🔒 Privacy Policy
1. Introduction
XPRV OÜ ("we," "our," or "us") operates the StampHash platform. This Privacy Policy explains what personal data we collect, why, the legal basis under GDPR (EU) 2016/679 and equivalent UK / US state laws, and your rights. By using StampHash you acknowledge you have read this policy.
2. Data Controller
Company: XPRV OÜ (Estonian Digital Consulting Company)
Managing Member: James S. Burrell, II
Contact for data requests: privacy@stamphash.app
3. What We Collect & Why
3.1 Evidence & File Data
- SHA-256 hash of your file — embedded in a Bitcoin transaction (“OP_RETURN”). This is permanent and cannot be deleted.
- Encrypted file — your file is encrypted client-side with your PIN before upload. The server stores only encrypted ciphertext; only you hold the key.
Legal basis: Performance of a contract (Art. 6(1)(b) GDPR) — these are the core deliverables of the Service.
3.2 Precise GPS Location
⚠ Blockchain Permanence Warning: If you grant GPS permission, your precise latitude/longitude is embedded in the Bitcoin transaction metadata alongside the file hash. StampHash does not collect, store, or link your name, email, account, or any other identifying information — the on-chain record is pseudonymous. However, the Bitcoin blockchain is permanent and immutable — this location data cannot be deleted, amended, or erased. The right to erasure (GDPR Art. 17) does not apply to data already anchored on-chain. You will be presented with a separate consent notice before your browser location permission is requested.
Legal basis: Explicit consent (Art. 6(1)(a) GDPR). Consent is freely given, specific, informed, and unambiguous — you may deny GPS permission and still use the service.
3.3 Device Information
- Browser user-agent string, platform, and language — embedded as tamper-evident metadata to support the evidentiary record.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — providing authenticated, court-ready evidence metadata. We have balanced this against your interests; you can review the exact data on the Capture screen before notarizing.
3.4 Payment Data
Mainnet payments are processed by Stripe, Inc. We do not receive or store your card number, CVV, or full billing details. We receive only a payment confirmation token. Stripe acts as an independent data controller for payment data; see Stripe's Privacy Policy.
Legal basis: Performance of a contract (Art. 6(1)(b) GDPR).
3.5 Technical & Server Logs
- IP addresses, request timestamps, API usage — retained for security and fraud prevention.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — security and abuse prevention.
3.6 Local Device Storage
We store your evidence history (transaction IDs, file names, hashes) in your browser's localStorage. This data never leaves your device and is under your control. You can clear it at any time from the "My Evidence" screen.
Legal basis: Consent via the first-use notice displayed when you first access the app (ePrivacy Directive / UK PECR).
4. Data Retention
- On-chain data (hashes, GPS, device metadata): Permanent — cannot be deleted.
- Encrypted evidence files on server: 90 days, then purged automatically.
- Server access logs: 90 days.
- Payment records: 7 years (financial regulations).
- localStorage on your device: Until you clear it.
5. International Transfers
Our servers are located in the EU (Estonia). Blockchain broadcast APIs (mempool.space, Blockstream) and Stripe (US) may process your data outside the EU under Standard Contractual Clauses (SCCs). Stripe holds a current EU–US Data Privacy Framework certification.
6. Your Rights (GDPR / UK GDPR)
Where technically feasible you have the right to: access, rectification, erasure (except on-chain data), restriction, portability, and to object to processing based on legitimate interests. To exercise any right contact privacy@stamphash.app. You may also lodge a complaint with your national supervisory authority (e.g., the Estonian Data Protection Inspectorate for EU residents, the ICO for UK residents).
7. California Residents (CCPA / CPRA)
We do not sell or share personal information for cross-context behavioural advertising. California residents may request disclosure of categories of personal information collected and request deletion (except for on-chain records). Contact privacy@stamphash.app.
8. Children
StampHash is not directed to children under 16. We do not knowingly collect data from anyone under 16. If you believe a child has provided data, contact us immediately.
9. Changes to This Policy
Material changes will be notified by updating the "Last Updated" date and a notice inside the app.
10. Contact
Privacy enquiries: privacy@stamphash.app