Privacy Policy

This Privacy Policy describes how StepEase ("the Website", "we", "us" or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from StepEase ("the Website") or otherwise communicate with us (collectively, the "Services"). In this Privacy Policy, "you" and "your" means you as a user of the Services, whether you are a customer, website visitor, or any other individual whose information we have collected in accordance with this Privacy Policy.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the website, update the "Last Updated" date, and take any other steps required by applicable law.

How We Collect and Use Your Personal Information

To provide the Services, we collect and have collected personal information about you over the past 12 months from a variety of sources, as set out below. The information we collect and use varies depending on how you interact with us.

In addition to the specific uses described below, we may use the information we collect about you to communicate with you, to provide the Services, to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

The types of personal information we obtain about you depend on how you interact with our website and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes, or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information We Collect Directly From You

Information that you submit directly to us via our Services may include:

• Basic contact details, including your name, address, phone number, and email.
• Order information, including your name, billing address, delivery address, payment confirmation, email address, and phone number.
• Account information, including your username, password, and security questions.
• Shopping information, including the items you view, add to your basket, or add to your wishlist.
• Customer support information, including the information you choose to include in communications with us, for example when sending a message through the Services.

Certain features of the Services may require you to directly provide us with certain information about yourself. You may choose not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect Through Cookies

We also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels, and similar technologies ("cookies"). Usage Data may include information about how you access and use our website and account, including device information, browser information, information about your network connection, your IP address, and other information regarding your interaction with the Services.

Information We Obtain From Third Parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

• Companies who support our website and Services, such as Shopify.
• Our payment processors, who collect payment information (e.g. bank account, credit or debit card details, billing address) to process your payment in order to fulfil your orders and provide you with products or services you have requested, in order to perform our contract with you.
• When you visit our website, open or click on emails we send you, or interact with our Services or adverts, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software development kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of information provided to us by third parties and are not responsible for any third party's policies or practices. For more information, see the section below, Third-Party Websites and Links.

How We Use Your Personal Information

• Providing products and services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfil your orders, send you notifications related to your account, purchases, returns, exchanges, or other transactions, to create, maintain, and otherwise manage your account, to arrange shipping, facilitate any returns and exchanges, and to enable you to post reviews.
• Marketing and advertising. We use your personal information for marketing and advertising purposes, such as to send you marketing, advertising, and promotional communications by email, text message, or post, and to display advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our website and other websites.
• Security and fraud prevention. We use your personal information to detect, investigate, or take action regarding possible fraudulent, illegal, or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We strongly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Communicating with you. We use your personal information to provide customer support and improve our Services. This is in our legitimate interest to be responsive to you, to provide effective services to you, and to maintain our business relationship with you.

Cookies

Like many websites, we use cookies on our website. For specific information about the cookies we use to operate our store using Shopify, please see https://www.shopify.com/legal/cookies. We use cookies to power and improve our website and Services (including to remember your actions and preferences), to run analytics, and to better understand user interaction with the Services (in our legitimate interest to administer, improve, and optimise the Services). We may also permit third parties and service providers to use cookies on our website to better tailor the Services, products, and advertising on our website and other websites.

Most browsers automatically accept cookies by default, but you can choose to set your browser to remove or reject cookies through your browser controls. Please note that removing or blocking cookies may negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking cookies may not completely prevent how we share information with third parties, such as our advertising partners.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for legitimate purposes covered by this Privacy Policy. Such circumstances may include:

• With vendors or other third parties who perform services on our behalf (e.g. IT management, payment processing, data analytics, customer support, cloud storage, fulfilment, and delivery).
• With business and marketing partners, including Shopify, to provide services and advertise to you. For example, we use Shopify to support personalised advertising with third-party services. Our business and marketing partners will use your information in accordance with their own privacy notices.
• When you direct us, request us, or otherwise consent to our disclosure of certain information to third parties, such as to ship products to you, or through your use of social media widgets or login integrations, with your consent.

We have, in the past 12 months, disclosed the following categories of personal information and sensitive personal information (denoted by *) about users for the purposes described above in "How We Collect and Use Your Personal Information" and "How We Disclose Personal Information":

Category:

• Identifiers such as basic contact details and certain order and account information
• Commercial information such as order information, shopping information, and customer support information
• Internet or other similar network activity, such as Usage Data

Categories of recipients:

• Vendors and third parties who perform services on our behalf (such as internet service providers, payment processors, fulfilment partners, customer support partners, and data analytics providers)
• Business and marketing partners
• Affiliates

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.

We have "sold" and "shared" (as those terms are defined under applicable law) personal information in the preceding 12 months for the purpose of engaging in advertising and marketing activities, as follows:

Category of personal information

• Identifiers such as basic contact details and certain order and account information
• Commercial information such as records of products or services purchased and shopping information
• Internet or other similar network activity, such as Usage Data

Categories of recipients

• Business and marketing partners

User-Generated Content

The Services may enable you to post product reviews and other user-generated content. If you choose to submit user-generated content to any public area of the Services, this content will be public and accessible to anyone.

We do not control who will have access to the information you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information you make publicly available, or for the accuracy, use, or misuse of any information you disclose or receive from third parties.

Third-Party Websites and Links

Our website may provide links to websites or other online platforms operated by third parties. If you follow links to websites not affiliated with or controlled by us, you should review their privacy and security policies and other terms of use. We do not guarantee, and are not responsible for, the privacy or security of such websites, including the accuracy, completeness, or reliability of information found on these websites. Information you provide on public or semi-public platforms, including information you share on third-party social networking platforms, may also be visible to other users of the Services and/or users of those third-party platforms without restriction as to its use by us or a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

Children's Data

The Services are not intended for use by children, and we do not knowingly collect any personal information about children. If you are a parent or guardian of a child who has provided us with their personal information, please contact us using the contact details below to request that it be deleted.

As of the effective date of this Privacy Policy, we have no actual knowledge that we "share" or "sell" (as those terms are defined under applicable law) personal information of individuals under 16 years of age.

Security and Retention of Your Information

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee "perfect security". In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on various factors, such as whether we need the information to maintain your account, to provide the Services, to comply with legal obligations, to resolve disputes, or to enforce other applicable contracts and policies.

Your Rights and Choices

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. These rights are not absolute, however — they may apply only in certain circumstances, and in some cases we may decline your request as permitted by law.

• Right to access/know. You may have the right to request access to personal information we hold about you, including information about how we use and share your information.
• Right to delete. You may have the right to request that we delete personal information we hold about you.
• Right to correct. You may have the right to request that we correct inaccurate personal information we hold about you.
• Right to portability. You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and subject to certain exceptions.
• Right to opt out of sale, sharing, or targeted advertising. You may have the right to direct us not to "sell" or "share" your personal information, or to opt out of the processing of your personal information for purposes considered "targeted advertising", as defined under applicable privacy laws. Please note that if you visit our website with the Global Privacy Control opt-out signal enabled, depending on your location, we will automatically treat this as a request to opt out of "sale" or "sharing" of information for the device and browser you use to visit the website.
• Right to limit and/or opt out of use and disclosure of sensitive personal information. You may have the right to direct us to limit our use and/or disclosure of sensitive personal information to only what is necessary to perform the Services or provide the goods reasonably expected by an average individual.
• Restriction of processing. You may have the right to ask us to stop or restrict our processing of personal information.
• Withdrawal of consent. Where we rely on consent to process your personal information, you may have the right to withdraw that consent.
• Appeal. You may have the right to appeal our decision if we decline to process your request. You can do this by replying directly to our refusal.
• Managing communication preferences. We may send you marketing communications, and you can opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-marketing emails, such as those about your account or orders you have placed.

You can exercise any of these rights where indicated on our website or by contacting us using the contact details below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to your request. In accordance with applicable laws, you may designate an authorised agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof that you have authorised them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request within the timeframe required by applicable law.

We use Shopify's advertising services, such as Shopify Audiences, to help personalise the advertising you see on third-party websites. To restrict Shopify merchants from using your personal information for such services, visit https://privacy.shopify.com/en.

Complaints

If you have any complaints about how we process your personal information, please contact us using the contact details below. If you are not satisfied with our response to your complaint, depending on where you live, you may have the right to appeal our decision by contacting us using the contact details below, or to lodge your complaint with your local data protection authority.

UK residents: you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection issues. You can reach the ICO at www.ico.org.uk.

International Users

Please note that we may transfer, store, and process your personal information outside the country in which you reside, including in the United States. Your personal information is also processed by staff and third-party service providers and partners in these countries.

If we transfer your personal information from the UK or Europe, we will rely on recognised transfer mechanisms such as the European Commission's Standard Contractual Clauses, or equivalent contracts issued by the relevant competent authority in the UK (such as the UK International Data Transfer Agreement), as relevant, unless the data transfer is to a country that has been found to provide an adequate level of protection.