Privacy Policy – Platform

Last updated30/09/2026

This privacy policy applies to the influencer marketing platform Stellar and to the cooperation between potential and existing contractual partners, in particular influencers and creators (hereinafter “influencers”), and HeavenTech SA (hereinafter “HeavenTech”). We attach great importance to data protection. We collect and process your personal data in compliance with the applicable data protection regulations, in particular the General Data Protection Regulation (GDPR) and the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

A separate Privacy Policy – Website applies to visits to our website stellar.io.

I. Controller

The controller responsible for the collection, processing and use of your personal data within the meaning of Article 4(7) GDPR is:

HeavenTech SA
54 Avenue Louise
1050 Brussels
Belgium

Email: andre.kilz@stellar.io

If you wish to object to the collection, processing or use of your data by us under this privacy policy, as a whole or for individual measures, you can send your objection to the controller. You can save and print this privacy policy at any time.

II. General purposes of processing

We use personal data to get in touch, to research and carry out influencer marketing campaigns via the Stellar platform, and to report on them.

III. Which data we use and why

A. Contacting us

When you contact us (for example by email or via a contact form), we process your information in order to handle your enquiry and in case of follow-up questions. Our contact forms are provided via HubSpot; details can be found in our Privacy Policy – Website. Where the data is processed to carry out pre-contractual measures taken at your or our request or, if you are already in contact with us, to perform the contract, the legal basis for this processing is Article 6(1)(b) GDPR. We only process further personal data if you consent to this (Article 6(1)(a) GDPR) or if we have a legitimate interest in processing your data (Article 6(1)(f) GDPR). A legitimate interest exists, for example, in replying to your email.

B. Data for the performance of our contractual obligations

We process personal data that we need to perform our contractual obligations, such as your name, address, telephone number and email address. The collection of this data is necessary for the conclusion of the contract. The data is deleted after the expiry of warranty periods and statutory retention periods.

The legal basis for processing this data is Article 6(1)(b) GDPR, because this data is required so that we can perform our contractual obligations towards you and our customers.

C. Data to facilitate the implementation of influencer marketing campaigns

We process personal data that facilitates the performance of our contractual obligations on the basis of Article 6(1)(b) GDPR and compile this data in the Stellar platform. The collection of this data helps HeavenTech and its customers to plan and carry out influencer marketing campaigns more efficiently. The data is deleted after the expiry of warranty periods and statutory retention periods. This data includes:

first name and last name
email address
telephone number
home address
shipping address
gender
relationship status
date of birth
pricing information
information from past campaigns in which the influencer took part
where applicable, information about the agency representing the influencer (first name and last name, email address, telephone number, address)
social media account information from blogs, Facebook pages, Instagram accounts, Pinterest pages, podcasts, Snapchat accounts, TikTok accounts, Twitch channels, X accounts (formerly Twitter), WeChat accounts and YouTube channels
profile picture (from the public feed)
account names (@…)
IDs
stored names
texts and links
account and post insights (including impressions, reach, comments, follower demographics)
anonymised market research data (follower demographics, social media usage behaviour).

The data is public data, data received personally from the influencer or from the agency or management representing the influencer, or data that came into our possession through business cards, flyers, media kits or similar received in person, or through direct collection.

D. Data for our own marketing purposes

HeavenTech reserves the right to use campaign content created in connection with a campaign for its own marketing purposes (reposting the posts on Stellar’s social media accounts, and campaign-related use of the posts on the website stellar.io and in online press releases and print media). The grant of the right of use is set out in a contract between the influencer and HeavenTech.

IV. Registration and authentication

By registering or authenticating, users authorise the Stellar platform to identify them and to give them access to specific services.

Depending on what is stated below, third parties may provide registration and authentication services. In this case, the platform may access some of the data stored by these third parties for registration or identification purposes.

Where you consent to this processing, the legal basis for the processing is Article 6(1)(a) GDPR.

A. Facebook authentication (Meta)

Facebook authentication is a registration and authentication service provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, and connected to the social network Facebook.

Personal data collected: profile picture (from the public feed), account names (@…), IDs, stored names, texts and links, account and post insights (including impressions, reach, comments, follower demographics).

We will only use the information received for the purposes described in this privacy policy (section V “Use of data”).

Place of processing: including the USA. Privacy policy: https://www.facebook.com/privacy/policy/

B. Google OAuth (Google)

Google OAuth is a registration and authentication service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and connected to the Google network.

We will only use the information received for the purposes described in this privacy policy (section V “Use of data”).

Place of processing: including the USA. Privacy policy: https://developers.google.com/terms/api-services-user-data-policy

V. Use of data

The data collected or received is used:

a) to decide on an advertising cooperation with us or our customers. For this purpose, the data is prepared in tabular and graphical form and displayed in the Stellar platform and in presentations (sedcards). Decisions are based on the actual reach and performance of the account concerned and on the age, gender and country distribution of its followers in relation to the advertising campaign
b) to evaluate the advertising campaign carried out with regard to the target group reached and the quality of the content created (image or video). On the basis of reach and agreed budgets, KPIs such as CPM (cost per mille), CPE (cost per engagement) and CTR (click-through rate) are calculated in order to assess the success of the advertising cooperation. The results (number of impressions, comments, likes, average viewing time) are prepared in tabular and graphical form and displayed in the Stellar platform and in presentations (reports).

VI. Recipients of the data

The data collected or received is mainly received by the employees of HeavenTech, by the Stellar platform and, beyond that, by customers and, where applicable, potential customers of HeavenTech. The data is shared with customers in a commercial context for the planning and implementation of influencer marketing campaigns.

VII. Storage period

Unless stated otherwise, we only store personal data for as long as necessary to fulfil the purposes pursued. In some cases, the law requires personal data to be retained, for example under tax or commercial law. In these cases, we continue to store the data only for these legal purposes, do not process it in any other way, and delete it after the statutory retention period has expired.

VIII. Your rights as a data subject

Under the applicable laws, you have various rights regarding your personal data. If you wish to exercise these rights, please send your request by email or by post, clearly identifying yourself, to the address given in section I. Below is an overview of your rights.

A. Right to confirmation and access

You have the right to clear information about the processing of your personal data. In detail: you have the right at any time to obtain confirmation from us as to whether personal data concerning you is being processed. If this is the case, you have the right to request from us, free of charge, information about the personal data stored about you together with a copy of this data. You also have the right to the following information:

a) the purposes of the processing
b) the categories of personal data processed
c) the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations
d) where possible, the envisaged period for which the personal data will be stored or, if this is not possible, the criteria used to determine that period
e) the existence of the right to request rectification or erasure of personal data concerning you, restriction of processing by the controller, or to object to such processing
f) the existence of the right to lodge a complaint with a supervisory authority
g) where the personal data is not collected from you, any available information as to its source
h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

Where personal data is transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

B. Right to rectification

You have the right to request that we rectify and, where applicable, complete personal data concerning you. In detail: you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of a supplementary statement.

C. Right to erasure (“right to be forgotten”)

In a number of cases, we are obliged to erase personal data concerning you. In detail: under Article 17(1) GDPR, you have the right to request that we erase personal data concerning you without undue delay, and we are obliged to erase personal data without undue delay where one of the following grounds applies:

a) the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed
b) you withdraw the consent on which the processing was based under Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal basis for the processing
c) you object to the processing under Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing under Article 21(2) GDPR
d) the personal data has been processed unlawfully
e) the personal data must be erased to comply with a legal obligation under Union or Member State law to which we are subject
f) the personal data has been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

Where we have made the personal data public and are obliged under Article 17(1) GDPR to erase it, we take reasonable steps, including technical measures, taking into account available technology and the cost of implementation, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copies or replications of, that personal data.

D. Right to restriction of processing

In a number of cases, you are entitled to request that we restrict the processing of your personal data. In detail: you have the right to obtain from us restriction of processing where one of the following applies:

a) you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data
b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead
c) we no longer need the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims
d) you have objected to the processing under Article 21(1) GDPR, pending the verification whether our legitimate grounds override yours.

E. Right to data portability

You have the right to receive, transmit or have us transmit personal data concerning you in a machine-readable form. In detail: you have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller without hindrance from us, where both of the following conditions are met:

a) the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, or on a contract pursuant to Article 6(1)(b) GDPR
b) the processing is carried out by automated means.

In exercising your right to data portability, you have the right to have the personal data transmitted directly from us to another controller, where technically feasible.

F. Right to object

You have the right to object to the lawful processing of your personal data by us where this is justified by your particular situation and our interests in the processing do not prevail. In detail: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

Where we process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

You have the right, on grounds relating to your particular situation, to object to the processing of personal data concerning you for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

G. Automated decisions including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. No automated decision-making takes place on the basis of the personal data collected.

H. Right to withdraw consent under data protection law

You have the right to withdraw your consent to the processing of personal data at any time with effect for the future.

I. Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you is unlawful. The competent authority for HeavenTech SA is the Belgian Data Protection Authority (Autorité de protection des données), Rue de la Presse 35, 1000 Brussels, contact@apd-gba.be.

IX. Data security

We make every effort to ensure the security of your data within the framework of the applicable data protection laws and technical possibilities. Your personal data is transmitted to us in encrypted form. Please note, however, that data transmitted over the internet (for example by email) can have security gaps. Complete protection of data against access by third parties is not possible. To secure your data, we maintain technical and organisational security measures in accordance with Article 32 GDPR, which we continuously adapt to the state of the art.

We also do not guarantee that our service will be available at particular times; faults, interruptions or failures cannot be ruled out. The servers we use are regularly and carefully backed up.

As a rule, we only use your personal data within our company. If and to the extent that we involve third parties in the performance of contracts (for example customers who plan and carry out an influencer campaign via the Stellar platform), they only receive personal data to the extent that the transfer is necessary for the service concerned. The data is shared with customers in a commercial context for the planning and implementation of influencer marketing campaigns.

Where we outsource certain parts of the data processing (“processing on our behalf”), we contractually oblige the processors to use personal data only in accordance with the requirements of data protection law and to ensure the protection of the rights of the data subject.

Where data is transferred to countries outside the European Union or the European Economic Area, for example in connection with the registration services mentioned in section IV or to customers of HeavenTech SA based outside the EU for the purpose of carrying out influencer marketing campaigns, this is done on the basis of an adequacy decision of the European Commission (Article 45 GDPR), such as the EU-U.S. Data Privacy Framework where the recipient is certified, or on the basis of appropriate safeguards, in particular the standard contractual clauses of the European Commission (Article 46(2)(c) GDPR).

XI. Data protection contact

If you have any further questions or concerns about data protection, please contact:

HeavenTech SA
54 Avenue Louise
1050 Brussels
Belgium
For the attention of André Kilz