Privacy Policy

Stella Growth Intelligence
Last Updated: January 27, 2026
Effective Date: January 27, 2026


Table of Contents

  1. Introduction
  2. Information We Collect
  3. How We Use Your Information
  4. How We Share Your Information
  5. Your Privacy Rights
  6. California Consumer Privacy Rights
  7. Automated Decision-Making Technology
  8. Data Security
  9. Data Retention
  10. International Data Transfers
  11. Children's Privacy
  12. Changes to This Privacy Policy
  13. Contact Us

1. Introduction

Welcome to Stella Growth Intelligence ("Stella," "we," "us," or "our"). We are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. This Privacy Policy explains how we collect, use, share, and protect information when you visit our website at stellaheystella.com (the "Website") or use our marketing measurement platform (the "Services").

Our Services: Stella is a marketing measurement platform that provides three integrated tools: Incrementality Testing, Media Mix Modeling (MMM), and Always-On Incrementality. We help marketers measure and optimize their advertising effectiveness.

Your Rights: We respect your privacy rights and are committed to transparency about our data practices. This Privacy Policy complies with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable privacy laws.


2. Information We Collect

2.1 General Website Browsing

For general browsing of our Website, we respect your privacy and do not collect or store personally identifiable information. You may explore our Website without providing any personal data. We use essential cookies only to enhance website functionality and optimize user experience, without collecting personally identifiable information.

Cookie Management: You can manage your cookie preferences directly on our Website. We do not use tracking cookies or third-party data aggregators for general browsing activities.

2.2 Account Creation and Registration

To access the full capabilities of our Services, you must create an account. During account creation, we collect:

  • Name - Your full name for account identification
  • Email Address - For account access, communications, and support
  • Organization Name - To understand your business context
  • Password - Encrypted credentials for secure account access
  • Payment Information - Processed securely through third-party payment processors (we do not store complete credit card numbers)

2.3 Information Collected During Service Use

When you use our Services, we collect and process:

Platform Integration Data: - Advertising platform data (Google Ads, Meta Ads, TikTok Ads, Pinterest Ads) - E-commerce platform data (Shopify, Amazon) - Campaign performance metrics - Conversion data - Advertising spend information

Uploaded Data: - Data you upload via Google Sheets integration - CSV files containing marketing and sales data - Custom data sources you connect to our platform

Usage Information: - Log data (IP addresses, browser type, device information) - Platform usage metrics and activity logs - Feature engagement analytics - Session information

Communications: - Support requests and correspondence - Feedback you provide - Survey responses

2.4 Categories of Personal Information (CCPA Classification)

Under the California Consumer Privacy Act, we collect the following categories of personal information:

Categories We Collect:

A. Identifiers - YES
Examples: Real name, email address, IP address, account name

B. Personal information categories listed in California Civil Code § 1798.80(e) - YES
Examples: Name, address, payment information

C. Protected classification characteristics under California or federal law - NO
Examples: Age, gender (if voluntarily provided)

D. Commercial information - YES
Examples: Transaction history, purchase records

E. Biometric information - NO
Examples: Fingerprints, voiceprints, facial recognition

F. Internet or other electronic network activity - YES
Examples: Browsing history, search history, interaction with our Services

G. Geolocation data - YES
Examples: Approximate location based on IP address

H. Sensory data - NO
Examples: Audio, electronic, visual, thermal, olfactory, or similar information

I. Professional or employment-related information - YES
Examples: Job title, company name, work email

J. Non-public education information - NO
Examples: Educational records

K. Inferences drawn from other personal information - YES
Examples: Profile reflecting preferences, behavior, attributes

L. Sensitive Personal Information - YES*
Examples: Precise geolocation, account credentials

*We collect account credentials (passwords) which are immediately encrypted and stored securely. We may collect precise geolocation with your explicit consent for location-based features.

2.5 Sources of Information

We collect information from:

  • Directly from you - When you create an account, use our Services, or contact us
  • Automatically - Through cookies and similar technologies when you use our Services
  • Third-party integrations - From advertising and e-commerce platforms you connect to our Services
  • Business partners - Service providers and technology partners who assist in delivering our Services

3. How We Use Your Information

3.1 Primary Purposes

We use your information for the following business and commercial purposes:

Service Delivery: - To create and manage your account - To provide, operate, and maintain our Services - To process your transactions and manage payments - To perform data analysis and generate insights - To deliver marketing measurement and attribution results

Communication: - To respond to your inquiries and provide customer support - To send you service-related announcements and updates - To provide technical notices and security alerts - To send you information about new features and services

Platform Improvement: - To understand how our Services are used - To develop new features and functionality - To diagnose technical problems and improve performance - To conduct internal research and analytics

Marketing (with your consent): - To send promotional materials about our Services - To provide information about products we think may interest you - To conduct market research and surveys

Legal and Security: - To comply with legal obligations and respond to legal requests - To protect our rights, property, and safety - To prevent fraud and enhance security - To enforce our Terms of Service

We process your information based on:

  • Contract Performance - To provide Services you've requested
  • Legitimate Interests - To improve our Services, prevent fraud, and maintain security
  • Legal Obligations - To comply with applicable laws and regulations
  • Consent - Where required by law, particularly for marketing communications

3.3 Automated Decision-Making and Profiling

We do not use fully automated decision-making that produces legal or similarly significant effects without human involvement. Our platform uses AI and machine learning to analyze marketing data and provide insights, but all significant decisions regarding your account, services, or business relationship remain subject to human review.

See Section 7 for detailed information about our use of Automated Decision-Making Technology (ADMT).


4. How We Share Your Information

4.1 Our Commitment

Stella does not sell or trade your personal information. We do not receive monetary compensation in exchange for sharing your personal data with third parties. However, we may share information in the following circumstances:

4.2 Service Providers

We share information with trusted third-party service providers who assist us in operating our Services:

  • Cloud hosting providers - To store data and host our platform
  • Payment processors - To process payments securely (they handle payment information directly)
  • Email service providers - To send communications
  • Analytics providers - To understand platform usage
  • Customer support tools - To provide technical assistance
  • Security providers - To protect against threats and vulnerabilities

All service providers are bound by strict confidentiality agreements and data protection obligations. They may only use your information to perform services on our behalf and are prohibited from using it for their own purposes.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, asset sale, or similar business transaction, we may transfer your information to the acquiring entity. The acquiring entity will be bound by the commitments made in this Privacy Policy. We will provide notice and obtain consent as required by applicable law.

We may disclose your information when required by law or to protect our rights:

  • To comply with legal obligations, court orders, or subpoenas
  • To respond to lawful requests from public authorities
  • To protect and defend our rights and property
  • To prevent fraud or illegal activity
  • To protect the safety and security of our users and the public
  • To enforce our Terms of Service and other agreements

We may share your information with third parties when you explicitly consent to such sharing.

4.6 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. This information may be used for research, analytics, and improving our Services without restriction.

4.7 Categories of Third Parties (CCPA Disclosure)

We share personal information with the following categories of third parties:

  • Service providers and contractors
  • Cloud infrastructure providers
  • Payment processors
  • Technology partners
  • Professional advisors (lawyers, accountants, auditors)
  • Government entities and law enforcement (when required)

5. Your Privacy Rights

5.1 General Rights

Depending on your location, you may have the following rights regarding your personal information:

Right to Access - Request access to the personal information we hold about you

Right to Correction - Request correction of inaccurate or incomplete information

Right to Deletion - Request deletion of your personal information (subject to certain exceptions)

Right to Data Portability - Request a copy of your information in a structured, commonly used format

Right to Object - Object to processing of your personal information for certain purposes

Right to Restrict Processing - Request restriction of how we process your information under certain conditions

Right to Withdraw Consent - Where processing is based on consent, you may withdraw it at any time

5.2 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: marketing-admin@stellaheystella.com
Mail: Stella Growth Intelligence, Privacy Rights Department, 1007 N Orange St. 4th Floor Suite #5033, Wilmington, Delaware 19801, United States

We will respond to your request within 15 business days (or as required by applicable law). We may need to verify your identity before processing your request.

5.3 No Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not:

  • Deny you goods or services
  • Charge different prices or rates
  • Provide a different level or quality of services
  • Suggest you will receive a different price or quality of services

6. California Consumer Privacy Rights

6.1 CCPA/CPRA Rights

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

Right to Know - You have the right to request that we disclose: - The categories of personal information we collected about you - The categories of sources from which we collected your personal information - The business or commercial purpose for collecting, selling, or sharing personal information - The categories of third parties to whom we disclose personal information - The specific pieces of personal information we collected about you

Right to Delete - You have the right to request deletion of your personal information that we collected from you, subject to certain exceptions.

Right to Correct - You have the right to request correction of inaccurate personal information we maintain about you.

Right to Opt-Out - You have the right to opt-out of: - The sale of your personal information (we do not sell personal information) - The sharing of your personal information for cross-context behavioral advertising (we do not share for this purpose)

Right to Limit Use of Sensitive Personal Information - You have the right to limit our use and disclosure of your sensitive personal information to purposes necessary to provide our Services.

Right to Non-Discrimination - We will not discriminate against you for exercising your CCPA rights.

6.2 Do Not Sell or Share My Personal Information

Stella does not sell personal information. We do not receive monetary or other valuable consideration in exchange for sharing your personal information with third parties for their commercial purposes.

Stella does not share personal information for cross-context behavioral advertising. We do not share your information with third parties for targeted advertising across websites, apps, or services.

Therefore, we do not provide a "Do Not Sell or Share My Personal Information" link, as these activities do not occur.

6.3 Global Privacy Control (GPC)

We recognize and honor Global Privacy Control (GPC) signals. If you have enabled GPC in your browser, we will treat this as a valid opt-out request for applicable data sharing activities.

6.4 Sensitive Personal Information

We collect the following categories of sensitive personal information:

  • Account credentials (username and password, which are immediately encrypted)
  • Precise geolocation data (only with your explicit consent for location-based features)

We use sensitive personal information only for: - Performing the services you requested - Ensuring security and integrity of our systems - Short-term transient use - Purposes that do not infer characteristics about you

You have the right to limit our use of sensitive personal information. To exercise this right, contact us at marketing-admin@stellaheystella.com.

6.5 How to Submit CCPA Requests

Email: marketing-admin@stellaheystella.com
Subject Line: "CCPA Privacy Rights Request"
Mail: Stella Growth Intelligence, Privacy Rights Department, 1007 N Orange St. 4th Floor Suite #5033, Wilmington, Delaware 19801, United States

Verification Process:
To protect your information, we must verify your identity before processing requests. We may ask for: - Email address associated with your account - Account information - Additional identifying information

We will match at least two data points you provide against information we maintain about you. For requests to access or delete sensitive personal information, we may require additional verification steps.

Authorized Agents:
You may designate an authorized agent to submit requests on your behalf. The authorized agent must provide: - Written permission signed by you - Verification of their own identity

We may also require you to directly verify your identity and confirm you authorized the agent.

Response Timeline:
We will respond to verifiable requests within 45 days of receipt. If we need more time (up to 90 days total), we will inform you of the reason and extension period within 45 days.

6.6 CCPA Metrics and Data Practices

Previous Calendar Year Metrics (2025):

We are required to report the following metrics annually. For the 2025 calendar year:

  • Requests to Know: Number received, number complied with (full or partial), number denied, median days to respond
  • Requests to Delete: Number received, number complied with (full or partial), number denied, median days to respond
  • Requests to Correct: Number received, number complied with (full or partial), number denied, median days to respond
  • Requests to Opt-Out: Number received, number complied with (full or partial), number denied, median days to respond

We will update these metrics annually by July 1st of each year on our website, as required by the CCPA.

6.7 Retention of Personal Information

We retain personal information for as long as necessary to provide our Services and fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

See Section 9 for detailed retention practices.

6.8 Minors Under 16

We do not knowingly sell or share personal information of consumers under 16 years of age without affirmative authorization.


7. Automated Decision-Making Technology

7.1 Overview of ADMT Use

Stella uses Automated Decision-Making Technology (ADMT), including artificial intelligence (AI) and machine learning, to analyze marketing data and generate insights. We are committed to transparency about how these technologies work and their impact on your experience.

7.2 What is ADMT?

ADMT refers to technology that processes information using computational algorithms, machine learning, or similar methods to make decisions, predictions, or recommendations that have significant effects.

7.3 How We Use ADMT

We use ADMT for the following purposes:

Marketing Analysis and Attribution: - Analyzing campaign performance across channels - Calculating incrementality and marketing attribution - Generating Media Mix Models (MMM) - Predicting future marketing performance - Optimizing budget allocation recommendations

Platform Features: - AI-powered interpretation of results - Automated insight generation - Pattern recognition in marketing data - Anomaly detection in campaign performance

7.4 Significant Decisions

We do not use ADMT to make "significant decisions" as defined by the CCPA - decisions that have legal or similarly significant effects concerning you, such as:

  • Denial of consequential services or support
  • Differential pricing for products or services
  • Opportunities for employment, housing, credit, education, or healthcare
  • Access to essential goods or services

All ADMT-generated insights and recommendations in Stella are advisory in nature. Decisions about your marketing strategy, budget allocation, and business operations remain entirely under your control.

7.5 Human Oversight

All ADMT processes include human oversight:

  • Platform features using ADMT are supervised by our data science team
  • Results are validated against statistical standards
  • Anomalies or unexpected outputs are reviewed by human analysts
  • Customer support and account management decisions involve human review

7.6 Your Rights Regarding ADMT

You have the right to:

Access Information - Request information about: - The logic involved in our ADMT processes - The likely outcome of ADMT processing on you - The categories of data used in ADMT

Opt-Out - Since we do not use ADMT for significant decisions, there is no need for a specific opt-out. However, you may always choose not to use specific platform features.

Human Review - Request human review of any ADMT-generated insights or recommendations

To exercise these rights, contact us at marketing-admin@stellaheystella.com.

7.7 Data Used in ADMT

ADMT processes the following types of data:

  • Marketing campaign data (spend, impressions, clicks, conversions)
  • Sales and revenue data
  • Customer behavior and conversion metrics
  • Platform integration data
  • Historical performance data

ADMT does not use: - Biometric information - Health information - Financial account numbers - Precise geolocation (except with explicit consent for location-based features)

7.8 ADMT Transparency

Model Performance:
Our ADMT models are continuously monitored for accuracy, fairness, and performance. We conduct regular audits to ensure models operate as intended.

Limitations:
ADMT recommendations are based on historical data and statistical modeling. They may not account for unprecedented market changes, external events, or unique business circumstances. Always apply human judgment when acting on ADMT insights.

Updates:
We regularly update and improve our ADMT systems. Material changes to how we use ADMT for significant decisions (if any in the future) will be communicated through updates to this Privacy Policy.


8. Data Security

8.1 Our Commitment to Security

Stella employs comprehensive security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. We recognize the critical importance of data security and maintain rigorous protocols.

8.2 Security Measures

Encryption: - All data is encrypted in transit using TLS 1.2 or higher - All data is encrypted at rest using AES-256 encryption - Passwords are hashed using industry-standard algorithms (bcrypt) - Database encryption with column-level encryption for sensitive fields

Access Controls: - Role-based access control (RBAC) for internal systems - Multi-factor authentication (MFA) for employee access - Principle of least privilege - access limited to what's necessary - Regular access reviews and deprovisioning procedures

Infrastructure Security: - Secure cloud infrastructure with leading providers - Network segmentation and firewalls - Intrusion detection and prevention systems (IDS/IPS) - Regular security patching and updates - Distributed Denial of Service (DDoS) protection

Monitoring and Response: - 24/7 security monitoring and logging - Security information and event management (SIEM) - Incident response plan and procedures - Regular penetration testing and vulnerability assessments

Personnel Security: - Background checks for employees with data access - Mandatory security awareness training - Confidentiality agreements for all personnel - Strict data handling policies and procedures

Third-Party Security: - Vendor security assessments before engagement - Ongoing monitoring of service provider security - Contractual data protection obligations - Annual SOC 2 Type II audits for critical vendors

8.3 SOC 2 Compliance

Stella maintains SOC 2 Type II compliance, demonstrating our commitment to: - Security - Protection against unauthorized access - Availability - System availability for operation and use - Processing Integrity - Complete, valid, accurate, timely, and authorized processing - Confidentiality - Protection of confidential information - Privacy - Collection, use, retention, disclosure, and disposal of personal information

We undergo annual SOC 2 audits by independent third-party auditors. Our SOC 2 report is available to customers upon request and execution of a non-disclosure agreement.

8.4 Compliance Certifications

We maintain compliance with: - SOC 2 Type II - ISO 27001 (in progress) - GDPR requirements - CCPA/CPRA requirements

8.5 Cybersecurity Audits

As required by CCPA regulations effective January 1, 2026, Stella undergoes regular cybersecurity audits conducted by independent auditors. These audits assess:

  • Technical safeguards and security controls
  • Administrative policies and procedures
  • Physical security of data centers and facilities
  • Employee training and awareness programs
  • Incident response and business continuity plans
  • Compliance with industry standards (NIST Cybersecurity Framework)

Audit results and certifications are maintained and available to regulatory authorities upon request.

8.6 Data Breach Response

In the unlikely event of a data breach affecting your personal information, we will:

  • Investigate the incident immediately
  • Take steps to contain and remediate the breach
  • Notify affected individuals within the timeframe required by law
  • Provide information about the breach, data affected, and steps you can take
  • Notify regulatory authorities as required
  • Conduct a post-incident review and implement improvements

To report a suspected security vulnerability, contact: marketing-admin@stellaheystella.com with subject line "Security Vulnerability Report"

8.7 Your Role in Security

While we implement strong security measures, you also play a role in protecting your information:

  • Use a strong, unique password for your Stella account
  • Enable multi-factor authentication if available
  • Keep your login credentials confidential
  • Log out of your account when using shared devices
  • Report suspicious activity immediately
  • Keep your contact information up to date

8.8 Limitations

While we use industry-standard security measures, no system is completely secure. We cannot guarantee absolute security of information transmitted over the internet or stored in our systems. You provide information at your own risk.


9. Data Retention

9.1 Retention Principles

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

9.2 Retention Periods

Account Information: - Retained while your account is active - Retained for 90 days after account closure (to allow account recovery) - Permanently deleted after 90-day grace period unless legal obligations require longer retention

Service Usage Data: - Marketing campaign data: Retained while your account is active plus 3 years - Platform analytics: Aggregated data retained indefinitely; individual-level data retained for 2 years - Log data: Retained for 12 months for security and troubleshooting purposes

Communication Records: - Support tickets: Retained for 3 years after resolution - Email correspondence: Retained for 3 years - Marketing communications: Retained until you unsubscribe plus 30 days

Financial Records: - Payment information: Retained for 7 years (required by tax and accounting laws) - Transaction records: Retained for 7 years

Legal and Compliance: - Records required for legal proceedings: Retained for duration of legal matter plus 7 years - Compliance documentation: Retained as required by applicable laws and regulations

9.3 Deletion Requests

When you request deletion of your personal information:

Immediate Actions: - Your account will be deactivated within 24 hours - You will no longer be able to access Services

Within 30 Days: - Personal identifiers are removed from active systems - Data is moved to secure deletion queues - Confirmation email sent to verify deletion

Within 90 Days: - All personal information is permanently deleted from production systems - Backup data is purged according to scheduled cycles - Deletion confirmation provided upon request

9.4 Exceptions to Deletion

We may retain information despite a deletion request when necessary for:

  • Completing transactions you initiated
  • Detecting and preventing security incidents or fraud
  • Debugging and repairing errors
  • Complying with legal obligations (tax, audit, reporting requirements)
  • Internal uses reasonably aligned with your expectations
  • Exercising free speech or ensuring another consumer's right to free speech
  • Scientific, historical, or statistical research in the public interest
  • Enabling solely internal uses reasonably aligned with your relationship with us

When we retain information for these purposes, we implement appropriate safeguards.

9.5 De-Identified and Aggregated Data

We may retain de-identified or aggregated data indefinitely for: - Platform improvement and development - Market research and analytics - Product development - Business intelligence

De-identified data cannot be re-associated with you and is not subject to this Privacy Policy.


10. International Data Transfers

10.1 Data Location

Stella is based in the United States. Your information may be transferred to, stored, and processed in the United States and other countries where we or our service providers maintain facilities.

10.2 Cross-Border Transfers

When we transfer personal information internationally, we implement appropriate safeguards to ensure your information receives equivalent protection:

Standard Contractual Clauses (SCCs):
For transfers from the European Economic Area (EEA), United Kingdom, or Switzerland, we use Standard Contractual Clauses approved by the European Commission.

Data Processing Agreements:
We enter into data processing agreements with international service providers that include appropriate data protection obligations.

Privacy Shield Principles:
Although the EU-U.S. Privacy Shield framework has been invalidated, we continue to adhere to Privacy Shield principles for European data transfers where applicable.

10.3 Your Rights Regarding International Transfers

If you are located outside the United States, you have rights regarding international transfers:

  • Right to information about transfer mechanisms
  • Right to object to transfers in certain circumstances
  • Right to access information about safeguards in place

To exercise these rights or learn more about our international transfer practices, contact marketing-admin@stellaheystella.com.

10.4 International Privacy Laws

We comply with applicable privacy laws in jurisdictions where we operate, including:

  • GDPR (European Union)
  • UK GDPR (United Kingdom)
  • PIPEDA (Canada)
  • LGPD (Brazil)
  • CCPA/CPRA (California, USA)

If you are located in a jurisdiction with specific privacy laws, additional rights may apply. Contact us for information about rights specific to your location.


11. Children's Privacy

11.1 Age Restrictions

Stella Services are not directed to children under 16 years of age. We do not knowingly collect personal information from children under 16.

If you are under 16 years of age, you may not create an account or use our Services without verifiable parental consent. Parents or guardians must create and manage accounts on behalf of users under 16.

11.3 Discovery of Children's Information

If we discover that we have collected personal information from a child under 16 without proper parental consent, we will:

  • Delete the information as soon as reasonably practicable
  • Terminate the associated account
  • Not use the information for any purpose
  • Not disclose the information to third parties

11.4 Parental Rights

If you are a parent or guardian and believe your child under 16 has provided personal information to Stella without your consent, please contact us immediately at:

Email: marketing-admin@stellaheystella.com
Subject Line: "Children's Privacy - Deletion Request"

We will promptly investigate and delete the information.

11.5 California Minors

If you are a California resident under 18 years of age and have created an account, you have the right to request removal of content or information you posted. To request removal, contact marketing-admin@stellaheystella.com with "California Minor Content Removal" in the subject line.

Please note that removal does not ensure complete or comprehensive deletion (e.g., content shared with others).


12. Changes to This Privacy Policy

12.1 Policy Updates

We may update this Privacy Policy periodically to reflect:

  • Changes in our data practices
  • New features or Services
  • Legal, regulatory, or technological developments
  • User feedback and industry best practices

12.2 Notification of Changes

Material Changes:
If we make material changes to this Privacy Policy, we will provide notice by:

  • Posting a prominent notice on our Website
  • Sending an email to the address associated with your account (at least 30 days before the effective date)
  • Displaying an in-platform notification upon your next login
  • Updating the "Last Updated" date at the top of this Privacy Policy

Non-Material Changes:
For non-material changes, we will update the "Last Updated" date. We encourage you to review this Privacy Policy periodically.

12.3 Continued Use

Your continued use of our Services after changes become effective constitutes acceptance of the updated Privacy Policy. If you do not agree with changes, you may close your account before the effective date.

12.4 Regulatory Changes

As privacy laws evolve (particularly CCPA/CPRA regulations), we will update this Privacy Policy to maintain compliance. Updates related to regulatory changes will be clearly marked.

12.5 Version History

We maintain a history of Privacy Policy versions. To request previous versions, contact marketing-admin@stellaheystella.com.


13. Contact Us

13.1 Privacy Questions and Requests

For questions about this Privacy Policy or to exercise your privacy rights, contact us:

Email: marketing-admin@stellaheystella.com
Mail: Stella Growth Intelligence
Privacy Rights Department
1007 N Orange St. 4th Floor Suite #5033
Wilmington, Delaware 19801
United States

Response Time: We respond to privacy inquiries within 15 business days (or as required by applicable law).

13.2 California Privacy Rights Requests

For CCPA-specific requests (access, deletion, correction, opt-out):

Email: marketing-admin@stellaheystella.com
Subject Line: "CCPA Privacy Rights Request"
Mail: Stella Growth Intelligence, Privacy Rights Department, 1007 N Orange St. 4th Floor Suite #5033, Wilmington, Delaware 19801, United States

13.3 Data Protection Officer (if applicable)

For users in the European Economic Area:

Email: marketing-admin@stellaheystella.com
Subject Line: "Data Protection Inquiry - EEA"

13.4 Supervisory Authority

If you are in the European Economic Area and believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with your local supervisory authority.

For California Residents:
California Privacy Protection Agency (CPPA)
Website: https://cppa.ca.gov
Email: info@cppa.ca.gov

For Other Jurisdictions:
Contact your local data protection authority.

13.5 Security Vulnerabilities

To report security vulnerabilities:

Email: marketing-admin@stellaheystella.com
Subject Line: "Security Vulnerability Report"

We take security reports seriously and will respond promptly.


Additional Information for California Residents

Notice at Collection

At or before the point of collection, we inform you about:

  • The categories of personal information to be collected
  • The purposes for which personal information will be used
  • Whether personal information is sold or shared
  • The length of time we retain personal information
  • Your rights regarding your personal information

This information is provided in Section 2 (Information We Collect) and Section 3 (How We Use Your Information) of this Privacy Policy.

Right to Opt-Out of Sale/Sharing

As stated throughout this Privacy Policy:

WE DO NOT SELL YOUR PERSONAL INFORMATION

WE DO NOT SHARE YOUR PERSONAL INFORMATION FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING

Therefore, there is no need to provide a "Do Not Sell or Share My Personal Information" link.

Financial Incentive Programs

We do not currently offer financial incentive programs that require disclosure under the CCPA. If we implement such programs in the future, we will provide a Notice of Financial Incentive explaining:

  • Material terms of the program
  • How to opt-in and opt-out
  • Explanation of how we value your personal information

Consumer Request Metrics

We will publish updated CCPA request metrics annually on our Website and in this Privacy Policy by July 1st of each year.


Definitions

Personal Information: Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Sell/Sale: Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating personal information to a third party for monetary or other valuable consideration.

Share/Sharing: Sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating personal information to a third party for cross-context behavioral advertising.

Service Provider: A person or entity that processes personal information on behalf of a business and is subject to contractual restrictions on use.

Sensitive Personal Information: Personal information that reveals social security number, driver's license, state ID, passport number; account log-in, financial account, debit card, or credit card number with security code; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, union membership; contents of mail, email, text messages (unless the business is the intended recipient); genetic data; biometric information for identification; health information; sex life or sexual orientation information.

Automated Decision-Making Technology (ADMT): Any technology that processes personal information using computational algorithms, machine learning, or similar methods to make or assist in making decisions, predictions, or recommendations.


Effective Date and Acceptance

This Privacy Policy is effective as of the date stated at the top of this document. By creating an account, accessing our Website, or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.


Last Updated: January 27, 2026
Version: 2.0 (CCPA/CPRA Compliant - 2026 Regulations)


© 2026 Stella Growth Intelligence. All rights reserved.