Initial Account Creation
Types Of Data We Collect.
We collect personal data and non-personal data about you. “Personal Data” means your name and any data that allows someone to identify or contact you, including, for example, your address, telephone number, e-mail address, geo-location data, device identifier as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
The following provides examples of the types of data that we collect, and how we collect them. Note that not all of the Sturb Services collect all of the data listed below:
|Account Credentials||We may require you to provide an phone number to use certain Sturb Service.|
|Device Information||We may collect certain software and hardware information about your Device. For example, we may collect an ID that is unique to the device on which you install and/or access the Sturb Service (“Device ID” and “Device,” respectively).|
|Distance Information||When you use the Sturb App, we will collect your location to determine your distance from other users (“Distance Information”) through the GPS, Wi-Fi, and/or cellular technology in your Device. Your last known location is stored on our servers for the purpose of calculating Distance Information between you and other users.|
|Messages||When you send a message (which may include photos, location, audio, or video) to other users of the Sturb Service, we may retain the message for archival purposes or as otherwise allowed by law.|
|Profile Information||We may collect Personal Data from you. For example, in the Sturb App, we may collect your photo, display name, status, relationship, ethnicity, age or date of birth, geo-location data, email address, password for the Sturb Service, height, weight, social network link, “Looking For,” “Favorites,” “Blocks,” “Tribes” and any other information that you voluntarily add to your profile on the Sturb App or that is generated through your use of the Sturb Service. You may also have the option to provide information concerning health characteristics, such as your HIV status. Remember that if you choose to include information in your profile, and make your profile public, that information will also become public. As a result, you should carefully consider what information to include in your profile.|
|If you provide us feedback or contact us for support we will collect your name and e-mail address and possibly other Personal Data, as well as any other content that you send to us in order to reply and address any issue. If you contact us for support, we may also collect and retain certain technical diagnostic data, such as your phone model.|
|Partner Promotion||We may collect information that you provide as part of a Partner Promotion (defined below).|
|Third Party Platforms||If you use or connect to the Sturb Site or download the Sturb Service through a third party platform, such as Facebook, you allow us to access and/or collect certain information from your third party platform profile/account. We may also access information contained in cookies placed on your device by the third party platform. Note that we may share this information with the third party platform for their use.|
|Third Party Tracking||Our advertisers and partners may also use their own cookies or other tracking technology which may collect information about you within the Sturb Service. We do not control use of these tracking technologies.|
Use And Processing Of Your Personal Data.
In addition to the uses described above, we use your Personal Data in the following ways:
- Identify You. To identify you as a user on the Sturb Service.
- Provide Products and Services. To provide the products and services you request, including the Sturb Service.
- Improve Services. To improve the Sturb Service.
- Communicate with you. To respond to your inquiries related to support, employment opportunities, or other requests, and to send Promotional Emails to those users that request or authorize them.
- Partner Promotions. To conduct a Partner Promotion that you request.
- Marketing and Advertising. For marketing and promotional purposes, including to inform you of products, services or offers of Sturb , our related companies or business partners that may be of interest to you.
- Administration. For internal administrative purposes, as well as to administer or manage our relationship with you, including to communicate with you regarding your use of Sturb Services.
- Employment. If you apply for employment with Sturb or currently work for Sturb , to manage your employment application, assess your qualifications, and manage your employment with us (applies solely to the Sturb Site).
Sharing Of Personal Data.
In addition to the specific situations discussed above, we disclose Personal Data in the following situations:
- User Profiles. The Sturb App is a social networking platform that is designed to allow users to share information. When you use the Sturb App, your Profile Information is public, and other users of the Sturb App can see your Profile Information and other Personal Data (including sensitive personal data) posted by you. For example, other users can search for you, search for your profile characteristics, or see you listed as being in their vicinity. Do not include information in your profile that you want to keep private. While the Sturb App may permit you to make certain items (e.g., Profile Information, preferences, opinions of other users, or other information) non-public, sophisticated users who use the Sturb App in an unauthorized manner may nevertheless be able to obtain this information and may be able to determine your identity. By becoming a member, you authorize that your photos are used for marketing purposes by our platform.
- Distance Information. The Sturb App is designed to allow users to share Distance Information. As a result, Distance Information is public, and other users of the Sturb App can see your Distance Information (including how many feet or meters you are from them). Sturb App users can use the search feature in the Sturb App to search for other users by distance. Your Distance Information will be used for these searches. Sophisticated users who use the Sturb App in an unauthorized manner, or other users who change their location while you remain in the same location, may use this information to determine your exact location and may be able to determine your identity. Please note: even if you choose to hide your Distance Information, the Sturb App will continue to sort and display your profile based on your relative distance from other users, so your Distance Information may still be approximated by other users. Thus, even if you choose to hide your Distance Information, others may nevertheless be able to determine your location.
- Other Disclosures. Sturb may disclose Personal Data in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws; to establish or exercise our rights to defend against legal claims; if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, violation of our policies, or as otherwise required by law.
You can make the following choices regarding your Personal Data:
- Promotional Emails. You may choose during the registration process to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials related to Sturb and/or the Sturb Service, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications, and our applications may deliver notifications directly to your mobile device.
- Behavioral Advertising. If you are using the Sturb Service on an Apple iOS device, you may opt out of behavioral targeting by going into Settings > Privacy > Advertising on your iOS device, or visiting Apple’s website for more information.
- Changes To Your Personal Data. Sturb relies on you to update and correct your Personal Data. You can modify or delete your profile within the Sturb Service. Please note that Sturb may keep historical information and content in our backup files and archives as permitted by law and to the extent we anticipate that the information may be required in connection with the original purpose of the collection, or as otherwise permitted or required by law.
- Revocation Of Consent. The Sturb Service relies on the processing of Personal Data that you have provided. If you revoke your consent for the processing of Personal Data, then we will no longer be able to provide the Sturb Service. In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
- Access To Your Personal Data. If required by law, upon request, Sturb will grant a user reasonable access to the Personal Data that Sturb holds about the user. All requests must be directed to the contact in the “Contact Information” section of the Sturb Service.
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While Sturb uses reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure, Sturb cannot guarantee the security of your Personal Data. In the event that we are required by law to inform you of any unauthorized access to your Personal Data, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
The following additional information relates to our privacy practices:
- Permissible Age. The Sturb Service is intended for users 18 years of age and older only (twenty-one (21) years of age in places where eighteen (18) years is not the age of majority). We do not intentionally gather Personal Data about visitors who are under the age of majority. If you are aware that a child or minor has submitted Personal Data on the Sturb Service, please contact us using the information provided below so that we can take appropriate action.
- Transmission Of Data To Other Countries. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding Personal Data may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach. By submitting your Personal Data, you agree to this transfer, storage and/or processing, including all associated risks.
Sturb will also initiate a prompt investigation if you contact us with a complaint against our privacy practices or a concern that our practices do not conform to the requirements in your jurisdiction. We will attempt, where practical, to ensure ongoing compliance with any legal obligations.
Last Revised: February, 2017