1. Who are we?

1.1. We are STELLAR LABS, a private limited liability company (besloten vennootschapor BV) incorporated under Belgian law, having its registered office at Grote Koraalberg 11, 2000 Anwerp (Belgium) (“STELLAR LABS”, “we”) and registered with the CrossroadsBank for Enterprises (Kruispuntbank van Ondernemingen or KBO) under enterprise number 0735.437.073 (RLE Antwerp, section Antwerp).

1.2. We at STELLAR LABS provide an upskilling platform and upskilling programmes (the “Platform”).

1.3. We valueyour right to privacy and make every effort to protect your personal data inaccordance with applicable data protection law, including the General DataProtection Regulation (EU) 2016/679 ("GDPR") and national implementinglegislation. In this privacy policy (the “PrivacyPolicy”), we explain whatpersonal data we collect from you, for what purposes we will process this data,on what legal basis we base this processing, to whom your personal data may betransferred, how long we keep your data, how we protect your data and whatrights you have in relation to the processing of your personal data.

2. From whom do we collect data?

2.1. In the course of our business, we may collect personal data from customers, users of the Platform, visitors of the website, prospects, persons who provide their business card or otherwise provide their contact details to us, and persons who contact us by e-mail or otherwise.

3. Which personal data do we process?

3.1. By using our Platform or visiting our website, we collect and process your data. Some aspects of these data can be qualified as personal data.  We process the following categories of personal data:

• Personal data that you enter yourself on the Platform/website such as your first and last name, professional e-mail address and job title.
• Personal data we receive from others such as your employer in order to create your account such as your professional e-mail address.
• Personal data collected when you use our Platform/website such as device information (IP address, device ID etc.), usage information (used features, users you connect and interact with, messages you send and receive).

3.2. STELLAR LABS may process the following personal data in accordance with the provisions of this Privacy Policy. The following personal data will have to be provided on a mandatory basis:

• Signup information such as the first and last name, professional e-mail address, and job title.
• Technical information such as IP-address.

The following personal data will have to be provided on a voluntary basis:

• Other information completed by you in the Platform or on our website.

4. For which purposes do we process your personal data?

4.1. We may use the aforementioned personal data for the following purposes:

• (1) Administer your account to allow STELLAR LABS to provide access to and use of its Platform;
• (2) Improve our Platform and website, and to support and improve your learning journey;
• (3) Interact with other users of the Platform;
• (4) Ensure legal compliance;
• (5) Prevent, detect and fight fraud and other illegal or unauthorized activities. 
• (6) Promoting and informing existing customers and subscribers about similar products and services through electronic communications, such as sending information about new products and features, survey requests, newsletters, and events via email.
• (7) Promoting and informing legal entities through electronic communications directed at a non-personal email address, e.g., info@ or sales@ (B2B communications).  
• (8) Promoting and marketing the Platform through electronic communication, which does not fall under the situation of (6) or (7), for example to prospects.  

In accordance with the GDPR, we process your personal data on the basis of the following legal grounds:

• We base the processing of personal data for (1), (2) and (3) on the necessity for the performance of the contract we have concluded with your employer, on which basis you have been granted access to the platform (art. 6.1 b) GDPR).
• We base the processing of personal data for (4) on the necessity for compliance with a legal obligation (art. 6.1 c) GDPR).
• We base the processing of personal data for (5) on the necessity for the performance of a task carried out in the public interest (art. 6.1 e) GDPR).
• We base the processing of personal data for (6) and (7) on the necessity for the purposes of our legitimate interests (art. 6.1., f) GDPR), namely, to promote our products and services. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you(unless we have your consent or are otherwise required or permitted to by law). You can easily unsubscribe at any time via the link at the bottom of the relevant electronic communication message.
• We base the processing of personal data for (8) on the explicit, prior, free, specific, and informed consent from the data subject (art. 13, Book XII, Belgian Code of EconomicLaw).

We will not use your personal data processed under the abovementioned purposes for any other purposes, including but not limited to advertising and marketing purposes.

5. With whom do we share your personal data?

5.1. We may disclose your personal data to the following parties:

• Other users of the Platform: you share information with other users when you disclose information on the Platform. Please be careful with your information and make sure you are comfortable with the visibility of the content you share.
• With our service providers and partners: We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, payment processing and security operations.
• With law enforcement/when required by law: We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

5.2. When transferring personal data to third parties, we always ensure that we implement appropriate technical and organisational protection measures. Where necessary, we will, for example, conclude a transfer agreement or a processor agreement, which sets out restrictions on the use of your personal data and obligations in respect of the security of your personal data.

5.3. Your personal data will not be lent or sold to third parties for marketing purposes.

5.4. To the extent that your data is transferred in the context of this article to countries outside the European Union which do not provide an adequate level of protection for your data, STELLAR LABS will ensure that the companies to which your data is transferred do provide an adequate level of protection. In particular, we have concluded Standard Contractual Clauses (SCC) with them. STELLAR LABS guarantees to always verify, on a case-by-case basis, whether an adequate level of protection is in place for transfers to third countries.

6. How long do we store your personal data?

6.1. We do not keep your personal data longer than necessary for the purposes for which it is collected and processed (as described above).

6.2. For the purposes of providing services to our customers, we will retain it for as long as necessary to fulfil the purposes set out above, unless a longer retention period is (i) necessary to cover our liability or (ii) required or permitted by law.

6.3. All personal data purely for the purpose of scientific research or statistical purposes may be stored for longer periods.

6.4. Regarding the data of visitors to our Platform or website, we refer to our Cookie Policy.

7. How do we secure your personal data?

7.1. We take appropriate technical and organisational measures to ensure a level of security appropriate to the specific risks we have identified.

7.2. We thus protect your personal data as best as we can against the destruction, loss, alteration or unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. More information on our security measures is available upon request.

8. Which rights do you have as a data subject?

8.1. Withdraw your consent at any time: you have the right to withdraw consent where they have previously given their consent to the processing of your personal data.

8.2. Object to processing of your personal data: you have the right to object to the processing of your personal data if the processing is carried out on the legal basis of a legitimate interest, including profiling. You also have the right to object to the processing of your personal data for direct marketing purposes. This right is absolute - we will always comply with it.

8.3. Right to access: You have the right to obtain confirmation from us as to whether or not we are processing your personal data, to obtain access to that personal data and how and why it is being processed, as well as to receive a copy of that data.

8.4. Right to rectification: You have the right to obtain a correction of your personal data or to request that we complete your personal data if you notice that we are processing incorrect or incomplete data about you.

8.5. Right to erasure: You have the right to obtain data erasure in certain specific cases.

8.6. Right to restriction: You have the right to have the processing of your personal data restricted in certain specific cases.

8.7. Right to data portability: You have the right to obtain the personal data you have provided us with in a structured, commonly used and machine-readable form, and to transfer that personal data (or have it transferred) to another controller.

8.8. You may exercise the above rights by sending an e-mail to privacy@stellarlabs.eu or in the case of the right to object to direct marketing also via the opt-out link included in our marketing e-mails. The exercise of these rights is in principle free of charge. Only in case of unreasonable or repeated requests may we charge a reasonable administrative fee. We always try to answer your requests or questions as quickly as possible. It is possible that we will first ask you for proof of identity in order to verify your identity. For further information and advice on the above rights, please visit the Application of the Data Protection Authority: gegevensbeschermingsautoriteit.be. In addition to the above rights, you also have the right at any time to lodge a complaint with the Data Protection Authority in connection with the processing of your personal data by us. You can contact the authority at contact@apd-gba.be or by mail at the following address:

Gegevensbeschermingsautoriteit
Drukpersstraat 35
1000 Brussel

8.9. Furthermore, you can always choose to uninstall the Platform or delete your account. When the information on your profile is inaccurate, you have the right to update your information.

9. Changes to the privacy policy

9.1. From time to time it may be necessary to amend this Privacy Policy. When we post changes to the policy, we will change the "last updated" date at the bottom of the document. The most recent version of this Privacy Policy will be available on our Platform and website at all times.

10. Links to other website

10.1. Our Platform and/or website may contain links to other sites that are not operated by us. When you click on a third-party link, you will be transferred to that third-party site. We strongly recommend that you review the Privacy Policy of any site you visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party web sites or services.

11. Contact

11.1. If you have any questions or concerns regarding this Privacy Policy or our processing of your personal data, you may contact us at privacy@stellarlabs.eu.