Privacy Policy

This Privacy Policy explains how JEFGROWZZ LLC ("we," "us," or "our") collects, uses, discloses, and protects personal information when you use Sterling, including the mobile application, sterlingtheapp.com, and related services (collectively, the "App").

Sterling is a social network organized around hubs: communities pinned to places in the world. People can post in hubs, explore hubs nearby or around the world, watch Clips, and discover creators. Hub owners may publish content that is shown in Clips, Discovery, and other surfaces.

By creating an account or using the App, you acknowledge this policy. If you do not agree, do not use the App. This policy should be read with our Terms of Use and Community Guidelines.

JEFGROWZZ LLC is the controller of personal information collected through the App, unless this policy says otherwise. Questions can be sent to support@sterlingtheapp.com.

3.1 Information You Provide

3.2 Information Collected Automatically

• Device type, operating system, app version, language, and unique device identifiers
• IP address, approximate network location, and diagnostic logs
• Screens viewed, features used, timestamps, and crash or performance data
• Push notification tokens
• Device integrity tokens (such as Apple DeviceCheck or Google Play Integrity) used to help confirm that location-sensitive actions come from a genuine device and to reduce automated abuse
• On the website, standard log data and any cookies or similar technologies we use to operate the site, remember preferences, or understand traffic

3.3 Information Collected With Your Permission

We use personal information to:

• Create and manage your account, verify age, and keep the App secure
• Operate hubs, feeds, Clips, Discovery, search, messaging, events, and maps
• Show your public content to other users, including in Clips and Discovery when those features apply
• Process purchases, subscriptions, creator applications, and payouts
• Play licensed soundtracks on Clips you create and report required usage to catalog partners
• Help prevent fake location claims, spam, and other abuse
• Send service messages and, if you allow notifications, alerts about activity in the App
• Moderate content, enforce the Terms and Community Guidelines, and handle reports
• Respond to support requests and resolve disputes
• Measure how the App is used, fix bugs, and develop new features
• Comply with law, including tax, accounting, and lawful requests

We do not sell your personal information. We do not share it for cross-context behavioral advertising as those terms are used under California law. We may disclose information as follows:

5.1 Other Users

Profile details and content you post in hubs, Clips, comments, and other public or hub-visible surfaces can be seen by other users. Hub owners may see activity in hubs they manage. Direct messages are visible to the people in that conversation. Do not post anything you want to keep fully private.

5.2 Service Providers

We use vendors who process data on our instructions, which may include:

• Cloud hosting, storage, and databases
• Authentication and security
• Mapping and location services
• Push notifications
• App store billing (Apple App Store, Google Play, and our billing partners) and, if applicable, payout providers
• Licensed music catalog partners (when you add a soundtrack to a Clip)
• Device integrity and anti-abuse services
• Email and customer support tools
• Crash reporting and product analytics used to run and improve Sterling

These providers are not allowed to use your information for their own independent marketing. They must protect it and use it only to provide services to us, except where they have a separate legal obligation.

5.3 Legal and Safety

We may disclose information if required by law, court order, or government request, or when we reasonably believe disclosure is needed to protect JEFGROWZZ LLC, our users, or the public, including in cases of fraud, security incidents, or credible threats of harm.

5.4 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction. We will take reasonable steps to keep it protected and will notify you where the law requires.

We keep personal information for as long as your account is active and as needed to provide the App. You may delete your account in the App under Profile settings, Delete Account, or by contacting us. We may ask you to verify your identity before completing deletion.

After deletion, we may keep limited information for a reasonable period to comply with law, prevent abuse, resolve disputes, or complete remaining payouts or accounting. Backup copies may persist for a short time until they are overwritten. Public content you posted may remain visible in limited residual form (for example, in other users' shares, quotes, or cached copies) until those copies age out or are removed. We do not sell your content to third parties.

We use reasonable administrative, technical, and physical safeguards, including:

• Encryption of data in transit
• Access controls on our systems
• Secure storage of credentials on device where the platform provides it
• Periodic review of our handling practices

No method of transmission or storage is completely secure. Use a strong, unique password and tell us if you think your account was compromised.

Sterling is for users 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If you believe we have, contact us and we will delete it.

You can:

• Update profile information in the App.
• Access or correct personal information by using the App or emailing us.
• Delete your account in Profile settings, or by emailing support@sterlingtheapp.com.
• Request a portable export of your data where technically feasible.
• Control notifications in your device settings.
• Revoke location, camera, microphone, photos, or contacts in device settings. Some features will stop working if you do.

9.1 Additional Rights

Depending on where you live, you may have the right to access, correct, delete, or export personal information, to object to or restrict certain processing, and to appeal a denial. To make a request, email support@sterlingtheapp.com. We will respond within the time the applicable law requires, generally no later than 30 days, and we may need to verify your identity.

If you are in the EEA, UK, or Switzerland, we process information as needed to perform our contract with you, to comply with law, and based on our legitimate interests in running a safe social product. Where consent is required (for example, certain device permissions), you can withdraw it in device settings.

If you are a California resident, you have rights under the CCPA/CPRA, including to know, delete, and correct personal information, and to opt out of sale or sharing. We do not sell personal information and we do not share it for cross-context behavioral advertising. We will not discriminate against you for exercising these rights. You may use an authorized agent as the law allows, subject to verification.

We are based in the United States. If you use the App from another country, your information will be processed in the United States and possibly other countries that may not provide the same legal protections as your home country. We use appropriate safeguards required by applicable law for such transfers.

The App may link to third-party sites or services. Their privacy practices are their own. Review their policies before you provide information to them.

We may update this policy. We will change the "Last Updated" date and, for material changes, provide notice in the App or by email where reasonably possible. Continued use after an update means you accept the revised policy. If you do not agree, delete your account and stop using the App.

Privacy questions, requests, and complaints:

We will respond within a reasonable timeframe and no later than 30 days of receipt, or sooner if the law requires.