# Privacy Policy

**Privacy Policy of Stride** **Stride Labs L.L.C.-F.Z.** (referred to as "we", "our", and "us") values your privacy and is dedicated to protecting it through our compliance with this policy. This document outlines our practices regarding the collection, use, and disclosure of your information through your interactions with the Stride move-to-earn fitness app (“App”).&#x20;

### **Collection of Personal Information**&#x20;

We collect personal information to provide and enhance the services we offer to you. This may include but is not limited to:

* Names, email addresses, physical addresses, and other contact details.
* Demographic information such as age, gender, and preferences.
* Health and fitness data necessary for the functioning of the App, like step count and location data for movement verification.

### **Use of Your Information**&#x20;

We use the information we collect about you to:

* Provide, maintain, and improve our services including the App.
* Understand and analyze how you use our services to develop new products, services, features, and functionality.
* Communicate with you, either directly or through one of our partners, for customer service, to provide you with updates and other information relating to the App, and for marketing and promotional purposes.

### **Sharing of Your Information**&#x20;

We work with the following subcontractors who assist us in achieving the purposes mentioned in section 2 above:

* **GOOGLE**: for hosting and storing your data
* **REDIS**: to create a database of our users

We also work with providers who help us measure the performance of our services and the Application and improve them, for example, Mixpanel, Adjust.

We contractually require these service providers to maintain the confidentiality of your personal data and not to use it for purposes other than those necessary for the execution of our contract with them.

**We also share your personal data with:**

* our third-party partners for advertising purposes via the Application. These partners use your data to know the origin of your purchase from them (in this case, a promotional code obtained through Stride). We ensure they do not process your data for other purposes.
* advertising intermediaries, for example, Facebook and TikTok. These intermediaries share your data with their own partners, in accordance with their privacy policies.
* other third-party recipients such as our banks, our advisors, legal and regulatory authorities when required by law, judicial or administrative authorities in case of a dispute between you and us.

We store your personal data within the European Economic Area (EEA). However, for the purposes outlined in this policy, it is sometimes necessary to provide some of your data to subcontractors and recipients located outside the European Economic Area (EEA). When we do so, we will ensure that these transfers guarantee an appropriate level of data protection.

Some countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws, and therefore no additional safeguards are required to export personal data to these jurisdictions.

In countries that have not received these approvals (the list of which can be found here: <http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm>), we use EU-approved "standard contractual clauses" to ensure the application of data protection safeguards equivalent to those required in the EEA.

Please contact us if you would like to obtain a copy of the safeguards we apply regarding the export of your personal data.

**You have the right to:**

* **Request information** about the personal data we process according to **Article 15 of the GDPR**. You can specifically request information about the purposes of the processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage duration, the existence of a right to correction, deletion, limitation of processing or objection, the existence of a right of appeal, the origin of your data if they were not collected from us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about the details of this decision-making.
* **Demand the immediate correction or completion** of incorrect personal data stored by us according to **Art. 16 GDPR**.
* **Demand the deletion** of your personal data stored by us according to **Art. 17 GDPR**, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims.
* **Demand the restriction of the processing** of your personal data according to **Art. 18 GDPR**, as far as the accuracy of the data is disputed by you, the processing is unlawful, but you refuse their deletion and we no longer need the data, but you need them for the assertion, exercise or defense of legal claims or you have objected to the processing according to **Art. 21 GDPR**.
* **Receive your personal data** that you have provided to us in a structured, commonly used and machine-readable format or to request the transfer to another controller according to **Art. 20 GDPR**.
* **Revoke your consent** given to us at any time according to **Art. 7 para. 3 GDPR**. As a result, we are no longer allowed to continue the data processing based on this consent for the future.
* **Complain to a supervisory authority** according to **Art. 77 GDPR**. You can find the list of contact details of the European competent authorities here: <http://ec.europa.eu/justice/data-protection/article-29/structure/data-protectionauthorities/index_en.htm>. Generally, you can contact the supervisory authority of your usual place of residence, your place of work, or our company headquarters.

You may have additional rights provided in the national legislation of your place of residence.

**If your personal data is processed based on legitimate interests, you have the right, according to Article 21 GDPR, to object to the processing of your personal data, provided that there are reasons arising from your particular situation or if the objection is directed against direct advertising.** In the case of direct advertising, you can exercise your right by clicking on the link provided for this purpose in the communications we send you, or by sending an email to <hello@stride.social>.

**How Is the Security of Your Data Ensured?**

Stride implements appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and to preserve the confidentiality of the data collected.

Stride cannot guarantee the absolute security of personal data. In the event that Stride becomes aware of a security breach, namely a loss of availability, integrity, or confidentiality of data, accidentally or unlawfully, Stride commits to notify the competent data protection authority and, if necessary, to inform you.

**You are responsible for maintaining the confidentiality of your Stride username and password.** We recommend that you never share this password.

**How Long Are Your Data Stored?**

Our data retention periods are based on business needs and legal requirements. We retain personal data for as long as necessary for the processing purposes for which the information was collected, and any other permitted related purpose.

We then securely archive them to meet our legal and regulatory obligations (for example, our accounting obligations, or to defend our interests in case of litigation with a user). When data is archived, only expressly authorized Stride collaborators can access it.

When personal data is no longer needed, and the legal archiving duration has expired, we irreversibly anonymize them or securely destroy them.

### **Your Choices**&#x20;

You may update, correct, or delete information about you at any time by logging into your account and modifying your information or by contacting us directly at the contact details provided in this policy.&#x20;

### **Location of Data Processing**&#x20;

All personal information is processed in our servers located in the United States. By using our App and providing us with your information, you consent to this processing.&#x20;

### **Changes to This Policy**&#x20;

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date.&#x20;

### **Contact Us**&#x20;

If you have any questions or comments about this policy, you may email us at <hello@stride.social> or by post to: P.O. Box No: 9305 \
Stride Labs L.L.C.-F.Z. \
The Meydan Hotel, Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E \
\
Effective Date: 11/04/2024


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