Privacy Policy

Our Policy

Welcome to the web site of Step Success, The Site is operated by 365 Health and Wellbeing Limited and has been created to provide information about Step Success to enable visitors of our Site (“you”, “your”) to collect, transport, analyse and view physiological data (the “Step Success Services”). This Privacy Policy sets forth Step Success’s policy with respect to physiologic and other personally identifiable data (“Personal Data”) as well as other information that is collected from visitors of our Site. We are entered with the Data Protection Registrar as 365 Health and Wellbeing Limited, registration number ZA164180.

Information We Collect

When you interact with us through the Site, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Site: We collect Personal Data from you when you voluntarily choose to provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Step Success Services or use certain Step Success Services, including by hooking up to an approved monitoring device that uploads physiologic and activity data to the Step Success system. Wherever Step Success collects Personal Data, where feasible, we make an effort to provide a link to this Privacy Policy. The types of Personal Data we collect are name, postal address, email address, telephone, credit card number, age, height, gender and, through monitoring devices, your weight, blood pressure and other health, physiologic and activity data.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to our Site, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Step Success and the authorised third parties referred to herein.

Non-Identifiable Data: When you interact with Step Success through the Site, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Step Success may store such information itself or it may be included in databases owned and maintained by Step Success affiliates, agents or service providers. The Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating the Site, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access a web site. Our cookies help provide additional functionality to the Site and help us analyse usage of the Site more accurately. For instance, our Site may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.

Aggregated Personal Data:

In an on-going effort to better understand and serve the users of the Step Success Services, Step Success often conducts research on its customer demographics, interests and behaviour based on the Personal Data and other information provided to us. This research may be compiled and analysed on an aggregate basis, and Step Success may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Step Success may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.

Our Use of Your Personal Data and Other Information

365 Health and Wellbeing Limited and its subsidiaries and affiliates (the “Related Companies”) use the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Step Success Services, such as to enable your health plan or employer to observe your activity levels or weight loss, we will use your Personal Data to provide access to such services, enable the transmission of the intended data, and monitor your use of such services.

365 Health and Wellbeing Limited and its Related Companies may also use your Personal Data and other personally non-identifiable information collected through the Site to help us improve the content and functionality of the Site, to better understand our users and to improve the Step Success Services. We may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving similar future communications. In addition, at any time you wish not to receive any future communications or to have your name deleted from our mailing lists, please contact us as indicated below.

If we intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected and be given the opportunity to opt-out of such use.

Our Disclosure of Your Personal Data and Other Information

We considers your information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, Personal Data may be part of the transferred assets, provided it remains subject to this Privacy Policy (or a substitute policy that you accept or fail to opt-out of).

Related Companies:

We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy; in such cases, our Related Companies will be required to comply with this Privacy Policy.

Agents, Consultants and Related Third Parties:

365 Health and Wellbeing Limited, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples include mailing information, maintaining databases and processing payments. When we employ another to perform a function of this nature, we only provide them with the information that they need to perform their specific function and obligate them to respect our privacy commitments to you.

Account Sponsors:

In some cases our users are introduced to us through third parties who are responsible for their participation in and use of the Step Success Site and Services and who monitor their use. If your account with us has been created by or through the involvement of such a third party, such as your employer, health plan or fitness centre, you should have been informed whether they have full or partial access to and/or monitor your Personal Data. If you are unsure of whether they can access your Personal Data, how they use this data or whom they share it with, or you want to disable or control their access, you must contact them directly – Step Success views these Third Parties (see “Links to Other Web Sites” below) as the managing “co-owner” of your account and data and follows their instructions.

Legal Requirements:

365 Health and Wellbeing Limited may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Step Success, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.


This Privacy Policy does not apply to any personal data or information received by 365 Health and Wellbeing Limited other than Personal Data deliberately collected through the Site. For example, this Privacy Policy shall not apply to any unsolicited information you provide to Step Success through this Site or to through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as bulletin boards (collectively, “Public Areas”) any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All such Unsolicited Information shall be deemed to be non-confidential and Step Success shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.


365 Health and Wellbeing Limited does not knowingly collect Personal Data from children under the age of 13 without approval of a parent or legal guardian. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Data on this Site without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through this Site without the consent of a parent or legal guardian, please contact us, and we will endeavour to delete that information from our databases.

Third Party Users and Links

This Privacy Policy applies only to the Site and only to use of your Personal Data by Step Success and its Related Companies and providers as set forth herein. The Site may frame or contain references or links to other web site not operated or controlled by Step Success, and your account may be set up to allow access by parties not controlled or related to Step Success (see “Account Sponsors” above), such as your employer, fitness center or health care provider (each of such uncontrolled persons, a “Third Party”). The policies and procedures we described here do not apply to the websites, services, policies or practices of Third Parties and the links from the Site do not imply Step Success’ review or endorsement of any Third Party site, services, policies or practices. We suggest contacting those Third Party Sites directly for information on their privacy policies.


365 Health and Wellbeing Limited takes reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Site may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to Step Success via the Internet.

Other Terms and Conditions

Your access to and use of the Site is subject to the Terms of Use

Changes to 365 Health and Wellbeing Limited Privacy Policy

The Site and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserves the right to update or modify this Privacy Policy at any time and from time to time by providing you with notice, including by email to your last known address, posting the changed policy on our Site, or other means. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Site after notice of any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting Step Success

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Site.

Please also feel free to contact us if you have any questions about our Privacy Policy or the information practices of the Site. You may contact us at