Data Processing Agreement

pursuant to Article 28 of Regulation (EU) 2016/679 (GDPR)

This Agreement forms an integral part of Stello's Terms and Conditions of Service and applies when the User, in using the Service, entrusts Stello with the processing of personal data for which the User is the data controller.

1. Parties and Roles

  • Data Controller: the User who uses the Service for their own business.
  • Data Processor: Stello Systems S.r.l., Via Generale Vincenzo Streva 62, 90143 Palermo (PA), VAT number and tax code 07450120824, email ciao@stello.it.

2. Subject Matter and Duration

Stello processes personal data on behalf of the User exclusively in order to provide the Service: hosting, processing, translating, publishing and making available the content entered by the User. The processing lasts for the entire duration of the account.

3. Categories of Data and Data Subjects

  • Data subjects: employees and collaborators of the User, Final Customers and other persons whose data the User decides to enter in the Service.
  • Data: identification and contact data, images, texts and other content entered by the User. The Service is not intended for the processing of special categories of data (Art. 9 GDPR); the User undertakes not to enter them.

4. Obligations of Stello

Stello undertakes to:

  • process the data only on the documented instructions of the User, consisting of the Terms and the use of the features of the Service;
  • ensure that the persons authorised to process the data are bound by confidentiality;
  • adopt appropriate technical and organisational measures pursuant to Article 32 GDPR, including encrypted connections, access controls, secure authentication, backup and monitoring;
  • assist the User, as far as possible, in responding to requests from data subjects and in fulfilling the obligations under Articles 32-36 GDPR;
  • inform the User without undue delay after becoming aware of a personal data breach affecting the User's data;
  • make available the information necessary to demonstrate compliance with this Agreement.

5. Sub-processors

The User authorises Stello to engage the following sub-processors:

ProviderService
Supabase Inc.Database, authentication and data infrastructure
Vercel Inc.Hosting and web infrastructure
Anthropic PBCAI features: translations, parsing, reports
Resend Inc.Sending of transactional emails

Stello imposes on sub-processors data protection obligations equivalent to those of this Agreement and informs the User of any changes to the list by updating this page. The User may object on legitimate grounds by writing to ciao@stello.it; in the event of an objection, the User may cancel the Service.

6. International Transfers

Where sub-processors process data outside the European Economic Area, transfers occur on the basis of adequacy decisions, Standard Contractual Clauses (SCCs) or other mechanisms provided for in Articles 44 et seq. of the GDPR.

7. Deletion of Data

Upon termination of the account, Stello deletes the data processed on behalf of the User within 90 days, unless legal retention obligations apply. Before deletion the User may export their content through the available features or request it from ciao@stello.it.

8. Contact

For any request relating to this Agreement: ciao@stello.it.