🔒 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 — this hash, and only this hash, is embedded in a Bitcoin transaction (“OP_RETURN”). It 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.
- Encrypted metadata — capture details (GPS, device, original filename, timestamp) are encrypted on your device with your PIN and stored only as ciphertext. We cannot read them; only you can decrypt them, and they are not written to the blockchain.
Legal basis: Performance of a contract (Art. 6(1)(b) GDPR) — these are the core deliverables of the Service.
3.2 Precise GPS Location (optional)
If you grant location permission, your latitude/longitude is included in your evidence metadata, which is encrypted on your device with your PIN before it is uploaded. Your GPS data is not written to the Bitcoin blockchain, and we never store it in readable form — the server holds only ciphertext that only you can decrypt. Because it is not on-chain, your location data is not subject to blockchain permanence: the encrypted evidence file is deleted from our servers after the retention period (see §4), and you control your own copy. GPS is optional — you may deny permission and still use the Service. We do not collect or link your name, email, or account.
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
Basic device details (such as platform and browser family) may be included in your client-side-encrypted metadata to support the evidentiary record. Like your GPS data, this is stored only as ciphertext that only you can decrypt, and it is not written to the blockchain. We do not store your full user-agent string or IP address within your evidence records.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) — providing authenticated evidence metadata — balanced against your interests; the data is encrypted under your sole control and you can review it 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
- Limited request logs (timestamps, API usage, and IP address) are retained transiently for security and abuse prevention. IP addresses are not stored within, or linked to, your evidence records.
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 (SHA-256 hash only): Permanent — cannot be deleted. GPS, device, and filename are not placed on-chain.
- Encrypted evidence file on server: 60 days, then automatically deleted. Encrypt and download your own copy before then — we cannot recover a deleted file. You will see the remaining time when you search for your evidence.
- Evidence record (hash, transaction ID, and your encrypted metadata blob): Retained so the proof remains verifiable. The metadata remains encrypted and decryptable only by you.
- Server access logs: Retained transiently for security.
- 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