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Privacy Policy

Last Updated on May 9, 2026

General

This Privacy Policy ("Policy") describes the policies and procedures on the collection, use, disclosure and protection of your information when you access and/or use the Steer Mobile Application and/or the following website: https://steer.coach (including related web services, software, mobile and other applications and functions and features thereof) ("Steer Tech") owned and operated by Steer Corp., incorporated in Delaware, United States of America ("Company" or "Steer").

Any reference to "you" or "your" or "user" (if applicable) refers to you as the visitor, subscriber or user of the Steer Tech and/or any features of functionalities on the Steer Tech. Any reference to "we", "our" and "us" shall refer to the Company.

Please read this Policy before accessing and/or using the Steer Tech or submitting any personal information to the Company. This Policy is a part of and is incorporated within, and is to be read along with the Terms of Use (https://steer.coach/terms.html) mentioned in the Steer Tech which govern the access and use by you of the Steer Tech and the activities, services, features, functionalities and / or resources available on the Steer Tech ("Terms").

The Company values the trust the users place in the Company. Therefore, the Company insists upon the highest standards for secure communication and user information privacy.

Please read and understand this entire Policy carefully to learn about the Company's information gathering, usage, storage, processing and dissemination practices. The Policy specified herein is subject to change at any time without notice. To make sure you are aware of any changes, please review this Policy periodically.

Your Consent

By accessing and/or using the Steer Tech, you agree and consent to the collection, transfer, use, storage, disclosure and sharing, in certain specific cases, of your information as described and collected by us in accordance with this Policy. If you do not agree with the Policy, please do not use or access the Steer Tech. You always have the option to not provide information by choosing not to use a service or feature or resource on the Steer Tech.

Protecting the Privacy

Your interactions with the Steer Tech, including chat messages, AI-generated insights, and stored memories, are treated as confidential. Steer does not monetize your personal data through advertising or data sales.

In connection with the offering Services through the Steer Tech, we are guided by the following core principles:

We are committed to complying with provisions of all applicable laws, with respect to collection, processing, use and storage of information and data.

All information submitted by the users on the Steer Tech shall be safeguarded and protected. The Company is committed to protecting the privacy, confidentiality, accuracy and security of the personal information that it collects, uses, retains and discloses in the course of conducting business and providing the services. This Policy will protect the data provided by you and will be used for the purposes of providing services to you through the Steer Tech and any other administration purposes relevant to any products/services provided by the Company.

AI-inferred Memory System and AI-assisted Personalization

The AI memory system allows the artificial intelligence tools integrated on or accessed through the Steer Tech to autonomously extract and store "memories" from user conversations, including life events, goals, preferences, and interests and source tracking. The Users may manage their memories via the in-app "Memories" screen (view, confirm, disconfirm, and permanently delete). The disconfirmed memories may be retained as negative examples in AI inputs (to avoid re-inferring incorrect information), subject to applicable laws.

1. Types of Information Collected

The Company may collect several types of information which is primarily used to serve you better and maintain authenticity of services by identifying you. Details of such information (collectively called "Information") are as follows:

1.1 Personal Identification Information

Steer collects personal information and data, including birth date, time, and location; current geographic location; gender; email or phone number; and conversation histories that may contain intimate details about relationships, health concerns, career anxieties, financial situations, and family dynamics. The AI memory system also stores inferred preferences, life events, and goals.

We may collect personal identification information from you in a variety of ways, including, but not limited to, when you visit the Steer Tech, register on the Steer Tech, fill out a form, respond to a survey, or in connection with other activities, services, features or resources we make available on the Steer Tech. We will collect the personal information from you only if you voluntarily submit such information to us. You can always refuse to supply this information, except that it may prevent you from accessing or using any or all of the activities, services, features or resources available on the Steer Tech.

The Steer Tech is intended for users aged 18 years or older. By creating an account, you represent and warrant that you are at least 18 years old. We do not knowingly collect personal data from individuals under the age of 18. If we learn that we have collected personally identifiable information from a person under 18 without verifiable parental consent or lawful authorization, we will promptly delete that information from our systems. If you believe a person under 18 has provided us with personal information, please contact us at support@steer.coach.

1.2 Non-personal Identification Information

We may collect non-personal identification information about you whenever you interact with our Steer Tech. Non-personal identification information may include the browser name, the type of computer or other communication device and technical information about your means of connection to our Steer Tech, such as the operating system and the internet service provider utilized, the domain server through which you access the Steer Tech, and other similar information. This Non-Personal Information would not assist us to identify you personally.

1.3 Surveys

The Company may email you or post various surveys on the Steer Tech. The surveys may request for your demographic information (age, gender, and familiarity with the Steer Tech, your interests, content, products and services) and your feedback on activities, services, features or resources available on the Steer Tech.

1.4 Customer Service Communications Information

The Company may collect Personal Information, Non-Personal or Other Information when you post or submit comments, questions, complaints or suggestions regarding products/services.

1.5 Other Information

The Company also collects information regarding your usage of the activities, services, features or resources available on the Steer Tech. This other information includes, but is not limited to, pattern of use of Steer Tech by you, pages visited, posts/comments made on any page of Steer Tech etc.

2. Mode of Collection of Information

1. When you use the Steer Tech, we collect and store your Information which is provided by you from time to time. Our primary goal in doing so is to provide you a safe, efficient, smooth and customized experience. This allows us to provide activities, services, features or resources available on the Steer Tech in a customised manner to make your experience safer and easier.

2. Some informational pages on steer.coach are accessible without an account; however, using the Steer coach features and Services requires registration and account creation. Once you give us your Personal Information, you are not anonymous to us. We may collect your Non-Personal Information, just by you browsing/downloading the Steer Tech. When collecting Personal Information from you we indicate which fields are required and which fields are optional. We may automatically track certain information about you based upon your behaviour on the Steer Tech. We use this information to do internal research on our users' demographics, interests, and behaviour to better understand, protect and serve our users. This information is compiled and analysed on an aggregated basis. This information may include the link/URL that you just came from (whether this URL is on our Steer Tech / app or not), which URL you next go to (whether this URL is on the Steer Tech or not), your computer browser information, and your IP address.

3. We may receive Personal Information about you from third parties, such as external APIs and social media services. If you access the Steer Tech through an external API or a social media service or connect a service/page on the Steer Tech to a social media service, the information we collect may include your user name associated with that social media service, any information or content the social media service has the right to share with us, such as your profile picture, email address or friends list, and any information you have made public in connection with that social media service. When you access the Steer Tech or otherwise deal with the Company entity through an external APIs or social media services or when you connect the Steer Tech to social media services, you are authorizing the Company to collect, store, and use and retain such information and content in accordance with this Privacy Policy.

4. We may use data collection devices such as "cookies" on certain pages of the Steer Tech to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. We offer certain features that are only available through the use of a "cookie". We also use cookies to allow you to enter your password less frequently during a session. Most cookies are "session cookies" meaning that they are automatically deleted from your device at the end of a session. We may automatically receive and collect certain anonymous information in standard usage logs through our web server, including computer-identification information obtained from "cookies". You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain services, features or resources on the Steer Tech and you may be required to re-enter your password more frequently during a session. Additionally, you may encounter "cookies" or other similar devices on certain pages of the Steer Tech that are placed by third parties. We do not control the use of cookies by third parties.

5. If you transact with us, we collect some additional information, such as a billing address, a credit / debit card number and a credit / debit card expiration date and/or other payment instrument details and tracking information.

6. If you choose to post messages on our message boards, if available, or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

7. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Steer Tech, we may collect such information into a file specific to you.

8. We shall not collect, store, or process any sensitive personal data unless essential and consented to by you. All such sensitive personal data shall be collected and processed strictly in accordance with the applicable laws.

3. Use of Information Collected

We process data only on lawful grounds like consent, contracts, legal obligations, or legitimate interests.

The Company undertakes not to disclose (includes selling, sharing and renting) your Personal Information collected by the Company at any time to any third party without your consent except in accordance with this Policy. However, the Company reserves the right to disclose Information in good faith:

1. if required by law or any authority; 2. to protect and defend rights and interests of the Company, employees/agents of the Company, other users or the general public; 3. to enforce Terms of Use and other policies of the Company; 4. to address concerns raised by a third party.

The Company uses Personal Information to market/provide its products/services. To the extent the Company uses your Personal Information to market to you, we will provide you the ability to opt-out of such uses. We use your Personal Information to identify and authenticate users; understand your needs and confirm your application information and assess your eligibility for services; establish and maintain communication, and to respond to your inquiries; investigate and settle your claims/requests, and determine your eligibility for benefits; resolve disputes; troubleshoot problems; help promote a safe service; billing and collect money; measure consumer interest in our products and services, inform you about services, and updates; customize and improve your experience; detect and protect us against error, fraud and other criminal activity; enforce our terms and conditions; meet regulatory requirements; and as otherwise specified in the Policy.

We collect passively tracked data primarily for purposes of administering, protecting and improving our Steer Tech and our systems, to better understand the preferences of our site visitors, to identify server problems, to compile aggregated statistics about site usage, and to help personalize your experience on our site.

We also use Information to curate the relevant articles and other content.

By using this Steer Tech, you hereby authorize the Company to contact you via calls, mails and/or text messages or by any other similar means using the contact details so provided, to furnish you with information regarding our various services currently available or as may be added or made available at any future date. In the event you do not wish to receive such information, you may unsubscribe to the facility.

In our efforts to continually improve our product and service offerings, we collect and analyse demographic and profile data about our users' activity on our Steer Tech.

We identify and use your IP address to help administer our Steer Tech. Your IP address is also used to help identify you and to gather broad demographic information.

We may occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like postal/zip code, age, or income level). We use this data to tailor your experience at the Steer Tech, providing you with content that we think you might be interested in and to display content according to your preferences.

The Company may also use all the data and information, generated in the course or on account of provision of products/services, on an anonymous basis for analytics purposes.

Information collected can be used by the Company within the Company or by its affiliates/contractors/agents for analysis and determination of statistics, demand and supply, pattern of usage etc.

The Company may use the user's data collected from external APIs for the purpose of allowing them to access and use the activities, services, features or resources available on the Steer Tech.

The Company retains the user's information for as long as the account is active and as needed to provide the Services. Upon account deletion, we will permanently delete the user's personal information immediately, except for limited records that we are required to retain for billing, legal, or dispute-resolution purposes (which we keep for two years from the date of account closure). All such data and information shall be processed and retained in accordance with the applicable laws.

4. Sharing of Information

4.1 With Service Providers

We may share your Information, on a need to know basis, with third parties that provide services to help with our business activities. These third parties are authorized to use your Personal Information only as necessary to provide certain services to us, including but not limited to:

Steer uses industry-leading AI infrastructure providers to process your conversations. We have signed Data Processing Addenda ("DPAs") with each provider under which they are contractually prohibited from using your data to train their models and are required to limit retention to what is necessary for service delivery. The current list of AI sub-processors is set out in §15 (Sub-processors) below. Your conversation data is transmitted to these providers via encrypted API calls.

Certain User data, including personal data like birth details, gender, location, conversation messages, and inferred memories, is transmitted to these third-party AI providers for the sole purpose of generating responses to your prompts. While the data is processed on the providers' infrastructure, our DPAs restrict retention and prohibit any use of the data outside the direct service-delivery relationship.

We collect anonymized usage data such as pages visited, features used, and general geographic region to improve our Steer Tech. This data is associated with randomly generated identifiers that cannot be linked to you. We process this data based on our legitimate interest in improving our services.

4.2 With Other Third Parties

We may share your Information with other third-party business partners, with your prior consent, strictly on a need-to-know basis, for the purpose of providing additional services on request. If you do not want us to share your Personal Information with third-party business partners, please contact us at the contact information below.

4.3 With Consent

The Company may share a user's personal data other than as described in this Policy, with prior consent of such user.

5. Your Conversations Are Private

We respect the confidentiality of your interactions in course of accessing/availing the Steer Tech. Conversations, prompts, questions, and other inputs you submit while using the Services ("User Interactions") are treated as private information.

We do not publicly disclose or share your User Interactions with third parties except:

We implement reasonable administrative, technical, and organizational safeguards designed to protect the confidentiality and security of your interactions. Where User Interactions are used to improve or develop our services, they are typically processed in aggregated, anonymized, or de-identified form.

6. Link to Other Website

The Steer Tech may contain certain hyperlinks to other websites. While the Company's Steer Tech is subject to this Policy, we are not responsible for the privacy practices or the content of any other website that are linked to this Steer Tech. Any information you provide to these other websites will be subject to their respective privacy policies. We therefore recommend that you read the privacy statement for each third party site you visit.

7. Rights and Obligations of the Users

To help the Company protect Information, the users may be required to maintain the privy of login credentials and other information required by them to access or use the Steer Tech. The users are also prohibited from communicating information provided by the Company to a third party unless required by law or in compliance with agreements entered between users and the Company.

You are always free to review and edit your Personal Information uploaded on the Steer Tech. You shall always have an option to withdraw your consent for collection and use by the Company of your Information by intimating the Company about such withdrawal by writing to the Company at the below mentioned contact information. In case, you withdraw your consent for collection, storage and use of your information by the Company, the Company shall be entitled to restrict, control or terminate your access and use of all or any of the activities, services, features or resources available on the Steer Tech.

8. Disclaimer as to Loss

Although, the Company has ensured the security of Personal Information collected, considering the open nature of internet, such Information may be accessed by unauthorised entities/software/codes in a cyber-security incident. The Company assumes no liability whatsoever with respect to access of Information in case of a cyber-security incident.

9. Security Measures

The Company adopts generally accepted, reasonable data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of the your Information, username, password, transaction information and data stored on the Steer Tech.

The Company deploys reasonable security measures in place to protect the loss, misuse, and alteration of the information under its control. Once the user's information is in the Company's possession the Company adheres to reasonable security guidelines, protecting it against unauthorized access.

In case of any data breach or a security incident, we will inform affected users and data authorities in accordance with applicable laws.

The user's information will primarily be stored in electronic form.

The Company may also use such Information for purposes of safety, security, fraud prevention and detection, and research and development for as long as it retains such information.

Only authorized personnel have access to your Information. Our systems and procedures are designed to prevent the loss, misuse, unauthorized access, disclosure, alteration, and destruction of your information. Our commitment to security extends to the contracts and agreements that we sign with external suppliers and service providers. We will retain your Information only as long as is required for the purposes for which it was collected and/or any legal or regulatory requirements. We shall only make use of, disclose and/or store your Personal Information in a secure and confidential manner.

We follow generally accepted industry standards to protect the personal information submitted to us. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use industry best practices to protect your Personal Information, we do not guarantee its absolute security.

All the data collected or generated pursuant to the Steer Tech is processed on the cloud Steer Tech/servers provided by third parties ("Cloud Provider"). The Cloud Provider has security measures in place to protect the loss, misuse and alteration of the information. You acknowledge that the standards followed by the Cloud Provider are not within control of the Company and are liable to change from time to time.

The data and information collected by us may be processed in USA or other countries with appropriate legal safeguards in place and in any case in accordance with the applicable laws.

10. Your Rights

Subject to applicable law, you have the following rights with respect to your personal information. We honor these rights regardless of where you reside.

10.1 Right to Access

You have the right to request a copy of the personal information we hold about you. You can request a downloadable export of your account data — including your profile, conversation history, AI-inferred memories, and account metadata — through the in-app Privacy Settings or by emailing support@steer.coach. Exports are provided in a machine-readable JSON format.

10.2 Right to Rectification

You have the right to correct inaccurate personal information. You can edit your profile information (including birth details, name, and other account fields) directly through the Steer Tech.

10.3 Right to Erasure (Right to Be Forgotten)

You have the right to delete your personal information. You can:

Upon account deletion, we will permanently delete your conversations, AI memories, profile, notifications, push tokens, device registrations, and friends-and-family records immediately. Limited records required for billing, legal, or dispute-resolution purposes are retained for two years from the date of account closure (see §3 above for details).

10.4 Right to Data Portability

The export referenced in §10.1 is provided in a structured, commonly used, machine-readable format (JSON) that you may transmit to another service.

10.5 Right to Restrict or Object to Processing

You may restrict or object to certain processing of your personal information by adjusting your in-app preferences (including notification preferences) or by contacting support@steer.coach.

10.6 Right to Withdraw Consent

Where we process your personal information based on consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.

10.7 California Residents (CCPA / CPRA)

If you are a California resident, in addition to the rights above, you have specific rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

10.8 European Economic Area, United Kingdom, and Switzerland Residents (GDPR / UK GDPR)

If you are located in the EEA, the UK, or Switzerland, we are the data controller for your personal information and our legal bases for processing are:

In addition to the rights above, you have the right to lodge a complaint with your local supervisory authority. We have not appointed a Data Protection Officer because we are not required to do so under Article 37 of the GDPR; however, you may contact our Grievance Officer (see §15) for any data protection inquiries.

10.9 India Residents (DPDP Act 2023)

If you are located in India, the Steer Tech is a Data Fiduciary under the Digital Personal Data Protection Act, 2023. You have rights to access, correct, erase, and grievance redressal in respect of your personal data, which are honored as set out above. Our designated Grievance Officer is identified in §15.

10.10 How to Exercise Your Rights

To exercise any of the rights described in this section, use the in-app Privacy Settings where available, or email support@steer.coach with your request. We will verify your identity (typically through your registered email address) and respond within the timeframes required by applicable law (generally within 30 days, extendable as permitted).

11. International Data Transfers

Steer Corp. is incorporated in Delaware, United States of America, and our primary data storage and processing infrastructure is hosted in Amazon Web Services' US East (N. Virginia) region. If you access the Steer Tech from outside the United States, your personal information will be transferred to, stored, and processed in the United States.

For users in the European Economic Area, the United Kingdom, or Switzerland, when we transfer your personal information to the United States, we rely on appropriate safeguards as required by applicable law, including the European Commission's Standard Contractual Clauses (SCCs) where applicable. For users in India, transfers outside India are made in accordance with the Digital Personal Data Protection Act, 2023. By using the Steer Tech, you acknowledge that your personal information may be processed in jurisdictions whose data protection laws may differ from those of your country of residence.

12. Sub-processors

We engage the following categories of sub-processors to help us provide the Services. Each sub-processor is bound by a Data Processing Addendum that restricts their use of your personal information to the purposes for which we engage them.

AI infrastructure providers (used to generate responses to your prompts):

Cloud infrastructure: Amazon Web Services (compute, storage, networking)

Authentication: Google Firebase Authentication

Communications and notifications: providers of email, push notification, and in-app messaging services

We may update this list from time to time as we add or change sub-processors. The current list is also reflected in our Terms of Use. Material changes that affect how your personal information is processed will be communicated through the Steer Tech or by email.

13. Changes to this Policy

We reserve the right to modify this Policy at any time. In the event that we do so, the updated privacy policy shall be posted on our Steer Tech and it will be incumbent upon you to review the same periodically. However, if we materially change our privacy practices we will notify you by sending an email or by posting a notice on our Steer Tech.

14. Governing Law and Dispute Resolution

All disputes in relation to this Policy will be resolved by arbitration under the rules of American Arbitration Association, in Washington State, USA, by a sole arbitrator appointed by the Parties mutually. The arbitration award shall be final and binding on the Parties, and enforceable in accordance with its terms. The arbitrator shall state the specific reasons for its findings in writing. The Parties agree to be bound thereby and to act accordingly.

Subject to the arbitration provision, the courts of competent jurisdiction at Washington State, USA shall have exclusive jurisdiction over all matters arising pursuant to the Agreement.

15. Contact Information / Grievances

If you have any questions about this Privacy Policy, the practices of this Steer Tech, your dealings with this Steer Tech or any grievances, please contact us at:

Samarth Bhargava

Email: support@steer.coach