Privacy Policy for Always Exploring AB ("Stellar")

Last updated on Monday, 24 august 2020

1. General Information


Always Exploring AB, company registration number 559175-3107 having its registered address at Adolf Fredriks kyrkogata 3, 111 37 Stockholm, Sweden (“Always Exploring”we”, “us” or “Stellar”). This document contains a policy statement regarding Stellar’s collection, use and processing of personal data (“Privacy Policy”). This Privacy Policy is applicable when you sign up and use our website, web shop and application, collectively the “Services”.


All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws, including, to the extent applicable, the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.

2. About Stellar

Stellar is adigital intelligent personal trainer based on technology, such as computervision and artificial intelligence. When we provide the Services to you, we alsoprocess your personal data. Your privacy is important to us and we arecommitted to maintain your confidence in trust when we process your personaldata.

3. Data processed


When you create an account on the Services and during your use of the Services, Stellar will process the following personal data:(a) name;

(b) email address;
(c) telephone number;
(d) password;
(e) information about your use of the Services;
(f) technical data, which may include the URL you are accessing the Websitefrom, your IP address, unique device ID, network and computer performance,browser type, language and identifying information and operating system;
(g) location data, depending on the settings in your application;
(h) pictures/video you take of yourself on the Services;
(i) voice command recordings;
(j) wearables data;
(k) skeleton joint position; and
(l) other information that you may provide directly to us in connection withthe Services.


We are unable to provide you with the Services in their entirety unless you provide us with the personal data above.

4. Purposes of Processing and Legal ground


We will process the personal data set out above for the following purposes:


Your name, email address, telephone number, username and password will be processed

(a) to administer your account, to enable and provide the Services and integration with third party services, and to provide, personalize and improve your experience with the Services, and to otherwise provide the Services according to the Terms of Use based on the fulfilment of the contract we have with you about the provision of the Services;

(b) sending you alerts, information about updates as well as verifying accounts and activities, according to the Terms of Use; and

(c) to send you newsletters by email, including to provide you with marketing of our Services that may be of specific interest to you.

This processing is based on your consent.


Information about your use of the Services, location data, and technical data will be processed to improve and develop the Services or new services and to analyse your use of the Services based on our legitimate interest to improve and develop ourService and offer Services that cater to your needs.


Pictures and video of the data subject, voice command recordings and wearables data will be processed during your use of the Service in order to provide the Services according to the Terms of Use. To guarantee the best performance of the Services, we recommend you use the Service in a closed space where no other persons can interfere with the data collected by the Services.


We may have to process some personal data for the purposes of fulfilling legal requirements, such as invoicing data that will be stored for at least 7 years. In this case, our legal ground for processing will be a legal requirement by which we are bound.

5. Sensitive Personal Data

Some personal data, such as your skeleton joint position, pictures and or video of the data subject and wearables data, may include sensitive personal data and may be considered biometric information. Such sensitive personal data is always processed by us on a legal basis of explicit consent. We will use this data to analyse your use of the Services to provide you personalized instructions and recommendations to maximise your use of the Services, as well as conducting emotion recognition to improve and develop our Services or new services, provided that you explicitly consent to us processing your personal data for this purpose. As to such sensitive biometric personal data, we retain this data as set forth in Section9 below.

6. Disclosure of Personal Data


We may have to share and disclose your personal data to certain third parties for the above stated purposes within and outside the EU/EEA where you may have less legal rights in relation to your personal data as set forth in Section 6.2 and 7below.


Personal data collected from you may be shared with third-party providers of Always Exploring that process personal data on behalf of Always Exploring; such as server hosting providers, data storage providers, companies carrying out system and sales performance monitoring, customer support systems- and payment service providers. These service providers will be considered processors of your personal data. For more details regarding these providers please email

At times, some of your personal data may be transferred and processed to processors, as described above, that are established in the United States or other countries (some of which will be outside the EEA). We may also transfer your personal data in the event that our business (or part of it) is sold, for instance as part of a merger or acquisition or asset sale in bankruptcy or similar proceedings. Always Exploring will always apply safeguards to protect your personal data from unauthorized disclosure. In case of transfer of data to third parties that are outside of the EU or EEA and that do not offer an adequate level of data protection, Always Exploring will apply the EU Commission’s model clauses or similar instruments/mechanism, for the safeguarding of integrity and security.

7. Responding to Legal Requests and Preventing Harm

We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.

8. Cookies, Pixels and Other System Technologies

We collect information by using technology such as cookies, pixels and tags (on your browser or device).For information about how we use these types of technologies, please see our cookie policy.

We do not respond to browser “do not track” signals.

9. Retention

We store your personal data for as long as necessary to perform the Services, unless there isa legal obligation to store the data for longer or for a shorter time period.The personal data is deleted or aggregated and anonymised when it does not longer fulfil the purpose stated in this Privacy Policy.

10. Children

The Services are not directed to persons under the age of thirteen (13) and we do not knowingly collect personal data from children under the age of thirteen (13). If you area parent or guardian of a person under the age of thirteen (13) and you become aware of that the child has provided personal data to us without your consent, please contact to exercise your access, rectification, erasure, limiting of processing and objection rights (and in such a situation, we will cease processing such data).

11. Your Rights


You have an absolute right to object to the processing of your personal data for direct marketing. You also have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal, and we may continue processing your personal data based on other legal grounds, except for direct marketing.


You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.


If the processing is based on the legal grounds consent or fulfilment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to other data controllers.

12. Contact Information


To exercise the aforementioned rights, or if you have any questions about our sharing practices, your rights under applicable law, or wish to have your personalinformation removed, please contact us at:

Always Exploring AB
Adolf Fredriks kyrkogata 3
111 37 Stockholm, Sweden

In order to ensure that you receive a swift response, please state your full name and the email address used for registration. Note that you should sign the request to receive information of the processing of your personal data yourself.


If you have any complaints regarding our processing of your personal data and you are located in the EU, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link:

13. Notice of Changes to the Privacy Policy

If we make changes to this Privacy Policy, we will notify you by e-mail and in the application. If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.

14. Notice to Nevada Consumers

We do not sell your Personal Information within the scope of, and according to the defined meaning of a “sale” under, NRS 603A.