title: Privacy Policy for Step10App (dev) url: author: Step10App Legal content: # Privacy Policy for Step10App **Last Updated: September 13, 2026** ## 1. Introduction & Our Commitment Welcome to Step10App ("we," "our," or "us"). We understand that recovery from addiction requires vulnerability, honesty, and deep trust. We treat the privacy of your daily reflections, inventories, and personal journey with the highest level of care, dignity, and confidentiality. This Privacy Policy explains how Step10App collects, uses, protects, and handles your information when you use our mobile application, web companion, and related services. By accessing or using Step10App, you acknowledge that you understand the terms of this Privacy Policy. If you do not agree with this policy, please do not use the application. ## 2. Information We Collect We practice data minimization: we collect only what is strictly necessary to deliver a high-quality recovery experience. ### 2.1 Personal & Account Information - **Guest / Anonymous Mode:** You can use Step10App without creating an account or providing an email address. All your data remains stored locally on your device. - **Registered Accounts:** If you choose to create an account or sign in with Google or Apple, we collect basic profile details (your email address and display name) to enable cross-device synchronization and account recovery. ### 2.2 Sensitive Recovery Data (Special Category Data) Our application allows you to record personal recovery information, which may include: - Sobriety / clean time start dates and milestone tracking. - Step 10 daily inventories (reflections on resentments, fears, dishonesty, amends, and daily blessings). - Subjective wellness metrics (mood ratings, meeting attendance markers, peer contact indicators). - Guardian / Sponsor designations and peer connections. Under data protection laws (including the **General Data Protection Regulation / GDPR**), recovery and health reflections are considered sensitive, special-category personal data. **We process this sensitive data solely based on your explicit, informed consent.** You may withdraw this consent, export, or permanently delete this information at any time. ### 2.3 Technical & Device Information We collect minimal non-identifying technical data necessary for application stability: - Device model, operating system version, and unique app instance identifiers for push notifications (via Firebase Cloud Messaging) if enabled. - Aggregated, non-personal diagnostic and crash logs (via Sentry) to detect errors and improve stability. ## 3. How We Use Your Information We use your data solely for the following purposes: - **Core Recovery Experience:** To calculate sobriety streaks, guide your daily Step 10 check-in, log reflections, and deliver timely reminder notifications. - **Permission-Based Accountability Sharing:** If you explicitly assign a Guardian or Sponsor, we share your designated check-in data according to the privacy level you choose (Private, Summary, or Detailed). You can change sharing preferences or revoke guardian permissions at any time. - **Security & Reliability:** To monitor app performance, authenticate sessions, and prevent abuse. - **Zero Third-Party Advertising:** We never sell, rent, or trade your personal or recovery data to advertisers or data brokers. ## 4. How Your Data Is Shared **Your inventory reflections are strictly private by default.** - **With Your Chosen Guardians / Sponsors:** Only if you explicitly invite and authorize a Guardian, and only at the sharing level you designate (e.g. sharing that an inventory was completed without exposing private reflections, or sharing full entries). - **With Recovery Friends:** If you connect with peer friends, only non-sensitive milestone celebration markers (e.g., "1 Year Clean!") are visible if you opt in. - **Service Providers:** We work with trusted enterprise cloud infrastructure providers (such as Google Cloud / Firebase) that act as strict data processors bound by robust Data Processing Agreements. - **Legal Compliance:** We will only disclose personal information if legally required by valid subpoena, court order, or applicable law, within the limits of Dutch and European legal standards. ## 5. Data Storage, Security & Retention ### 5.1 Local & Cloud Security - **Local Storage:** On-device data is secured using platform-level sandboxing and encryption. - **Cloud Infrastructure:** Data in transit is secured using modern TLS encryption, and data stored in our cloud backend (Firebase Firestore) is encrypted at rest using enterprise AES-256 standards. ### 5.2 Automated Account & Data Deletion You maintain complete control over your data. Clicking **"Delete Account"** within the Step10App Settings initiates an automated, immediate, and permanent erasure of all your personal data, inventory entries, sobriety records, and authentication credentials from our cloud systems. - This automated erasure requires no manual review, approval, or waiting period. - If you use Guest mode, clearing app data or uninstalling the app deletes all local data immediately. ## 6. Children's Privacy Step10App is not intended for use by children under the age of 13 (or under 16 where required by applicable local privacy laws without parental consent). We do not knowingly collect personal information from children under these ages. ## 7. Your Rights (GDPR & International) Under applicable privacy legislation, you have the right to: - **Access & Export:** View and export your personal data and inventory history. - **Rectification:** Update or correct any incomplete or inaccurate profile details. - **Erasure ("Right to be Forgotten"):** Delete your account and all associated data at any time via the in-app deletion button. - **Withdraw Consent:** Revoke consent for processing sensitive recovery data at any time. ## 8. Changes to This Policy We may periodically update this Privacy Policy to reflect app enhancements or legal changes. We will notify you of any material changes by updating the "Last Updated" date and providing a prominent in-app notice. ## 9. Contact Our Privacy Team If you have questions about this Privacy Policy or wish to exercise any of your data protection rights, please contact our Data Protection Officer at: **legal [at] step10app [dot] com** Step10App / Willem Evenwel Zuid-Holland, The Netherlands