Privacy Policy

  1. Introduction

    Stumped.app respects your privacy. We are committed to ensuring the protection and security of your personal data.

    When this Policy mentions “we”, “us”, “our” or the “Company”, it refers to the controller of your personal data under this Policy, namely RedDigital OÜ (Harju Maakond, Tallinn, Kesklinna Linnaosa, Veerenni tn 24, 10135) with which you had, have or will have a business relationship.

    Please keep in mind that since RedDigital OÜ is company registered under RedDigital OÜ laws, this Policy may be replaced or supplemented or modified in order to fulfil requirements of the local laws or to provide you with additional information on how we process your data through specific RedDigital OÜ products, services, or applications.

    This Privacy Policy explains the types of personal data that we may collect, the purposes for the collection, how the personal data is processed as well as your rights in relation to your personal data.

  2. The Personal Data That We May Collect

    In the course of you accessing this website, we may collect certain data which is considered personal in nature. As we respect your privacy, we understand the term “personal data” to mean any information that may directly or indirectly identify you. We treat all such data with the requisite standards of safety.

    We do not collect any more personal data than what is necessary to provide you with access to our website. Depending on the circumstances and on our business relationship with you, we may collect different categories of personal data, including, but not limited to the following:

    1. Personal Data Provided By You, depending on the circumstances:
      • Contact information (e.g. name, address, e-mail address, phone)
      • Personal information (e.g. age, date of birth, gender)
      • Account log-in information (e.g. username, security question)
    2. Data Automatically Collected When You Use Our Website/App, depending on the circumstances:
      • Browser type
      • IP address
      • Your browsing activities, such as the web pages you have clicked on our Website and App
      • The operating system you use
      • Date and time of access

    COOKIES:A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website again and improve our service to you. Cookies may also be used to compile aggregate information about areas of our website that are visited most frequently. This traffic information can be used to enhance the content of our website and make your use of it easier. By continuing to access our website, you give your consent to our usage of cookies. The information stored and collected through the usage of these cookies will not be shared with any third party except as specified in this document. The information stored and collected through the usage of these cookies will not be sold to any third party for profit.

    If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny the cookie feature. But you should note that acceptance of the cookies feature may be necessary for us to provide you with certain specific features of our website.

  3. Sensitive Personal Data

    We do not collect sensitive personal data. The definition of sensitive personal data varies from country to country. RedDigital OÜ considers sensitive personal data to be any information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership in addition to data concerning your health, genetic and biometric information and sex life or sexual orientation.

  4. Children’s Personal Data

    We do not knowingly collect personal data from children (i.e, any individual below the age of 16) unless it has been indicated to us that their legal guardian has consented to collection of such personal data. The level of protection afforded to such data shall never be less than what is afforded to the personal data of adults collected by us.

  5. Links to Third Parties

    Our Website and Apps may contain links to websites of third parties which are not covered by this Privacy Policy. We cannot make any claims or assurances as to how these third parties collect, store, and use data collected by them.

    Why Do We Collect Your Personal Data?

    We may collect your personal data for multiple reasons. In general, we collect your personal data to:

    • Enable you to browse on our websites and improve your user experience
    • Provide you with our services
    • Provide you with marketing and customer services
    • Communicate with you about changes or updates, such as of our terms and conditions, privacy policy or any other matters that may be relevant to you
    • Carry out data analytics
    • Perform or conclude a contract between you and us
    • Carry out our fraud detection and prevention services
    • Understanding general trends as to consumption of sports-related media and fandom
  6. How Do We Process Your Personal Data?

    We process your personal data in accordance with the following principles at all times:

    • Lawfulness

      When processing your personal data, we always ensure that the processing is done in accordance with the applicable laws.

    • Transparency

      When collecting your personal data, we strive to provide you with as much information as possible about the processing of your personal data.

    • Purpose Limitation

      Your data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with the original collection purpose. The data being collected by us shall only be used for the purposes set out above. We shall not use the same for any other purpose without seeking your express permission to do so.

    • Data minimization

      We only collect and/or process data which is strictly necessary for our services that include personal data processing activities.

    • Accuracy

      We keep your personal data as accurate as possible and you may rectify your personal data at any time.

    • Storage Limitation

      We do not retain your personal data for longer than it is necessary (see also Section 8 below).

    • Integrity and Confidentiality

      We make use of the appropriate security measures to ensure the protection of your personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

  7. How Long Do We Keep Your Personal Data?

    We do not keep your personal data for longer than it is necessary. When keeping your personal data, we take into account legal obligations and the original purpose of collection. The retention period of your personal data may vary in accordance with the purpose of collection.

  8. On What Legal Basis Do We Process Your Personal Data?

    The processing of your personal data may be based on the following grounds:

    • Your consent (You may withdraw your consent for processing data at any time provided our processing is based on your consent)
    • The necessity of data processing to conclude and/or perform a contract between you and us
    • To comply with legal obligations as well as to establish, exercise, or defend ourselves from legal claims
    • Us legitimately acting in our interest, provided that such an act does not override your interests or fundamental rights and freedoms
    • To perform a task in the public interest

    The legal grounds for processing your personal data vary according to the circumstances and context for the collection. We do not process your personal data without a legal justification.

    We may use the services of third parties to process the data collected by us on our behalf. However, these third parties shall be bound to protect your privacy to the same extent we are bound you.

  9. Do We Share Your Personal Data?

    We may make your personal data available to affiliated companies or other trusted third parties.

    If your data is collected within the EU and transferred to countries outside the EU which do not provide the same standard of personal data protection, we have put in place adequate measures to protect your data, such as organizational and legal means, to ensure the protection of your personal data.

    When transferring your personal data, we make sure that we are compliant with the applicable data protection laws.

  10. Your Rights

    Your individual rights may vary depending on the applicable data protection laws. Where required by law and as long as the conditions laid out by law are met, we shall give effect to your rights to:

    • Be informed about the processing of your personal data
    • Access your personal data collected or processed by us
    • Rectify your personal data
    • Erase your personal data
    • Object to the processing of your personal data
    • Restrict the processing of your personal data

    To exercise any of your rights, you may write to us at reporting@stumped.app.

  11. Security of Your Personal Data

    We use all available technical and organizational security measures in order to protect your personal data against a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data transmitted, stored or otherwise processed.

    All of our employees are required to keep personal data confidential. We will only transfer your personal data to third parties as described in Clause 10 of this Policy.

  12. Changes and Updates to This Privacy Policy

    We may update, change, modify, add or amend this Policy by publishing a new version on our Website.

    This Privacy Policy was published in May 2019.

  13. How to Contact Us

    Should you have any questions regarding the processing of your personal data or should you wish to exercise a right as provided in Clause 11 of this Policy, please contact our Data Protection Officer at dpo@stumped.app

  14. Disclaimers
    • The content of this website is the copyright of RedDigital OÜ (a company incorporated under the laws of RedDigital OÜ). RedDigital OÜ’s copyright must remain on all reproductions of material procured from this website (“Material”).
    • You may download, store and use the Material for your own personal use and research or that of your firm or organization. You may not republish, retransmit, redistribute, or otherwise make the Material available to any other party or make the same available on any website or other online service or make the same available in hard copy or on any other media without our express prior written consent.
    • We accept no liability or responsibility whatsoever for any loss or damage suffered by any user of the information contained on this Website.
  15. Jurisdiction

    This Policy shall be governed by, construed and enforced in accordance with the laws of RedDigital OÜ Any action that you, any third party or RedDigital OÜ may bring to enforce this Policy or, in connection with, any matters related to this Website shall be subject to the exclusive jurisdiction of the courts of RedDigital OÜ, RedDigital OÜ.

  16. Disputes

    Any disputes that may arise through the usage of this website relating to the subject matter of this Privacy Policy shall be settled through binding arbitration conducted by a sole arbitrator appointed by us. The seat of such arbitration shall be at RedDigital OÜ The arbitral proceedings shall be conducted in accordance with the law applicable in RedDigital OÜ.

  17. Severability

    The invalidity or unenforceability of any provision of this Policy, in whole or in part, in any jurisdiction shall not affect the validity, legality or enforceability of the remainder of this Policy in such jurisdiction and this Policy shall continue to operate to its fullest extent, permissible under law.

    This is the entire agreement between the parties relating to the matters contained herein and shall not be modified except in writing, signed by RedDigital OÜ.