1. Purpose and scope of the policy
Stellar Global attaches the greatest importance and care to the protection of privacy and Personal Data, as well as to the respect of the applicable data privacy legislation (hereinafter “Applicable Legislation”). The Applicable Legislation includes notably the UK General Data Protection Regulation, the Data Protection Act 2018, and the EU General Data Protection Regulation (EU) 2016/679.
Under the Applicable Legislation, Personal Data must be processed lawfully, fairly, and transparently. Thus, this privacy policy (hereinafter the “Policy”) aims to provide you with simple, clear information on the Processing of your Personal Data, in the context of your browsing and interactions with our website.
2. Data Controller
In the course of your activity on the https://stellar.global website, we collect and use Personal Data relating to you, an individual (hereinafter “Data Subject”).
For all the Processing activities, Stellar Global, a Marvesting company, Company number 11857396, located in Ground Floor, 1 Newham’s Row, London, SE1 3UZ, UK, determines the means and purposes of the Processing. Thus, within the meaning of the Applicable Legislation, we act as a Data Controller.
3. What Personal Data do we collect and how?
By using our website, you provide us with a certain amount of information about yourself, some of which may be used to identify you (“Personal Data”). This is the case when you browse our site, when you fill in online forms, or when you apply for job openings.
The nature of the Personal Data collected will vary depending on the relationship you have with Stellar Global, the main ones being:
- Identification data: This includes all the information that would allow us to directly identify you, such as your name, telephone number, e-mail address, and postal address.
- Technical data: IP addresses are collected for security and technical purposes by our hosting provider and retained for 30 days.
- Documents: PDFs, Word Documents, Images etc. with titles, contents, or information related to a document, such as comments written in the documents.
- Browsing information: by browsing our website, you interact with it. As a result, some information about your browsing is collected.
- Data collected from Third Parties: Personal Data that you have agreed to share with us or on publicly available social networks and/or that we may collect from other publicly available databases.
4. Why do we collect your Personal Information and how?
We collect your Personal Data for specific purposes and on different legal grounds.
On the basis of your consent, your Data is processed for the following purposes:
- Management of cookies that require your consent
- Newsletter management
On the basis of our legitimate interest, your data is processed for the following purposes:
- Contact via the online form
- Satisfaction surveys and polls
- Commercial prospecting and marketing
On the basis of our contractual or precontractual relationship, your Data is processed for the following purposes:
- Service management
- Contract management
- Apply for a job opening on the website
On the basis of our legal obligations, your Data is processed for the following purposes:
- Pre-litigation and litigation management
5. Do we share your Personal Data?
Your Personal Data is intended for the authorized Stellar Global collaborators in charge of the management and the execution of the agreements and legal obligations, according to the purposes of the collection and within the limits of their respective attributions.
It may be transmitted for certain tasks related to the above purposes, and within the limits of their respective missions and authorisations, to the following recipients:
- Entities of the Marvesting group when certain processing operations are outsourced to another entity of the group.
- Service providers and processors that we use to carry out a range of operations and tasks on our behalf such as for the (i) the management of cookies, (ii) the management of the website.
- Duly authorised public authorities (judicial, control…), in the framework of our legal and regulatory obligations.
- Regulated professions (lawyers, etc…) who may intervene in the context of the implementation of litigation.
When your Data is provided to our service providers and processors, they are also required not to use the Personal Data for purposes other than those originally intended. We make every effort to ensure that these third parties maintain the confidentiality and security of your Personal Data.
In all cases, only the necessary Personal Data is provided. We make every effort to ensure the secure communication or transmission of your Personal Data.
We do not sell your Personal Data.
6. Is your Personal Data transferred to third countries?
Stellar Global strives to keep the Personal Data in the UK, or at least within the European Economic Area (EEA).
However, it is possible that the Personal Data we collect when you use our platform or services may be transferred to other countries. This is for example the case if some of our service providers are located outside the UK or the European Economic Area.
In the event of such a transfer, we guarantee that it will be carried out:
- to a country ensuring an adequate level of protection, i.e. a level of protection equivalent to what the UK privacy regulations require; or
- within the framework of ICO’s International data transfer agreement/standard contractual clauses; or
- within the framework of Binding Corporate Rules.
7. How long do we keep your Personal Data?
We retain your Personal Data only for as long as is necessary to fulfill the purpose for which we hold the data, notably to meet your needs or our legal obligations.
Retention times vary depending on several factors, such as:
- Stellar Global’s business needs.
- Contractual requirements.
- Legal requirements.
- Recommendations from regulatory authorities.
The retention periods for your Data are as follows:
| Purposes | Retention periods |
| Service management | 6 years from the end of the contractual relationship |
| Contract management | 6 years from the end of the contractual relationship |
| Commercial prospecting and marketing | Duration of consent |
| Newsletter management | Duration of consent |
| Statistics for product/service improvement | Up to 13 months (data will then be anonymised) |
| Satisfaction surveys and polls | Up to 13 months (data will then be anonymised) |
| Pre-litigation and litigation management | Applicable statutory period and duration of litigation, if any |
8. How do we ensure the security of your Personal Information?
Stellar Global is committed to protecting the Personal Data we collect and process from loss and unauthorised destruction, alteration, access, or disclosure.
Thus, we implement all appropriate technical and organisational measures, depending on the nature of the Personal Data and the risks that their processing entails. These measures must preserve the security and confidentiality of your Personal Data. They may include practices such as limiting access to Personal Data on a need-to-know basis, pseudonymisation or encryption.
In addition, our practices, policies, and security measures (secure access, authentication process, backup, software, etc.) are regularly reviewed and updated as necessary.
9. What are your rights?
The Applicable Legislation provides Data Subjects with rights that they can exercise. Thus, are provided:
- Right to information: the right to have clear, precise, and complete information on the use of your Personal Data by Stellar Global.
- Right of access: the right to obtain a copy of the Personal Data that the Data Controller holds on the requester.
- Right to rectification: the right to have Personal Data rectified if they are inaccurate or obsolete and/or to complete them if they are incomplete.
- Right to erasure / right to be forgotten: the right to have your Personal Data erased or deleted, unless Stellar Global has a legitimate interest in keeping it.
- Right to object: the right, under certain conditions, to object to the processing of Personal Data by Stellar Global for reasons related to the particular situation of the requester.
- Right to Withdraw Consent: the right to withdraw Consent at any time where the processing is based on your consent.
- Right to the restriction of processing: the right, under certain conditions, to request that the processing of Personal Data be suspended.
- Right to Data Portability: the right to request that Personal Data be transmitted in a reusable format that allows it to be used in another database.
- Right not to be subject to a decision based solely on automated processing: the right of the requester to refuse fully automated decision-making and/or to exercise the additional safeguards offered in this regard.
Additional rights may be granted to Data Subjects by local legislation.
In order to facilitate the exercise of these rights, Stellar Global has implemented a procedure for the management of data subjects’ rights in accordance with the requirements of the Applicable Legislation. This procedure lays out:
- the standards to be respected to ensure the transparent information of data subjects;
- the applicable legal requirements;
- the modalities for exercising each right, depending on the category of Data Subjects;
- The business processes for handling these requests in accordance with the above requirements;
- The stakeholders involved in these processes, their roles, and responsibilities.
To exercise your rights, you may contact the Data Protection Officer (DPO): privacy@stellar.global
When you send us a request to exercise a right, please specify as far as possible the scope of the request, the type of right being exercised, the concerned data processing activity, and any other useful information in order to facilitate the examination of your request. In addition, in case of reasonable doubt, you may be asked to prove your identity.
You also have the right to complain to the ICO, at the following address: https://ico.org.uk/make-a-complaint/data-protection-complaints/ , about the way in which Stellar Global collects and processes your data.
10. Updating of this policy
This Policy may be updated from time to time to reflect changes in the Applicable Legislation.
Date of last update: 21/08/2025
