This Privacy Policy for Sodo Studios Limited (' we ', ' us ', or ' our '), describes how and why we might
access, collect, store, use, and/or share (' process ') your personal information when you use our services (' Services '), including when you: Visit our website at https://sodo-app.com or any website of ours that links to this Privacy Policy Download and use our mobile application (SoDo), or any other application of ours that links
to this Privacy Policy Engage with us in other related ways, including any marketing or events Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights
and choices.
We are responsible for making decisions about how your personal information is processed.
If you do not agree with our policies and practices, please do not use our Services.
If you still have any questions or concerns, please contact us at sodomobileapp@gmail.com. SUMMARY OF KEY POINTS This summary provides key points from our Privacy Policy, but you can find out more details
about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. What personal information do we process? When you visit, use, or navigate our Services, we
may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us. Do we process any sensitive personal information? Some of the information may be considered
'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs.
We do not process sensitive personal information.
Do we collect any information from third parties? We do not collect any information from third
parties.
How do we process your information? We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, and to comply with law.
We may also process your information for other purposes with your consent.
We process your information only when we have a valid legal reason to do so.
Learn more about how we process your information. In what situations and with which types of parties do we share personal information? We may
share information in specific situations and with specific categories of third parties.
Learn more about when and with whom we share your personal information. How do we keep your information safe? We have adequate organisational and technical processes
and procedures in place to protect your personal information.
However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe. What are your rights? Depending on where you are located geographically, the applicable privacy
law may mean you have certain rights regarding your personal information.
Learn more about your privacy rights. How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We
will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Policy in full. TABLE OF CONTENTS 1. WHAT INFORMATION DO WE COLLECT? 2. HOW DO WE PROCESS YOUR INFORMATION? 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION? 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES? 6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 7. HOW DO WE HANDLE YOUR SOCIAL LOGINS? 8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY? 9. HOW LONG DO WE KEEP YOUR INFORMATION? 10. HOW DO WE KEEP YOUR INFORMATION SAFE? 11. DO WE COLLECT INFORMATION FROM MINORS? 12. WHAT ARE YOUR PRIVACY RIGHTS? 13. CONTROLS FOR DO-NOT-TRACK FEATURES 14. DO WE MAKE UPDATES TO THIS NOTICE? 15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services,
express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the
context of your interactions with us and the Services, the choices you make, and the products and features you use.
The personal information we collect may include the following: Name To identify the user and personalise the account experience. Phone number To verify the account, enhance security, and enable account-related communication
if necessary.
Email address To create the account, authenticate access, and send important service-related
communications.
Username To uniquely identify the user within the platform and display the profile publicly.
Password To securely authenticate the user and protect account access. Contact preference To respect the users chosen communication method and frequency.
Contact or authentication data To verify identity, prevent unauthorised access, and maintain
account security.
Sensitive Information. We do not process sensitive information. Social Media Login Data. We may provide you with the option to register with us using your existing
social media account details, like your Google, Apple, or other social media account.
If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called ' HOW DO WE HANDLE YOUR SOCIAL LOGINS? ' below. Application Data. If you use our application(s), we also may collect the following information if you
choose to provide us with access or permission: Geolocation Information. We may request access or permission to track location-based information
from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services.
If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Access. We may request access or permission to certain features from your
mobile device, including your mobile device's camera, contacts, microphone, sms messages, social media accounts, storage, and other features.
If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device
ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile devices operating system or platform, the type of mobile device you use, your mobile devices unique device ID, and information about the features of our application(s) you accessed.
Push Notifications. We may request to send you push notifications regarding your account
or certain features of the application(s).
If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for
troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must
notify us of any changes to such personal information.
Information automatically collected In Short: Some information such as your Internet Protocol (IP) address and/or browser and device
characteristics is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information
does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location,
information about how and when you use our Services, and other technical information.
This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes: Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance
information our servers automatically collect when you access or use our Services and which we record in log files.
Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet,
or other device you use to access the Services.
Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device's location, which
can be either precise or imprecise.
How much information we collect depends on the type and settings of the device you use to access the Services.
For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).
You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.
However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION? In Short: We process your information to provide, improve, and administer our Services, communicate
with you, for security and fraud prevention, and to comply with law.
We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact
with our Services, including: To create and manage user accounts. We
process your information to enable account registration, secure login, profile management, and to ensure your account remains functional and accessible.
To provide user support and respond to inquiries. We
process your information to respond to questions, resolve technical issues, and provide assistance related to your goals, habits, or account.
To send service-related communications. We process your information to send important administrative messages, including updates to features, changes to our terms or policies, security alerts, and other essential notices.
To enable social and community features. We
process your information to allow you to post updates, interact with other users, comment, follow profiles, and participate in the SoDo social feed.
To request feedback and improve user experience. We
may process your information to request feedback about your experience and to improve SoDos features, usability, and overall functionality.
To send marketing communications (where permitted). We
may process your information to send promotional messages, product updates, or feature announcements in accordance with your communication preferences.
You may opt out at any time.
To personalise content and recommendations. We
may process your information to display relevant content, goal suggestions, or community updates tailored to your interests and activity.
To maintain platform safety and security. We
process your information to detect, prevent, and address fraud, abuse, policy violations, or unauthorised access to protect users and the platform.
To analyse usage and improve the Service. We
process information about how you use SoDo to understand user behaviour, improve features, enhance performance, and optimise habit-tracking tools.
To measure the effectiveness of communications and campaigns. We
may process your information to evaluate how users engage with notifications, announcements, or promotional efforts to improve relevance and effectiveness.
To protect vital interests. We may process your information when necessary to protect the safety or vital interests of an individual, including preventing harm or addressing serious misuse of the platform.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have
a valid legal reason (i.e.
legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal
bases we rely on in order to process your personal information.
As such, we may rely on the following legal bases to process your personal information: Consent. We may process your information if you have given us permission (i.e. consent)
to use your personal information for a specific purpose.
You can withdraw your consent at any time. Learn more about withdrawing your consent. Performance of a Contract. We may process your personal information when we believe
it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably
necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process
your personal information for some of the purposes described in order to: Send users information about special offers and discounts on our products and services
Develop and display personalised and relevant advertising content for our users Analyse how our Services are used so we can improve them to engage and retain users
Support our marketing activities Diagnose problems and/or prevent fraudulent activities Understand how our users use our products and services so we can improve user experience
Legal Obligations. We may process your information where we believe it is necessary for
compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect
your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the
following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with
third-party vendors, service providers, contractors, or agents (' third parties ') who perform services for us or on our behalf and require access to such information to do that work.
We have contracts in place with our third parties, which are designed to help safeguard your personal information.
This means that they cannot do anything with your personal information unless we have instructed them to do it.
They will also not share your personal information with any organisation apart from us.
They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
The categories of third parties we may share personal information with are as follows: Google Analytics We use Google Analytics to analyse how users interact with SoDo, understand
usage patterns, and improve features, user experience, and app performance.
Google AdMob We use Google AdMob to display advertisements within the app and generate
revenue, which may include personalised or non-personalised ads depending on user preferences and applicable laws.
Firebase Push Notification s We use Firebase Push Notifications to send real-time alerts
related to goals, habit reminders, account activity, security updates, and other important service-related communications.
Expo Push Notifications We use Expo Push Notifications to deliver timely reminders, progress
updates, and engagement notifications directly to your device to support your goal tracking and habit-building experience.
We also may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we use Google Maps Platform APIs. We may share your information with certain
Google Maps Platform APIs (e.g.
Google Maps API, Places API).
Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location.
GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors.
This data helps Google Maps provide directions, but it is not always perfectly precise.
Other Users. When you share personal information (for example, by posting comments, contributions,
or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity.
If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity.
Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES? In Short: We are not responsible for the safety of any information that you share with third parties
that we may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services may link to third-party websites, online services, or mobile applications and/or contain
advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications.
Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications.
The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety
and privacy of data you provide to any third-party websites.
Any data collected by third parties is not covered by this Privacy Policy.
We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services.
You should review the policies of such third parties and contact them directly to respond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information
when you interact with our Services.
Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online tracking technologies on our Services
for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences).
The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
Specific information about how we use such technologies and how you can refuse certain cookies
is set out in our Cookie Notice.
Google Analytics We may share your information with Google Analytics to track and analyse the use of the Services.
To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS? In Short: If you choose to register or log in to our Services using a social media account, we may
have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account
details (like your Google or Apple logins).
Where you choose to do this, we will receive certain profile information about you from your social media provider.
The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this Privacy Policy
or that are otherwise made clear to you on the relevant Services.
Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider.
We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY? In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United Kingdom. Regardless of your location, please be aware that
your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see ' WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? ' above), including facilities in the United States, and other countries. If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland,
then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country.
However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.
European Commission's Standard Contractual Clauses: We have implemented measures to protect your personal information, including by using the European
Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers.
These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations.
Our Standard Contractual Clauses can be provided upon request.
We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
9. HOW LONG DO WE KEEP YOUR INFORMATION? In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this
Privacy Policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out
in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will
either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. HOW DO WE KEEP YOUR INFORMATION SAFE? In Short: We aim to protect your personal information through a system of organisational and technical
security measures.
We have implemented appropriate and reasonable technical and organisational security measures
designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will
not be able to defeat our security and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.
You should only access the Services within a secure environment.
11. DO WE COLLECT INFORMATION FROM MINORS? In
Short: No.
SoDo is not intended for, and may not be used by, individuals under 18 years of age.
We do not knowingly collect, solicit, or market to individuals under 18 years of age, and individuals
under 18 are not permitted to create an account or use the Services.
By using the Services, you represent that you are at least 18 years old.
If we learn that an account has been created or used by a person under 18, we may deactivate or
delete the account and take reasonable steps to remove associated personal information from our records, subject to applicable law.
If you become aware of any data we may have collected from a person under 18, please contact us at sodomobileapp@gmail.com.
12. WHAT ARE YOUR PRIVACY RIGHTS? In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and
Switzerland, you have rights that allow you greater access to and control over your personal information.
You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data
protection laws.
These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.
In certain circumstances, you may also have the right to object to the processing of your personal information.
You can make such a request by contacting us by using the contact details provided in the section ' HOW CAN YOU CONTACT US ABOUT THIS NOTICE? ' below.
We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner. Withdrawing your consent: If we are relying on your consent to process your personal information,
you have the right to withdraw your consent at any time.
You can withdraw your consent at any time by contacting us by using the contact details provided in the section ' HOW CAN YOU CONTACT US ABOUT THIS NOTICE? ' below. However, please note that this will not affect the lawfulness of the processing before its withdrawal
nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing
and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section ' HOW CAN YOU CONTACT US ABOUT THIS NOTICE? ' below. You will then be removed from the marketing lists. However, we may still communicate with you for example, to send you service-related
messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information If you would at any time like to review or change the information in your account or terminate your
account, you can: Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information
from our active databases.
However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you
prefer, you can usually choose to set your browser to remove cookies and to reject cookies.
If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. If you have questions or comments about your privacy rights, you may email us at sodomobileapp@gmail.com. 13. CONTROLS FOR DO-NOT-TRACK FEATURES Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track
('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.
At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised.
As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
14. DO WE MAKE UPDATES TO THIS NOTICE? In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this Privacy Policy from time to time. The updated version will be indicated by an
updated 'Revised' date at the top of this Privacy Policy.
If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.
We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? If you have questions or comments about this notice, you may email us at sodomobileapp@gmail.com. 16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT
FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal
information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.
You may also have the right to withdraw your consent to our processing of your personal information.
These rights may be limited in some circumstances by applicable law.
To request to review, update, or delete your personal information, please email us at: sodomobileapp@gmail.com.