Stellaxius Privacy Policy

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:

Visit our website at https://stellaxius.com (‘Website’), or any website of ours that links to this privacy policy;

Engage with us in other related ways, including when providing professional services, in any sales, marketing, or events;

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 privacy@stellaxius.com.

SUMMARY OF KEY POINTS

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 visiting https://stellaxius.com/data-request, or 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.

WHAT DATA DO WE COLLECT?
HOW DO WE PROCESS YOUR DATA?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL DATA?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW LONG DO WE KEEP YOUR DATA?
HOW DO WE KEEP YOUR DATA SAFE?
DO WE COLLECT DATA FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS POLICY?
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT DATA DO WE COLLECT?

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:

Identification data, such as, inter alia, names (first and last name), email addresses, usernames, mobile phone, tax number;
Contact data, when you make a complaint or compliment to us, send us a request or enquiry by email or letter, or provide us with other contact details for our Services;
Service subscription data or purchases of services that you make;
Professional data, such as place of work, professional background, life history, and, where applicable, curriculum vitae;
Usage data about your preferences for products, services and activities, whenever you provide us with such information or it is possible for us to infer such preferences from the way you interact with the Website and use the products and services;
Data collected using cookies, web beacons and other technologies, including for marketing and advertising purposes. To find out more, see our Cookie Policy: https://stellaxius.com/cookie-policy/.

We will collect personal data about you when:

You register on the Website or, without registering, you browse our website with the cookie functionality enabled. Find out more about our Cookie Policy: https://stellaxius.com/cookie-policy/. ;
Contact us through various channels or request information about our Services;
Buy or use Stellaxius products or services;
Subscribe to newsletters or alerts;
Participate in a questionnaire organised by us;
In cases where your information is publicly available.

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://stellaxius.com/cookie-policy/.

The data we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance data our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device data, browser type, and settings and data about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event data (such as system activity, error reports (sometimes called ‘crash dumps’ ), and hardware settings).

Device Data. We collect device data such as data about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include data such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration data.

Location Data. We collect location data such as data about your device’s location, which can be either precise or imprecise. How much data we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this data either by refusing access to the data or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

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.

2. HOW DO WE PROCESS YOUR DATA?

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:

To deliver and facilitate delivery of Services to the user. We may process your data to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your data to respond to your inquiries and solve any potential issues you might have with the requested service.
To send service communications. We may process your data to keep you up to date with information about products and services you have purchased or subscribed to. For example, we will contact you to inform you of any changes to our terms and conditions, new services available, as well as any changes to this Policy.
To invoice. We may process your data to issue an invoice for the use of our products and Services.
For technical improvement. We may process your data to improve your experience of using the Website, to detect and correct fraudulent use of our networks, to resolve technical problems if they occur, to check whether the Services and products are compliant or whether there are improvements to be made;

To request feedback. We may process your data when necessary to request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We may process the personal data you send to us for our marketing purposes (e.g., to send you newsletters or reports, invitations to take part in questionnaires and events or notices of offers, promotions), if you have given your free, specific, informed and unambiguous consent. Please not that, even if you have given your consent, you can withdraw it at any time. For more information, see ‘WHAT ARE YOUR PRIVACY RIGHTS?‘ below.
To personalize the service to you.We may process your data to develop and display personalised commercial offers and recommendations based on the way you use our services, your location information or browsing history, provided that you have consented to processing for this purpose.
To deliver relevant advertising to you.We may process your data to develop and display content and advertising relevant to you, through the use of Cookies. For more information see our Cookie Policy: https://stellaxius.com/cookie-policy/.
To protect our Services.We may process your data as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To identify usage trends.We may process data about how you use our Services to better understand how they are being used by users so we can improve them.
To fulfil our legal, accounting and tax obligations.

For hiring and human resources. We may process your data for recruitment, performance evaluation, training and other related purposes.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR DATA?

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:

Consent. We may process your data if you have given us permission (i.e. consent) to use your personal data for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Performance of a Contract. We may process your personal data when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services, or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your data when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal data for some of the purposes described in order to:

Analyse how our Services are used so we can improve them to engage and retain;
Diagnose problems and/or prevent fraudulent activities;
Understand how our users use our products and Services so we can improve user experience.

Legal Obligations. We may process your data where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your data as evidence in litigation in which we are involved.

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:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next of kin

If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the data and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the data was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the data is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

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:

Business Transfers.We may share or transfer your data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company;
Service providers. We may share data with third parties that perform functions and provide services for and on our behalf;
Judicial, administrative, supervisory, or regulatory authorities. In order to comply with a law, regulation, legal process or a government request, protect the safety of any person and the safety or integrity of our Services and to protect our rights or property, or the rights or property of those who use our Services.
Other third parties, provided that you have specifically given us your consent.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

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://stellaxius.com/cookie-policy/.

6. HOW LONG DO WE KEEP YOUR DATA?

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:

for the duration of the processing purpose set out in this privacy policy;
to the extent applicable, until you withdraw your consent;
for the entire term of the contractual relationship established with Stellaxius, plus the period set for the conservation of accounting and financial information (10 years) and beyond (including, nevertheless, within it) until the end of the general term of the obligations (20 years);
In the context of recruitment, if you are hired the data is kept during the duration of the contractual relationship; if you are not hired we will keep the data for 2 years.

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.

7. HOW DO WE KEEP YOUR DATA SAFE?

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.

8. DO WE COLLECT DATA FROM MINORS?

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 privacy@stellaxius.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

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://stellaxius.com/cookie-policy/.

If you have questions or comments about your privacy rights, you may email us at privacy@stellaxius.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

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.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

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:

Category A – As long as the user has an account with us

Category B – As long as the user has an account with us

Category C – As long as the user has an account with us

Category D – As long as the user has an account with us

Category F – 1 year

Category I – 1 year

Category J – 1 year

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:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

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://stellaxius.com/cookie-policy/.

You may contact us by email at privacy@stellaxius.com, by visiting https://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:

whether we collect and use your personal data;

the categories of personal data that we collect;

the purposes for which the collected personal data is used;

whether we sell or share personal data to third parties;

the categories of personal data that we sold, shared, or disclosed for a business purpose;

the categories of third parties to whom the personal data was sold, shared, or disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal data; and

the specific pieces of personal data we collected about you.

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

You may object to the processing of your personal data.

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.

You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.

You may request to opt out from future selling or sharing of your personal data to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at privacy@stellaxius.com, by visiting https://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.

12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

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:

Personal data we collect

How we use your personal data

When and with whom we share your personal data

Your rights with respect to your personal data

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)

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://stellaxius.com/cookie-policy/.

You may contact us by email at privacy@stellaxius.com, by visiting https://stellaxius.com/data-request, 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 privacy@stellaxius.com. 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.

13. DO WE MAKE UPDATES TO THIS POLICY?

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.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at privacy@stellaxius.com or contact us by visiting https://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

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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 visit: https://stellaxius.com/data-request.

Privacy Policy