This section supplements Stella Palm’s Privacy Policy and provides additional transparency regarding the collection and processing of personal data through digital advertising and lead generation campaigns.

1. Purpose of Data Processing

Stella Palm collects and processes personal data submitted through social media platforms (including, but not limited to, META) and digital lead forms in order to:

• Respond to inquiries and requests for information

• Contact potential customers and qualified leads

• Provide information about products, services, and commercial programs

• Support and optimize sales and marketing activities

• Take pre-contractual steps at the request of the data subject, where applicable

Personal data will not be processed in a manner incompatible with these purposes.

2. Categories of Personal Data Collected

Depending on the information voluntarily provided, Stella Palm may process:

• Full name

• Email address

• Telephone number

• Company name

• Business role or industry (if applicable)

• Product interests or preferences

• Any additional information voluntarily submitted

Stella Palm does not intentionally collect sensitive personal data through lead campaigns.

3. Legal Basis for Processing (EU/EEA)

Where the General Data Protection Regulation (GDPR) applies, personal data is processed on the basis of:

• Consent, provided when a data subject submits a lead form;

• Legitimate interest, consisting of Stella Palm’s interest in developing commercial relationships with individuals who have expressed interest in its products or services; and/or

• Pre-contractual necessity, where processing is required to respond to a request prior to entering into a potential agreement.

4. U.S. Privacy Notice (Including California)

For U.S. residents, including California residents under the California Consumer Privacy Act (CCPA/CPRA):

• Stella Palm collects personal information for business and commercial purposes as described above.

• Stella Palm does not sell personal information.

• Stella Palm does not share personal information for cross-context behavioral advertising beyond what is necessary to operate advertising campaigns through authorized platforms.

Where required by applicable U.S. state law, individuals may have the right to:

• Know what personal information is collected and how it is used

• Request deletion of personal information

• Request correction of inaccurate information

• Opt out of certain data sharing practices

• Not be discriminated against for exercising privacy rights

Requests may be submitted using the contact information provided on this website.

5. Data Sharing and Third-Party Service Providers

Personal data may be shared with trusted third-party service providers that support Stella Palm’s marketing, CRM management, IT infrastructure, and advertising operations. These may include:

• Social media and advertising platforms (e.g., META)

• CRM providers

• Marketing automation and analytics providers

• IT and hosting service providers

Such third parties are contractually required to process personal data in accordance with applicable data protection laws and solely on documented instructions from Stella Palm.

Stella Palm does not sell personal data to third parties.

6. International Data Transfers

Where personal data is transferred outside of the European Economic Area (EEA), Stella Palm will implement appropriate safeguards in accordance with applicable data protection laws, which may include Standard Contractual Clauses or other legally recognized transfer mechanisms.

7. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, resolve disputes, or enforce agreements. When no longer required, personal data will be securely deleted or anonymized.

8. Data Subject Rights

Subject to applicable law, individuals may have the right to:

• Access their personal data

• Request correction of inaccurate or incomplete data

• Request deletion of their personal data

• Object to or restrict certain processing

• Withdraw consent at any time (without affecting prior lawful processing)

To exercise these rights, please contact Stella Palm using the contact details provided on this website.

9. Limitation of Liability and Updates

Stella Palm makes reasonable efforts to ensure compliance with applicable data protection laws in the jurisdictions in which it operates. However, the interpretation and application of privacy laws may vary by jurisdiction and may evolve over time.

Stella Palm reserves the right to update or amend this section at any time to reflect changes in legal requirements or business practices. The most current version will always be available on this website.

Nothing in this section shall be construed as creating contractual rights beyond those required under applicable data protection laws.