Privacy Policy

How we collect, use, and protect your personal data. Updated 14 August 2026.

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📅 Effective: 14 August 2026 · Last updated: 14 August 2026 · Version: 2.2

About This Policy

Stellar Mentoring UG ("we", "us", or "our") operates the Stellar Mentoring Platform (the "Service"). This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use the Service.

Your data is processed in accordance with the EU General Data Protection Regulation (GDPR) and other applicable laws. Our infrastructure is hosted in the United States; international transfers are protected by the safeguards described in Section 4. We never sell personal data.

Section 1

Collection and Use of Personal Data

We collect only the data necessary to support the operation of mentorship programs hosted on our platform.

Profile data you provide

  • Name
  • Portrait photo
  • Email address
  • Employer name
  • Phone number
  • Work biography

Data we collect during a mentoring program

As you take part in a mentoring program on the platform, we also process the data the program itself generates:

  • Registration & application data — the answers you give when you register for a program, any application-interview notes, and your registration status (requested, confirmed, or rejected, including any reason given).
  • Matching (tandem) data — the mentor–mentee pairing you belong to, the coordinator assigned to it, and the approvals each participant gives to the match.
  • Session data — the sessions you plan or record, including their date, time, duration, notes/description, meeting links, the comments the mentor and mentee add, and any satisfaction rating (stars) you give.
  • Activities & milestones — the tasks, learning, mentoring, on-site and reporting activities you complete, and your progress against program milestones (including completion and approval status).
  • Mentoring agreement — your acceptance and electronic signature of the mentoring agreement, where your program uses one.
  • Documents you upload — files you attach to your tandem (name, type, size, and content), together with who uploaded them and when.
Section 2

Purposes of Collection

We collect personal data for the following purposes:

  • To verify the identity of invited mentorship participants
  • To create and manage user accounts
  • To enable continuous access to mentorship features as a mentor, mentee, or administrator
  • To deliver high-quality service
  • To meet regulatory or contractual obligations
  • For other legitimate legal purposes related to the delivery of mentoring services
Section 4

Data Sharing and Transfers

Personal data may be shared only under the following conditions:

  • With selected mentoring partners (mentor/mentee) as part of the match process
  • With authorized administrators of the mentorship program
  • With third-party service providers who support the Service (under strict data processing agreements)
  • If legally required or to enforce legal rights

We do not sell personal data. The Service is operated using cloud infrastructure hosted in the United States (Amazon Web Services, N. Virginia / us-east-1 region). Regardless of where you are located, your personal data is transferred to and stored in the United States.

Where personal data is transferred out of the European Economic Area (EEA), the United Kingdom, or Switzerland, we rely on appropriate safeguards under GDPR Chapter V — the EU–U.S. Data Privacy Framework (including the UK Extension and the Swiss–U.S. framework), under which our infrastructure provider is certified, and, where required, the European Commission's Standard Contractual Clauses — so that your data receives an essentially equivalent level of protection. A copy of the applicable safeguards is available on request at privacy@stellarmentoring.com.

Our Service Providers (Sub-processors)

We use the following processors to operate the Service. Each acts on our documented instructions under a data processing agreement. This list may change as our providers evolve; the current list is available on request at privacy@stellarmentoring.com.

Provider Purpose Data categories Location
Amazon Web Services (AWS) Cloud hosting, database, authentication, file storage, transactional email (Amazon SES), and content delivery / security (CloudFront & WAF) All account, profile, and program data processed by the platform United States (us-east-1)
Cloudflare (Turnstile) Bot / abuse detection on sign-up and public forms Technical request signals; no profile data United States / European Union
Sentry (Functional Software, Inc.) Application error monitoring — loaded only with your analytics consent Technical error/diagnostic data; personal identifiers are stripped before transmission United States
Atlassian (Jira Service Management) In-app help/support widget — loaded only with your support consent Contact details and message content you provide in a support request United States / European Union
Wild Apricot (Personify, Inc.) Membership-management synchronisation, where your organization uses it Name, email, and membership record data United States / Canada
Plausible Analytics Cookieless, privacy-friendly aggregate website analytics — loaded only with your analytics consent Aggregate page metrics only; no cookies, no cross-site identifiers, no stored IP address European Union
Section 5

Data Retention

We retain personal data only as long as needed to fulfill the purposes outlined in this policy, or as legally required. Once data is no longer required, it is securely deleted or anonymised.

Section 6

Your Data Rights

As a data subject under GDPR, you have the right to:

  • Access your personal data
  • Request corrections or updates
  • Object to certain processing activities
  • Withdraw consent at any time
  • Request data deletion (which includes account removal)

To exercise your rights, email privacy@stellarmentoring.com. If your account was created through a mentoring program organizer, you may also contact them and we will coordinate as needed. For full deletion, email privacy@stellarmentoring.com with the subject line "Account Deletion Request" and include the email address tied to your account.

Section 7

Data Hosting and Security

Our Service is hosted on secure cloud servers operated by Amazon Web Services in the United States (us-east-1 region), with encrypted backups stored in separate secure data centers. We use appropriate security safeguards including encrypted storage, access control, and regular audits. No online system is fully immune to risk — we act responsibly but cannot guarantee absolute security.

Section 8

Log Data and Analytics

We may collect log data such as IP address, browser details, and pages accessed. This data is used only for platform performance monitoring and security — not for cross-site tracking or advertising. For aggregate website analytics we use Plausible, a cookieless, privacy-friendly tool that stores no cross-site identifiers and is loaded only with your analytics consent. We do not use Google Analytics.

Section 9

Cookies

Cookies and similar technologies are used strictly for managing login sessions and storing your preferences. Non-essential and third-party technologies (such as error monitoring or the in-app help widget) are loaded only after you give the matching consent through our granular consent panel, and we do not use cookies to track your behaviour across sites. See our Cookie Policy for the full category-by-category detail and to change your choices at any time.

Section 10

Children's Privacy

Our platform is intended for users 18 years and older. We do not knowingly collect data from minors. If you believe a minor has submitted data, please contact us immediately.

Section 11

Policy Updates

We may revise this Privacy Policy from time to time. Material changes will be communicated — continued use of the Service after changes implies acceptance.

Section 12

Data Controller & Contact

Stellar Mentoring UG (haftungsbeschränkt)
Neumarkter Strasse 6, 81673 Munich, Germany

For any questions about this Privacy Policy: contact@stellarmentoring.com