Privacy Policy

1. INTRODUCTION

StellarAlgo Corp. (the “Company”, “we“, “us“, “our“) owns and operates the StellarAlgo websites, available at all subdomains of stellaralgo.com, including all subpages (collectively, “Website”), the StellarAlgo analytics and data insights application ( “Application”), and the StellarConnect community platform (“StellarConnect” and together with Website and Application, “Services”). The following privacy policy (“Privacy Policy”) describes how we collect, store, use and distribute personal information in the provision of our Services.

Our goal is to collect, use and disclose only that personal information reasonably required to enable us to provide the particular product or service that you have requested, to respond to your inquiries or feedback, and for other purposes further described in this Privacy Policy.

2. SCOPE

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals (“Personal Information”) who engage with our personnel or use our Services. More specifically, this Privacy Policy applies to Personal information we collect about (i) visitors of our Website, (ii) StellarAlgo customers who access and use the Application and StellarConnect (“Customers”), and (iii) authorized users of our Customers who are permitted to access to the Application and StellarConnect (“Authorized Users”). Individuals under Section 2(i)-(iii) are collectively referred to as “Users”, “you”, or “your”.

This Privacy Policy does not apply to the practices of Customers and their Authorized Users, and other companies that we do not own or control, such as third-party organizations with which you choose to share Personal Information. You should review the applicable privacy policy of any company with which you do business. We do not knowingly collect or solicit Personal Information from anyone under the age of 13.

3. COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA

3.1 Application Users

In order to use certain aspects of the Application, representatives of our Customers may be required to have a valid StellarAlgo account to log in to the Application (“Account”). We may collect the following type of Personal Information to set up and provide access to the Account: name and email address. Further, we collect any other Personal Information that Customer or their Authorized Users choose to provide to us while using the Application.

3.2 Website Users

Certain functions of the Website allow you to share Personal Information with us. For example, you may provide us Personal Information when you fill out the “Contact” form on the Website. We collect any Personal Information you choose to provide to us via the Website.

3.3 StellarConnect Users

StellarConnect permit Customers and Authorized Users to share user content, which becomes available to other users of StellarConnect. Please note that sharing of Personal Information via StellarConnect is expressly prohibited by our Terms of Service. Sharing of any Personal Information (whether directly or embedded within any user content) via StellarConnect will be deemed a violation of our Terms of Service.

3.4 Prospective Customers and Business Partners

The Company also collects certain Personal Information about prospective customers, including name, company, role/position, email address(s), phone number, company address. This Personal Information is used to confirm the identity and authorization of the person requesting our services on behalf of the prospect or current customer, as well as to communicate with the company in respect of the requested Services.

3.5 Customers and End User of our Clients

In connection with its provision of the Application, StellarAlgo processes Personal Information related to end users and customers of our Customers (“End Users”) on behalf of our Customer and in accordance with contracts between StellarAlgo and the Customer.

Generally, Personal Information of End Users is processed directly from our Customers who collect this Personal information in the course of providing their services. However, in some cases, we may obtain Personal Information of End Users from other third-party databases made available to our Customer or us.

Further, StellarAlgo may process Personal Information of End Users on behalf of the relevant Customer and in accordance with the Customer’s instructions. In particular, StellarAlgo may receive email addresses of the Customer’s End Users, which the Customer may use to create marketing campaigns, including online and social media campaigns using the Customer’s online and social media accounts (incuding, but not limited to Facebook audiences, Google audiences, marketing automation lists). Any additional Personal Information processed about the End Users on behalf of our Customer in connection with such activities will be shared with StellarAlgo by the relevant Customer.

In all such instances, our Customers are the controllers of such Personal Information and StellarAlgo collects and processes such Personal Information of End Users solely on behalf of the Customer and pursuant to the Customer’s instructions. Please note that the Customer’s privacy policies (rather than this Privacy Policy) will apply to such Personal Information of End Users.

The specific types of Personal Information of End Users collected will depend on the Customer’s practices and business needs. If you are an End User, you should contact your organization directly if you have any questions regarding their privacy practices.

3.6 Third-Party Integrations

We may integrate with or rely on third-party platforms and services to provide some aspects of the Services to you (“Third-Party Integrations”). Any Personal Information submitted to us via Third-Party Integrations that we can access will be subject to this Privacy Policy. However, such Personal Information will also be subject to the terms of the applicable Third-Party Integration. Please consult the relevant third party’s privacy policy to understand how they process your Personal Information. A list of third-parties is available upon request, or from the Accoutn Manager assigned to the relevant Customer.

3.7 Employee Information

StellarAlgo collects Personal Information about prospective and current employees to administer the hiring and employment process. If you submit hiring materials to us (either directly or through a Third-Party Integration or recruiter), we collect any Personal Information in your hiring materials, such as your resume, cover letter, transcripts, or certifications. We ask you to include only information relevant to the position you’re applying for, such as your employment history and education. Please note that any Personal Information you submit through a Third-Party Integration or recruiter will be subject to the privacy practices of those entities. If you are a current StellarAlgo employee, please contact the StellarAlgo Privacy Officer per Section 12 below for more information on how your employee information may be collected, stored, used, and distributed.

4. USE OF PERSONAL INFORMATION

In addition to the purposes described above, we use Personal Information for the following purposes and in the following ways:

To authenticate and onboard Users, and to provide Services to Users.
To send Users relevant information and updates related to the Services and relevant advertising and promotional materials (where the User has subscribed to receive them);
To manage our Customer relationships, including servicing Accounts and managing billing;
To generate anonymous analytics in order to improve and customize our Services;
To support, troubleshoot, and improve the Services and to develop new StellarAlgo products, features, and services;
To investigate violations and enforce our policies and terms, and as required to meet our regulatory or legal compliance obligations; and
To monitor system performance and network capacity, test and fix systems, and develop and implement upgrades to systems.

In connection with the foregoing purposes, we may share your Personal Information with our third-party service providers which support the delivery of the Services, enable our marketing activities, and support our business operations. Further, we may share your Personal Information with our professional advisors, including lawyers, accountants, financial advisors, consultants and insurance brokers.

When we share your Personal Information with third parties, we either (i) enter into written agreements that require each such third party to provide a comparable level of protection for your Personal Information as the protection offered by StellarAlgo; or (ii) ensure that any sharing of Personal Information with a third party who will be using the Personal Information for their own purposes is conducted in compliance with applicable laws.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

5. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

StellarAlgo stores its data, including Personal Information, on servers located in different provinces within Canada and in jurisdictions outside of Canada, such as the United States, and the European Union including through the use of our third-party service providers. Data for North American Customers is stored in Canada and the United States, and data for European customers is stored in the European Union. Accordingly, please note that your Personal Information may be transferred to different provinces within Canada or to jurisdictions outside of Canada and that your Personal Information may be accessible to law enforcement and governmental agencies in Canada, the U.S. and the E.U. under lawful access regimes or court order.

6. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

6.1 Business Transfers

We may disclose your Personal Information to third parties in connection with a corporate transaction or any due diligence exercise carried out in relation to the same. For example, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law. In case of such disclosures, Personal Information disclosed shall continue to be used for the purposes permitted by this Privacy Policy by the entity acquiring the Personal Information.

6.2 With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.

6.3 Legal Reasons

We may disclose your Personal Information to third parties if we have reason to believe that disclosing this Personal Information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities, or if we believe in good faith that such disclosure is required by and in accordance with the law.

7. COOKIES

Technologies such as cookies, scripts and tags are used by us and our third party partners. These technologies are used in analyzing trends, administering the Website, tracking Users’ movements around the Website, and gathering demographic information about our User base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.

Standing alone, cookies do not identify you personally. They merely recognize your browser. Cookies come in two types: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you’ve closed your browser or turned off your computer. They include information such as a unique identifier for your browser.

StellarAlgo uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows StellarAlgo to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required in order to use the Company Services.

StellarAlgo uses persistent cookies, that only StellarAlgo can read and use, to identify the fact that you are a User and track the webpages you view and use. We are especially careful about the security and confidentiality of the information stored in persistent cookies. Users who disable their web browser’s ability to accept cookies will be able to browse our Website but may not be able to use all features of our Services.

Our third party partners also employ clear gifs, images, and scripts that help them better manage content on our Website. Please note that we do not have control over such third parties’ use of cookies.

To the extent any information collected via cookies that is available to us constitutes Personal Information, such Personal Information will be subject to this Privacy Policy.

8. SECURITY

The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

9. RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.

You can request that the Company delete your Personal Information at any time, and we will do so to the best of our ability. However, we may retain certain Personal Information as necessary to prevent fraud or future abuse, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

10. ACCESS, CORRECTION AND ACCURACY

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Send requests for information of this nature to privacy@stellaralgo.com. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another User. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date. You have the right to request a correction of Personal Information we hold about you, and we will correct your Personal Information as appropriate, provided that we may not be able to correct all relevant Personal Information (for example, where that Personal Information also pertains to another User). In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for modifications in a timely manner. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

11. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time at our sole discretion. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. We encourage you to review this Privacy Policy each time you use the Services to see if there have been any changes, as indicated by the “Last Updated” date above. We may require you to provide consent to the updated Privacy Policy before further use of the Services is permitted.

12. CONTACT US

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, contact our Privacy Officer at:

Mail: 1000, 214 11 Ave SW, Calgary, AB, Canada T2R 0K1

Email: privacy@stellaralgo.com

Last Updated: October 2, 2025