We are committed to protecting your privacy and any personal information you share with us. As part of this effort, we process personal information in accordance with the General Data Protection Regulation (GDPR) and other data protection regulations applicable to us.
2. WHO IS STELLARUP AND HOW CAN YOU CONTACT US?
StellarUp provides a cloud-based software solution enabling organizations, both big and small, to set-up and manage (mentoring) programs, communities and or/events. The party responsible for the processing of your personal data is Mentorjam B.V. (trading as StellarUp). Our address:
Vijzelgracht 31/1 1017HN, Amsterdam The Netherlands
If you have any questions or wishes in connection with your personal data, you may contact us at email@example.com.
4. HOW DO WE USE YOUR PERSONAL DATA?
Below is an overview of the purposes for which StellarUp processes your personal data. The overview indicates the personal data used for a specific purpose, what the legal basis is for processing these data, and how long the data is stored. In order to keep things organised, all information is grouped by type of data subject.
- (A) Invite: In order to invite you to register for an account on the StellarUp platform your email address might be provided to StellarUp by the organization managing the program or event. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by StellarUp (Article 6.1(f) GDPR), in order to invite individuals for our services at the request of our clients.
- (B) Account: In order to make use of the services as provided by StellarUp, you need to register for a personal account. You will provide us with personal data, including your name, email address and password. The processing of your personal data in this context is necessary for the performance of a contract to which you are a party in connection with the use of service (Article 6.1(b) GDPR). You cannot register for an account and make use of our services without providing us with these personal details.
- (C) Profile: In your account you may choose to provide additional information to complete your profile. — Personal information you may provide include for example, a description of who you are, your experience, your goals and what value you think you can bring as a participant in a programme. You can also include your profile photo, CV and location. Your profile is central to everything in StellarUp and will be shared with others in the programme. Profiles are matched based on the descriptions and skills provided as well as location and position. We compare you with other similar and/or complementary profiles to help find your ideal match. The result is a personal list of your best matches. The processing of these personal data is therefore necessary for the purposes of the legitimate interests pursued by StellarUp (Article 6.1(f) GDPR).
- (D) Relationship page: A Relationship Page is a dedicated workspace with features designed to ease communications between, and organisation of (a group of) people. A timeline provides an instant view of your (mentoring) relationship including the start and current finish date. You can also change the title, objectives and finish date of your relationship and send direct messages to participants. You can create Tasks, Goals and Events. Calendar invites are attached to notifications of meetings so that you can add them to your calendar of choice. You can also choose to upload video content. We process this information in order to facilitate your relationship. The processing is therefore necessary for the performance of a contract in connection with the use of service (Article 6.1(b) GDPR).
- (E) Integrations: If you have enabled such integrations you can also add your Google or other MS365 applications. When you do so, we will process the data you provide when you use such applications in order to enable you to integrate third party applications on the StellarUp platform. The processing of these personal data is therefore necessary for the purposes of the legitimate interests pursued by StellarUp (Article 6.1(f) GDPR).
- (F) Communications: In your account, you can send or receive direct messages or participate in discussions on the forum. When you make use of these functionalities we process your name, profile photo (if any) and your message. We do so to enable you to communicate with other participants. The processing of these personal data is therefore necessary for the purposes of the legitimate interests pursued by StellarUp (Article 6.1(f) GDPR).
- (G) Customer service: To provide customer service, StellarUp may collect and process your personal data to be of service to you and to respond to any questions you submit, including helping you with any issues which may arise regarding our services. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by StellarUp (Article 6.1(f) GDPR), namely being able to serve you efficiently and to optimise our customer service.
- (H) Clients: StellarUp may process personal data of (contact persons of) its clients in order to conclude an agreement, to provide the service and to communicate about the service. Payment details and payment history are used for billing purposes. The processing is therefore necessary for the performance of a contract in connection with the use of service (Article 6.1(b) GDPR).
- (I) Newsletters: To inform you on the developments of our services, StellarUp allows you to sign up for its newsletters. If, at any moment, you do not wish to receive newsletters of StellarUp anymore, you can unsubscribe by using the opt-out option that is provided in every newsletter that we send you. To subscribe you provide StellarUp with your email address. The processing thereof is necessary for the purposes of the legitimate interests pursued by StellarUp (Article 6.1(f) GDPR), namely direct marketing.
- (J) Google Analytics: StellarUp uses Google Analytics in order to collect statistics about the use and visits of the service. With these analytical cookies a permanent cookie is saved on your device to register your use of the service. Google Analytics analyses this data about the service and provides StellarUp with the results. This way, StellarUp obtains insight into the traffic of the service and the way in which the service is used. Based on this information we are able to make adjustments to the service. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by StellarUp (Article 6.1(f) GDPR), in order to measure how the service is used and how to improve our service. The following measures were taken to protect your privacy:
- (I) StellarUp has entered into a data processing agreement with Google in which agreements have been made regarding the processing of personal data.
- (Ii) StellarUp does not allow Google to use the obtained data for other Google services.
- (Iii) StellarUp has removed the last octet of your IP address. An IP address consists of 4 so-called octets of 3 digits each. Google offers the opportunity to remove the last octet of the IP address. This happens before your IP address is retained by Google.
- (Iv) StellarUp does not make use of other Google services in combination with Google Analytics.
Consequences of not providing personal data
Failure to provide (correct) personal data may result in StellarUp not being able to register your account, match you with other participants or for you to make use of certain functionalities.
5. HOW DO WE SHARE YOUR PERSONAL DATA?
In order to provide the services, (some of) your personal data is shared with service providers. These service providers process your personal data on behalf of StellarUp. The processing by service providers is governed by a so-called data processing agreement in which StellarUp has ensured that the service provider shall only process the personal data on instructions of StellarUp. Third parties are:
external hosting providers, including cloud providers for the storage and management of data;
Google Analytics; Service provider for email marketing.
When you make a transaction, your transactional data is sent to our payment service provider in order to process your payment. For instance, if you pay by means of SEPA direct debit, your name, address, place of residence and invoice number will be disclosed to Mollie BV in order to process your payment. Please read Mollie’s privacy statement for more information on the processing of your personal data.
As described above, your profile is visible to other participants and will be shared with others in the programme(s) or event(s) you participate in.
6. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA?
Some of our service providers are located outside the European Economic Area (EEA), in this case the United States. To comply with EU data protection laws around international data transfer, service providers outside the EEA are only allowed to process your personal data in accordance with a contract entered into between StellarUp and the service provider, incorporating the European Commission’s Standard Contractual Clauses, which ensure that adequate data protection arrangements are in place (Article 46.1(c) GDPR). For more information on where and how the relevant document may be accessed or obtained, please contact firstname.lastname@example.org.
7. HOW LONG DO WE REATAIN YOUR PERSONAL DATA?
Your personal data will be stored in accordance with laws and regulations and for as long as necessary for the purposes for which this data was collected. The following retention periods for your personal data apply:
- (A) Your personal data is stored for as long as you have an account and will be deleted within 6 months after you terminate your account.
- (B) StellarUp has a legal obligation to retain financial records for a period of 7 years.
- (C) Your email address is retained for as long as you are subscribed to the newsletter and no longer than 3 months after you unsubscribe.
- (D) Personal data as processed through Google Analytics are retained for a period of 6 months.
8. WHAT RIGHTS DO YOU HAVE REGARDING YOUR DATA?
Under the GDPR, you have a number of rights with regard to your personal data and the processing thereof:
- (A) Right to access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and additional information about the processing of your personal data.
- (B) Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- (C) Right to be forgotten: You have to right to ask us to erase your personal data (right to be forgotten) for example if the personal data are no longer necessary in relation to the purposes for which they were collected; you withdraws consent on which the processing is based, and where there is no other legal ground for the processing; or the personal data have been unlawfully processed.
- (D) Right to restriction: You have the right to obtain restriction of processing of your personal data, for example when you have contested the accuracy of your personal data.
- (E) Data portability: You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, where the processing is based on your consent or on a contract.
- (F) Right to object: You have the right to object to processing of personal data which is based on our legitimate interests. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims; where personal data are processed for direct marketing purposes, you always have the right to object to processing of personal data for such marketing. In that case, we shall no longer process your personal data for such purposes.
- (G) Withdraw consent: Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Any request regarding this policy or our procedures may be sent to email@example.com. We will respond to your request without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
If we do not take action on your request, we will inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action. In that case, you also have the right to lodge a complaint with the supervisory authority and to seek a judicial remedy.
9. WHAT TO DO IF YOU HAVE COMPLAINTS?
It is possible that, despite our careful approach, you have a complaint about the way StellarUp processes your personal data and/or the way we deal with your rights. In that case, you may also submit a complaint to the national data protection authority. If you have any questions or complaints in connection with your personal data, you may also choose to contact us at firstname.lastname@example.org.