Privacy Policy
How we collect, use, and protect your information.
Privacy Policy
SART CREATIVE TRADING SRL · Draft — not yet in effect
Introduction
This Privacy Policy explains how SART CREATIVE TRADING SRL ("PAS CU PAS," "we," "us," or "our") collects, uses, shares, and protects information when you use the PAS CU PAS Android app (the "Platform Android app") and the PAS CU PAS website (the "Platform website"), together referred to as the "Platform", as defined in the Terms & Conditions.
PAS CU PAS is established in Romania, a European Union Member State. Where EU data protection law, including the General Data Protection Regulation ("GDPR"), applies to our processing of your personal information, we intend to comply with it.
At present, the Platform website consists of public information pages, a Contact page that opens your own email app so that you can send us a message, and an Account Deletion request form. Accounts, Challenge purchases, Wallets, referral-code entry, Shield purchases, and withdrawal requests on the Platform website, and activity tracking in the Platform Android app, are described in this Policy as they will operate when those features are available. A description of a feature is not a statement that it is already available.
This Policy should be read alongside the Terms & Conditions and the Official Pas cu Pas Handbook, which describe how Challenge Levels, Badges, Streaks, Pas cu Pas Shields, the Pas cu Pas Wallet, Prize Pools, and Contribution Weight function.
Information We Collect
The Platform website and the Platform Android app process different information. The Platform Android app processes your activity data — GPS location, step counts, and session records — and synchronizes it with our servers for verification, and it may display your Challenge progress, statistics, Shield status, and, for information only, your Commitment Wallet, Prize Wallet, and Referral Wallet balances. Financial and commercial actions — Challenge purchases, payments, referral-code entry at Challenge checkout, Shield purchases, and withdrawal requests — take place on the Platform website, and the related payment, referral, and withdrawal information is processed there. The Platform Android app cannot be used to make a purchase, buy a Shield, redeem a referral reward, or request a withdrawal.
Account Information
When you create a PAS CU PAS account, we collect information such as your name, email address, and password (or authentication credentials, if you sign in through a third-party provider). Because PAS CU PAS requires users to be at least 18 years old, we may also collect information necessary to confirm your age.
Challenge & Activity Data
To operate the Platform, we collect the data generated by your use of it, including:
- Your selected Challenge Level for each month;
- Session records (start/end time, duration, steps, distance);
- Verification results for each session;
- Your streak, Badge history, Shield inventory, and Prize Pool history;
- The statistics listed in the Official Pas cu Pas Handbook (Current Challenge Level, Current Streak, Longest Streak, Current Badge, Highest Badge Achieved, Sessions Completed, Total Steps, Total Distance, Monthly Success Rate, Prize Pool History, Rewards Earned).
As described in the Handbook, these statistics represent your permanent journey within PAS CU PAS. They are generated by the Platform and are not editable by you. This does not limit any right you have under data protection law to have inaccurate personal data corrected (see Section 7).
Location Data
During a tracked walking or running session, we collect location data from your device. This data is used to verify that your session was completed outdoors and meets the requirements of your selected Challenge Level.
Payment, Challenge Purchase & Wallet Data
When you purchase a Challenge on the Platform website, your payment is processed by our payment provider, Stripe. We receive confirmation of payment, payment status, and transaction history from Stripe, but we do not store the full card or bank account number you use to pay through Stripe.
When you request a withdrawal on the Platform website, we process the details of your request (such as the amount and its status) and, if the request is approved, the payment details you give us so that SART CREATIVE TRADING SRL can pay the approved amount directly from its company bank account. We record the status of your withdrawal and make it available to you.
We also maintain your Commitment Wallet, Prize Wallet, and Referral Wallet balances separately, together with the underlying records of Commitment Deposits paid, held, returned, and forfeited, and a complete Wallet History covering Challenge purchases, Commitment Deposit refunds, Bronze Rewards, Silver/Gold/Elite Prize Pool rewards, referral rewards, Shield purchases using Referral Wallet balance, and withdrawals. As with your other PAS CU PAS statistics, your Wallet History is permanently recorded and remains available in your account on the Platform website. Your Wallet balances may also be displayed in the Platform Android app for information only.
When the referral programme launches, we expect to process referral information on the Platform website, such as the referral code entered when purchasing a Challenge, referral attribution and the relationship between a referrer and a referred user, referral status and history, and Referral Wallet transactions, together with the records we keep to prevent and review referral abuse. Referral codes are not entered in the Platform Android app.
Fraud & Account Review Data
If suspicious activity is detected on your account, we collect any additional information you provide during the resulting review, including any evidence submitted in response to our request within the 14-calendar-day response window.
Device & Technical Information
We may collect technical information such as device type, operating system version, app version, and crash or diagnostic logs, to operate and improve the Platform.
Communications
If you contact our support team, we collect the content of your communications and any information you choose to provide to resolve your inquiry.
When you submit the Account Deletion request form on the Platform website, we process the email address you enter, the optional account username or identifier you enter, the date and time of the request, and technical information such as your IP address, which is used to limit repeated submissions. The request is sent by email to our support team. The Contact page does not send anything to us itself: it opens a message in your own email app, and we receive it only if you send it.
Website Cookies
The Platform website may use cookies and similar technologies. See the Cookie Policy for details.
How We Use Your Information
We use the information described above to:
- Create and maintain your account, and confirm you meet the minimum age requirement;
- Manage Monthly Enrollment and verify your sessions against your selected Challenge Level's requirements;
- Calculate your streak, Badge, Shield inventory, Contribution Weight, and Prize Pool eligibility and rewards;
- Process your Challenge purchases, Platform Fee, Commitment Deposit, and Wallet balance, including refunds, forfeitures, and withdrawal requests, via Stripe (for Platform website payments) and PAS CU PAS's own systems;
- Review withdrawal requests and pay approved withdrawals from our company bank account;
- Operate the referral programme, including attributing referrals, crediting rewards to the Referral Wallet, and preventing and reviewing abuse;
- Process Shield purchases made with Referral Wallet balance;
- Perform Monthly Settlement;
- Send you service-related communications and, where permitted, push notifications;
- Provide customer support;
- Detect and review suspicious activity and prevent fraud, cheating, or misuse of the Platform;
- Comply with legal obligations;
- Improve and develop the Platform.
PAS CU PAS does not use your Challenge, activity, or location data to sell targeted advertising to third parties.
GPS and Location Permissions
The Platform Android app requests access to your device's location services so that it can verify that a walking or running session was genuinely completed outdoors, in line with the Session Requirements described in the Official Pas cu Pas Handbook. You can decline or revoke this permission at any time through your device settings, but doing so will prevent you from completing a verifiable session.
The precise technical mechanism used to verify sessions using location data is part of PAS CU PAS's internal verification system and is intentionally not detailed publicly.
Data Retention
We retain your account and activity data for as long as your account is active, and for a further period afterward as necessary to comply with legal, accounting, or dispute-resolution obligations.
As documented in the Official Pas cu Pas Handbook, your historical statistics (streak history, Badge history, Prize Pool history, and rewards earned) and your complete Wallet History (Challenge purchases, Commitment Deposit refunds, Bronze Rewards, Prize Pool rewards, Shield purchases, and withdrawals) are retained permanently as a record of your journey for as long as your account exists, and are not editable by you. This does not affect your right to have inaccurate personal data corrected (see Section 7). If your account is deleted through the account-deletion process, the account records covered by that process are removed at the end of the 30-day pending-deletion period, subject to applicable legal retention requirements.
We keep other categories of information, such as location data, fraud review records, support communications, and device logs, only for as long as necessary for the purposes described in this Policy, to resolve disputes, and to meet legal obligations.
Your Rights
Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, or port your personal information, and to object to certain processing. Where applicable law grants these rights, you may exercise them by contacting us at support@pascupas.app. You also have the right to lodge a complaint with a data protection supervisory authority.
If you believe personal information we hold about you is inaccurate, contact us at support@pascupas.app. Where the law gives you the right to have it corrected, we will correct it, while preserving the integrity of historical Challenge and financial records as far as the law allows.
To request deletion of your PAS CU PAS account, see the Account Deletion section of the Contact page, which explains the conditions that must be met and the 30-day pending-deletion period.
Where your account is deleted through the account-deletion process, the account records covered by that process are removed at the end of the 30-day pending-deletion period, subject to applicable legal retention requirements (see Data Retention). Any Referral Wallet credit that remains when deletion is completed is forfeited, as described in the Terms & Conditions.
International Data Transfers
Your information may be processed in a country other than the one in which you reside, including by Stripe and any hosting or infrastructure providers we use. Where information is transferred outside the European Economic Area, we will ensure that the transfer complies with applicable data protection law.
Data Security
We use reasonable technical and organizational measures designed to protect your information from unauthorized access, loss, or misuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
PAS CU PAS does not claim any specific compliance certification (e.g., ISO 27001, SOC 2) unless and until it has actually been obtained.
Push Notifications
The Platform Android app may send you push notifications relating to your monthly challenge, sessions, streaks, Badges, Prize Pools, or Wallet activity. You can manage or disable push notifications at any time through your device's notification settings.
Minimum Age
The Platform is only available to users who are at least 18 years old, as described in the Official Pas cu Pas Handbook. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has created a PAS CU PAS account or provided us with personal information, please contact us at support@pascupas.app.
Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice through the Platform Android app, the Platform website, or email before the changes take effect.
Contact Us
Questions about this Privacy Policy, or requests relating to your personal information, can be sent to support@pascupas.app.