Privacy Policy

The purpose of this Privacy Policy (“Policy”) is to inform you about the “Personal Data”, information that is linked or can be reasonably linkable to an identified or an identifiable natural person or household, Stellon Labs, Inc., (“Stellon,” “we,” “us,” or “our”), collects, how we use and share that information, and the ways in which you can control how we process that information. By using our platforms and products (collectively, our “Services”), by accessing our website, or otherwise interacting with us, you agree to the terms of this Privacy Policy (“Policy”). Where our processing of your Personal Data is based upon consent, you expressly consent to our collection, use, and disclosure of your Personal Data in accordance with this Policy. This Policy applies where we are operating as the “Data Controller” (as defined under applicable data protection laws) of your Personal Data.

We receive and/or collect Personal Data from you when you use our Services, access our website or otherwise interact with us. This may include the following categories and types of Personal Data:

• Identifiers, User Registration Data and Account Information: We collect and maintain identifying information about you, including your name, email address, postal address, mobile phone number, user account and registration information. If you connect with us on social media, we will also collect information about your social media handles and usernames.
• Use of Services: We collect and maintain information regarding the Services you use, including any input, including audio/voice recordings, and output and any information you provide to enhance your use of the Services. We also collect information on your preferences with respect to your use of the Services as well as any feedback or other customer service information you provide to us when you contact us for support or to inquire about the Services.
• Financial Information: Where you are using a paid Service, we will collect relevant financial information, including your credit or debit card details and billing address.
• Internet or Other Similar Network Activity: We collect technical information about your use of and interactions with the Services and our website through the use of cookies and other online tracking mechanisms. Depending upon how you use our Services and website, this may include your browser type, Internet Protocol (“IP”) address, device type, operating system version and type, wireless carrier, performance metrics of our Services and website, and other related information. We may also collect information on the pages of our website you visit, the time and date of your visit, and time, frequency, and duration spent on those pages, as well as the features of the website you use.
• Professional and Employment Information: If you apply for employment with us, we will collect information such as your name, email address, phone number, postal address, work history, education information, and other resume information.

Depending upon your interactions with us and our Services, we use your Personal Data for different purposes, including as follows:

Legitimate Interests/Consent: Please note, to the extent we rely on our legitimate interests as a legal basis for processing of your Personal Data, we have considered the balance between our own interests (among other things, the lawful and efficient operation of our Services and website, and quality and enhancement of our services, products and relationships with you) and your interests and we believe that (a) you would reasonably expect us to carry out the kind of processing outlined in this Policy and (b) such processing will not cause you any harm and/or will not seriously impact your rights and freedoms with regard to data privacy.

Depending on where you reside, consent may be the only lawful basis for our processing of your Personal Data. Where our legal basis to process your Personal Data is based upon your consent, you have the right to withdraw consent for such processing at any time by contacting us at info@stellonlabs.com.

We may share your Personal Data as set forth below:

• With our vendors and service providers: including with companies that provide us with support services, in marketing, information security, consultants, and other professional advisors.
• With governmental authorities, regulators, and law enforcement: including disclosures to governmental authorities and regulators, law enforcement agencies, courts, tribunals, and other regulatory bodies to comply with our legal and regulatory obligations.
• In relation to corporate transactions: including in the event of a proposed or completed corporate transaction, such as a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets or liabilities, some of the Personal Data that we hold may be among the assets or liabilities transferred to a buyer or other successor. We may also transfer Personal Data to another entity or its affiliates or service providers in connection with, or during negotiations of, any merger, acquisition, sale of assets or liabilities or any line of business, change in ownership control or financing transaction.

We may also share your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation, such as upon receipt of a duly authorized subpoena or court order or in the event of an audit.
• Protect and defend the rights or property of our business, our Services or our website or the legal rights of third parties or our employees, agents, and contractors.
• Prevent or investigate possible wrongdoing in connection with the Services.
• Protect the personal safety of users of the Services or other members of the public.
• Protect against legal liability.

If there is a transfer or sharing of your Personal Data in accordance with this Policy, we will seek assurance from the recipients of such information (prior to the transfer) that they will safeguard the information in a manner consistent with this Policy.

We have implemented appropriate technical, physical and organizational measures to ensure a level of security appropriate to the risk and in accordance with applicable laws. These measures are designed to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure while in our possession. We work to limit access to Personal Data to authorized employees, agents, contractors, or vendors.

We will only keep your Personal Data for as long as it is needed to fulfil the purpose for which it was collected, including to comply with any of our legal and regulatory obligations, to enable compliance with any requests made by regulators or other relevant authorities and agencies, to enable us to establish, exercise and defend legal rights and claims, and for other legitimate business reasons (such as preventing fraud, responding to regulatory or supervisory inquiries, or disputes or complaints).

We may transfer your Personal Data to a jurisdiction other than the one from which it was collected, including to countries that may not have the same levels of protection for the rights and freedoms of data subjects. If we do transfer your Personal Data to another jurisdiction, we will do so following due diligence and provided that the data recipient has committed to ensuring appropriate technical and organizational measures are implemented and maintained at all times.

Depending upon where you reside, certain rights and choices may be available to you with respect to your Personal Data, including the following:

• Right to Be Informed: You may have the right to know or be notified about the collection of your Personal Data, including through this Policy.
• Right to Access: You may have the right to be provided with a copy of your Personal Data.
• Right to Data Portability: You may have the right to receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format and/or to ask that we transmit your Personal Data to a third party, where applicable.
• Right to Delete/Be Forgotten: You may have the right to request that we delete the Personal Data we have collected about you, subject to certain legal exceptions.
• Right to Correct: You may have the right to request that we correct any inaccurate Personal Data we have collected about you.
• Right to Restrict Processing: You may have the right to require us to restrict processing of your Personal Data.
• Right to Object: You may have the right to object to the processing of your Personal Data for direct marketing/profiling or where we are processing your Personal Data for our legitimate interests.
• Right to Withdraw Consent: Where you have provided us with consent the processing of your Personal Data, you have the right to withdraw such consent.
• Right to Not be Subject to Automated Individual Decision-Making: You may have the right to not be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.
• Right to Contact Supervisory Authority and Right to Appeal. You may have the right to contact the relevant supervisory authority and to lodge a complaint and/or the right to appeal any decisions we may make with respect to your privacy rights.

You may exercise your rights by contacting us at info@stellonlabs.com. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will respond within the timeframe required by the applicable data protection laws.

We do not knowingly collect any information from anyone under eighteen (18) years of age. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us so that we may delete that information from our records. If we become aware that we have collected Personal Data from a person under eighteen (18), Stellon will take commercially reasonable steps to delete such information and terminate the associated account, as applicable.

This Policy will be periodically reviewed and evaluated in connection with new products, new services, new technologies, changes in law, and your needs. We may make changes or modifications to this Policy as a result thereof. We will post the updated Privacy Policy, along with the effective date, on our website and we may also provide you with notice of the updates by email. You are responsible for updating your account information to provide us with your most current email address as the email notice constitutes effective notice of said changes.

If you have any questions about this Policy, our privacy practices, how we collect or process your Personal Data, or wish to exercise any of the privacy rights or choices, please contact us info@stellonlabs.com.