Privacy Policy
Your privacy is important to us. This policy explains how Stelear Capital collects, uses, and protects your personal information.
Last updated: December 12, 2025
Table of Contents
1. Data Controller
Stelear Capital ("we," "our," or "us") is the data controller responsible for your personal information. We are committed to protecting and respecting your privacy in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and other relevant privacy legislation.
Contact Details:
2. Data Collection
We collect personal information that you provide to us directly and information that is automatically collected when you use our website and services.
Information You Provide:
- Contact information (name, email address, phone number)
- Professional information (company, job title, investment experience)
- Financial information (investment capacity, risk tolerance)
- Communication preferences
- Any other information you choose to provide when contacting us
Information Automatically Collected:
- IP address and location data
- Browser type and version
- Device information
- Website usage data and analytics
- Cookies and similar tracking technologies
3. How We Use Your Data
We use your personal information for the following purposes:
Investment Services
- Assess investment suitability
- Provide investment advice
- Process investment applications
- Manage investor relations
Communication
- Respond to inquiries
- Send investment updates
- Provide customer support
- Send marketing communications
Legal Compliance
- Meet regulatory requirements
- Prevent fraud and money laundering
- Maintain records as required by law
- Comply with tax obligations
Website Improvement
- Analyze website usage
- Improve user experience
- Develop new features
- Ensure website security
4. Data Sharing
We may share your personal information in the following circumstances:
Service Providers
We work with trusted third-party service providers who assist us in operating our business, such as technology providers, legal advisors, and auditors.
Legal Requirements
We may disclose your information when required by law, regulation, or legal process, or to protect our rights and interests.
Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.
5. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law.
Retention Periods:
- Investment records: 7 years after relationship ends
- Marketing communications: Until you unsubscribe
- Website analytics: 26 months
- Legal compliance: As required by applicable law
6. Your Rights
Under applicable data protection laws, you have the following rights regarding your personal information:
Access & Portability
Request a copy of your personal data and receive it in a structured format.
Rectification
Request correction of inaccurate or incomplete personal information.
Erasure
Request deletion of your personal data in certain circumstances.
Restriction & Objection
Restrict processing or object to certain uses of your data.
To exercise any of these rights, please contact us at invest@stelear.com. We will respond to your request within 30 days.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.
Encryption
Data encrypted in transit and at rest
Access Controls
Strict access controls and authentication
Regular Audits
Continuous monitoring and security audits
9. International Transfers
Your personal information may be transferred to and processed in countries other than your country of residence. We ensure that such transfers are conducted in accordance with applicable data protection laws and that appropriate safeguards are in place.
Safeguards Include:
- Standard Contractual Clauses approved by the European Commission
- Adequacy decisions by relevant data protection authorities
- Binding Corporate Rules where applicable
- Other appropriate safeguards as required by law
10. Contact Information
If you have any questions about this privacy policy or our data practices, please contact us:
General Inquiries
Data Protection Officer
For specific privacy-related inquiries and exercising your data rights
Policy Updates
We may update this privacy policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date at the top of this policy.
We encourage you to review this policy periodically to stay informed about how we protect your information.