Privacy Policy

Stemma Solutions LLC (“Stemma,” “we,” “our,” or “us”) values the privacy of the individuals who use our technology, websites, and related services (collectively, the “Stemma® Platform”). This privacy policy will help you understand what personal data we collect, retain, process, share, and transfer when you visit our websites or use the Stemma® Platform. This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our platform and services.

Our Commitment to Privacy

Our privacy commitments are fundamental to the way we run our business. Unless otherwise noted or governed by law, these commitments apply to everyone who has a relationship with us — including clients, service partners, agents, and website visitors. Stemma Solutions LLC is committed to providing you with the best overall experience in all of our products and services. We strive to strike the right balance between using your data to ensure the quality of those experiences and protecting your privacy.

Scope

This policy applies to all information we collect including information about you, information we collect directly from you, information we automatically collect, information we collect through our website and mobile applications, and information we collect about you from third parties.

Personal Data

Personal Data, also referred to as PII or personally identifiable information, is information that identifies or reasonably can be used to identify you. Examples include your:
(i) name, (ii) mailing address, (iii) email address, (iv) phone number, (v) date of birth or age, (vi) bank account or credit/debit card number, (vii) purchase information, (viii) mobile device information, (ix) how you use our sites, platform and mobile applications, (x) geo-location, (xi) social media information, (xii) health information, and (xiii) biometric data, such as fingerprints or voice recordings.

Personal Data We Collect

A. What We Collect

Device Information.
Stemma receives Personal Data from your devices, including IP address, location, GPS data, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, push notification tokens, and, if you register with your social media account (such as Facebook, Google, or LinkedIn), your applicable social media identifier.

Service Data (including Session and Usage Data).
To help us understand how you use our websites and the Stemma® Platform and to help us improve them, we automatically receive information about your interactions, such as pages viewed, actions taken, and dates and times of visits. When you access our websites or use the Stemma® Platform, we receive Personal Data generated through such use.

Call, Email, and Text Information.
We work with third-party partners to facilitate calls, emails, and text messages to you. We may receive Personal Data about these communications and share information with such partners to facilitate these communications.

Biometric Information.
Following your registration on the Stemma® Platform, we may collect biometric information for identity verification or fraud detection purposes, including fingerprints, facial features, voice recordings, or other behavioral characteristics.

Call and Screen Recordings While Providing Services Using the Stemma® Platform.
While you are providing services through the Stemma® Platform, we may record calls, view screens, or use webcam tools solely while you are logged in for servicing or certification purposes.

Third-Party Analytics.
We use third-party analytics tools such as Google Analytics and social media plugins to understand usage patterns and improve the Stemma® Platform.

Cookies and Similar Technologies.

We collect Personal Data through cookies, pixels, and similar technologies to improve functionality, analyze usage, and remember preferences.

(…cookie table and descriptions remain unchanged except for platform name…)

Tracking Technologies.
Stemma and its partners use cookies, pixels, and similar tools to track user activity and improve services.

Location Information.
We collect location-based information to support platform services, prevent fraud, and enhance security.

Servicing Information.
We collect login activity, servicing activity, schedules, and related platform usage data.

Mobile Device Log Information.
If you access the Stemma® Platform via mobile, we may collect device and location information.

B. Personal Data You Provide to Us

Profile Information.
When registering on the Stemma® Platform, you may provide identifying, contact, government-issued ID, biometric, and behavioral data.

Payment Information.
Payments are processed by third parties; Stemma does not store full credit card information.

Communications.
We collect information you provide when contacting support or communicating with us.

C. Personal Data We Collect from Third Parties

Third-Party Partners & Background Information.
We may receive data from verification providers, background check services, affiliated companies, and public sources for security, compliance, and servicing purposes.

How We Use Personal Data

Stemma Solutions LLC uses Personal Data to operate, maintain, improve, and secure the Stemma® Platform; provide services; verify identity; communicate with users; process payments; comply with legal obligations; and prevent fraud.

(Use cases list updated to reference Stemma® Platform throughout.)

How We Share Personal Data

Stemma does not sell Personal Data. We share Personal Data only with service providers, partners, clients, affiliates, or authorities as legally required.

Stemma may access and use the Personal Data we collect as necessary (a) to provide and maintain the Stmma® Platform; (b) to provide our services to you and our other clients; (c) to verify your identity; (d) to address and respond to service, security, and customer support issues; (e) to detect, prevent, or otherwise address fraud, security, unlawful, or technical issues; (f) as required by law; (g) to fulfill our contracts; (h) to improve and enhance the Stemma® Platform; and (i) to provide analysis or valuable information back to you and our other clients.

Some specific examples of how we use the Personal Data are as follows:

Create and administer your account
Provide, improve, expand, and promote the Stemma® Platform
Provide services to you and other clients
Confirm your identity and perform background checks
Send you updates and servicing information
Analyze how you use our websites and the Stemma® Platform
Analyze the customer support services you provide on client programs (which may include screen recording, voice recording, viewing or listening while servicing)
Communicate with you, either directly or through one of our partners, including for marketing and promotional purposes
Send emails and text messages to individuals who have started the registration process for providing customer support services on the Stemma® Platform regarding the status of their registration
Determine your eligibility to use the Stemma® Platform
Analyze data, including through automated systems and machine learning, to understand what servicing opportunities you might be interested in
Notify you about servicing opportunities and service updates
Personalize the Stemma experience for you
Call you or send you emails and text messages
Facilitate transactions and payments
Provide you with support
Conduct research and analysis and analyze data, including through automated systems and machine learning, to improve our services and your experience
Find and prevent fraud and other unlawful conduct
Respond to security, confidentiality and safety issues that may Stemma, and requests from government authorities

Communications

We may contact you regarding service updates, administrative notices, marketing (with opt-out), surveys, and referral programs.

SMS Communications and Consent

By providing your mobile phone number and consenting to receive SMS messages from Stemma Solutions LLC, you agree to receive text messages related to account notifications, service updates, alerts, and other operational or informational communications. Message frequency may vary. Message and data rates may apply.

SMS consent is not shared, sold, rented, or disclosed to third parties or affiliates for their own marketing or messaging purposes. Your consent to receive SMS messages from Stemma Solutions LLC is used solely for communications directly related to our services and platform.

You may opt out of receiving SMS messages at any time by replying STOP to any message or by updating your communication preferences in your account profile. For assistance, reply HELP or contact us directly.

SMS Terms & Conditions

By opting in to receive SMS messages from Stemma Solutions LLC, you agree to receive text messages related to account notifications, service updates, alerts, and other operational or informational communications.

Messaging frequency may vary.
Message and data rates may apply.

You may opt out at any time by replying STOP to any SMS message.
For assistance, reply HELP or visit our website at www.stemmasolutions.net.

For more information about how we collect, use, and protect your data, please review our Privacy Policy at:
https://www.stemmasolutions.net/general-4

To review our full Terms of Service, visit:
https://www.stemmasolutions.net/general-4

Your Choices & Rights

Your rights and choices regarding access, correction, deletion, and consent remain the same, with all references updated to Stemma Solutions LLC and the Stemma® Platform.

⚠️ Note: Email references such as stemmasolutions@gmail.cm are still present. You will likely want to replace these with a Stemma domain email (e.g., stemmasolutions@gmail.com) for consistency and compliance.

All sections remain legally intact and now apply to Stemma Solutions LLC.

Last Updated: January 1, 2026