Stardust Privacy Policy

Last Updated: October 23, 2024

This Privacy Policy describes how Stardust (“Stardust,” “we”, or “us”) collects, uses, discloses and otherwise processes information about you. This Privacy Policy applies to information we collect when you access or use our websites, mobile applications, and other online products and services that link to this Privacy Policy (the “Services”), or when you otherwise interact with us, such as through our customer support channels.

You can also find our Health Data Privacy Policy here.

This Privacy Policy is effective as of the “Last Updated” date above. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information directly from you when you register an account on our app, request customer support, or otherwise communicate with us.

The categories of information we collect include:

Identifiers: we collect your name and birthdate. We also collect your email address, phone number, and log-in credentials but we store those separately with a third-party privacy-focused authentication platform.
Health Data: we collect reproductive or sexual health information, including menstrual activity, fertility, pregnancy information, and sexual activity; and information about your health conditions, symptoms, and use of medications.
- Please note that we do NOT associate your Health Data with your contact information (e.g., email address used for account login, password, email, and phone number). Instead, we generate an identifier that we associate with your Health Data.
Financial Information: we engage third party payment processors to collect your payment information for our paid features or merchandise.
Communication Information: we collect information included in your communications with us.

We may also collect any other information you choose to provide.

Information We Collect Automatically

We automatically collect the following categories of information:

Transactional Information: we keep a history of your transactions with us, including the dates and the amounts paid for the Services or merchandise.
Internet Activity Information: we collect information about how you access our Services, including data about the device and network you use, such as your device type/model, operating system version, mobile network, IP address, user agent, mobile device advertising identifiers, other unique device identifiers, time zone, browser type, CPU and battery information, system language, device motion parameters, screen orientation, and the country in which you download our app. We collect information about how you interact with our app, such as information about app downloads, openings, trials, registrations, and subscriptions.
Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies, pixels, and SDKs, to collect information about your interactions with our Services and communications, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services. You can learn more about cookies below.

Information We Collect from Other Sources

We may collect information from the following third-party sources:

Third-Party Apps: If you connect third-party apps to the Services, we may collect certain information from such third-party apps under your direction. For example, if you connect Apple HealthKit or Google Health with the Services, we may import certain information under your direction such as step count. If you connect the Services with your Oura ring we will collect sleep information and basal body temperature.
Third-Party Logins: Additionally, if you create or log into your Stardust account through a third-party platform (such as Apple or Google), we will have access to certain information made available by that platform, in accordance with the authorization procedures determined by such platform.
Social Media Platforms: We may also collect information you share when you interact with us on social media platforms like Instagram and TikTok.

Derived Information

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address and may infer your interests based on your browsing behavior and past activities.

COOKIES

Like most companies, we use cookies and similar technologies in our Services. The technologies we use include the following:

Cookies which are small data files stored on your browser or device.
Pixels, which are small images on a web page or in an email. Pixels collect information about your browser or device and can set cookies and be used to track your use of or interaction with one or more websites.
SDKs, or software development kits, which are software packages containing tools that help build mobile apps and introduce new features or functionality.

We refer to these technologies collectively as “cookies”. You can find information about cookies and how they work at www.allaboutcookies.org.

First-Party and Third-Party Cookies

Some cookies are referred to as “first-party” which means they are placed by the website you are visiting or the app you are using – so in our case first party cookies and pixels are placed by our Services. “Third-party” cookies are placed by other organizations (with our permission) via our Services. They work by collecting information from your device and passing it directly back to the third-party. For example, we partner with third-party analytics providers that set cookies when you visit our Services.

How Do We Use Cookies?

We use cookies for a number of reasons, like helping us see which features of our Services are most popular, counting visitors, improving our users’ experience, keeping our Services secure, and advertising. The cookies we use fall into one of the following categories:

Category	Subcategory	Why We Use These Cookies
Essential	Essential	These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into secure areas or make purchases.
Non-Essential	Advertising	We use these cookies in our iOS app to allow us or third-party partners to collect information to measure advertising performance or show advertisements on other sites, apps or platforms, including social media.
Non-Essential	Analytics	We use these cookies in our iOS app and Android app to allow us or third-party partners to measure and analyze performance and improve our Services and services.

Your Choices

You can control certain cookies in the iOS app through your device’s privacy settings

Most browsers allow you to manage your cookies preferences. We will always set our essential cookies and if you block these cookies using browser settings you may not be able to use certain features of our Services.

USE OF INFORMATION

We use the categories of information we collect for the following business and commercial purposes:

Service Delivery: we use information to provide and maintain our Services, personalize your experience with us, and process or fulfill transactions.
Communication: we use information to communicate with you about Stardust and our Services, including to send you newsletters, respond to your questions, inform you of changes to our Services or prices for paid features, and send you other transactional or relationship messages.
Marketing and Advertising: we use information to send direct marketing messages (including via email) and serve digital advertisements to you on third-party platforms and websites as described below. You can opt out of direct marketing messages we send by following the instructions in those communications (such as by clicking “unsubscribe” in the emails) or by contacting us.
Research and Development: we use information to monitor and analyze Services trends, usage, and activities, improve our products and services, develop new products and services, and generate de-identified or aggregated data.
Protection and Compliance: we use information to detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, help protect the rights and property of Stardust and others, and comply with our legal and financial obligations.
Notice/Consent: we may also use information in other circumstances after giving you notice and/or getting your consent.

ADVERTISING TECHNOLOGIES

We do not use or disclose Health Data to serve digital advertising.

With your consent, we will share device identifiers and app usage data (app downloads, openings, trials, registrations, and subscriptions) with Appsflyer and its integrated partners to promote the Services and find new users, including by creating and serving ads to audiences made up of non-users the advertising platforms deem similar to our users, and to optimize our advertising efforts. You can withdraw your consent to these activities on iOS devices through the device’s privacy settings.

DISCLOSURE OF INFORMATION

We disclose the categories of information described above as follows. When we share information with third parties we enter into agreements with them that require them to provide equal protection of information as described in this Privacy Policy and as required by Apple’s App Review Guidelines.

Vendors: we disclose information to vendors, service providers, contractors and consultants that need this information to provide services to us, such as companies that assist us with web hosting, payment processing, fraud prevention, customer service, data enrichment, analytics, operating systems and platforms, debugging, authentication and identity verification, data storage, and marketing and advertising.
Advertising Partners: we disclose information to third parties for the Marketing and Advertising purposes described above.
Professional Advisors: we disclose information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
Legal Authorities and Others Involved in Legal Proceedings: we may disclose information to legal authorities and others for the Protection and Compliance purposes described above, including if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements and if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Stardust, our users, the public, or others.
Corporate Transactions: we reserve the right to disclose information in connection with, or during negotiations of certain corporate transactions, including the merger, sale of Stardust assets, financing, or acquisition of all or a portion of our business by another Stardust.
Affiliates: we reserve the right to disclose information between and among Stardust and any current or future parents, affiliates, subsidiaries, and other companies under common control and ownership.
Consent: we may disclose information when we have your consent or you direct us to do so (such as when you direct us to disclose information to third-party apps which are connected to the Services or use third-party services to log-in to the Services, as described above).

We also disclose de-identified or aggregated information that cannot reasonably be used to identify you.

DATA RETENTION AND DELETION

We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy. Users can delete their information through their app settings.

INDIVIDUALS IN EUROPE

This section supplements this Privacy Policy if you are in the European Economic Area (“EEA”), the United Kingdom, or Switzerland.

Legal Basis for Processing

When we process your personal information as described above, we do so in reliance on the following lawful bases:

To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
When we have a legitimate interest in processing your personal information to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
When we have your consent to do so (e.g., when you give us permission to process Health Data to provide the Services or you opt in to advertising campaigns from us). When consent is the legal basis for our processing your personal information, you may withdraw such consent at any time.

Data Subject Requests

You have the right to delete your information via your app settings. You can also request access to or correction of your personal information, or object to or request we restrict certain processing by contacting us.

If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Data Transfers

We may transfer personal information from the EEA, the United Kingdom, or Switzerland to non-adequate countries like the United States. We rely on appropriate safeguards such as the standard contractual clauses (“SCCs”) to do so, and you may obtain a copy of the SCCs by contacting us.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at support@stardust.app.

Stardust Health Data Privacy Policy

Last Updated: October 10, 2024

This notice supplements Stardust’s Privacy Policy and provides additional information about how we collect, use, and disclose health data as required by laws like Washington’s My Health My Data Act and Nevada’s Consumer Health Data Privacy Law.

Health Data Storage

Please note that we store your contact information with third parties and we store your health data against a random account ID. This means that we do not link your health data to you.

Collection of Health Data

We collect health data that you provide through our Service and through our integrations with third-party mobile health apps.

The health data we collect includes:

Reproductive or sexual health information including, menstrual activity, fertility and pregnancy information, and sexual activity;
Information about your health conditions, symptoms, and use of medications; and
Information we collect through third party integrations such as step count, sleep data, and basal body temperature.

Sources of Health Data

We collect health data directly from you, from your interactions with the Services, and from third-party mobile health applications and services.

Use of Health Data

We collect and use health data for the following purposes:

Service delivery, including to track menstrual cycles, ovulation dates and fertility, create your profile, and ensure the secure and reliable operation of the Services.
Protection and compliance purposes, including to comply with our legal obligations and to detect and prevent fraud and illegal activity.

We may use health data for other purposes with your consent as required by law.

Sharing of Health Data

We may share each of the categories of health data described above with the following categories of third parties:

Processors. Vendors or agents working on our behalf may access health data to provide services to us. For example, companies that host our servers or provide customer support may need access to health data to provide those functions.
Third-party mobile health applications and services. At your direction, we may share health data with other companies such as Apple HealthKit.
Parties to a corporate transaction. We may disclose health data in connection with or following a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
Others. You may choose to share your health data with other users of the Service or with your friends and/or partners. We are not responsible for their collection, use or sharing of your health data.

Your Rights

You can access or delete your health data or withdraw consent to our processing of your health data, subject to certain exceptions. To delete your health data, you can hit the ‘delete’ button within your profile. You can also request to exercise any of these rights by emailing support@stardust.app.
If we deny your request to exercise one of those rights, you may appeal that decision by emailing support@stardust.app. If your appeal is unsuccessful, you may be able to raise a concern or lodge a complaint with the Attorney General in your state. (Washington residents click here and Nevada residents click here).