Contents
1. Summary and defined terms
Stampup operates a digital loyalty service (the "Services") under which a business running a loyalty programme (respectively the "Merchant" and the "Programme") issues a loyalty card (the "Card") to a customer (the "Card Holder"). The Card is held in the Apple Wallet or Google Wallet application on that person's phone (the "Wallet"), and it records the stamps collected at that Merchant. The controller responsible for the Services is stampup, and section 2 gives its particulars. Section 3 identifies the matters for which a Merchant is the controller instead.
The information collected at enrolment varies according to the form of sign-up page which the Merchant has selected. It ranges from no personal information whatsoever, through the name and date of birth of the Card Holder, to the name, email address and date of birth of that person. Each Merchant has sight solely of the customers enrolled in its own Programme, so that a Card held with one Merchant remains with that Merchant alone. A stampup account, where the Card Holder chooses to open one, assembles that person's Cards in a single place, and stampup operates that account on its own responsibility.
A Merchant may send its news and offers to a Card Holder through the Card only where that person has given a separate consent for the purpose, and any consent so given may be withdrawn at any time. The Card Holder may at any time obtain a copy of the personal data held about that person, require its correction, receive it in a portable form or require its erasure, as section 10 sets out in full. Neither the website nor the application carries any tracking or analytics tool.
2. The controller
Stampup provides loyalty cards to small businesses. A Merchant issues a Card, the Card Holder adds that Card to a phone, and the Card then records the stamps which that person collects at the Merchant in question.
The controller of the personal data described in this notice, save to the extent that section 3 provides otherwise, is Stampup VOF, whose registered address is Vivaldilaan 95, 3122 HW Schiedam, the Netherlands, whose company number is 42187962 in the Handelsregister of the Kamer van Koophandel, and which may be contacted at privacy@stampup.app.
3. Allocation of responsibility
Two distinct roles arise under the Services, and the identity of the controller in any given matter determines the party to whom an enquiry about that matter should be addressed.
3.1 Where a Card Holder collects stamps at a Merchant, that Merchant determines what its Programme is worth and the circumstances in which a stamp is awarded. It is accordingly the controller of the stamps, the rewards and the customer list belonging to its own Programme. Stampup operates the software for that Merchant and acts on its instructions. A Card Holder with a question about those records should approach the Merchant in the first instance, and stampup will assist.
3.2 The stampup account, being the arrangement under which the Cards of a single Card Holder are held together in one place and under which that person signs in, stands on a different footing. Stampup determines how that account operates, and stampup answers to the Card Holder for it directly.
3.3 Stampup is likewise the controller of the measures by which the Services are kept secure and abuse of them is prevented, and any enquiry about those measures should be addressed to stampup.
3.4 The messages which a Merchant sends through the Card are determined by that Merchant. That Merchant is the controller of them, and an enquiry about them should be addressed to it. A withdrawal of consent communicated either to the Merchant or to stampup takes effect in both places alike.
4. Personal data collected
4.1 Each Merchant selects one of three forms of sign-up page, so that what a Card Holder is asked to provide depends on the Card presented to that person. Under the first form, the wallet Card, no name, no email address and no date of birth is requested; a single tap places the Card in the Wallet, and stampup then holds the Card and the stamps recorded on it and nothing further about that person. Under the second form, stampup collects the name which the Card Holder types, together with the date of birth where that field is completed. Under the third form, the email Card, stampup collects the name which the Card Holder types, an email address, and the date of birth where that field is completed.
4.2 The email address is the means by which the same person is recognised on a new phone. A Card whose date of birth field has been left empty works in precisely the same way as one whose date of birth field has been completed.
4.3 On the card page belonging to the Card Holder, that person may add or amend the name, the email address, the phone number and the date of birth held. The phone number is requested on that page alone, and at no earlier point in the enrolment.
4.4 The pass held in the Wallet carries two items about the Card Holder, namely a card code which is scanned at the counter and a login code which opens the stamps page belonging to that person. The name, the email address, the phone number and the date of birth are absent from the pass and remain in the stampup database. Where a Merchant sends an offer, the words which that Merchant composed appear on the reverse of a Card held in Apple Wallet.
4.5 The Merchant whose Card a person holds has sight of that person's first name, of the number of stamps collected and of the dates on which that person attended. It also holds the details which that person typed, and those details constitute its own customer list. Each Merchant has sight solely of its own customers. Merchants use the Services on the conditions that they employ that list for the purposes of their own business, that they keep it to themselves and that they delete a Card Holder's details upon request. Where a Merchant acts in breach of those conditions, the Card Holder should inform stampup and should inform the data protection authority as well.
4.6 Every enrolment, every stamp and every reward is written once to a record which is then neither altered nor removed, and those records hold reference numbers and dates. The code which writes those records refuses the name, the email address, the phone number and the date of birth of a Card Holder.
4.7 Where a person runs a Merchant business on stampup, stampup holds that person's name, business email address, phone number and business address, and it stores the password only in a one-way scrambled form from which the original cannot be recovered. The sign-in library records the IP address and the browser type of each sign-in and keeps them with the session, so that the Security screen can display to that person the browsers in which the account stands open. The pins belonging to a Merchant are held in the stampup database so that the Pins screen can display them back to that Merchant.
5. Purposes and lawful bases
5.1 Stampup processes personal data to perform its contract with the Card Holder in three respects. It issues a Card, counts the stamps collected and delivers the reward earned, because that person asked a Merchant for a Card. It updates the Card held in the Wallet whenever a stamp is recorded, because a Card which shows the wrong count is of no use to the person holding it. It also keeps that person's Cards together in one place and recognises that person on a new phone, because that person asked stampup for an account.
5.2 Stampup processes personal data on the basis of consent in two respects. A Merchant sends its news and offers to a Card Holder through the Card, and the Card Holder gives that consent by the separate affirmative answer on the sign-up form. Stampup also keeps the date of birth so that the Merchant can provide the birthday treat offered under its Programme and send a birthday message through the Card on the day, and the Card Holder supplies that date by completing the birthday field. A consent given for either purpose may be withdrawn at any time.
5.3 Stampup processes personal data on the basis of its legitimate interests in four respects. It keeps accounts secure and keeps a record of sign-ins, because stampup has an interest in keeping people out of accounts which belong to somebody else. It identifies stamp farming, shared codes and automated enrolments, because stampup has an interest in stamps which are earned by genuine visits. It counts attempts and slows floods of them, because stampup has an interest in keeping the Services standing when they are subjected to a sudden weight of traffic. It observes which parts of the Services people use and which parts confuse them, because stampup has an interest in correcting the parts which cause confusion.
5.4 Stampup also compiles overall figures about visits and the frequency with which customers return. Merchants have an interest in a point of comparison, and stampup has an interest in understanding how the product performs. Those figures describe groups of people from which no individual can be singled out, and they accordingly fall outside the data protection rules. Stampup uses such figures freely and discloses them both to Merchants and to others.
5.5 Where a purpose rests on the legitimate interests of stampup, as paragraph 5.3 identifies, you may object to the processing carried out for that purpose. Stampup will consider any objection so raised and will respond to the person who raised it.
7. Location of processing and transfers
The personal data described in this notice is stored within the European Union, in Frankfurt. Email passes through Microsoft, and the booking of a demonstration passes through Cal.com; sections 15.8 and 15.9 say where each of those companies processes it.
Certain of the companies with which stampup works are established in the United States. Where the European Commission has determined that a company affords the protection which the law requires, stampup relies on that determination. Where the European Commission has made no such determination, stampup relies on the standard contractual clauses which that Commission has adopted. Apple stands on those clauses as at the date of this notice, and stampup will send a copy of them upon request.
8. Retention periods
8.1 The account of a Card Holder and the Cards held within it are kept for as long as that account exists. Where a Card has received no stamp, no reward and no sign-in for 24 months, stampup sends a warning by email, and 30 days later it removes the details of the Card Holder.
8.2 Where a Card Holder asks stampup to delete the personal data held about that person, the name, the email address, the phone number and the date of birth are removed within 30 days. The stamp history is kept as anonymous counts from which the details of that person have been detached.
8.3 Records of the matters to which a person has agreed are kept for 5 years after the end of the agreement in question. Security and sign-in records are kept for 90 days. The counters which slow repeated attempts are kept for 24 hours.
8.4 Apple device registrations relating to a pass are kept until the phone in question unregisters the pass, or until Apple reports that the token is dead. Google permits nobody to delete a Google Wallet pass object, so stampup expires such objects and blanks them, and the Card Holder removes the pass from within the Google Wallet application.
8.5 Invoices and accounting records are kept for 7 years, because the tax law of both markets in which stampup operates asks for seven. Every backup is discarded within 30 days.
8.6 Where a Card Holder deletes a Card, stampup removes the name, the email address, the phone number and the date of birth, and it keeps the bare record that a stamp occurred. That record is kept under a reference number, and stampup holds nothing which links that number back to the person. That record is what keeps the totals of a Merchant in balance.
9. Messages sent through the Card
The Card held in the Wallet updates whenever a stamp is recorded on it. That update is the ordinary operation of the Card, and it happens because the Card Holder asked a Merchant for the Card.
A Merchant may in addition send its news and offers to a Card Holder through the Card, once that person has consented. The consent is a separate affirmative answer on the sign-up form, it stands empty until the Card Holder completes it, and it belongs to that one Merchant alone.
Messages are held overnight and delivered in the morning. Each Merchant is allotted a small number of messages to any one Card Holder, and Google permits at most three notifications on a pass in any period of 24 hours.
A Card held in Apple Wallet carries an unsubscribe link on its reverse, and a single tap on that link brings the offers of the Merchant in question to an end. On any Card, a communication to the Merchant or an email to stampup has the same effect.
The withdrawal of a consent to offers leaves the Card exactly as it stands, and the stamps collected and the rewards earned remain where they are.
10. Rights of the Card Holder
Subject to the conditions which the applicable data protection law imposes, you may exercise the rights set out in paragraphs 10.1 to 10.4 below.
10.1 You may obtain a copy of everything which stampup holds about you, you may require the correction of anything which is inaccurate, and you may require that the personal data held about you be deleted.
10.2 You may require that the use of your personal data be placed on hold while a question about that data is resolved, and you may receive that data in a file capable of reuse, so that you may take it elsewhere.
10.3 You may object to those uses which rest on the legitimate interests of stampup, being the uses which paragraph 5.3 identifies, and you may at any time withdraw a consent previously given. The processing carried out before that withdrawal remains lawful.
10.4 You may lodge a complaint with a data protection authority, on the terms which paragraph 10.7 sets out.
10.5 A request under paragraphs 10.1 to 10.3 should be addressed to privacy@stampup.app, and stampup will answer within one month. Deletion of the personal data held about a Card Holder brings that person's Card and stampup account to an end. A Merchant keeps its own copy of the customers which it enrolled, and that copy is the Merchant's to delete. A Card Holder should therefore approach the Merchant, should inform stampup as well, and stampup will assist.
10.6 A Merchant sees the members of its Programme grouped according to the frequency with which they return, and it selects from among those groups the people to whom an offer is sent. A person at the Merchant makes that selection. Every reward which the stamps of a Card Holder have earned remains that person's to claim. No decision which produces legal effects concerning a Card Holder, or which similarly significantly affects that person, is taken by automated means, and a person takes every such decision. Where a Card Holder instructs stampup to stop using personal data in this way, stampup will stop.
10.7 Stampup is established in the Netherlands, so the Dutch Autoriteit Persoonsgegevens, at Postbus 93374, 2509 AJ Den Haag, is the lead supervisory authority. A complaint may equally be lodged with the Austrian Datenschutzbehörde, at Barichgasse 40-42, 1030 Wien, or with the data protection authority of the country where you live.
10.8 Where personal data is exposed and that exposure is liable to place a Card Holder at risk, stampup will inform that person of what has happened, of what it means for that person, and of the steps which stampup is taking in response. Stampup will inform the data protection authority as the law requires.
12. Age of the Card Holder
Cards issued under the Services are intended for people aged 16 and over, and the birthday field accepts a date from the age of 16 upwards. Where a Card belongs to a person under the age of 16, an email to privacy@stampup.app will cause stampup to delete that Card.
13. Amendment of this notice
This notice carries a version and a date at its head, and the version which you are reading is version 2026-10-19, in effect from 19 October 2026.
Where stampup changes something which matters to the Card Holder, it asks that person again the next time they join a Card or amend their details, and it records the version to which that person agreed together with the date of that agreement.
14. Contact
Any question about personal data, and anything on this page which stands in need of explanation, may be addressed to privacy@stampup.app.
In respect of the customer list which a Merchant holds for itself, the Card Holder should approach that Merchant in the first instance, should inform stampup as well, and stampup will assist.
15. Sub-processors
15.1 The companies identified in the paragraphs which follow handle personal data in the course of the work which they perform for stampup. Stampup keeps this list current, and it notifies Merchants 30 days before it adds a company to the list.
15.2 Render runs the stampup servers. The processing takes place in Frankfurt, Germany, and the company itself is established in the USA. The transfer rests on the EU-US Data Privacy Framework.
15.3 Neon runs the stampup database and stores the logos of Merchants. The processing takes place in Frankfurt, Germany, and the company itself is established in the USA. The transfer rests on the EU-US Data Privacy Framework, under which it is listed under Databricks, Inc. with Neon, LLC as a covered entity.
15.4 Google provides Google Wallet passes, the address suggestions which appear on Merchant screens, and the fonts of the stampup marketing site. The processing takes place in the USA, and the transfer rests on the EU-US Data Privacy Framework.
15.5 Apple provides Apple Wallet passes and the push by which those passes are updated. The processing takes place in the USA, and the transfer rests on the standard contractual clauses adopted by the European Commission.
15.6 Stripe takes payment from Merchants, from the date on which billing begins. The processing takes place in Ireland for European Merchants, the parent company is established in the USA, and the transfer rests on the EU-US Data Privacy Framework.
15.7 Cloudflare carries the network in front of the stampup website, so that every request to the website passes through it. The company is established in the USA and operates a worldwide network. The transfer rests on the EU-US Data Privacy Framework and on the standard contractual clauses in Cloudflare's data processing addendum.
15.8 Microsoft sends and receives the email of stampup, including the messages which stampup sends to Card Holders and Merchants. The processing of a European customer's data takes place within the European Union under Microsoft's EU Data Boundary, the company itself is established in the USA, and the transfer rests on the EU-US Data Privacy Framework.
15.9 Cal.com takes the bookings of a demonstration of stampup, namely the name, the email address and the chosen time of the person who books. The processing takes place in the USA. The transfer rests on the standard contractual clauses adopted by the European Commission.
15.10 jsDelivr serves one script library to the stampup marketing site, and so receives the address of the visitor's connection. The company is established in the United Kingdom, which the European Commission has determined affords adequate protection.