Privacy Policy
STELLA / STELLA STARPASS — Navun Pty Ltd
- OVERVIEW
- We understand and respect your privacy.
- This Privacy Policy describes how your personal information is collected, used, stored and shared when you engage with, sign up for, or make a purchase from Stella Mgmt, STELLA STARPASS (Australia), each operated by Navun Pty Ltd ("we" or "our") websites and any related mobile applications (collectively, the "Site") as well as any information collected or held by Navun Pty Ltd or any of its subsidiaries.
- We will collect, use, store and share your personal information in accordance with applicable law.
- If you would like to receive a copy of this Privacy Policy in a particular form, please contact us here and this will be provided.
- PERSONAL INFORMATION WE COLLECT AND HOLD
- When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We may also collect location data, including the location data of your mobile device, if you have enabled the collection of such data from your device. We refer to this automatically collected information as ("Device Information").
- We collect Device Information using the following technologies:
- "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org or click here to view our Cookie Policy.
- "Log files" track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages and date/time stamps.
- "Web beacons", "tags" and "pixels" are electronic files used to record information about how you browse the Site.
- Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including identifiers such as your name, billing address, shipping address, email address, and phone number and commercial and financial information such as payment information (including credit card numbers) and order history. We refer to this information as ("Order Information").
- Finally, when we engage with you through the Site or otherwise, we may collect certain information from you that is reasonably necessary for our business functions, including identifiers such as your name, address, email address, and phone number and commercial and financial information such as payment information and order history. We refer to this information as ("Other Information").
- When we talk about ("Personal Information") in this Privacy Policy, we are talking both about Device Information, Order Information and Other Information. Personal Information is any information which relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
- In the past 12 months we may have collected Device Information and Order Information from you using the technologies and sources identified above if you have visited our Site or placed an order with us.
- Once collected, this information may be held by Squarespace, third party logistics providers and our internal IT framework.
- HOW DO WE USE YOUR PERSONAL INFORMATION?
- We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping and providing you with invoices and/or order confirmations).
- Additionally, we use this Order Information to: communicate with you; screen our orders for potential risk or fraud; and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
- We use the Device Information that we collect (in particular, your IP address) to help us screen for potential risk and fraud, and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
- We may use the Other Information in our interactions with you, including if we engage you as an independent contractor.
- WHAT LEGAL BASIS DO WE USE TO PROCESS PERSONAL INFORMATION?
- Depending on the nature and purposes of processing being carried out, our basis for processing may include: pursuing our legitimate interest or those of a third party, complying with legal obligations or performance of a contract.
- Except for residents of Canada, we generally do not rely on consent as a legal basis for processing your Personal Information, although we will obtain your consent before sending third party direct marketing communications to you, or where your consent is otherwise required under applicable law. You have the right to withdraw your consent at any time by contacting us.
- We use AI-assisted tools to support our processing activities (see the section on Use of Artificial Intelligence below). We do not use your Personal Information for solely automated decision-making that produces legal or similarly significant effects on you without human involvement.
- USE OF ARTIFICIAL INTELLIGENCE
- We use artificial intelligence ("AI") tools, agents and automated systems to assist with our business functions, including drafting and responding to communications with clients, talent and other third parties, scheduling, generating documents, and processing information you provide to us.
- AI outputs may contain errors or inaccuracies and should not be relied upon as professional, legal, financial or other specialist advice. Material decisions and binding agreements remain subject to human review and written confirmation by an authorised representative of Stella Management.
- Right to human interaction. You may request that your communications with us be handled solely by a human representative. To opt out of AI-assisted communication, contact us here with the subject line "Human Contact Request." We will action such requests within a reasonable timeframe for non-automated correspondence. Certain system-generated messages (such as transactional emails and booking confirmations) may remain automated.
- Personal Information processed by our AI systems is handled in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and this Privacy Policy.
- We may modify, expand or discontinue our use of AI tools at any time.
- SHARING YOUR PERSONAL INFORMATION
- We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Squarespace to power our online store – you can read more about how Squarespace uses your Personal Information here. We also use Google Analytics to help us understand how our customers use the Site – you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.
- We may also disclose your Personal Information to third parties as permitted or required by applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
- Finally, we may also share your Personal Information with other members of our group of companies and with third parties in connection with investments in, or the sale of, our business or assets.
- We do not sell your Personal Information.
- CREDIT REPORTING
- Where we offer you deferred payment of fees over a period of seven (7) days or more (including any payment plan, instalment arrangement, or subscription — including in connection with STELLA STARPASS), we are a "credit provider" within the meaning of section 6G of the Privacy Act 1988 (Cth), and Part IIIA of that Act applies to credit information we hold about you.
- Credit reporting bodies we may deal with:
- Equifax Australia Information Services and Solutions Pty Limited (ABN 26 000 602 862) — equifax.com.au
- illion Australia Pty Ltd (ABN 95 006 399 677) — illion.com.au
- Experian Australia Credit Services Pty Ltd (ABN 70 142 762 175) — experian.com.au
- What we may disclose to a credit reporting body: identification information; the type and amount of credit provided; account open and close dates; payments overdue for at least 60 days where the overdue amount is $150 or more (subject to a section 6Q notice and a separate section 21D notice having been issued at least 30 days apart, with at least 14 days having elapsed since the section 21D notice); new arrangement information; payments made to clear default information; serious credit infringements; and any other information permitted under Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code 2024.
- What we may collect from a credit reporting body: credit reports, identification information, default information, repayment history information and other credit information about you, for the purposes of assessing any application for a payment plan or other credit arrangement, managing your account, and collecting overdue payments.
- Your rights. You may:
- access the credit information we hold about you;
- request correction of credit information that is inaccurate, out-of-date, incomplete, irrelevant or misleading;
- make a complaint to us about a failure to comply with Part IIIA of the Privacy Act or the Privacy (Credit Reporting) Code 2024;
- request that a credit reporting body not use your credit reporting information for the purposes of pre-screening of direct marketing;
- request that a credit reporting body not use or disclose your credit reporting information if you reasonably believe you have been, or are likely to be, a victim of fraud (including identity fraud);
- request financial hardship assistance under Division 3 of Part IIIA of the Privacy Act.
- How to exercise these rights or make a complaint. Please contact us here or write to our Privacy Compliance Officer (details below). We will acknowledge your request within 7 days and respond substantively within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at oaic.gov.au.
- Credit Reporting Policy. Full details of how we manage credit information — including how we handle access, correction and complaint requests, our likely overseas disclosures, and whether we participate in comprehensive credit reporting — are set out in our Credit Reporting Policy.
- PERSONAL INFORMATION OF THIRD PARTIES
- To the extent that you provide us with Personal Information of third parties, you agree and acknowledge that you have informed them of, and they have agreed to, our use, collection and disclosure of their Personal Information as set out in this Privacy Policy.
- DO WE TRANSFER PERSONAL INFORMATION INTERNATIONALLY?
- The sharing of your Personal Information described above may involve transferring your Personal Information outside of your home country.
- If you are dealing with us within the European Economic Area (the "EEA"), you should be aware that this may include transfers to countries outside the EEA, including the UK and Guernsey. Some of these countries do not have similarly strict data privacy laws.
- If you are dealing with us from Australia, you should be aware that the sharing of your Personal Information described above may involve transferring your data to the following countries: New Zealand, European Union, United Kingdom, Canada and the United States.
- We will ensure that any such transfers are carried out in compliance with applicable law.
- DIRECT MARKETING
- We will only use your Personal Information for direct marketing purposes if you have provided your information to us for that purpose or if you have otherwise consented to us using your information for direct marketing.
- If you agree to receive direct marketing communications from us, we may contact you from time to time (such as by mail, telephone, email, SMS or social media platforms) with information about our products and services.
- You can always choose to stop receiving direct marketing communications from us by 'opting-out'. Our communications with you will include instructions on how to do this.
- BEHAVIOURAL ADVERTISING
- As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.
- You can opt out of targeted advertising by visiting: Facebook, Google, Bing.
- Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at: http://optout.aboutads.info/.
- DO NOT TRACK
- Please note that we do not alter our Site's data collection and use practices when we see a Do Not Track signal from your browser.
- YOUR RIGHTS
- If you are a California resident or if applicable EU, UK or Canadian law applies to you, you may have the right to request that we disclose what categories of Personal Information about you that we collect, use and disclose, the source of this Personal Information, and the third parties to whom we have disclosed your Personal Information.
- You may also have the right to request the specific pieces of Personal Information we have collected about you, as well as the right to request that we delete your Personal Information (subject to certain exceptions).
- In addition, if applicable Australian law applies to you, you may have the right to access your Personal Information, seek correction of your Personal Information or make a complaint about a breach of applicable Australian law using the contact details below.
- We will not discriminate against you for exercising any of these privacy rights.
- DATA RETENTION
- When you place an order through the Site, we will maintain your Order
Information for our records:
- as long as it is required for our legitimate purpose or to fulfil the purposes for which it was collected;
- as long as it is required to perform our contractual obligations;
- as long as we have your consent; or
- for such period as is required or permitted by law or regulatory obligations which apply to us.
- We will delete or anonymise your personal data when it is no longer required.
- When you place an order through the Site, we will maintain your Order
Information for our records:
- CHANGES
- We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
- When we do make a change, we will revise the "last updated" date at the beginning of the policy.
- MINORS
- The Site is not intended for individuals under the age of 14, and we do not knowingly collect Personal Information of such individuals.
- If you are a parent of a child under the age of 14 and believe that we have collected Personal Information of your child, please contact us to request that we delete this information.
- DISPUTE SETTLEMENT
- Any dispute, claim, or controversy arising out of or relating to this Privacy Policy shall be determined in accordance with the Dispute Resolution provisions in the Terms of Service.
- CONTACT US
- For more information about our privacy practices, if you have questions, if you would like to exercise any of your privacy rights or if you would like to make a complaint, please contact us here.
- Stella Management
Attention: Privacy Compliance Officer
Level 8/805, 220 Collins Street, Melbourne VIC 3000, Australia
Last updated: July 2025