Aurora Privacy Policy

Last updated: September 1, 2025

Stellagent Inc., including its affiliated entities (collectively, “we”, “us”, or “our”), provides "Aurora," an advanced marketing analysis service leveraging artificial intelligence (AI) (the “Service”). This Privacy Policy describes how we handle personal information that we collect through the Service.

1. Personal Information We Collect

Depending on the context of your interactions with us, we may collect the following personal information.

1.1. Information You Provide Directly to Us

Contact Data: Such as your first and last name, email address, billing and mailing addresses, professional title, company name, and phone number.
Profile Data: Such as the username and password you set to establish an online account with the Service, any teams you are a part of, and any other information you add to your account profile.
Communications Data: Based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
Transactional Data: Such as information relating to or needed to complete your subscriptions on or through the Service, including subscription type and transaction history.
Marketing Data: Such as your preferences for receiving our marketing communications and details about your engagement with them.
Inputs, Prompts, and User-Generated Content: Such as messages, questions, files, and other content or information that you input, use as a prompt, generate, transmit, or otherwise make available on the Service, as well as associated metadata (e.g., how, when, and where content was collected or edited; keywords; location info).
Data Derived from Your Inputs: When you use certain features of the Service, we may derive certain information from your inputs in order to provide those features. We do not use such data for the purpose of identifying any specific individual.
Payment Data: Payment information needed to complete transactions is collected and processed directly by our payment processors, such as Stripe, as further described in Section 4, “How We Share and Disclose Your Personal Information,” below.
Other Data: Data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

(Request) We ask that you not provide us with any sensitive personal information (e.g., social security numbers, financial account numbers, government-issued ID numbers, information related to racial or ethnic origin, political opinions, religious or other beliefs, health, biometric or genetic information, criminal background information) on or through the Service or otherwise.

1.2. Information We Obtain from Third Parties

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public Sources: Such as public records, social media platforms, and other publicly available sources.
Third-Party AI Providers: Parts of the Service are integrated with third-party AI platforms (“Third-Party AI Providers”) that help generate outputs (i.e., responses) to your inputs and prompts. These Third-Party AI Providers may infer information about you and share it with us as part of their processing.
Service Providers: Parties that provide services on our behalf or help us operate the Service or our business.
Third-Party Login/Linked Services: Third-party services, such as Google or Apple, that you use to log into or otherwise link to your Service account. This data may include your username and other information made available to us based on your account settings on that third-party service.

1.3. Information Collected Automatically

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service and our communications, such as:

Device Data: Such as your operating system type and version, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, language settings, and general location information such as city, state, or geographic area.
Online Activity Data: Such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages, access times, and duration of access, and whether you have opened our emails or clicked links within them.
Communication Interaction Data: Such as your interactions with our emails or other communications (e.g., whether you open and/or forward them). We may collect this data through the use of pixel tags (also known as clear GIFs), which may be embedded in our emails.

2. Cookies and Other Tracking Technologies

Some of the automatic collection described above is facilitated by cookies and other technologies. We also utilize technologies provided by our Third-Party AI Providers to operate the chat and prompt features you can use to communicate with us and input data. These technologies may use cookies and software code.

For information about your choices with respect to the use of tracking technologies, please see Section 6, “Your Rights and Choices,” below and our Cookie Policy.

3. How We Use Your Personal Information

We do not process, disclose, or otherwise use your personal information for the development, training, or refinement of any artificial intelligence or machine learning models.

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service Delivery and Operations:
- To provide the Service.
- To transmit your inputs to our Third-Party AI Providers for processing and to receive outputs, as necessary to fulfill your requests.
- To enable security features of the Service.
- To establish and maintain your user account on the Service.
- To communicate with you about the Service, including by sending service-related announcements, updates, security alerts, and support and administrative messages.
- To provide support for the Service and to respond to your requests, questions, and feedback.
Service Personalization:
- To understand your needs and interests.
- To personalize your experience with the Service and our service-related communications.
- To remember your selections and preferences as you navigate webpages.
Service Improvement and Analytics:
- To analyze your usage of the Service and to improve the Service and the rest of our business.
- To help us understand user activity on the Service, including which pages are most and least visited.
- To develop new products and services.
Marketing and Advertising:
- Direct Marketing: We may send you direct marketing communications and may personalize these messages based on your needs and interests. For information on how to opt out, please see Section 6, “Your Rights and Choices.”
Compliance and Protection:
- To comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities.
- To protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims).
- To audit our internal processes for compliance with legal and contractual requirements or our internal policies.
- To enforce the terms and conditions that govern the Service.
- To prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
Creation of Aggregated, De-identified, and/or Anonymized Data:
- We may create aggregated, de-identified, and/or anonymized data from your personal information by removing information that makes the data identifiable to you. We may use this data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

4. How We Share and Disclose Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates: Our corporate parent, subsidiaries, and affiliates.
Service Providers: Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, IT, customer support, email delivery, marketing, and website analytics).
Third-Party AI Providers: We use Third-Party AI Providers to power certain aspects of the Service, such as operating chat features, processing user inputs/prompts, data analytics, and recommendations.
Payment Processors: Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe.
Third Parties Designated by You: We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Linked Third-Party Services: If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service.
Professional Advisors: Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
Authorities and Others: Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the “Compliance and Protection” purposes described above.
Business Transferees: We may disclose personal information in the context of an actual or prospective business transaction (e.g., an investment, financing, public offering, or the sale, transfer, or merger of all or part of our business, assets, or shares).
Other Users and the Public: At your election, user-generated content may be visible to other users of the Service and the public. We are not responsible for any such use of this information.

5. Data Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period, we consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements.

6. Your Rights and Choices

We describe the rights and choices available to all users.

Access or Update Your Information: If you have registered for an account with us, you may review and update certain account information by logging into the account.
Opt-Out of Communications: You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us.
Cookies: For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Policy.
Blocking Images: Most browsers and devices allow you to configure them to prevent images from loading.
Do Not Track: Some Internet browsers may be configured to send “Do Not Track” signals. We currently do not respond to these signals.
Declining to Provide Information: If you do not provide information we identify as required or mandatory, we may not be able to provide certain services.
Linked Third-Party Platforms: If you choose to connect to the Service through a third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it.
Delete Your Content or Close Your Account: You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

7. Other Sites and Services

The Service may contain links to websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control online services operated by third parties, and we are not responsible for their actions.

8. Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, online transmissions are not fully secure, and we accept no liability for any unauthorized circumvention of any privacy or security measures.

9. International Data Transfers

We are headquartered in Japan but may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the important information provided below.

10. Children's Privacy

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

11. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or by other appropriate means. Depending on the change, we might notify you and ask for your consent.

12. How to Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at: Contact: support@stellagent.com

13. Notice to European Users

The information in this section applies only to individuals in the European Economic Area (EEA) or the United Kingdom (collectively, “Europe”).

Controller: For the purposes of European data protection legislation (GDPR), STELLAGENT is the “controller” of the processing of your personal information covered by this Privacy Policy.
Legal Bases for Processing: We process your personal information based on legal grounds such as performance of a contract, our legitimate interests, compliance with a legal obligation, or your consent.
Your Rights: If you are in Europe, you have rights regarding your personal information, including the right to access, correct, delete, transfer, restrict processing of, object to processing of, and withdraw consent. To exercise these rights, please contact us at the address above.
Data Transfers outside Europe: Your personal information may be transferred to countries that may not be deemed to provide the same level of data protection as in Europe (such as Japan or the United States). We endeavor to ensure your personal information is protected by implementing appropriate safeguards, such as entering into Standard Contractual Clauses.