase Crashlytics is a Google-powered service, which allows us to track application performance, i.e. we can discover the causes and severity of crashes in our App. 

In order to provide the services, Crashlytics collects your device-related and app-interaction data, such as the timestamp of when the crash occurred, technical characteristics of particular crash and your device etc. 


Please review Privacy and Security in Firebase as well as Crashlytics and App Distribution Data Processing and Security Terms to learn more about data collection related to Crashlytics. 


5) Amazon Mobile Analytics

We use Amazon Mobile Analytics, which is an Amazon service for collecting, visualizing and understanding app usage data at scale, to learn and analyse how our App is being used.

With the Amazon Mobile Analytics help we can collect and analyse the following information regarding our Application:

General – monthly active users; daily active users; new users; daily sessions; sticky factor; 1-day retention; average revenue per daily active user; daily paying users; average revenue per paid daily active user;

Active users – tracking how many users engage with our App daily and monthly and to monitor their stickiness to improve engagement, monetization and appeal;

Sessions – tracking how often our App is used on a given day and how often each user opens our App during a day;

Revenue – tracking in-app revenue trends to identify areas for monetization improvement;

Retention – tracking the rate at which users come back to our App on a daily and weekly basis.

In order to receive these services from Amazon Mobile Analytics, we share such data as:

Daily active users, monthly active users and new users;

Sticky factor (daily active users divided by monthly active users);

Session count and average sessions per daily user;

Average revenue per daily active user and average revenue per paid daily active user;

Day 1, 3 and 7 retention and week 1, 3 and 7 retention.

You can learn more about the Amazon Privacy Policy here: https://aws.amazon.com/privacy/.


6) Intercom (Intercom R&D Unlimited Company, an Irish company with offices at 2nd Floor, Stephen Court, 18-21 St. Stephen's Green, Dublin 2, Republic of Ireland) [applicable to iOS users only]


We have incorporated an Intercom live chat to provide you with a fast connection with our customer support. 


In order to enable the Intercom live chat functionality, we may share such data as operating system type and version number, manufacturer and model; browser type and language; screen resolution; IP address; unique device identifiers (‘device data’); time you spent on a page or screen; navigation paths between pages or screens; session date and time; activity status (including first seen, last seen, last heard from - and last contacted); pages viewed; links clicked; language preferences; Intercom assigned user identifier (‘service data’).


Further, in order to work correctly, Intercom may place cookie to your device (if relevant). Nonetheless, Intercom does not collect, retain, or share data regarding a particular user's activity across multiple websites or applications. Intercom does assign each user a unique user ID within the scope of an individual website, but does not collect or retain IP or any information that would allow Intercom to identify the same particular user on more than one website. 


7) Google Vision [applicable to iOS users only]


We use Google Vision in order to provide You with functionality allowing You to recognize the food You eat by Your image of such food and, consequently, share the photo of Your food with Google. Based on Google’s representation, GOOGLE WILL NOT USE Your photo for the purpose, OTHER then recognition of the food You eat. You may familiarize with more detailed privacy-related information as regards Google Vision via the link: https://cloud.google.com/vision/docs/data-usage 


8) Apple Health Kit [applicable to iOS users only]


Provided that you opt in, We may also obtain access to Your personal information (such as Your motion data, data on your weight and device from which weight data has been collected) from and share Your Personal Information with the Apple HealthKit on Your iOS device for the purpose of provision of activity tracking functionality of our App. We will not transfer or otherwise dispose of data from Apple Health Kit; instead, data from Apple HealthKit will be used solely for maintenance of relevant App functionality. 


Separately, please be aware that procession of data we tranfer to HealthKit is subject to Apple privacy-related regulations and may not be controlled by us. For more information on how Apple processes Your data collected within Apple Health Kit, please see https://developer.apple.com/documentation/healthkit/protecting_user_privacy


9) Facebook Pixel (if data processing concerns EU, UK citizens and certain other jurisdictions: by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland; for processing of data originating from other jurisdictions: Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA)


The Facebook pixel is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions the users take within the Service. Facebook may collect or receive information from our Product and use that information to provide measurement services and targeted ads.


Please mind that you may opt-out of the collection and use of information for ad targeting. Options you may use in order to opt-out, are described below in this Privacy Policy. Some of the and mechanisms for exercising the choice to opt out are via the links: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.


10) Send Pulse (SendPulse Inc., 220 E 23rd St #401, New York, NY 10010)

In order to deliver customized emails or web push-notifications to our customers, we transfer customer-related data, such as e-mail address, device information, payment status, subscription date and user’s precise location to a Send Pulse – marketing personalization platform . 


You can access the Send Pulse Privacy Policy via the link: https://sendpulse.com/legal/pp.

10) FitBit [for Android devices only]

Provided that you opt in, We may obtain access to Your personal information, such as general quantity of steps during the day or during workout per minute; as well as share Your personal information, such as your activity/workout details (burned calories, start time/date and duration of workout, distance, system used for distance measurement) to FitBit. Please be aware that procession of Your data by FitBit shall be performed based on FitBit Privacy Policy, which may be accessed via the link: https://www.fitbit.com/global/us/legal/privacy-policy#info-we-collect 

11) The App may provide links to external groups/communities at external platforms, e.g., Facebook. We do not control handling data processing at such external platforms; any data related operations at such platforms are regulated under the terms/policies of each specific platform. Nonetheless, we may collect certain aggregated data on users’ behaviour within linked external groups/communities, such as poll results, user experience comments etc. without any link/not in conjunction to/with personally identifiable information. 


12) Front (FrontApp, Inc., 1455 Market Street, 19th Floor, San Franisco, CA 94103)


In order to provide you with swift and smooth customer support we use Front - software allowing us to optimise users' and customer support's conversations. In this regard, Front receives and stores copies of all data related to your customer support requests, such as emails, purchase details, feedback etc.  


13) Facebook Conversions API (if data processing concerns EU, UK citizens and certain other jurisdictions: by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland; for processing of data originating from other jurisdictions: Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA)


We use Facebook Conversion API in order to maximise effectiveness of our marketing/advertising campaigns, measurement services and targeted ads. At that, Facebook may collect or receive certain information from the App, for example, information on your interaction within the App. 


Please mind that you may opt-out of the collection and use of information for ad targeting. Options you may use in order to opt-out, are described below in this Privacy Policy. Some of the and mechanisms for exercising the choice to opt out are via the links: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.


II. Law enforcement agencies and other public authorities

We may use and disclose Your information to enforce our Terms of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, You or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

III. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Information on customers is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

International data transfers

Please note that our business is global, so when You provide Your information through our Service, the information may be sent to servers located in different countries around the world.

How You Can Access Your Information

If You would like to update or correct any information that You have provided to us through Your use of the Service, You may use the Service to do so. If You need help with rectification of data You think is inaccurate, please contact us via email at support@stay-on-track.io.

You may also change certain Personal Information in Your account by going to the ‘Settings’ menu or sending an email request to us at support@stay-on-track.io.

You can make a request to erase Your Personal Information through the ‘Settings’ menu of this Application. Please note that it may affect the Services provided, and You will not be able to use the full scope of the Services. When we delete any information, it will be deleted from the active database, but it may remain in our archives. Should You require the deletion of such Personal Information from our archives, please contact us at support@stay-on-track.io. Please note that we may be required to keep such information in our archives and not delete it (or to keep this information for a certain time, in which case we will comply with Your deletion request only after we have fulfilled such requirements).

You can make a request to receive the Personal Information related to You through the ‘Settings’ menu of this Application. Should You make such a request, You will be required to provide us with an email address which we would be able to send Your Personal Information to. Please note that You confirm and guarantee that the email address You provide to us in order to receive Your Personal Information shall belong to You and You shall be solely responsible for its correctness and validity and, therefore, we shall in any case not be liable for any breach of Your Personal Information due to sending it to that email address.

If You reside in the European Economic Area, You may object to the processing of Personal Information concerning You for marketing purposes by contacting us at support@stay-on-track.io and the related Personal Information shall no longer be processed for such purposes.

Please note that You may also opt out from collection of Your information for marketing and advertising purposes using:


Your iOS device settings:

go to “Settings” > “Privacy” > “Advertising” > “Limit Ad Tracking”. You may additionally reset Your advertising identifier (this also may help You to see less of personalized ads) in the same section.

Your Android device settings:

for Android 6.0 and higher – go to “Settings” -> “Google” -> “Ads” -> ”Opt out of interest-based ads”. For Android 5.2 and lower, use Google Settings app -> “Ads” -> ”Opt out of interest-based ads”. You may additionally reset Your advertising identifier (this also may help You to see less of personalized ads) in the same section for both options mentioned.

and links below:

Network Advertising Initiative – http://optout.networkadvertising.org/

Digital Advertising Alliance – http://optout.aboutads.info/

Digital Advertising Alliance (Canada) – http://Youradchoices.ca/choices

Digital Advertising Alliance (EU) – http://www.Youronlinechoices.com/

DAA AppChoices page – http://www.aboutads.info/appchoices

Please note that the result of such objection or cancellation may affect the process of the Services improvement. However, You would still be able to use the App.

If You think that the Personal Information related to You is inaccurate, but You can’t rectify it as described above, You may contact us at support@stay-on-track.io to restrict the processing of such data for the period of time we need to verify the accuracy of the Personal Information, which we will inform You of.

You can stop all collection of information by the Application by uninstalling the Application from Your mobile device. You may use the standard uninstall processes as may be available as part of Your mobile device or via the Application marketplace or network.

How We Secure Your Information

Security is our highest priority. Our App has been designed with Your security and privacy in mind.

We protect the security of Your information by using encryption protocols and software;

We aggregate all Your information;

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of Your information;

We employ Your information systematic backups, which are intended to reduce the risk from disk crashes and errors, such as accidental information deletion.

While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we make all reasonable efforts to prevent it. However, You should bear in mind that submission of information over the Internet is never entirely secure.

Children’s Privacy

This Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from children under 16. If we discover that a child under 16 has provided us with Personal Information, we shall take steps to delete such information and terminate the child’s account. If You are a parent or a guardian and You are aware that Your child has provided us with Personal Information, please contact us so that we will be able to take the necessary actions.

Retention

We will retain Your information for as long as the Application is installed on Your mobile device or as needed to provide You with our Service. If You remove the Application, we will remove Your information and use copies of Your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Therefore, You are advised to check our Service occasionally to inform Yourself of any changes. We will notify You of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page. Your continued use of the Application after changes to the Privacy Policy have been posted will constitute Your acceptance of such changes.

Contact Us

Please submit any questions, concerns or comments You have about this Privacy Policy or any requests concerning Your information via email to support@stay-on-track.io.


Last updated 29 October 2021