Privacy Policy

1.1

Welcome to Stellawise (“Controller”, “we”, “us”, “our”). We are committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, store and protect your information when you sign up for the Waitlist for the launch of the Stellawise application.

1.2 Scope of this Policy

This Policy applies only to signing up for the Waitlist. It does not cover use of the Stellawise Application; a separate privacy policy for the Application will be made available before its launch.

1.3 Data Controller

Working Reason Kaja Dobrzańska

ul. Kapelanów Armii Krajowej 1/411, 04-046 Warsaw, Poland

NIP (Polish Tax ID): 6932133808

REGON (Polish Statistical No.): 021260621

Email: hello@stellawise.app

2.1 Information you provide directly

When you sign up for the Waitlist, we collect:

• Email address. Providing your email address is voluntary, but necessary to receive notification of the Application launch. If you do not provide your email address, you cannot join the Waitlist.

That’s all. We do not collect:

• First or last name.
• Password (you do not create an account at this stage).
• Information about your skin type or sensitivities.
• Information about pregnancy, breastfeeding or age.
• Any other personal or health data.

This data will only be collected when you create an account in the Application after its launch, on the terms set out in the separate privacy policy for the Application.

2.2 Information collected automatically

Technical data:

• IP address.
• Device type and operating system.
• Browser type and version.
• Access dates and times.
• Error logs and performance data.

Cookies:

• Essential cookies (technical, for the website to function).
• Analytics cookies (with your consent).

3.1

We process your personal data on the following bases:

• Consent (Article 6(1)(a) GDPR): your voluntary consent given by signing up for the Waitlist and accepting this Privacy Policy.
• Legitimate interest (Article 6(1)(f) GDPR): ensuring website security and detecting abuse (bots, spam).
• Legal obligation (Article 6(1)(c) GDPR): retaining anonymised logs required by law.

You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

4.1 Notification of the Application launch

We use your email address to:

• Notify you of the launch of the Stellawise Application.
• Send you information about priority (early) access as a beta tester.
• Send a maximum of 1-2 emails with important product information before launch.

Legal basis: your consent (Article 6(1)(a) GDPR).

4.2 What we don’t do with your email

• We don’t sell it to anyone.
• We don’t share it with marketing partners.
• We don’t send you ads for other companies’ products.
• We don’t send a commercial newsletter.

4.3 Technical operations

• Detecting and preventing abuse (bots, spam).
• Ensuring website security.
• Meeting legal requirements.

5.1

We do not sell your personal data.

We may share your information only in the following limited circumstances:

5.2 Service providers

We work with trusted third-party providers:

Email service provider: [TBD - to be completed, e.g. Mailchimp, ConvertKit, Brevo]

• Data shared: email address.
• Purpose: sending notifications about the Application launch.

Website hosting: [TBD - to be completed]

• Data shared: technical data (server logs).
• Purpose: making the stellawise.app website available.

Analytics (optional): [TBD - e.g. Google Analytics, Plausible]

• Data shared: anonymised usage data.
• Purpose: analysing website traffic.

All service providers are contractually bound (standard contractual clauses, data processing agreements) to protect your data and use it only for the specified purposes.

5.3 Legal requirements

We may disclose your information if required by law, court order or government regulation, or where necessary to:

• Protect our rights.
• Prevent fraud or security threats.
• Protect the safety of our users.

5.4 Business transfer

If Stellawise is involved in a merger, acquisition or sale of assets, your data may be transferred. We will notify you before your data is transferred and becomes subject to a different Privacy Policy.

6.1

Your data may be processed in countries outside the European Economic Area (EEA), for example if the email service provider processes data in the USA.

When we transfer data internationally, we ensure appropriate safeguards:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Adequacy decisions issued by the European Commission.
• Other legally approved transfer mechanisms.

7.1

We implement appropriate technical and organisational measures to protect your personal data.

Technical measures:

• Encryption in transit (TLS/SSL).
• Secured servers.
• Access control and authentication.
• Regular backups.

Organisational measures:

• Restricted access to personal data.
• Incident response procedures.

However, no security is guaranteed to be 100% effective. If you suspect a breach:hello@stellawise.app

8.1 Waitlist data

• Email address: until the Application launch + 30 days after launch.
• A maximum of 24 months from your last activity (no email opens).
• After withdrawal of consent: deleted within 7 days.

8.2 Technical data

• Server logs (anonymised): up to 12 months (legal requirement).
• Cookies: according to your browser / cookie banner settings.

8.3 Legal requirements

• Some data may be kept longer if required by law.
• Anonymised data may be kept indefinitely for statistical purposes.

9.1

You have the following rights regarding your personal data:

9.2 Right of access

You can request a copy of the personal data we hold about you.

9.3 Right to rectification

You can request correction of inaccurate data or completion of incomplete data.

9.4 Right to erasure (“right to be forgotten”)

You can request deletion of your personal data when:

• the personal data is no longer necessary for the purposes for which it was collected,
• you have withdrawn your consent to processing,
• you have objected to the processing,
• the personal data was processed unlawfully,
• the data must be deleted to comply with a legal obligation.

9.5 Right to restriction of processing

You can request that we restrict how we use your data, in the cases provided for in the GDPR.

9.6 Right to data portability

You can request your data in a structured, commonly used, machine-readable format.

9.7 Right to object

You can object to processing based on legitimate interest or for direct marketing purposes.

9.8 Right to withdraw consent

If processing is based on your consent, you can withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

The easiest way: click the “unsubscribe” link in any email from us. Your address will be removed from the list.

9.9 Right to lodge a complaint

You can lodge a complaint with the Polish data protection authority:

Personal Data Protection Office (UODO)

ul. Stawki 2, 00-193 Warsaw, Poland

Tel.: +48 22 531 03 00

Website: www.uodo.gov.pl

9.10 How to exercise your rights

Contact us:hello@stellawise.app

Clearly indicate which right you are exercising.

We will respond within 30 days of receiving your request. If the request is complex, we may extend this period by a further 60 days; in that case, we will inform you within 30 days with an explanation.

10.1

The Stellawise Waitlist is not intended for persons under 16.

We do not knowingly collect personal data from children under 16. If you are under 16, please do not sign up for the list or provide your email address.

If we learn that we have collected data from a person under 16, we will delete it promptly.

11.1 Types of cookies

Essential (always active):

• Session management cookies.
• Security cookies (prevent abuse).

Analytics (optional, with your consent):

• Website traffic statistics.
• Error monitoring.

11.2 Managing cookies

You can control cookies through:

• Your browser settings.
• Our cookie consent banner.

Disabling essential cookies may affect website functionality.

12.1

The stellawise.app website may contain links to third-party sites or services (e.g. social media). We are not responsible for the privacy practices of these external sites.

We encourage you to read the privacy policies of any third-party services and sites you visit.

13.1

We may update this Privacy Policy from time to time to reflect:

• Changes in our practices.
• New legal requirements.
• The selection of specific service providers (email, analytics).

When we make changes:

• We will update the “Last updated” date.
• We will notify you by email of material changes with appropriate advance notice.

14.1

If you have questions, concerns or requests regarding this Privacy Policy or your personal data:

Email: hello@stellawise.app

Website: www.stellawise.app

Address: Working Reason Kaja Dobrzańska, ul. Kapelanów Armii Krajowej 1/411, 04-046 Warsaw, Poland

Supervisory authority: Personal Data Protection Office (UODO)

ul. Stawki 2, 00-193 Warsaw, Poland

Tel.: +48 22 531 03 00

www.uodo.gov.pl

IMPORTANT

This is only a summary. In the event of a legal dispute, the full text of the Privacy Policy above prevails.

What we do

• We collect only your email.
• We use it to notify you of the Application launch.
• We send a maximum of 1-2 emails before launch.

What we don’t do

• We don’t sell your data.
• We don’t send ads for other companies.
• We don’t collect health or personal data beyond your email.

Your rights

• You can unsubscribe with one click (link in every email).
• Full GDPR rights (access, erasure, objection).
• Complaint to UODO if you believe we are breaching your rights.