• Personal data means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• Controller means a legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
• Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
• Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
• Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
• Personal data breach means a breach of security leading to the accidental or unlawful destruction, , unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
• Cross-border processing means either:
  • Processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union where the controller or processor is established in more than one Member State; or
  • Processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State.

Introduction

• As your service provider, we need to keep and process information about you at the time of check-out whenever you make a purchase from our web site to complete your transaction. To process your order, we require you to supply us with your correct billing, shipping and contact information. The information remains secure and cannot be received or read by others.
• When you "Login" at our support center, we receive your contact information. We require you to submit your name and email address to be able to respond to your inquiry.
• You may also register to receive periodic email correspondence from us through our "Newsletter Desk" The information we collect for this purpose is your name and email address.
• The information we hold and process will be used for our management and administrative use only. We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately.
• This policy applies where we are acting as a data controller and data processor with respect to the personal data of our customers; in other words, where we determine the purposes and means of the processing of that personal data.
• We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

How we use your personal data?

Online Order: The personal information you supply when placing an online order is used to ship your order and to send you order confirmation email. We may also use it to contact you in case of seeking any clarification on the order or a related correspondence.

Technical Support: We use the personal information you supply when you submit a support question to respond to your question. Your email address is used to send a response from our Technical Support team.

Email message: When you submit permission by subscribing through our newsletter desk, we will send email messages to let you know about changes at our Web site, new releases, promotional offers and special discounts on products and services. With every email newsletter, customers are provided an option to remove themselves from receiving future emails.

Survey & Contest: Stellar may request you for information for a survey or contest. Requested information may include your name, shipping address and demographic information. Contact information will be used to notify contest winners and award prizes.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

Providing your personal data to others

We may disclose your personal data (name, contact no. email address etc.) to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
Financial transactions relating to our products and services may be handled by our payment services providers, Digital River & Avangate. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at:

https://order.shareit.com/info/privacy_statement; http://www.avangate.com/privacy.php

In addition to the specific disclosures of personal data set out above, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

International Transfers of your Personal Data

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and Process your Personal Data in India and elsewhere in the world. We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other countries. By using our Sites and Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Sites and Services are appropriate or available in any particular jurisdiction.

Retention and Deletion of Personal Data

• Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
• Data recovered from the customers availing data recovery services will be retained for a maximum period of 7 days following payment date for the availed service.
• Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

How We Protect Your Information

Stellar Information Technology Pvt. Ltd. takes reasonable steps to provide a level of security appropriate to the sensitivity of the information we collect. We have implemented ISO/IEC 27001 (ISMS- Information Security Management System) standards to protect your personal data from unauthorized access and disclosure.

When we collect or transmit sensitive information, we use industry standard methods to protect that information as required by applicable laws. We leverage industry best practices to mitigate potential compromises. If the Personal Data under the custody of Stellar Information Technology is (or is likely to be) divulged, damaged or lost, we will immediately take remedial measures, inform the users in a timely manner and report to the competent government agencies as required by applicable laws.

Collection of Information, including Use of Cookies

INFORMATION YOU MANUALLY PROVIDE

We collect Personal Data from you when you use this Website such as:

• When you provide information during a purchase of a product or service,
• When you request information about or otherwise use the Website,
• When you enter into a contest or promotion, sign-up for a newsletter or related services,
• When you submit an order or purchase, download or register products, or request additional services,
• When you call our customer service, you may voluntarily provide information to our representatives, and

SPECIAL CATEGORIES OF DATA

Generally, Special Categories of Data will not be collected or processed. However, there could be a situation where such data may be processed. In this case, we will be sure to comply with applicable data protection legislation, including relying on the necessary legal grounds to process the data. We shall use reasonable security practices and procedures to safeguard your Special Categories of Data.

INFORMATION FROM YOUR BROWSER OR DEVICE

We may likewise get data from your web program. This may incorporate data that does not distinguish you personally, (for example, the date and time of your visit). The data we get relies upon the settings on your web program. If you created a user identity during a visit to this Website, this shall be regarded as giving your consent for processing your Personal Data, if any, and we may link the information provided by your browser to information that identifies you personally, as described below. Please review the settings on your web browser to learn how to change your browser settings. We may likewise gather constrained Personal Data (email address) regarding your utilization of a Website, as portrayed underneath.

• COOKIES AND OTHER SIMILAR TECHNOLOGIES:
  The information we collect using cookies and similar technologies is not typically personally identifiable, but we may link it to Personal Data that you provide. We use cookies and other similar technologies to collect information and support certain features of this Website. As the Internet evolves, we may use different types of technologies for this purpose. For example, we may use these technologies to collect information about the ways visitors use this Website (such as which pages they visit, links they use). We analyze this information to better understand our visitors' interests, needs and to improve the content and functionality of the Website. We also use the information to support Website features by not asking you to re-enter information already in our database. We also use this information to personalize your experience when you use the Website and to improve our marketing efforts, including through use of targeted advertising.
  If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies, you may be unable to use all of the Website functionality if your browser rejects our cookies.
• LOCATION INFORMATION:
  When you use a smart phone, mobile device or computer to access our Website or use our mobile application, we may collect information about your physical location. We may combine this information with other location-based information (e.g., your IP address and billing/postal code), to provide you with other services on your mobile device. We share your location information only with third parties that help us provide you with services. You can opt-out of sharing this information by changing the permissions in your mobile device.

How We Use Your Data?

We may use your Personal Data for the following purposes:

• To contact you if you have requested communication from us.
• To determine the country where you are located such as for trade compliance, security and fraud prevention.
• To otherwise verify compliance with applicable laws.
• To help verify that data we have about you is accurate.
• to provide you with product updates, special offers and other promotional information, either on our own behalf or on the behalf of a Partner, where you have consented to receive it and in accordance with applicable law.
• In connection with keys, access codes or other information so you can access the websites or services of our Partners to receive products or services.
• As identified in a supplemental privacy notice posted on the Website.

We may also use your Personal Data for the following purposes where you visit the Website to complete a transaction:

• To process your order, process payment, contest chargebacks, determine your eligibility for a line of credit, or notify you of the status of your order,
• For fraud monitoring and prevention purposes,
• To provide you with a personalized shopping experience,
• To register your purchase with the manufacturer or service provider for warranty, technical support or similar purposes,
• To provide notice of your purchase to the provider of an online service for which you purchase a service use right from us,
• To establish an account for future purchases that you have consented to,
• To facilitate the renewal of subscriptions for products or services, and
• to provide you with an effective experience and support (which may, as allowable by law, include contacting visitors who start a checkout process to follow-up on the incomplete session or to see if there was a problem with their use of the Website).

We will take reasonable steps to ensure any person or entity receiving Personal Data for the purposes described above, are obligated to keep the Personal Data secure. If any Special Categories of Data are being collected, received or retained by an external entity, details of such entity will be shared with you if required by applicable law. Our obligations will not, apply to information shared with any Government entity mandated under law to obtain such information or by an order under law for the time being in force.

Automated Processing

In limited situations, we may use your Personal Data to help us make automated decisions to further improve our business. For example, in the context of marketing, we could use data to segment and target users with personalized messages. For example, we may use a job title to determine the users' persona and alter the content accordingly. We may also use that users' geographic location and company data. In some circumstances, for account-based marketing, this could include "likes" that we find in the public domain.

OUR USE OF ANONYMOUS INFORMATION

We may use Anonymous Information collected by us. In this case, the following data elements will be anonymized such as first and last name, street address, phone number, email address and other data elements in accordance with applicable law. The Anonymous Information will be used as described here:

• To personalize and support your use of this Website and/or the services of our Partners,
• To improve this Website, the customer experience, our advertising systems, and our products and services,
• For fraud prevention purposes, such as device fingerprinting,
• To identify transactions as originating through an affiliate marketing or referral program,
• To deliver targeted advertisements on this Website and other commerce solutions,
• To provide reporting to our current and prospective Partners and service providers, and
• For historical, statistical, research and analysis.

OUR SERVICE PROVIDERS

We utilize other companies, including our corporate affiliates, to provide certain services to us or on our behalf to help us operate our business such as:

• To host or maintain this Website
• To process credit card payments
• To provide fraud monitoring or detection services,
• To perform data integrity checks,
• To offer you a line of credit
• To provide optimization services,
• To fulfill your order,
• For payment collection,
• To deliver advertisements on this Website and third party websites,
• To send mail or e-mail,
• For purposes related to employment and human resources, and/or
• To provide customer service.

We will not share your Personal Data with our service providers in connection with their offering of services to us, unless it is required for the purposes of our Legitimate Interests and purposes of fulfilling our obligations as to delivery of our commerce solution to you.
These service providers may be contractually required to use any information we share with them only to perform services to us or on our behalf and to protect the confidentiality of your Personal Data. We may also allow these companies to use Anonymous Information for their business purposes. We will not share your Personal Data with our affiliates or unrelated third parties to use for their own marketing purposes without your consent.

TO COMPLY WITH LEGAL REQUIREMENTS, PREVENT FRAUD AND CRIMES

As permitted by applicable law, we may disclose Personal Data about you when we believe disclosure is appropriate to:

• To comply with the law or a regulatory requirement,
• To comply with governmental, administrative or judicial process, requirement or order (such as a court order),
• To cooperate with law enforcement or other governmental investigations or report any activities that may be in violation of legal or regulatory requirements,
• To prevent or investigate a possible crime (such as fraud or identity theft) or breaches (also suspected breaches) of security or of this Privacy Policy,
• To enforce a contract,
• to protect the legal rights, Website or safety of Digital River and our employees, Partners, third parties, the public in general or you.

Access to Your Information

If you would like to review, correct, restrict the processing thereof, object to direct marketing, or request erasure of your Personal Data or Special Categories of Data, please send us a request using the information on privacy@stellarinfo.com. For example, if there is any error in the Personal Data that you have submitted to us, please contact us and we will take appropriate measures to correct the error.
If you contact us we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements as noted in our data retention policy. When we delete your Personal Data or Special Categories of Data, it will be disposed of in a manner that prevents loss, theft, misuse, or unauthorized access in-line with our data retention policy.
You have the right to report to your local Supervisory Authority where you feel as though your rights under data protection legislation have not been appropriately considered. However, before doing so, please contact us directly as we are committed to working with you to help resolve any concerns about your privacy.

Marketing and Related-Communications

When you provide Personal Data, we may offer you a choice as to whether you would like to receive further marketing and related communications from us or our Partners. These communications could be in the form of direct mail, email or telephone and will contain information to inform you of our products and services. You may opt-out of receiving these communications by e-mailing us at unsubscribe@stellarinfo.com, or by following any unsubscribe instructions in e-mail communications.
If you give us consent to add your contact information to our Partner's mailing list and later withdraw this permission, you must contact our Partner (or follow the unsubscribe instructions in the e-mails from our Partner) to have your name removed from our Partner's mailing lists.

Children's Privacy

This Website is not directed at nor targeted to children. If you have not reached the age of majority or are not able to enter into legally binding agreements in your country, you may not use this Website unless necessary parental consent has been obtained. If you believe that we have received information from a person protected under child protection laws where necessary parental consent was not obtained, please notify us immediately, and we will take reasonable steps to securely remove that information.

Data Protection Officer

Our Data Protection Officer's contact details are

Email id - privacy@stellarinfo.com.