Privacy Policy for STELLYM

This Privacy Policy explains how STELLYM (“we”, “us”, or “our”) collects, uses, stores, and protects personal data when you use our journaling and personal development mobile application (the “App”).

We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection
Regulation (GDPR).

1. Data Controller

For the purposes of STELLYM, STILL & SKY LTD, based in the United Kingdom, isthe data controller responsible for your personal data. Contact email: contact@stellym.com

2. Personal Data We Collect

Data You Provide
Journal entries, reflections, goals, and notes you create (text, images, audio, or video)
Account information such as your email address (if account creation is enabled)
Communications sent to us (support requests or feedback)


Data Collected Automatically
Device type, operating system, and app version
Anonymous or pseudonymised usage analytics
Crash and performance diagnostics
Location data: By default, we collect only your approximate location (town or nearest town). You can choose to share your exact location (GPS) if you want more precise features.


All location data is collected only with your consent, can be changed or revoked at any time in the app settings, and is stored securely. Location information is used solely to improve your experience.

3. Special Category Data (Sensitive Data)

Journal content may include special category personal data under GDPR (for example, information relating to mental health, emotions, or personal beliefs).
This data is processed only at your request and for your private use
We do not analyse, sell, or use this data for advertising or marketing
Where AI-powered features are offered, they process content solely to provide user-initiated functionality (such as reflection, insights, or summarisation) and are not used for profiling or automated decision-making that produces legal or similarly significant effects

The App does not provide medical, psychological, or therapeutic advice and is notintended to diagnose, treat, or manage any health condition.

4. Lawful Basis for Processing

We process personal data on the following lawful bases:
Contractual necessity – to provide the App’s core functionality
User consent – where you choose to provide content or enable optional features
Legitimate interests – to maintain security, stability, and improve the App
Legal obligation – where required by law


You may withdraw consent at any time where processing is based on consent.

5. How We Use Your Data

We use your data to:
Provide journaling and personal development features
Store and sync content across devices (if enabled)
Maintain app security and prevent misuse
Improve performance and reliability
Respond to support requests


We do not use personal data for advertising or sell it to third parties.

6. Data Sharing

We do not sell personal data. We may share limited data only with:
Trusted service providers (e.g. hosting, analytics, infrastructure) strictly for operating the App
Authorities or regulators where legally required
All service providers are contractually required to meet GDPR standards.

7. International Data Transfers

Your data may be processed outside the UK or European Economic Area (EEA). Where this occurs, we rely on appropriate safeguards such as:

Adequacy decisions
Standard Contractual Clauses
Equivalent legal protections

8. Data Retention

Personal data is retained only for as long as necessary to provide the App and meet legal obligations
Users can delete their account and associated personal data via the App settings or by contacting contact@stellym.com
Some limited data may be retained where legally required (e.g. security or compliance)


This aligns with Apple’s data deletion expectations.

9. Data Retention

You have the right to:
Access your personal data
Correct inaccurate data
Request deletion
Restrict or object to processing
Data portability
Withdraw consent


You may also lodge a complaint with the UK Information Commissioner’s Office
(ICO) or your local EU supervisory authority.

10. Children and Young Users

The App is intended for users aged 16 and over.
We do not knowingly collect personal data from children under 13. If such data is identified, it will be deleted promptly.

11. Children and Young Users

We implement appropriate technical and organisational measures to protect personal data.


No system is completely secure, but we work continuously to safeguard user information.

12. Third-Party Links

We are not responsible for the privacy practices of third-party websites or services linked from the App or website.

13. Changes to This Policy

We may update this Privacy Policy from time to time.
Material changes will be communicated via the App or website.

14. Changes to This Policy

For privacy-related questions or requests:
Email: contact@stellym.com