Privacy Policy

1. Introduction

1.1 Welcome to Stellar! We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose and store personal information in connection with our website (Website), the Program, and our other dealings with you. Please read it carefully.

1.2 In this Privacy Policy, Stellar, we, our or us means Gandel Invest Pty Ltd ACN 160 466 624, trading as Stellar Program, the owner and operator of the Website, and you or your includes an applicant, Startup, Founder, Partner, Program Alumni or any other individual whose personal information we collect.

1.3 In this Privacy Policy, the Program means the Stellar Program, and a reference to a startup, founder, partner or program alumnus (however capitalised) is to a company, founder, partner or alumnus of (or otherwise connected with) the Program, as described on the Website.

1.4 We are committed to protecting your privacy through compliance with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) and any other privacy laws applicable to the Website and the Program.

1.5 By accessing or using the Website, submitting a contact form or an application for Stellar (Application), signing up to our newsletter, participating in our events or the Program, or otherwise engaging with Stellar, you agree to the collection, use and disclosure of your personal information as described in this Privacy Policy.

1.6 Where the Website contains links to third-party websites, those sites are not governed by this Privacy Policy. We are not responsible for their operation or their privacy practices, so we recommend you read their privacy policies.

2. The information we collect

2.1 Personal information: We collect personal information to assess and process an Application, administer the Program, engage partners, communicate with you, and operate and improve the Website. Depending on your relationship with us, this may include your name, contact details, business and role, the information contained in an Application form (including information about a Startup's business, financial position and founders), information you provide to us as a Partner, and information collected through any due diligence we may conduct as part of our Application process.

(a) “Personal information” has the meaning given to it in the Privacy Act, but generally means any information that can be used to identify you.

(b) “Sensitive information” is a subset of personal information and generally includes an individual’s racial, religious or ethnic origin, health information, or political or philosophical affiliations or beliefs. We may collect sensitive information (for example, health information such as allergies, dietary requirements, medical conditions and accessibility needs, so that we can provide food and manage health and safety at our office and at events), but only with your consent or where otherwise permitted by law.

2.2 Log Data: When you use the Website, our servers automatically record information that your browser or device sends (Log Data), including device identifiers, device type, geo-location information, connection information, statistics on page views, traffic to and from the Website, the type of operating system and browser, IP address, date and time of your visit, pages visited, search terms, cookie information and standard web log data. We use Log Data to operate the Website, provide the Program, ensure security, maintain back-ups and communicate with you.

2.3 Cookies and similar technologies: We may use cookies and similar technologies (such as pixels, web beacons and local storage) to collect and store information about how you use the Website, and to retain your preferences between visits. You can opt out of cookies through your browser settings, although parts of the Website may then have limited functionality. By using the Website, you agree to our use of these technologies.

2.4 Third party analytics: We may use third-party analytics tools to collect information (which may include personal information such as IP addresses and cookie identifiers) about how the Website is used, to help us improve it. Third-party cookies may be placed on your device by these tools or by our service providers. By using the Website, you consent to the processing of that information by these tools as described in this clause.

3. Why we collect, use and disclose your information

3.1 We collect, use and disclose your personal information through lawful and fair means for the following primary purposes:

(a) assessing and processing an Application, and reviewing and conducting due diligence on a startup;

(b) administering the Program, including engaging and communicating with partners, founders, startups and program alumni;

(d) contacting and communicating with you;

(e) hosting you at events;

(f) providing food and drink and managing health and safety at our office and at events (including emergency response);

(g) verifying your identity;

(h) complying with our legal and contractual obligations;

(i) internal record keeping, invoicing and billing; and

(j) responding to and managing queries and complaints.

3.2 We may also collect, use and disclose your personal information for a related purpose that could reasonably be anticipated at the time of collection, including:

(a) internal operations such as record keeping, database management, data analytics or training;

(b) sending you marketing and promotional messages (including newsletters and event invitations) and other information that may be of interest to you; and

3.3 We may also use personal information to meet our internal and external audit requirements, for information security purposes, and as we otherwise believe necessary or appropriate to comply with applicable laws, regulations or government directions, or to protect our rights, privacy, safety or property, or those of other persons.

4. Automated decision-making and AI tools

4.1 If we use a computer program to substantially assist in making a decision that could reasonably be expected to significantly affect your rights or interests (for example, in the assessment of an Application), we will, to the extent required by the Privacy Act, disclose in this Privacy Policy the kinds of personal information used by that program and the kinds of decisions made by it (together with related information about those decisions).

4.2 We may use software, including artificial intelligence (AI) tools, to help with administration (such as data entry, record keeping, transcription and note-taking), research and the drafting of internal documents (such as investment memos).

5. If you choose not to provide your information

5.1 You can choose not to provide us with your personal information. However, this may mean we are unable to assess an Application, admit a Startup into the Program, engage you as a Partner, or otherwise provide our services to you.

6. How we collect, use and disclose your information

6.1 We will collect your personal information when you submit a contact form or an Application for Stellar, sign up to our newsletter or to an event, or participate in the Program, or otherwise engage with us and provide your information to us. We may also collect your personal information from third parties who have referred you to us.

6.2 We take reasonable steps to ensure your personal information is only accessible to people with a genuine need to know it. We may disclose your personal information, and you consent to us disclosing it, to our related bodies corporate, employees, service providers (including our professional advisers and the third-party platforms we use to host the Website, receive and manage Applications, manage our pipeline and run events), Partners engaged to support the Program (to the extent relevant to your participation), and any government or regulatory body.

6.3 Your personal information may be transferred or stored overseas, including where our service providers (such as data hosting or IT providers and the platforms described above) are based overseas. We take steps to ensure your information is handled by providers who maintain acceptable data protection standards. By providing us with your information, you consent to it being used, stored and disclosed overseas, and acknowledge that an overseas recipient may not be subject to the same privacy laws as apply in Australia.

7. Data security

7.1 Destruction and de-identification: We keep personal information only for as long as we need it for a purpose described in this Privacy Policy, and then destroy or permanently de-identify it, in accordance with APP 11, unless we are required or authorised by law to retain it.

7.2 Data quality and security: We take reasonable steps to ensure the personal information we collect, use, store and disclose is accurate, complete, relevant and up to date, and we recommend you keep us informed of any changes to your information. We take reasonable precautions (such as firewalls, encryption and access controls) to protect your personal information from loss, misuse or unauthorised access, but cannot guarantee its absolute security. We are not responsible for misuse, loss or unauthorised access to your personal information where this is not within our control.

7.3 Notifiable Data Breach Scheme: If we are required to comply with the Notifiable Data Breach Scheme under the Privacy Act, we will take reasonable steps to contain a suspected or known data breach and, where we have reasonable grounds to suspect it is likely to result in serious harm, complete an assessment within 30 days (or sooner if possible) in accordance with guidance published by the Office of the Australian Information Commissioner.

8. Your choices about your information

8.1 You may contact us to access, correct, update or delete your personal information. We may refuse a request to the extent permitted by law, including where granting access would have a negative impact on the privacy of another person.

8.2 You can ask us to stop sending you marketing communications at any time, including by using the unsubscribe function in our communications. If you opt out of marketing, we may still send you communications necessary to administer the Program or your Application.

9. Assignment, change of control and transfer

9.1 Our rights and obligations under this Privacy Policy are freely assignable by us to a related body corporate, or in connection with a merger, acquisition, restructure or sale of assets, and we may transfer your personal information to a successor entity or new owner as part of that transaction.

10. Changes to this Privacy Policy

10.1 We may change this Privacy Policy from time to time, and the most current version will be posted on the Website. If you continue to use the Website or participate in the Program after a change takes effect, you agree to the updated Privacy Policy. If a change is significant, we may provide a more prominent notice or seek your consent, as required by law.

11. Contact us

11.1 If you have any questions or complaints about this Privacy Policy, any privacy-related dealings with us, or a possible breach of your privacy, you can contact us at:

Stellar

Address: 201/115 High St, Armadale VIC 3143

Email: hello@stellarprogram.com.au

11.2 If you wish to raise a concern about our use of your information, you may also contact the Office of the Australian Information Commissioner at www.oaic.gov.au.

This Privacy Policy was last updated on 9 October 2026.