Privacy Policy

Effective Date: [2026-02-11]

Welcome to Stella. This Privacy Policy describes how Stella (“we,” “us,” or “our”) collects, uses, processes, and shares your information in connection with the Stella mobile application (the “App”).

At Stella, your privacy is our priority. We are committed to protecting your personal data and ensuring transparency in our data practices. We process your personal information only to provide and improve our Services, and only after obtaining your explicit consent in accordance with the terms outlined below.

1. Scope of This Policy

This Privacy Policy explains:

l The types of personal information we collect and when we collect it.

l How and why we use your information.

l The legal basis for processing your data.

l The conditions under which we may share your data with third parties.

l Your rights regarding your personal information and how to exercise them.

l The measures we take to ensure your data remains secure.

2. Acceptance and Updates

By downloading, registering for, or using the App, you acknowledge that you have read and understood this Privacy Policy. This document is an integral part of our Terms of Use.

We may update this Privacy Policy periodically to reflect changes in our practices or for legal, regulatory, or operational reasons. We will notify you of any material changes by updating the "Effective Date" at the top of this policy or through in-app notifications.

 Stella will not use your videos or photos for any purpose other than providing Stella’s AI conversation and video creation services. Stella will never use your videos or photos for face recognition, as Stella does not implement face recognition technology or any other technology that processes biometric data for unique identification or authentication purposes.

Uploaded content may be collected and displayed in your library to allow reuse and facilitate service functionality. The content may be stored on your device and in the cloud for a limited period and will only be visible to you during your use of the service. By submitting content for processing, you explicitly consent to its collection and storage as described above. We do not use this content for face recognition or identity verification.

3. Information We Collect

We collect information to provide, improve, and protect our Services. The data we collect falls into the following categories:

A. Information You Provide Directly

When you interact with our Services, you may provide us with content directly:

l Photos and Videos: We collect the photos and videos you capture within the App or upload from your device's library. Access to your camera and photo library is required to provide these features. We only access specific files you select or capture.

l Facial Features: To provide our AI-driven features (such as face-swapping), we analyze facial points and features within your uploaded photos.

l Text Prompts and Inputs: When you interact with our AI-powered features, we collect the text prompts, instructions, and queries you provide to process and generate the requested content.

Note: This analysis is used solely for the technical execution of the App's features. We do not use this data to identify individual users, nor do we collect "biometric identifiers" or "biometric information" as defined by applicable privacy laws.

B. Usage and Device Information

When you access our Services, we automatically collect information about your interaction with the App and the device you use:

l Activity Data: Information regarding your interactions with the App, such as features used, pages viewed, and session duration.

l Device Identifiers: We may collect device-specific information including your IP address, operating system, hardware model, browser type, and language settings.

l Advertising & Tracking IDs: Subject to your "Allow Tracking" consent, we may collect identifiers such as IDFA (Identifier for Advertisers) to help us understand traffic sources and measure marketing effectiveness.

l Network & Performance: Details about your wireless or mobile network, time zone, and battery level to ensure optimal App performance.

C. Cookies and Local Storage

Like many mobile applications and online services, we use cookies and similar technologies (such as pixels, web beacons, and local storage) to enhance your experience.

l Authentication: We use session cookies primarily for authentication purposes. These cookies are temporary and expire once you close the App.

l Consent: Where required by law, we will obtain your explicit consent before placing non-essential cookies or tracking technologies.

l Functionality: Local storage helps us remember your preferences and provide a seamless user experience across sessions.

4. How We Use Your Information

A. Purpose of Processing

Stella uses your photos, videos, and facial feature data (collectively, "User Content") exclusively to provide and maintain the face-swapping functionality and other creative features of the App.

B. Prohibition on Face Recognition and Identification

We are committed to your privacy. Stella does not use your User Content for face recognition, biometric identification, or authentication. Specifically:

l We do not utilize technologies designed to identify a unique individual.

l We do not use your data to create a biometric profile of you.

l Your data is processed solely to apply visual effects and filters at your request.

C. Storage and Display of Uploaded Content

To provide a seamless user experience, your Uploaded Content is processed as follows:

l Storage: Content is stored locally on your device and temporarily on our secure cloud servers to enable the Services. This allows you to access your library for repeated use without re-uploading files.

l Access: Uploaded Content is displayed exclusively to you within the App. We do not share this content publicly or with unauthorized third parties.

l Consent: By submitting content for processing (e.g., clicking "Swap"), you provide your express consent for the collection and temporary storage of that content as described in this Policy.

D. Changes to Processing Purposes

Should we intend to use your personal information for any purpose not disclosed in this Privacy Policy, we will provide you with prior notice. Where required by applicable law (such as GDPR or CCPA/CPRA), we will obtain your explicit, opt-in consent before any such new processing begins.

5. How We Share Information

A. No Sale of Personal Data

We do not sell, rent, or trade your personal information to third parties. Your data is never treated as a commodity. We only share information when it is strictly necessary to provide our Services or perform legitimate business functions as described in this Policy.

B. Protection of Facial Data and AI Ethics

We maintain strict controls over your most sensitive content:

l No Third-Party Sharing: We do not share or disclose your facial feature data, photos, or videos to any third party outside of Stella and its essential service providers (such as secure cloud storage).

l No AI Training: We do not use your personal data, photos, or facial features to train, improve, or develop separate artificial intelligence models or third-party products. Your content is used solely to generate the output you request within the App.

C. Business Transfers

In the event that Stella is involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred as part of that transaction. In such cases, we will:

l Notify you before your personal information is transferred and becomes subject to a different privacy policy.

l Require the successor entity to maintain protections at least as stringent as those established in this Privacy Policy.

D. Legal and Regulatory Compliance

We may disclose your information only if we have a good-faith belief that such disclosure is necessary to:

l Comply with applicable laws, regulations, or legal processes.

l Protect the safety, rights, or property of our users, the public, or Stella.

l Detect, prevent, or otherwise address fraud or security issues.

6. How We Store Information

Stella will retain your data only for the minimum period necessary to achieve the purposes for which the data was collected and processed. In furtherance of this principle:

l Your photos and videos are stored on Stella’s servers exclusively during your active editing session. Upon completion of your editing session, this data will be immediately and permanently erased from our servers. At all other times, any photos and videos used within the Stella app are stored locally on your mobile device. You may remove this local data at any time by either deleting the applicable files directly from your device’s file system or uninstalling the Stella app.

l Your facial data is deleted from your device immediately after the completion of its intended use, in order to protect your privacy.

l Anonymous, aggregated, or de-identified data may be retained for as long as necessary to fulfill the objectives set forth in this Privacy Policy.

Data Security

Stella processes your data using computer systems and other IT-enabled tools. We maintain robust technical and organizational security measures designed to ensure the confidentiality, integrity, and availability of your information. These measures are implemented to protect against unauthorized or unlawful processing, as well as the accidental loss, destruction, or damage of data.

For example, Stella engages only vetted third-party contractors that may access your data, as specified in Section 4 of this Privacy Policy. All such contractors are required to enter into legally binding data processing agreements with us. We also provide ongoing guidance and training to our personnel to ensure that they process your data securely and in compliance with our internal data protection policies and procedures.

7. Your Rights Regarding Your Personal Information

You have the right to access your personal data processed by the Stella app and the right to data portability.

This means you may request Stella to disclose what personal data of yours we process. You may also seek clarifications regarding the details outlined in this Privacy Policy, including: the purposes of data collection and processing; the retention period of your data; and the third parties that have access to your data. Additionally, you have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format. Where processing is based on your consent or the performance of a contract, and is carried out by automated means, you may also transmit this data to another data controller directly.

You have the right to request rectification of your personal data.

This means you may require Stella to correct any inaccurate personal data pertaining to you. You may also request the completion of any incomplete personal data in your records.

You have the right to request erasure of your personal data (also known as the "right to be forgotten").

You may submit a request for erasure if: the processing of your personal data is no longer necessary to fulfill the original purposes for which it was collected; or there are no longer any valid legal grounds to support the continued processing of your data.

You have the right to request restriction of processing of your personal data.

Under certain circumstances prescribed by applicable law, you may request Stella to restrict the processing of your personal data. Examples include:

l You contest the accuracy of your personal data (in which case processing may be restricted until we verify the data’s accuracy);

l Processing is unlawful, but you oppose erasure and request restriction instead;

l We no longer need the personal data for processing purposes, but you require it to establish, exercise, or defend legal claims;

l You have objected to processing pending the verification of whether our legitimate grounds override your interests, rights, and freedoms.

You have the right to withdraw your consent at any time.

You may withdraw your consent to the collection and processing of your personal data by Stella at any time by contacting us. Withdrawal of consent shall not affect the lawfulness of any processing conducted prior to the withdrawal. Upon receipt of your withdrawal request, Stella will act on it in a timely manner and cease further processing of your personal data, unless required to continue processing by applicable law.

You have the right to object to the processing of your personal data.

Under certain circumstances prescribed by applicable law, you may object to the processing of your personal data by Stella. Specifically, you may object if:

1. Processing is related to the performance of a task carried out in the public interest or in the exercise of official authority vested in Stella;

2. Processing is based on Stella’s or a third party’s legitimate interests, and you believe your fundamental interests, rights, or freedoms override those legitimate interests.

If you submit a valid objection to processing, Stella will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary to establish, exercise, or defend legal claims.

Right to object to direct marketing (no justification required)

Please note that if your personal data is processed for direct marketing purposes, you have the unconditional right to object to such processing at any time, without providing any justification. We will immediately cease processing your personal data for direct marketing purposes upon receipt of your objection. For details on whether Stella processes your data for direct marketing, please refer to the relevant sections of this Privacy Policy.

8.Safety and Objectionable Content Policy (UGC)

A. Prohibited Objectionable Content

To ensure a safe and positive experience within the Apple ecosystem, [App Name] maintains a zero-tolerance policy toward objectionable content. You are strictly prohibited from using our AI tools to generate, upload, or distribute:

Sexually Explicit Content: Including, but not limited to, pornography, nudity, or graphic depictions of sexual acts.

Suggestive or Sensational Content: Content intended to be sexually provocative or featuring "NSFW" themes.

Non-Consensual Imagery (Deepfakes): The creation of sexually explicit or defamatory content involving real persons without their express consent.

Protection of Minors: Any content that exploits, sexualizes, or endangers minors. Such violations will result in an immediate permanent ban and reporting to relevant authorities.

Violence and Harassment: Content that promotes extreme violence, self-harm, animal cruelty, or hate speech targeting individuals or groups.

B. AI Safety Safeguards and Moderation

In compliance with Apple’s safety requirements for AI-driven platforms, we implement the following proactive measures:

Automated Filtering: We employ sophisticated AI-based safety filters to intercept prohibited text prompts and monitor generated video outputs for inappropriate visual patterns.

Manual Review: In limited circumstances—such as when required by applicable law, to investigate reported complaints, or to prevent severe fraud and platform abuse—flagged content may be subjected to manual review by authorized personnel bound by strict confidentiality obligations.

C. Enforcement and Termination of Access

Any user found to be in violation of this Safety Policy will face immediate enforcement actions:

Content Removal: All infringing content will be removed without notice.

Account Termination: We reserve the right to permanently terminate the accounts of users who attempt to generate or distribute prohibited material.

9. Payment Information

The handling of your personal information in connection with billing, payment processing, and in-app purchases is solely the responsibility of our trusted e-commerce provider, Apple. Apple maintains industry-leading security measures to safeguard the confidentiality and integrity of your payment details. The processing of such information forms part of the contractual arrangements governing your use of the Stella app.

Please note that Stella does not access, store, or process any of your credit or debit card information at any point during your in-app purchase transactions.

Rules, terms, and policies applicable to in-app purchases are available for review directly within the App Store and are governed by Apple’s terms of service.

In addition to Image Data, Stella and our authorized third-party partners may use cookies, Software Development Kits (SDKs), and other similar tracking technologies to automatically collect the Personal Data described in this Privacy Policy.

10. Third-Party Account Login

A. Third-Party Account Login Procedures

When you log in to Stella using a third-party account (e.g., Meta, Google, or Apple), we will request access to basic account information from the respective platform, including your username, email address, and public profile details. To complete the login authentication process, we may also share your unique app ID, access token, and referral URL with the corresponding third-party platform.

You retain full control over your data: you may revoke our access permissions at any time by adjusting the settings within your third-party account, which will immediately terminate any further sharing of information between that platform and Stella.

B. Advertising and Analytics Practices

We may combine the information we collect directly from you with your interaction data on our platform and data from authorized third-party scenarios (e.g., browsing history, purchase behavior) to analyze your interests and preferences. This data combination is solely for the purpose of delivering personalized, relevant advertisements, optimizing ad recommendation algorithms, and evaluating ad performance effectiveness.

No data processed for advertising and analytics purposes will be used to identify you personally without your explicit consent, where required by applicable law.

11. Children’s Privacy

Protecting the privacy of children is a top priority for Stella.

A. General Age Restriction

Stella’s services are only available to individuals aged 13 years or older. Any access to or use of our services by persons under the age of 13 is strictly prohibited and constitutes a violation of our Terms of Service and this Privacy Policy.

If you are between the ages of 13 and 17, you must obtain the express consent of your parent or legal guardian before providing any personal information to Stella or using our services. We reserve the right to request reasonable documentation verifying such parental/guardian consent. You are required to provide the requested proof within three (3) business days of our request. Failure to respond or provide valid proof of consent may result in the termination of your access to Stella’s services.

B. Age Restriction for EU Residents

Pursuant to the requirements of the EU General Data Protection Regulation (GDPR), individuals residing in the European Union must be at least 16 years old to use Stella’s services without parental/guardian consent.

Use of our services by EU residents under the age of 16 is prohibited unless the prior express consent of a parent or legal guardian has been obtained, in accordance with the requirements set forth above.

C. Accidental Collection of Children’s Personal Data

If Stella becomes aware that it has inadvertently collected personal data from a child under the age of 13 (or under the age of 16 for EU residents), or discovers content pertaining to such a child, we will promptly and permanently delete the relevant information from our systems.

12. Changes to Our Privacy Policy

Stella may update this Privacy Policy from time to time. Such updates will be made when necessary to comply with applicable laws, regulations, or changes to the actual operation of our Services. We recommend that you review this Privacy Policy periodically to stay informed of any modifications.

Following any amendment to this Privacy Policy, we will provide prominent notification of the changes to you. This notification may be displayed directly within the Stella app when you access or use our Services, or communicated via other reasonable means as permitted by applicable law.

If you continue to use our Services within one week of receiving the change notification, your continued use will be deemed acceptance of the updated Privacy Policy. However, if applicable law requires Stella to obtain your explicit consent for the amendments—for example, when the changes involve material adjustments to the nature of your personal data processing or the purposes of such processing—we will seek your explicit consent before the updated policy takes effect.

13. Contacts

We hope this Privacy Policy helps you understand how Stella handles your personal information. Stella is committed to taking all reasonable and necessary measures to protect the security and confidentiality of your personal data.

If you have any questions, concerns, or inquiries regarding this Privacy Policy, or our data processing practices in connection with the Services, please contact us at [email protected].