Last updated September 13, 2023
This privacy policy for STELLAXIUS, LDA (‘we‘, ‘us‘, or ‘our‘), describes how and why we might collect, store, use, and/or share (‘process‘) your data when you use our services, such as when you:
Any of the foregoing could be referred to collectively and hereinafter as the ‘Services’.
Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices or have any reservations or doubts, please do not use our Services and refrain from disclosing, showing, transmitting and sharing any personal data. If you have any questions, please contact us at [email protected].
This summary provides key points from our privacy policy, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal data do we process? When you visit, use, or navigate our Website, we may process personal data depending on how you interact with us and the Website, the choices you make, and the products and features you use. Learn more about personal data you disclose to us.
Do we process any sensitive personal data? We do not process sensitive personal data.
Do we receive any data from third parties? We may receive data from public databases, business partners, social media platforms, and other outside sources. Learn more about data collected from other sources.
How do we process your data? We process your data to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your data for other purposes with your consent. We process your data only when we have a valid legal reason to do so. Learn more about how we process your data.
In what situations and with which parties do we share personal data? We may share data in specific situations and with specific third parties. Learn more about when and with whom we share your personal data.
How do we keep your data safe? We have organisational and technical measures in place to protect your personal data. However, no electronic transmission over the internet or data storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your data. Learn more about how we keep your data safe.
What are your rights? Depending on where you are located geographically, the applicable data protections laws may mean you have certain rights regarding your personal data. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any data we collect? Review the privacy policy in full.
Personal data you disclose to us
In Short: We collect personal data that you provide to us.
We collect personal data that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities related to the Services, or otherwise when you contact us.
Personal Data Provided by You. The personal data that we collect depends on the context of your interactions with us and the Website, the choices you make, and the products and features you use. The personal data we collect may include the following:
We will collect personal data about you when:
Sensitive Data. We do not process sensitive personal data.
All personal data that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal data.
Data automatically collected
In Short: Some data — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
We automatically collect certain data when you visit, use, or navigate the Website. This data does not reveal your specific identity (like your name or contact data) but may include device and usage data, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, data about how and when you use our Website, and other technical data. This data is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect data through cookies and similar technologies. You can find out more about this in our Cookie Policy: https://www.stellaxius.com/cookie-policy/.
The data we collect includes:
Data collected from other sources
In Short: We may collect limited data from public databases, business partners, and other outside sources.
In order to enhance our ability to provide relevant Services to you, we may obtain data about you from other sources, such as public databases, business partners, affiliate programs, data providers, and from other third parties. This data includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.
In Short: We process your data to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your data for other purposes with your consent.
We process your personal data for a variety of reasons, depending on how you interact with our Website, including:
For hiring and human resources. We may process your data for recruitment, performance evaluation, training and other related purposes.
In Short: We only process your personal data when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal data. As such, we may rely on the following legal bases to process your personal data:
Under European data protection laws, we act as a ‘data controller’ of the personal data described in this privacy policy, since we determine the means and/or purposes of the data processing we perform. This privacy policy does not apply to the personal data we process as a ‘data processor’ on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the ‘data controller’ responsible for your personal data, and we merely process your data on their behalf in accordance with their instructions. If you want to know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.
If you are located in Canada, this section applies to you.
We may process your data if you have given us specific permission (i.e. express consent) to use your personal data for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your data without your consent, including, for example:
In Short: We may share data in specific situations described in this section and/or with the following third parties.
We are not in the personal data selling, trading, or renting businesses and therefore our exchanging and/or sharing of personal data with third parties is made solely in strict conformity with the Services and in accordance with the applicable laws.
We may need to share your personal data in the following situations:
In Short: We may use cookies and other tracking technologies to collect and store your data.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store data. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy: https://www.stellaxius.com/cookie-policy/.
In Short: We keep your data for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.
We will only keep your personal data:
Unless a longer retention period is required by law.
No purpose in this policy will require us keeping your personal data for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise such data, or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal data through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal data we process. However, despite our safeguards and efforts to secure your data, no electronic transmission over the Internet or data storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your data. Although we will do our best to protect your personal data, transmission of personal data to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
Our Services are not suitable or intended for individuals under 18 (eighteen) years of age, therefore we do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal data from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal data. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal data, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal data; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal data. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS POLICY?‘ below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal data, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Data Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal data, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time at your sole and fair judgement and criteria. You can withdraw your consent by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS POLICY?‘ below. However please note that withdrawal of a previously granted consent may prevent us, in some cases, from performing the Services.
The foregoing will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie policy: https://www.stellaxius.com/cookie-policy/.
If you have questions or comments about your privacy rights, you may email us at [email protected].
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal data.
California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are California residents to request and obtain from us, once a year and free of charge, data about categories of personal data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact data provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact data provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy policy
The California Code of Regulations defines a ‘resident’ as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as ‘non-residents’.
If this definition of ‘resident’ applies to you, we must adhere to certain rights and obligations regarding your personal data.
What categories of personal data do we collect?
We have collected the following categories of personal data in the past twelve (12) months:
| Category | Examples | Collected |
A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
C. Protected classification characteristics under California or federal law | Gender and date of birth | YES |
D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
E. Biometric information | Fingerprints and voiceprints | NO |
F. Internet or other similar network activity | Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
G. Geolocation data | Device location | NO |
H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | YES |
J. Education Information | Student records and directory information | YES |
K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO |
| L. Sensitive Personal Information | NO |
We will use and retain the collected personal data as needed to provide the Services or for:
We may also collect other personal data outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
How do we use and share your personal data?
More data about our data collection and sharing practices can be found in this privacy policy and our Cookie Policy: https://www.stellaxius.com/cookie-policy/.
You may contact us by email at [email protected], by visiting https://www.stellaxius.com/contact-us/, or by referring to the contact details at the bottom of this document.
If you are using an authorised agent to exercise your right to opt out we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
Will your data be shared with anyone else?
We may disclose your personal data with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the data on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal data for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be ‘selling’ of your personal data.
We have not disclosed, sold, or shared any personal data to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal data in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal data. If you ask us to delete your personal data, we will respect your request and delete your personal data, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer data that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Data
We do not process consumer’s sensitive personal data.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the data in our system. These verification efforts require us to ask you to provide data so that we can match it with data you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain data so that we can match the data you provide with the data we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal data provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional data from you for the purposes of verification. However, if we cannot verify your identity from the data already maintained by us, we may request that you provide additional data for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided data as soon as we finish verifying you.
Other privacy rights
To exercise these rights, you can contact us by email at [email protected], by visiting https://www.stellaxius.com/contact-us/, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal data.
Virginia CDPA Privacy policy
Under the Virginia Consumer Data Protection Act (CDPA):
‘Consumer’ means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
‘Personal data’ means any data that is linked or reasonably linkable to an identified or identifiable natural person. ‘Personal data’ does not include de-identified data or publicly available data.
‘Sale of personal data’ means the exchange of personal data for monetary consideration.
If this definition ‘consumer’ applies to you, we must adhere to certain rights and obligations regarding your personal data.
The data we collect, use, and disclose about you will vary depending on how you interact with us and our Services. To find out more, please visit the following links:
Your rights with respect to your personal data
We have not sold any personal data to third parties for business or commercial purposes. We will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More data about our data collection and sharing practices can be found in this privacy policy and our Cookie Policy: https://www.stellaxius.com/cookie-policy/.
You may contact us by email at [email protected], by contacting us, or by referring to the contact details at the bottom of this document.
If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
Verification process
We may request that you provide additional data reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorised agent, we may need to collect additional data to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this privacy policy from time to time without prior policy. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective from the date of its publication. If we make material changes to this privacy policy, we may notify you either by prominently posting a policy of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your data.
If you have questions or comments about this policy, you may email us at [email protected] or contact us by visiting https://www.stellaxius.com/contact-us/ or by post at:
STELLAXIUS, LDA
Av. António Serpa 36, 9° flor – 1050-027 Lisboa, Portugal
Lisbon, Lisbon 1050-027
Portugal
You have the right to request access to the personal data we collect from you, change that data, or delete it. To request to review, update, or delete your personal data, please contact us: https://www.stellaxius.com/contact-us/