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Privacy Policy

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (pii) is being used online. Pii, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our service.


1. How Stumble Privacy Works!


Encrypted text messages are stored whilst awaiting delivery, and removed once delivered, however Stumble does not hold the encryption keys for such messages, decryption keys are only held by the receiving devices, and can only be decrypted as such.


Video and voice calls are encrypted between devices with a unique encryption per call and are not recorded or stored on any physical server/database.


Please note: a user may record such calls, this is beyond Stumbles control and therefore Stumble cannot be held responsible for such actions.


Encrypted user data and text messages are held on the user’s device, putting user data privacy in the hands of our users and their devices, only the sender and receiver hold on to their data at any time. Stumble does however require some user data for the service to run, please refer section 2 directly below.


2. What personal information do we collect from the people that visit/use Stumble?


When registering on our service, as required, you will be asked to enter your name/user name and email address, a mobile phone number is not required, but may be asked for at a later date, this would be optional, other details may be required such as Childs full name, age and email address when sending consent forms for children aged 13 and under, these are required to comply with C.O.P.P.A. see section 8 of this policy.


3. When do we collect information?


We collect information from you when you register on our service; Information is also collected and stored when you fill in your profile details, i.e. by uploading a profile picture or avatar.


Transaction information is stored when making a purchase from the Google play store, this is a record of the purchase only (transaction id.), NO credit information is recorded or stored on our service in any form.


4. How do we use your information?


We use the information we collect from you when you register, subscribe or fill in your profile information for the following site features, in the following ways:


  • To aid the loading of your member profile.
  • As proof of in app purchases from the Google play store.

5. How do we protect visitor information?


Our service is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our service as safe as possible. Your personal information is contained behind secured networks, encrypted and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.


We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.


6. Third Party Disclosure


We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include hosting partners and other parties who assist us in operating our service, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.


7. Google


Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users.


https://support.google.com/adwordspolicy/answer/1316548?hl=en

We have not enabled Google Ad-sense on our site but we may do so in the future.


8. Children's Online Privacy Protection Act ("COPPA")


The primary goal of COPPA is to place parents in control over what information is collected from their young children online. The Rule was designed to protect children under age 13 while accounting for the dynamic nature of the Internet.


Stumble is aimed at a general audience and does comply with COPPA.


The Rule applies to Stumble Ltd. Services as a whole that may be directed to children under the age of 13 that collect, use, or discloses personal information from children, and operators of general audience websites or online services with actual knowledge that they are collecting, using, or disclosing personal information from children under 13.


Please read Article 19 of the terms and conditions for information on parental consent etc. it is very important if you have a child aged 13 years or under that may want to use any of the Stumble Ltd. Platforms or service.


Knowing what your young child may be doing across the many internet based platforms can be a daunting experience COPPA is a small step in helping your child be more protected whilst using any app etc. that shares information.


Stumble Ltd does NOT share personal information, however we cannot be held responsible for what your child may share on their own account it is for this reason that the parent of the child must give permission via signed email to the address below.


Emails to the address provided are for permissions only and should be sent before your child registers, emails should include both, your user name and your Childs full name, age and email address. It is in yours and your Childs best interests to complete a parental consent email. [email protected]


More fine grained information about COPPA can be found at:


https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule

9. California Online Privacy Protection Act


CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at:


https://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA we agree to the following:


Users can visit our site anonymously, but will need to subscribe to reach the full content. Once this privacy policy is created, we will add a link to it on our home page or as a minimum on the first significant page after entering our website. Our Privacy Policy link includes the word ‘Privacy’, and can easily be found on the page specified above. Users will be notified of any privacy policy changes:


10. Does our site allow third party behavioural tracking?


It is very important to note that we do not allow third party behavioural tracking in any form on our service.


11. Fair Information Practices.


The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:


  • We will notify the users via email or we will notify the users via an in service notification within 1 business day.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that, individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.


Stumble Ltd will not share or dispose of member’s information to third parties as per the data protection act 1998, this can be read at the following link:


https://www.legislation.gov.uk/ukpga/1998/29/data.pdf

Stumble Ltd will not share or dispose of member’s information to third parties as per the Republic Act 10173 – Data Privacy Act of 2012


https://www.privacy.gov.ph/data-privacy-act/

Stumble Ltd will not share or dispose of member’s information to third parties as per the General Data Protection Regulation GDPR


https://gdpr-info.eu/