Stellar Heal Privacy Policy

STELLAR PRIVACY POLICY
1. INTRODUCTION
At AI Driven Healthcare, Inc.  (“Stellar,” “us,” “we,” or “our”), our mission is to be a conversation thought partner. We exist to improve your life, by offering an Artificial Intelligence based mental health coach. We take your privacy seriously and want you to understand how we use, collect, and share Personal Data, and the measures we take to protect your Personal Data.
This Privacy Policy applies to Personal Data we collect about members and other consumers who interact with Stellar or use our services, including by visiting our websites or our social media pages, or using our mobile apps, the Stellar app (collectively, the “Services”). This Privacy Policy does not cover the practices of companies that we do not own or control, or people that we do not manage. We are not responsible for the policies and practices of any third parties, and we do not control, operate, or endorse any information, products, or services that may be offered by third parties or accessible on or through the Services.
We have provided supplemental notices below for residents of California
2. HOW WE COLLECT PERSONAL DATA
We collect Personal Data about you from:
  • Yourself, when you provide such information directly to us, such as when completing your profile;
  • Stellar app when you interact with and receive responses from the Stellar app as described in Section 8 below;
  • Automatic data collection, such as Cookies, local storage objects, web beacons, and other similar technologies in connection with your use of the Services;
  • Customers and partners, such as employers, insurance companies, coaches, teams, or other organizations that engage with our Services;
  • Marketing and advertising partners, such as companies that have entered in joint marketing relationships with us or assist us with marketing or promotional services, which may provide us with data related to how you interact with our Services, advertisements, or communications;Social media, other third-party platforms, and linked accounts, devices, or features, if you interact with our pages on social media sites, post content to their sites using the Services, sign into the Services through a third-party site or service, or otherwise link accounts, devices, or features to your Stellar account; and
  • Data providers, such as information services and data licensors, when we supplement your data.
3. PERSONAL DATA WE COLLECT
We may collect the following types of Personal Data:
  • Contact details, such as your first and last name, email and mailing address, and phone number;
  • Profile data, such as username and password that you may establish to create a Stellar account, as well as any photographs or information you choose to include in your Stellar profile;
  • Communications that we exchange with you, including when you contact us via email, web app, or mobile app with questions, feedback, or reviews;
  • Wellness Data, such as resting heart rate, heart rate variability, and blood oxygen saturation level collected from connected wearable devices, Apple HealthKit, and Google Fit; metadata on workouts and sleep; the type of physical activity you engage in and the duration of your activity; your physiological profile, including birthday, gender identity, weight, height; and details you choose to submit about your diet, medications, female health tracking and any textual context related to your health & wellness. We may use certain of this information to customize your experience with us as part of our Services;
  • Conversations that you participate in with the Stellar App, as described in Section 8 below;
  • Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them (e.g., the marketing emails that you open and the links within them that you click);
  • Device data, such as your computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP Address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area;
4. HOW WE USE PERSONAL DATA
We process Personal Data to operate, improve, understand, and personalize our Services. We use Personal Data for the following purposes:
Service delivery, including to:
  • Provide, operate, improve, develop, understand, and personalize the Services and our business, including testing, research, analysis, and product development;
  • Satisfy the reason you provided the information to us, including responding to and fulfilling requests;
  • Communicate with you about the Services, including Service announcements, updates, or offers;
  • Provide support and assistance for the Services;
  • Create and manage your account or other user profiles;Customize website content and communications based on your preferences; and
  • Process orders, memberships, or other transactions.
Research and development. We may create and use Aggregated Data, De-identified Data, or other anonymous data from Personal Data we collect, including Wellness Data, for our business purpose, including to analyze the effectiveness of the Services, to improve and add features to the Services, and to analyze the general behavior and characteristics of users of the Services. We also use anonymous Wellness Data for research purposes to help us and our research partners answer important questions about human performance and create an even-better experience for our members by identifying cutting-edge insights and providing new content and product features.
Direct marketing and advertising. We may use data from the Personal Data we collect, including Wellness Data and certain data collected when you browse our website, to send you direct offers marketing messages or advertise the Services or other Stellar product offerings.
  • Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use Cookies and similar technologies to collect information about your interaction over time across the web, our communications, and other online services, and may use that information to serve online ads. We comply with the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising. To learn more about the industry self-regulatory programs and other information and choices about interest-based ads, please see the section above entitled “Online tracking opt-outs.”
Compliance and protection, including to:
  • Protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services;
  • Comply with or enforce our legal or contractual obligations, resolve disputes, and enforce our Terms of Service
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); and
  • Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
5. HOW WE SHARE PERSONAL DATA
We may share your Personal Data with:
  • Service providers, such as payment processors, vendors who advertise our Services or other Stellar products, security and fraud prevention consultants, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel, that provide services to us or on our behalf; our service providers also include our third-party Large Language Model (“LLM”) partners that power Stellar app, as described in Section 8 below;
  • Advertising partners that may collect information on our website through Cookies and other automated technologies, including for the interest-based advertising purposes described above. We do not share your Wellness Data with advertising partners;
  • Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us;
  • Authorities and others, including law enforcement, government authorities, and private parties we believe in good faith to be necessary or appropriate to comply with the law or legal process; and
  • Business transferees, such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Stellar or our affiliates (including, in connection with a bankruptcy or similar proceedings).
  • Distributors and retailers of our Services or other Stellar products;
  • Affiliates of Stellar.
6. HOW YOU MAY SHARE PERSONAL DATA THROUGH Stellar
Depending on your use of the Services, you may share Personal Data with:
  • The other users of the Service, and users are by default searchable by other users;
  • Third-party social media platforms, or linked accounts, devices, or features, when you choose to connect your account on those services with Stellar or post content to social media, such as through the Stellar Live feature;
  • The Public. When you make Personal Data visible to other users of the Services, including through the Stellar Live or Stellar Teams features, it may become publicly available and can be collected, viewed, and used by anyone;
  • Corporate wellness programs. If you use the Services in connection with an employer or organizational corporate wellness program, we may share your information with that organization subject to your consent. Typically, we will share only Aggregated Data with these organizations.
7. Stellar & THIRD-PARTY AI TECHNOLOGY
Stellar is based on generative AI features that are intended to help you with your daily anxiety, by acting as a conversational partner and making progress to your goals. Stellar creates a coaching experience by combining your unique, anonymized Stellar metrics with the science of Stellar to help you optimize your mental health and performance.
If you decide to use Stellar, please note that Stellar leverages third-party AI technology provided by our LLM partners. This technology is trained on real-world data to generate intelligent and personalized responses in conversations with users. Responses from Stellar are based on your requests and relevant information collected through your device metrics among other relevant data. For example, if you ask Stellar a sleep-related question, then Stellar will provide personalized tips for improving your sleep based on your anonymized sleep data collected through the Services.
We require our LLM partners to use your anonymized Stellar metrics only for the purpose of allowing us to generate responses to your chats. We have ensured that our LLM partners has a “Zero-Retention/Zero Training Policy” with respect to your Stellar metrics, meaning that our LLM partners will not store or retain any of the anonymized Stellar metrics they receive through your use of Stellar, and our LLM partners will not use any of the anonymized Stellar metrics they receive for training any algorithms or LLM technologies.
We will only share your anonymized Stellar metrics with our LLM partners. We ask that you refrain from providing any identifying information, such as your name, in conversations with Stellar Coach.
Stellar may retain the history of your conversations to ensure you continue to have access to previous conversations while using the feature. When you revisit any topics from previous chats, Stellar may share the context of your previous conversations to create a better experience for you. You may delete your Stellar chat data at any time via the in app settings.
If you agree to use Stellar, please note that Consistent with our Privacy Principles, Stellar employees will only access member Personal Data when required to provide services and support, which may include collecting information about your experience with Stellar to assess the performance of and improve Stellar and other product offerings.
8. YOUR CHOICES
Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting privacy@stellarheal.com. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it.
Push notifications and device permissions. Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting support@stellarheal.com. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it.
Geolocation data. You may allow or disallow Stellar to collect geolocation data by enabling or disabling location services on your mobile device. If you decline to grant Stellar access to this data, we will not be able to provide certain Services, capabilities, or features to you.
We will only share your anonymized Stellar metrics with our LLM partners that power Stellar if you enable and engage with the feature. If you wish to update your data preferences, you can visit the “Permissions” section of your Stellar settings and device settings. If you no longer wish to use Stellar, you can simply not interact with the feature, or you can disable the feature entirely from your settings at any time.
9. OTHER SITES AND SERVICES
The Services may contain links to websites and other online services operated by Third Parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any Third Party. We do not control mobile applications, websites or online services offered or operated by Third Parties, and we are not responsible for their actions. You can learn about and control how these Third Parties use and share Personal Data about you, including with Stellar, by reviewing their privacy notices and exercising the privacy choices the Third Party may offer.
10. DATA SECURITY AND RETENTION OF PERSONAL DATA
We employ a number of physical, technical, organizational, and administrative security measures designed to protect the Personal Data we collect. While we endeavor to protect the privacy of your account and other Personal Data we hold in our records, no security measures are failsafe, and we cannot guarantee the security of your Personal Data.
We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.
11. PERSONAL DATA OF CHILDREN
If you are under the age to consent to data sharing, as applicable based on your jurisdiction, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under the age to consent to data sharing, as applicable based on jurisdiction, we will delete that information as quickly as possible. If you believe that a child under the age to consent to data sharing, as applicable based on your jurisdiction,, may have provided us Personal Data, please contact us at privacy@stellarheal.com.
12. CHANGES TO THIS PRIVACY POLICY
We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. We will alert you to changes by placing a notice on the Stellar website, by sending you an email, and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
13. CONTACT US
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@stellarheal.com or at the mailing address below.AI Driven Healthcare, Inc.  Attn: Legal Department One Kenmore Square, #601 Boston, MA 02215
14. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”).
We do not sell Personal Data. As we explain in this Privacy Policy, we use Cookies and other tracking technologies to analyze website and application traffic and use, and to facilitate advertising. To limit use of Cookies and other tracking technologies, please review the instructions provided in the “Online tracking opt-outs” section. You may also direct us to share your data, as described in the “How You Share Personal Data Through Stellar” section of the Privacy Policy.
California Privacy Rights. If you are a California resident, you have the following rights:
  • Information: The Privacy Policy describes the types of Personal Data we collect in the “Personal Data We Collect ” section above and the sources through which we collect Personal Data in the “How We Collect Personal Data section above. We describe the purposes for which we use and share this data in the “How We Use Personal Data section above and the “How We Share Personal Data section above.
  • Access: You can request a copy of the personal information that we maintain about you.
  • Deletion: You can ask to delete the personal information that we have collected from you.
  • Opt-out of sale of your Personal Data: We do not sell Personal Data. We offer instructions on how to limit online tracking in the “Online tracking opt-outs” section of the Privacy Policy.
Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.
You are entitled to exercise the rights described above free from discrimination.
Exercising Your Rights. To exercise these rights, you can submit requests as follows:
  • To request access to or deletion of Personal Data collected via your use of the Services, please either (i) use the “Data Management” feature available on the Stellar Privacy Center stellarheal.com/privacy; or (ii) email us at privacy@stellarheal.com.
  • To learn how to opt-out of interest-based ads and other online tracking, see the “Online tracking opt-outs” section of the Privacy Policy.
  • To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional Personal Data to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
  • Authorized agents: California residents can empower an “authorized agent” to submit requests on the resident’s behalf. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.