Stellic, Inc., a Delaware corporation (“Stellic,” “we,” “our,” “us”) thanks you for visiting www.stellic.com, our Internet website (“Site”), or for being a vendor or end-user of our services. Data privacy is fundamental to Stellic’s values as we seek to empower students and their educational journeys. As such, we are deeply committed to maintaining the privacy and security of personal information we collect or which is provided to us directly by our partner institutions. We value your trust in sharing your personal information with us and are dedicated to protecting your privacy, as further described in this Privacy Policy.

Updates to this Privacy Policy

From time to time, this Privacy Policy may be updated to reflect changes to our products and services, the way we operate, or to meet new legal and regulatory requirements. You will find the latest version of this Privacy Policy at https://stellic.com/privacy-policy.

Scope of this Privacy Policy

This Privacy Policy governs the information collected through stellic.com and all services we provide directly to you, including the services through your institutional Stellic site. It applies to personally identifiable information for any students and end users. This Privacy Policy does not relate to anonymized, aggregated, or de-identified data. Whether you are accessing our public website or using one of our products via a software application, this Privacy Policy governs our use of personal information for all our products and services that we provide directly to you. When we collect personal information directly from you in connection with our interactions with you, we are considered a data controller.

Connection to Your Institution’s Privacy Policies

If you are an employee, student, or other end user of our partner institution, and we are collecting your personal information in connection with the products and services we provide to our partner institutions, we are considered to be a data processor. In this case, our use of your personal information is governed by the privacy policy of the institution from which we have received, or on whose behalf we collected or use, your personal information (“your institution”). Our Privacy Policy does not supersede the terms of any agreements between us and your institution, nor does it affect the terms of any agreements between you and your institution, including any prior consent you have provided concerning the use and distribution of your personal information.

Note: Stellic takes privacy extremely seriously, and strictly adheres to the Family Education Rights Protection Act of 1974 (“FERPA”). Stellic works with Institution(s) to ensure compliance with FERPA and applicable privacy laws, and one of the most important ways in which it ensures compliance with FERPA is by never storing any student personally identifiable information or student academic records in unencrypted form. 

Information That We Collect

The type of personal information we collect about you depends upon your relationship with us. Unless otherwise identified, information in our Privacy Policy applies to all our activities.

Website Visitors

Stellic maintains a website generally accessible by the public. Our website provides general information about our company and its products and services. Our website also may contain information concerning employment opportunities and provide the opportunity for individuals to submit applications for open roles.

We collect personal information in the following manner:

Directly from You

We collect certain personal information directly from you, including your name, email address, institution and role, phone number when you submit a request for us to contact you about Stellic’s services. 

Indirectly from You

We collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services for analytics purposes (including the pages you visit and how you access and use our services using cookies and third-party analytics tools (e.g., log files, event data, GPS data, clear gifs and scripts). This information includes information about the device(s) you use to access the service including unique device identifiers, IP address, operating system, browser, internet service provider, referring/exit pages, clickstream data and cookies. Depending on your device settings, we may also collect information about your geographical location. We may use third-party analytics services, such as Google Analytics and Adobe Analytics to collect this information. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of Stellic’s service or help administer Stellic’s services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/. To learn more about Adobe Analytics, please visit https://www.adobe.com/privacy.html.

Third Party Integrations, Links, and Features

You may connect third party integrations to your Stellic account(s) (e.g., Google SSO), which may ask for certain permissions to send information to your Stellic.com account. Stellic’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy. These third parties operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we suggest you review. To the extent any linked online service or third-party feature is not owned or controlled by Stellic, we are not responsible for these third parties’ information practices.

End User of an Institution That Uses Our Products

Your institution decides how your personal information is used. We provide nearly all of our products and services to end users of an institution as a data processor on behalf of our partner institutions (e.g., colleges, universities, and school districts). This means that the main responsibility for data privacy compliance lies with your institution as a data controller. It also means that your institution’s privacy policy governs the use of your personal information (rather than ours). Your institution determines what information we collect through our products and services and how it is used, and we process your information according to your institution’s explicit instructions.

The following section is primarily for informational purposes and describes how your information is generally collected when we provide products and services to you on behalf of a partner institution. How your personal information is used depends on your institution, so you should read your institution’s privacy policy carefully.

We collect personal information in the following manner:

Received Directly from Your Institution

Depending on the products or services that Stellic provides to your institution, we may collect the following types of identifiable information:

• Your name, email address, student ID, account credentials, course enrollment data, grades, and directory information.
• Application, enrollment and financial aid information.
• Other information directly from your institution or other third parties related to your enrollment or application status at your institution, or other institutions, or related to your success at your institution.

Received Directly from You

Depending on the Stellic products and services you use or your institution uses, we may collect the following types of identifiable information:

• Content that you enter directly into our products, including educational plans, results of surveys or polls, notes and summaries, academic and career interests.
• Workflow submissions and appointment requests submitted to advisors and other users at your Institution.

Indirectly from You

We collect information on your use of our products and services. Depending on the products and services you access or use, we may collect the following data categories indirectly from you:

• We collect information about the pages you visit and how you access and use our products using cookies and third-party analytics tools. This information includes information about the device(s) you use to access the websites including unique device identifiers, IP address, operating system, browser and cookies.
• Depending on your device settings, we may also collect information about your geographical location.

How We Use and Disclose the Information That We Collect

We may share the categories of personal information we obtain about you (as described above) with the categories of third parties listed in this section. Stellic collects, retains, processes, uses, and transfers your personal information for the following purposes and to the following third parties:

To Provide our Services

We use personal information that we collect in order to provide our services, including the Stellic Research Forums service; verify the identity of users; communicate with users of our services; provide information about briefings, events, professional development sessions, and research collaboration opportunities; manage relationships with users of our services; provide support and troubleshooting services; and improve our services. We process personal information for these purposes because we have a legitimate interest in doing so.

Service Providers

We use service providers to help us provide our products and services to our partner institutions and you or to perform work on our behalf. Where this requires access to personal information, we are responsible for the data privacy practices of the service providers. Our service providers are not allowed to use personal information they access or receive from us for any other purposes than as needed to carry out their work for us. Examples of our service providers include data storage providers, analytics platform providers, email and messaging services.

Analytics and Marketing

We use personal information that we collect in order to analyze use of our services; enhance the services; develop new products or services; and to perform market, trend, and statistical research and analysis. We analyze usage information for marketing purposes and for trends about our visitors’ demographics and use of our websites and services. This analysis is necessary to further our legitimate interest in understanding our users and how they interact with us and our website, improving our website and communicating with you. For more information about our use of third-party analytics tools, please see Section 3 of this Privacy Policy. You can learn more about our use of cookies in our Cookie Notice.

Record Keeping

We use personal information that we collect for our internal record keeping purposes, and for accounting, audit and other internal functions. 

On Behalf of Your Institution

For end users of institutions that use our products, we use your information on behalf of and under the instruction of your institution, which is the data controller. We share the information that we collect in accordance with our agreement with your institution. Your institution determines how your information is used.

Product Enhancements and Research

To the extent permitted by applicable law or by our agreement with your institution, we may also use:

• Your personal information to evaluate and improve our products and services to develop new products and services;
• To tailor your experience on our websites; and/or
• De-identified information for research or business purposes like providing similarly-situated institutions a benchmarking data report on completion rates or class size.

Partner Institution Engagement and Marketing

Stellic uses your information for partner institution engagement and marketing purposes in limited circumstances, including:

• To manage the partner institution relationship, including for invoicing, notification of product updates and maintenance, and similar purposes.
• To promote Stellic’s products and services.

We do not disclose personal information about students that we collect through the provision of our educational products and services to third parties for behavioral targeting of advertisements to students.

Our marketing emails will include a link so that you can opt-out of receiving marketing communications from us. You can do this by clicking on the “Unsubscribe” link in the email footer.

Other Types of Uses and Disclosures

We will also use and share your information to the extent required or appropriate in the following circumstances:

• To industry associations and other businesses with which Stellic co-hosts events, if you chose to participate.
• To comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes.
• To protect and defend the rights, property, or safety of us, our partner institutions, or third parties, including enforcing contracts or policies or in connection with investigating and preventing fraud.
• To process transactions when you use our services to make a deposit to one of our partner institutions, we will share your payment and transaction data with third party payment processors.
• To carry out operational tasks for legitimate business purposes. 
• In the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Cookies and Other Usage Information

Like many websites, we use “cookie” technology to collect additional website usage data and to improve our services, but we do not require cookies to use the Site. A cookie is a small data file that is transferred to your computer’s hard disk. Stellic may use both session cookies and persistent cookies to better understand how you interact with our services, to monitor aggregate usage by our users and web traffic routing on our services, and to improve our services. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

We, as well as our affiliate program partners and other third parties, may also employ a software technology called clear gifs, or web beacons to help us better manage content on our Services, and improve the quality and experience of our Services. The same is applicable to any embedded script we may use in addition to flash and HTML5. Various browsers may offer tools for removing certain usage information trackers such as HTML5 LSOs. 

We may also work with analytics service providers and other vendors to provide us with information regarding traffic on the services.

Children’s Privacy

Stellic’s products and services are not intended for children under the age of 13, and we do not knowingly collect any information from children. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information upon request. Please contact us at privacy@stellic.com if you believe we have inadvertently collected personal information from a child under 13 without proper consent.

Your Rights and Choices

If you are a California resident, for more information about your privacy rights, please see the Stellic Privacy Notice for California Residents, or the Privacy Notice for California Residents available on our service-specific privacy notices linked above.

If you are a resident of Colorado, Connecticut, Utah or Virginia, you may have the right to request:

• that we provide you with access to the personal information collected about you;
• that we provide a copy of your personal information to you in a portable format;
• that we correct or update your personal information that is inaccurate, incomplete or outdated and that you are not otherwise able to update via your profile;
• that we delete your personal information.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. If you choose to exercise any of these rights, you have the right to not receive discriminatory treatment by us.

Security

We employ a variety of physical, administrative, and technological safeguards designed to protect personal information against loss, misuse, and unauthorized access or disclosure. Stellic has an applicable security policy provided to each partner institution upon request.

Specific Regional & Country Information

European Union

Stellic is not established in the European Union (“EU”) or the United Kingdom (“UK”); however, in certain limited circumstances, we may be subject to the General Data Protection Regulation or the Data Protection Act of 2018 (collectively, “GDPR”).

How We Transfer the Personal Information That We Collect

We may transfer the personal information that we collect about you to recipients in countries other than the country in which the personal data originally was collected, as described above. Those countries may not have the same data protection laws as the country in which you initially provided the personal information. When we transfer your personal data to recipients in other countries (such as the U.S.), we will protect that personal data as described in this Notice.

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA and the UK. In all such cases, we will only transfer your personal information if:

• The country to which the personal data will be transferred has been granted a European Commission adequacy decision or has been recognized as adequate under UK law;
• We have put in place appropriate safeguards in respect of the transfer, for example the EU or UK Standard Contractual Clauses; or
• In certain limited circumstances, one or more of the derogations for data transfers provided by applicable law applies.

You may request a copy of the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in the ‘Contact Us’ section below.

California

California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of Personally Identifiable Information to third parties for their direct marketing purposes. We do not provide your Personally Identifiable Information to any third parties for direct marketing purposes as defined in California Civil Code Section § 1798.83. Please contact us support@name-coach.com for any questions regarding your Personal Information.

AB 1584 is a California law that defines student and educational agencies rights with regard to pupil records. Stellic maintains compliance with AB 1584 as described in this Privacy Policy and as described in, as applicable, a MSA with California Institution(s).

California Consumer Privacy Act (“CCPA”)

As set forth above, we collect the following categories of information: identifiers (such as your name, student identifier,, and email address), other personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (such as your name and contact information), internet or other similar network activity, geolocation data, and inferences drawn from the collected personal information. This information is collected directly from you when you provide it to us (for example when you submit a form requesting more information, or when you enter into a contract with us) or automatically as you navigate through the Site. We use this information for one or more legitimate business purposes, including to provide our Services, improve our Services, and offer information about our Services to you. 

If you are a resident of California, you have other rights under the CCPA. Any personal data that we collect is based upon your consent as detailed in this Privacy Statement. You have many choices concerning the collection, use, and sharing of your data, including the following rights:

• Right of Access: You can access your collected personal information by contacting us at support@stellic.com.
• Right to Correct, Update, or Delete: You can correct, update or request deletion of your personal information by contacting us at support@stellic.com. We can’t make changes to or delete your information in some situations where it is necessary for us to maintain your information, for example if we need the information to comply with applicable law.
• Right to Request Disclosure of Information Collected: Please contact us at support@stellic.com to request further information about the categories of personal information we have collected about you, where we collected your personal information, and for what purpose we use your personal information.
• Right to Disclosure of Information Sold and Right to Opt-Out: You have the right to know what information of yours we have sold, and you have the right to opt-out of any sale of your information. We do not sell any of your information. If you have any questions about these rights, please contact us at support@stellic.com.
• Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the CCPA.

When you contact us regarding any of your rights under the CCPA, we will verify your identity before we provide any information. If you have any questions or comments about your rights under the CCPA, please contact us at support@stellic.com.

Data Breach Notification

Stellic maintains an information security plan to protect the security, confidentiality, and integrity of personally identifiable information of users and Institutions. As part of its information security plan, Stellic will promptly notify affected individuals and the Institution of a data security breach. Written notification will be sent by first-class mail to the address on record for the individual or Institution. Written notification will contain:

• A brief description of what occurred with respect to the breach, including, to the extent known, the date of the breach and the date on which the breach was discovered;
• A description of the types of personally identifiable information that were involved in the breach;
• A description of the steps the affected individual or Institution should take to protect against potential harm from the breach;
• A description of what Stellic is doing to investigate and mitigate the breach and to prevent future breaches; and
• Contact procedures for individuals to ask questions or learn additional information, which will include a toll-free telephone number, an email address, website or postal address.

If Stellic determines individuals or an Institution should be notified urgently of a breach because of possible imminent misuse of unsecured personally identifiable information, Stellic may, in addition to providing notice as outlined above, contact the individual or Institution by telephone or other means, as appropriate.

Contact Us

If you have any questions or concerns about our Privacy Policy or data privacy practices, contact us at:

Stellic, Inc.

204 E 2nd Ave #603
San Mateo, CA 94401

Email: support@stellic.com