Privacy Policy

Effective date: May 18, 2022

We are a travel focused content mobile application and website that allows users to create travel inspired stories using photos and videos stored on their mobile devices. In this Privacy Policy (“Policy”), we Expedition Travel Advisor, Inc dba Steller (“Steller” or “we”), with offices at 1100 Carillon Point, Kirkland, WA 98033, describe how we collect, use, and disclose information that we obtain about visitors to our website https://www.steller.co (the “Site”), users of our mobile application (the “App”) and the services available through our Site and App (collectively, the “Services”).

For users who are not EEA or UK residents: By visiting the Site, using or downloading the App, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site, App or Services, and any dispute over privacy, are subject to this Policy and our Terms of Service including its applicable limitations on damages and the resolution of disputes. The Steller Terms of Service are incorporated by reference into this Policy.

For EEA or UK residents: Please also read important additional information about our use of your personal information, and your rights concerning your personal information, available here.

The Information We Collect About You

We collect information about you directly from you and automatically through your use of our Site, App and Services.

Information We Collect Directly From You

The information we collect from you depends on how you use our Services.

  • Account Registration. To create an account, which you will need to do to use features of our Services such as creating content (which may include text, software, scripts, graphics, photos, sounds, music, videos, audiovisual combinations, interactive features and other materials you may view on, access through, or contribute to the Services), following other users, liking or commenting on other users' content, or sharing content, you must provide your name and email address, and a user ID. Once you have created an account, you have the option to, but are not required to, add a picture and description to your profile. To upload your photos and videos to your stories, we will request access to your phone's camera.

  • Registered Account Users. When you create an account, you will have the option to configure your settings, including to choose the types of notifications you would like to receive from the App. For example, you can choose to receive a notification when someone new follows you, when someone comments on your story, when your friend joins, or when you are mentioned in another user's content. Once you have created an account, you will have the option to upload content to your account through our App, including your photos, videos and stories, and to add other information to that content, such as the location where the story took place, or where permitted by applicable law and licensing restrictions, music. When you post content, we may make additional content available to you based on the content you have posted, or your location. In addition, when you share content to a social media site, we will keep a record of the fact that you shared content. If you are a registered account user, you will have the option to provide feedback on other users' content by, for example, commenting on the content, or 'liking' the content. If you use our Services through our Site, you will not be able to create content, but you can share content you have created on our App, or provide feedback on content other users have uploaded. When you add content to your account, or provide feedback on other users' content, unless you have chosen to make your account private, your content and feedback will be visible to all visitors to our Site and App, including visitors and other users who choose to follow your account. If you have chosen to make your account private, other users will only be able to view your content if you invite or permit them to follow you.

  • Visitors. If you visit our Site or App, but do not create an account, you can view content that others create, but you will not be able to create your own content, or provide feedback on the content that others have created.

Information that We Collect About You from Social Networking and Other Sites

We collect information about you when you interact with us on social networking platforms. If you message us or tag us in a social network post, we will collect information about your message or the post we are tagged in.

You may log into our Services through your social networking and other accounts, including Facebook, Twitter, and Apple. If you do this, we obtain information from these sites as follows:

  • Facebook. If you log into our Services using Facebook, you must enter your Facebook login information. When you log in to our Site or App using your Facebook credentials, we will be given permission to: (i) access and collect your Facebook basic profile information (this includes your name, profile picture, gender, networks, user IDs, date of birth, email address, and any other information you have set to public on your Facebook account); and (ii) collect your email address. Will also request permission to access and use your list of friends. If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public on Facebook

  • Twitter. If you log into our Services using Twitter, you must enter your Twitter login information. By logging in through Twitter, you are granting us access to read Tweets from your timeline and see whom you follow.

  • Apple.If you log into our Services using your Apple credentials, you must enter your Apple login information.

We store the information that we receive from Facebook, Twitter and Apple with other information that we collect from you or receive about you.

Any social networking site controls the information it collects from you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies. We have no control over how any unaffiliated site uses or discloses the personal information it collects about you.

Information We Collect Automatically

We automatically collect information about your use of our Site and App through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we may combine this information with other information we collect about you, including your personal information.

When you visit our Site, we automatically collect the following information about you:

  • device ID
  • Mac address
  • domain name
  • your browser type and operating system;
  • web pages you view on the Site
  • links you click on the Site
  • your IP address
  • the length of time you visit our Site and or use our Services
  • the referring URL, or the webpage that led you to our Site

When you use our App, we automatically collect the following information about you:

  • IP address
  • mobile device ID
  • device name and model
  • operating system type, name, and version
  • web pages you view on the App
  • language information
  • activities within the App and the length of time that you are logged into our App
  • location information

With your permission, we will collect location information from your mobile device (including the device camera and photos or videos you choose to import) to show your location or the location of the content you post on the map page related to the locations tagged in the content. You may turn off this feature through the location settings on your mobile device.

Please see the section “Cookies and Other Tracking Mechanisms” below for more information. EEA and UK residents should read the additional information available in our EEA and UK Cookie Policy, available here.

How We Use Your Information

We use your information, including your personal information, for the following purposes:

  • Transactional Purposes: For transactional purposes, such as to provide our Services to you. This may include cooperating with other entities in the travel services business to provide our Services and to enhance the features and offerings available through our Services.

  • Customer Service and Support: For customer service and support purposes, such as to communicate with you about your use of our Services, changes to our services, and to respond to your inquiries.

  • Customization: To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services.

  • Advertising and Marketing: For marketing purposes, including where permitted by applicable law, to send you email marketing, news or newsletters about our or our affiliates' products and services, or the products and services of other entities that we think may be of interest to you. To assist us in advertising on unaffiliated websites, mobile apps, and other online services, and to evaluate the success of our adverting campaigns through unaffiliated channels (including our online targeted advertising and offline promotional campaigns).

  • Information: For our information gathering purposes, such as to administer surveys and questionnaires, such as for market research or member satisfaction purposes.

  • Administration: For administrative purposes, including to help us better understand how our customers access and use our Site and App, including the pages viewed, ad impressions clicked, or other Site or App activity; to maintain security and operability of our Site and App (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; to enforce this Policy, our Terms of Service and other policies.

  • Analytics: For research and analytics purposes, including to better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site and App are most (or least) used by users.

  • Business Transfers: As part of a contemplated or actual acquisition, merger or investment, sale of shares or assets, or a bankruptcy or insolvency proceeding.

  • Legal Compliance: To comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.

  • Protection of Us and Others: Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Policy.

When we ask for personal information on a form, that information is required to enter into a contract with you (such as in anticipation of creating an account) or to perform a contract with you (such as to provide information or the Services at your request). Failure to provide any information may result in our inability to provide requested Services.

How We Share Your Information

We may share your information, including personal information, as follows:

  • Service Providers: We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include entities that host our Site, App and databases, provide information technology services related to our Services, including managing our information technology infrastructure, and assist us in performing analytics on our Site and App.

  • Affiliates: We disclose the information we collect from you to our affiliates or subsidiaries.

  • Steller Users: Your user name and any information that you post to our Site or App, including, without limitation, content, photos, reviews, comments, and text will be available to, and searchable by, all users of the Site and App.

  • Travel Partners: We partner with other entities in travel services space to provide our Services and to enhance the features and offerings available through our Services. For example, our Services may include content from our travel partners that allow you to see hotels available in a city where you are traveling; our Services may also include links to other entities' websites that enable online bookings of travel products and services (e.g., accommodations, tours, attractions and others). When our partners and other entities use your information, they do so in accordance with their own privacy policies and we are not responsible for their use.

  • Social Networking Sites: If you choose to, you may share your stories to other social media networking sites, including Twitter, Instagram, and Facebook. In addition, other registered users may share the content that you upload to their accounts on other social media networking sites. When you or another user shares your content to other social media networking sites your information will be subject to the privacy policies of those sites, and not this one. If you are not comfortable with how someone has shared your content, you can report that activity by contacting us at copyright@steller.co.

We also disclose information in the following circumstances:

  • Business Transfers: If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our shares or assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and advisors, including attorneys and consultants.

  • In Response to Legal Process: We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

  • To Protect Us and Others: We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.

  • Aggregate and De-Identified Information: We share aggregate, anonymized, or de-identified information about users with other entities for marketing, advertising, research or similar purposes.

Please note that we do not share information with unaffiliated third parties for their own direct marketing purposes.

Our Use of Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf). EEA and UK residents should read the additional informationavailable in our EEA and UK Cookie Policy, available here.

Cookies

Cookies are alphanumeric identifiers that we transfer to your device's hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, App and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site, App and Service. There are two types of cookies: session and persistent cookies.

  • Session Cookies: Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site, App and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site, App and Services.

  • Persistent Cookies: Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function. Persons in the EEA and UK can opt-in to cookiesby using our Cookie Preference Center, available here.

Clear GIFs, pixel tags and other technologies

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web and app pages. We and our service providers may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and App users, help us manage content, and compile statistics about Site usage.

Analytics

We use automated devices and applications, such as Google Analytics and Google Firebase, to evaluate usage of our Site, and to the extent permitted, our App. We also may use other analytic means to evaluate our Site and App. We use these tools to help us improve our Site's and App's performance and user experiences. The entities that operate these tools may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google's privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy and the How Google Uses Information from Sites or Apps that Use Our Services Policy, available at https://policies.google.com/technologies/partner-sites. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Use

We and our service providers, including Google, may use the information that we collect about you (whether directly from our Site, App, through your device(s), or from an unaffiliated entity) to help us and our service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We, and our service providers also may use the cross-device use and other information we learn about you to align the content that you see and the Services that you receive when you use our Services on our Site and App. In addition, we and our service providers may use the cross-device and browser tracking and other information we learn about you to serve targeted advertising on your devices and to send you emails. To opt-out of cross-device and browser advertising, you may follow the instructions set forth in the Ad Networks section below. Please note: if you opt out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt out of each browser or device that you use.

Do-Not-Track

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Ad Networks section below.

Ad Networks

We use other entities such as network advertisers, advertisers, sponsors and/or traffic measurement services (“Advertisers”) to serve advertisements on our Site and on other websites or other media (e.g., social networking platforms). This enables us and these entities to target advertisements to you for products and services in which you might be interested. Advertisers may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each Advertiser's specific privacy policy, not this one. We may provide these Advertisers with information, including personal information, about you.

We may disclose certain information to other parties - such as Facebook (more info on Facebook Custom Audience here) - so that we can better target ads and content to our users, and others with similar interests on these external platforms or networks (“Custom Audiences”). We may also work with Advertisers that enable us and other participants to target ads to Custom Audiences submitted by us and others.

Users in the United States may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info and the NAI's website at www.networkadvertising.org.

Our Site, App and Services may contain links to unaffiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites.

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Access To My Personal Information

You may modify personal information that you have submitted by logging into your account and updating your profile information or sending us an email at support@steller.co. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or App for a period of time.

What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional emails to you; where required by law, we will only do so with your prior consent. You may opt-out of promotional emails by following the opt-out instructions contained in the email or, if you are a registered user, by adjusting your account settings. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

Children Under 13

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at support@steller.co. Our EEA representative, Denice Brewer, can be reached at denice@steller.co. Our UK representative, Jordan Foy, can be reached at jordan@steller.co.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and App.

IMPORTANT ADDITIONAL INFORMATION FOR USERS IN THE EEA OR UK

Legal Bases for Processing Personal Information

All processing and use of your personal information is justified by a "legal basis" for processing. In the majority of cases, processing will rely on one of the following legal bases:

  • Contract performance: The processing is necessary to perform a contract with you or take steps to enter into a contract at your request, such as to provide you Services or to provide information you have requested

  • Legitimate interests: The processing is in our legitimate interests, which are not overridden by your interests and fundamental rights

  • Consent: You have consented to the processing

We use the personal information we collect for the following purposes, relying on the legal bases set forth below:

  • Contract performance: To provide our Services to you (this may include cooperating with other entities in the travel services business to provide our Services); to provide customer service and support purposes; to communicate with you about your use of our Services and changes to our services; and to respond to your inquiries.

  • Legitimate interests in customizing our Services in order to better anticipate and meet your needs and to grow our business: To tailor the content and information that we may send or display to you; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences while using the Services.

  • Legitimate interests in promoting our Services in order to grow our business: For marketing purposes, including where permitted by applicable law, to send you email marketing, news or newsletters about our or our affiliates' products and services, or the products and services of other entities that we think may be of interest to you; to assist us in advertising on unaffiliated websites, mobile apps, and other online services; and to evaluate the success of our adverting campaigns through unaffiliated channels (including our online targeted advertising and offline promotional campaigns).

  • Legitimate interests in improving our Services in order to better anticipate and meet your needs and to grow our business: For our information gathering purposes: to administer surveys and questionnaires, such as for market research or member satisfaction purposes; to help us better understand how our customers access and use our Site and App, including the pages viewed, ad impressions clicked, or other Site or App activity; for research and analytics purposes to better understand how users access and use our Services, both on an aggregated and individualized basis; to evaluate which features of our Site and App are most (or least) used by users; and to enhance the features and offerings available through our Services.

  • Legitimate interests in efficiently operating our business: For administrative purposes: as part of a contemplated or actual acquisition, merger or investment, sale of shares or assets, or a bankruptcy or insolvency proceeding; to provide reports to prospective partners, service providers.

  • Legal obligation: To comply with applicable EEA or UK legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; as part of legal proceedings; and to provide reports to regulators.

  • Legitimate interests in operating our business in a compliant manner: To comply with applicable non-EEA or UK legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; as part of legal proceedings; to provide reports to regulators; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; and to enforce this Policy, our Terms of Service and other policies.

  • Legitimate interests in protecting our reputation or assets: Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Policy; to maintain security and operability of our Site and App (including for debugging purposes).

Transfers of Personal Information

We and our service providers are located in the US. When you freely choose to interact with our App and Site and use our Services, your personal information will be transferred outside the EEA or UK and to the United States, whether to Company or our affiliates or third parties, including service providers. This transfer is not covered by the requirements of the EU or UK General Data Protection Regulation.

Retention of Personal Information

We apply a general rule of keeping personal information only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal information for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us. However, in some circumstances we may retain personal information for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

With respect to marketing, we retain your personal information for 12 months after your last request for service or other contact you initiate.

Your Rights

Subject to the laws applicable to you and your personal information and the conditions described in those laws, you are entitled to certain legal rights in relation to your Personal information.

  • Right to Access - you have the right to request access to any of your personal information that we hold, and to obtain information about the processing of that data.

  • Right to Correct - we will take steps in accordance with applicable legislation to keep your personal information accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal information corrected (that is, rectified).

  • Right to Erasure - you are entitled to have your personal information erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where personal information is unlawfully processed.

  • Data Portability - where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal information is processed by automated means, you have the right to receive all such personal information which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.

  • Right to Restriction of Processing - you have the right to restrict our processing of your personal information (that is, allow only its storage) where:

    • you contest the accuracy of the personal information, until we have taken sufficient steps to correct or verify its accuracy;

    • where the processing is unlawful but you do not want us to erase the personal information;

    • where we no longer need your personal information for the purposes of the processing, but you require such personal information for the establishment, exercise or defense of legal claims; or

    • where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.

Where your personal information is subject to restriction, we will only process it with your consent or for the establishment, exercise or defense of legal claims.

  • Right to object to processing (including profiling) based on legitimate interest grounds - where we are relying upon legitimate interests to process personal information, you have the right to object to that processing on grounds relating to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal information for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

  • Right to object to direct marketing - you have the right to object to our use of your personal information (including profiling) for direct marketing purposes, such as when we use your personal information to invite you to our promotional events.

  • Right to Withdraw Consent - in the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

If you would like to exercise one or more of these rights, or if you have any enquiries or complaints regarding the processing of your personal information please contact us at support@steller.co.

You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal information infringes applicable law. A list of data protection supervisory authorities is available here http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

Changes to this Policy

Material changes to this Policy will be posted in advance.