Date of Last Revision: November 28, 2022
Please read this Policy carefully to understand our policies and practices regarding your information. This Policy may change from time to time (see Changes to this Policy). Your continued use of this Website or our other Services after we make changes is deemed acceptance of those changes, so please check the Policy periodically for updates. Your access to and use of the Services is subject to Stir’s Terms of Service and other terms that may be made available to you in connection with your use of the Services.
In addition to this Policy, individuals residing in the United States may also refer to the Stir U.S. Consumer Privacy Notice, which provides additional details about our collection, use, and sharing of your personal information in connection with the financial services that we provide to individuals, and associated rights you may have under federal law.
Sources of Personal Information
The categories of personal information we collect depend on how you interact with us and our Services, and the requirements of applicable law. We collect different types of information about you depending on how you interact with us and how you use our Services. As further described below, we may collect information that you provide to us and information that we obtain automatically when you use our Services, and we may additionally obtain information about you from third parties. In order to provide our Services, we partner with or otherwise use third-party companies to perform certain business-related functions on Stir’s behalf (“Service Providers”), which may also collect personal information from or about you. In addition to the information below, please see the “Third Parties” section of this Policy for more information about our Service Providers.
A. Information that you provide to us
- Information necessary to provide you with the Services. We may also collect additional information from you when you use the Services. This may include financial information such as your bank account or debit card number, through one or more of our Service Providers.
- Public communications and content. Certain areas and aspects of our Services may permit or require you to provide us with your username or handle for one or more social networking or video/photo content platforms. If you provide us with this information, we may collect information related to your interactions with those platforms, such as posts that you have made, or photos and videos that you have uploaded. Take care not to share personal information publicly on those platforms unless you intend to share that information with us.
- Communications to Stir. You may contact us via a contact form, email, by chat services or by other means (for example, with questions about our Services, for customer support, or to let us know your ideas for new products or modifications to existing products). You may also choose to respond to surveys that we send out. When you contact us, we collect the information you choose to provide us, such as your contact details, any images you choose to upload and the contents and nature of your message.
B. Information that is passively or automatically collected when you use our Services
We also automatically collect certain information based on your use of our Services. This data would include your activities on our Services. For example, we, or our third-party partners, may collect:
- Activity Information. This information may include details of the activities you carry out when using our Services, including visits to our Website.
- Technical Information. This information may include the Internet protocol (“IP”) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and device identification information. Some of this information, such as your IP address, may identify your geographic region, time zone, and other rough location data.
- Inferences, such as those drawn from any of the personal information we collect, to better understand your preferences.
C. Information that is passively or automatically collected when you use our Services
We may also receive information about you from other sources, such as payment, analytics, and security Service Providers, social network platforms, and others, consistent with any privacy or sharing choices you have made with any such third-party platform.
How We Use Your Personal Information
We use the information that you provide (or otherwise permit the Services to access) for the following purposes:
- Communicating With You. We may use the information we collect to contact you for administrative purposes (e.g. to provide services and information that you request or to respond to comments and questions). Subject to your preferences regarding marketing communications, we may also use the information we collect to send you communications relating to the Services, such as updates on events, communications relating to products and services offered by us and by third parties, and communications about services we believe will be of interest to you. If you have chosen to provide us with your mobile number, we may communicate with you to provide information regarding your Stir account by phone or text message. You can opt out of text messages by following the instructions provided in those messages, or by contacting us.
- Providing the Services. We use the information we collect to operate, maintain, and provide our Services, such as enabling access to the Services, customer support, or to complete transactions.
- Security and Fraud Prevention. We use the information we collect to secure our Services and to verify identity, prevent fraud, and to continually improve these aspects of our Services.
- Analytics, Research and Product Development. We use the information we collect to analyze data usage trends and preferences in order to improve the accuracy, effectiveness, security, usability or popularity of our Services. We further use data in connection with our research on our customer demographics, interests and behavior.
- Customization. We use the information we collect, such as device identifiers, to learn how users interact with our Services in order to personalize the content of our Services.
- Legal. We use information we collect to defend our legal rights, comply with national, state, local, federal, regional or international laws, and to enforce our Terms of Service and this Policy.
- Use of Aggregated Data. We may aggregate, anonymize and/or de-identify information collected from or about you so that the information no longer identifies you (“Aggregated Data”).
How We Disclose Your Information
There are certain circumstances in which we share information collected through the Services with third parties, as set forth below. Stir does not sell your personal information.
- With our successors-in-interest. We will share your information with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) and, in each case, any due diligence relating thereto.
- With our agents, consultants, vendors and related third parties. We provide access to or share your information with third parties so they can perform services for us. Examples of such functions include marketing, mailing information, data storage, security, identity verification, fraud prevention, payment processing, legal services, and maintaining databases. We limit the personal information provided in this context to that which is reasonably necessary for them to perform their functions.
- To meet our legal obligations. Stir may disclose your information when we have a good faith belief that doing so is necessary to: (i) comply with the law including with subpoenas, search warrants, court orders, and other legal process; and respond to inquiries or requests from government, regulatory, law enforcement, public authorities, or content protection organizations; (ii) protect and defend the legal rights, privacy, safety or property of Stir, its affiliates, subsidiaries, employees, agents, contractors, or its users; (iii) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages we may sustain; or (iv) enforce this Policy or any applicable Terms of Service.
- Your Consent. In certain situations, we may share your information in the event that you consent to or authorize the sharing of your information, such as if you link or login through a social network account.
- Aggregated Data. We may share Aggregated Data with business partners, research facilities, or other third parties. This information does not identify you.
- Other Users of Our Services. We provide your information to other users of our Services if you choose to make your information publicly available in a publicly accessible area of the Services.
Depending on the Services you use, we may use Service Providers and other third parties to help us provide the Services and for other purposes, such as to gather information about how you view and use our Services and content, and to connect your activity with other information we store about you. The manner in which these third parties collect, use, store, and disclose your information (and the types of information that they collect) is governed by the policies of such third parties, and some information about your online activities may be tracked over time and across third-party websites or other online services. Stir has no responsibility for the privacy practices or other actions of any third party that may be enabled within, or integrated with, the Services. Some of these third parties and the services they provide include:
For information about your choices with respect to cookies and other technologies, please refer to the “Your Rights and Choices” section of this policy, below.
Our Services are not designed for use by individuals under the age of 13, and, for individuals between the ages of 13 and 18, Stir requires consent of a parent or legal guardian prior to the use of our Services. If you are under the age of 13, or if you are between the ages of 13 and 18 and have not obtained consent from your parent or legal guardian to use the Services, please do not use the Services or submit any information through the Services. If you have reason to believe that a child under the age of 13 has provided personal information to Stir through the Services, please contact us, and we will delete that information from our databases to the extent required by law..
We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and take steps to ensure only those at Stir with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have created an account with us, you are responsible for keeping confidential any usernames and passwords you use to access our Services. Do not to share this password with anyone else and not to use this password for other services or products.
If you have reason to believe that your personal information is no longer secure, please immediately contact us as set forth below in the “Contact Us” section.
We retain your information for as long as necessary for the purpose for which that information was collected and for our legitimate business operations; provided, however, that your information is only retained to the extent permitted or required by applicable laws. When we no longer need to retain your information, we will take reasonable steps to remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies.
We may also delete your information after a prolonged period of inactivity with respect to our Services, except to the extent necessary to comply with our legal obligations. When determining the retention period for your information, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the Services we provide to you if we delete some information about you, and mandatory retention periods provided by law and associated limitations periods.
Your Rights and Choices
Stir is committed to help you exercise your rights regarding your personal information.
A. Deletion of Your Information
To close an account that you have created with us, please contact us. Closure or deletion of your account may mean that you lose access to the personal information and data associated with the account. Certain personal information or de-identified information associated with your account may nonetheless remain on systems owned or maintained by us when required to comply with the law, our contractual obligations, or in carrying out legitimate business functions.
In addition to your choice to close your account, please note that we may also delete your information after a prolonged period of inactivity with respect to our Services. See the “Data Retention” section of this Policy for more information.
B. Communications Preferences
Depending on where you live and your choices about how to engage with us, you may receive marketing communications from us. For individuals in the United States, please follow the instructions below to opt out of marketing communications.
- Emails. In order to opt-out of email communications, please click the “unsubscribe” link at the bottom of the email or contact us.
- Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future marketing text messages by following the instructions in the text message you have received, or by otherwise contacting us as set forth below in the “Contact Us” section.
- Push Notifications. In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.
Please note that if you opt out of receiving marketing communications, we may still send you informational communications about your account or any Services you have requested, used, or received.
C. Cookies and Similar Technologies
We use various tools to collect information when you use our Services, including cookies, pixels, software development kits, advertising identifiers, and other similar technologies. In some cases, these tools are provided by our Service Providers or other third parties. Some of these technologies store information in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and information is then stored on your computer or other device so the website or app can access information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, your search history, and content you have viewed.
You may stop or restrict the placement of some types of cookies and related technologies on your device or remove them by adjusting your preferences as your browser or device permits. You can also consult the “Help” section of your browser for more information (e.g. Google Chrome, Mozilla Firefox, or Apple Safari). However, please note that cookie-based opt-outs are typically not effective on mobile applications. You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry additionally provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, the Your Ad Choices for App tool, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.
D. Do-Not-Track and Global Privacy Controls
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browser, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and developing a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
E. Residents of Canada
If you are a resident of Canada and would like access to the personal information that Stir holds about you as required by applicable law, please contact us.
Changes to This Policy
Stir reserves the right to update or modify this Policy periodically and at any time. If you disagree with our revisions to the Policy, you can deactivate your account or discontinue the use of our Services. Please review this Policy periodically for any updates or changes to this Policy.
By using our Services and Services after any such update or modification, you acknowledge that you have read and understood the terms of the Policy as updated or modified.
Please contact us if you have any questions about this Policy or the information practices of the Services.
You can contact us as follows:
228 Main St., Suite 5, Venice, CA 90291