Legal

Privacy Policy

What personal data we hold, why we hold it, who sees it, how long we keep it, and what you can ask us to do about it.

Last updated 25 July 2026 · Version 3.0

Template for review. Bracketed operational details, retention periods and the identity of the data protection contact must be confirmed against your actual processing activities and systems before this page goes live.

1. Who controls your data

StellarStart Global Limited, registered in England and Wales, is the controller for personal data described in this policy. Where we process personal data contained in client files on a client’s instructions, we may act as a processor for that data, in which case the terms of our data processing agreement with that client govern.

Data protection contact: privacy@stellarstart.global.

2. Data we collect

Data you give us

  • Enquiry and contact data: name, email address, company, jurisdictions involved, the nature of your matter, and anything else you choose to include in a message.
  • Client and engagement data: billing details, correspondence, instructions, documents you send us, and records needed for identity and conflict checks.
  • Newsletter data: email address and subscription status.
  • Recruitment data: CV and application content, if you apply to work with us.

Data we collect automatically

  • Technical and usage data: IP address, device and browser type, pages viewed, referring URL and timestamps, collected through server logs and, where you consent, analytics cookies. See our Cookie Policy.

Data from third parties

  • Platform data where you engage us through a marketplace such as Upwork.
  • Verification data from identity, sanctions and company-registry checks.
  • Information provided by StellarPartners, counterparties or public registers in the course of a matter.

3. Why we use it, and our lawful basis

PurposeData usedLawful basis (UK/EU GDPR)
Responding to enquiries and scoping a matterEnquiry and contact dataLegitimate interests; steps prior to entering a contract
Providing services under an engagementClient and engagement dataPerformance of a contract
Identity, conflict, sanctions and AML checksVerification dataLegal obligation; legitimate interests
Invoicing, accounting and tax recordsBilling dataLegal obligation
Sending the newsletterEmail addressConsent
Analytics and site improvementTechnical and usage dataConsent (analytics cookies)
Site security and abuse preventionServer log dataLegitimate interests
Establishing, exercising or defending claimsAny relevant dataLegitimate interests; legal claims

Where we rely on legitimate interests, we have assessed that our interest in operating and protecting the practice does not override your rights and freedoms. You can ask us for that assessment.

4. Special category and sensitive data

Some matters, particularly employment and dispute work, involve special category data such as health information, or data about criminal allegations. We process it only where necessary for the matter and where an additional condition applies, most commonly that the processing is necessary for legal claims or advice. We do not ask for special category data at the enquiry stage and would prefer you did not include it in a first message.

5. Who we share it with

  • StellarPartners and local professionals instructed on your matter, on your instructions or where necessary to deliver the agreed scope.
  • Registries, courts, tribunals and authorities where a filing or submission requires it.
  • Service providers that support our operations, including email and document hosting, practice and matter management, e-signature, accounting and payment processing, and analytics. Each is bound by contract to process data only on our instructions.
  • Professional advisers, insurers and auditors where needed.
  • Acquirers in the event of a reorganisation or sale of the business, subject to confidentiality.

We do not sell personal data and we do not share it for cross-context behavioural advertising.

6. International transfers

We operate across more than 24 countries, so personal data may be transferred outside the UK and the EEA. Where it is, we rely on an adequacy decision where one exists, and otherwise on the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the EU SCCs, supported by a transfer risk assessment and additional safeguards where the assessment calls for them. You can request details of the mechanism used for a specific transfer.

7. How long we keep it

Record typeRetention period
Enquiries that do not become engagements12 months from last contact
Client matter files7 years from closure of the matter, longer where a limitation period or registry requirement demands it
Identity and AML verification records5 years from the end of the business relationship
Accounting and tax records6 years from the end of the relevant financial year
Newsletter subscription recordsUntil you unsubscribe, plus 12 months to evidence consent
Server and security logs90 days
Unsuccessful job applications6 months, unless you agree to a longer period

8. Security

We apply access controls on a need-to-know basis, encryption in transit and at rest for hosted systems, multi-factor authentication on business accounts, device encryption, supplier due diligence, and staff confidentiality undertakings and training. No system is perfectly secure. If a breach occurs that is likely to result in a risk to your rights, we will notify the relevant supervisory authority within 72 hours where required, and tell you where the risk to you is high.

9. Your rights

Subject to the conditions in applicable law, you can ask us to:

  • confirm what personal data we hold about you and give you a copy (access);
  • correct data that is inaccurate or incomplete (rectification);
  • delete data where there is no continuing basis to keep it (erasure);
  • restrict how we use it while a question about it is resolved;
  • provide it in a portable format, or send it to another controller;
  • stop processing based on legitimate interests, or stop direct marketing at any time (objection); and
  • withdraw consent where consent was our basis, without affecting processing already carried out.

We respond within one month, and will tell you if we need an extension for a complex request. We do not charge unless a request is excessive or repetitive. Some rights are limited where data is subject to legal professional privilege or a confidentiality obligation to another client, and we will explain the reason if we have to rely on an exemption.

To exercise a right, write to privacy@stellarstart.global.

10. Notice for individuals in India

Where India’s Digital Personal Data Protection Act, 2023 applies to our processing, we act as a Data Fiduciary. You have the right to access a summary of your personal data and our processing, to correction and erasure, to nominate another individual to exercise your rights in the event of death or incapacity, and to a readily available grievance redressal mechanism. Where we rely on consent, our notice sets out the purposes in plain language and you may withdraw consent at any time with the same ease as it was given. Grievances can be sent to privacy@stellarstart.global and will be acknowledged within seven days.

11. Notice for US state residents

If you are a resident of California or another US state with a comprehensive privacy law, you may have the right to know what personal information we collect and disclose, to request deletion or correction, to obtain a portable copy, and to appeal a refusal. We do not sell personal information and do not share it for cross-context behavioural advertising, so no opt-out of sale or sharing is required. We will not discriminate against you for exercising a right. Requests can be made to privacy@stellarstart.global, and we will verify your identity before responding. An authorised agent may act for you with written permission.

12. Children

Our services are directed at businesses and professionals. We do not knowingly collect personal data from children. If you believe a child has provided us with data, contact us and we will delete it.

13. Cookies

Cookies and similar technologies are covered in our Cookie Policy, which explains what we set, what each one does, and how to change your choices.

14. Changes

We update this policy as our processing changes. The version in force is published here with its date. Where a change materially affects how we use data about you, we will take reasonable steps to tell you directly.

15. Contact and complaints

Contact us at privacy@stellarstart.global or through our contact page. We would like the chance to resolve a concern first, but you can complain to a supervisory authority at any time: the Information Commissioner’s Office in the UK, your local supervisory authority in the EEA, or the Data Protection Board of India, as applicable to you.