USA Privacy Policy

Last Modified on May 25, 2018

Our Privacy Commitment

 

Starship Technologies, Inc. (“Starship,” “we,” “us” or “our”) is committed to respecting the privacy rights and concerns of all users of Starship’s mobile application (the “App”) and the services made available by Starship (collectively with the App, the “Service”). As such, we have established and implemented this Privacy Policy to inform users of the Service how we use and protect the information we collect through the Service. By using the Service, you consent to Starship’s collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy. This Privacy Policy is effective as of the date set forth above and is only applicable to the Service and not to any other website that you may be able to access from the Service which may have its own data collection and use practices and policies.

 

This policy answers the following questions:

  • What information do we collect about you and how do we use it?
  • Will we share your personal information with third parties?
  • What choices do you have about the collection and use of your personal information?
  • What security measures do we take to safeguard your personal information?

 

What Information Do We Collect About You and How Do We Use It?

 Types of Information We Collect

 

Personal information means information that can be used to identify and contact you. You do not need to submit personal information to access the Service generally. However, you may be required to submit personal information to access certain aspects of the Service. We may also collect non-personal information such as your mobile device operating system, when you accessed the Service and from what location you access the Service. This information may be aggregated to measure the number of visits, average time spent, page views, and other statistics about users of the Service. We also may use this data to monitor the Service’s performance and to make the Service easier and more convenient to use.

 

We collect personal information when you purchase a product; subscribe to our newsletter; receive customer or technical support; or participate in components of the Service through which users may post content. The types of data we may collect from you include your name, email address, billing address, phone number, and a credit card number or other payment information.

 

By submitting personal information through the Service, you authorize Starship to share this personal information for the purposes identified herein, such as responding to user inquiries, processing transactions, distributing materials, and requesting feedback.

 

Third-Party Privacy Policies

 

Through the Service, you may be able to link to technology, software and services owned and controlled by third parties (“Third-Party Features”). You may be permitted or required to submit personal information to access Third-Party Features. Such use of Third-Party Features and submission of information through Third-Party Features will be subject to such applicable third party’s terms of use, terms of service and privacy policy. You agree to look solely to the applicable third party and not to Starship to enforce your rights in relation thereto. When you have clicked on a third-party logo or URL displayed via the App, or accessible through the Service, which links you to any Third-Party Features, our Privacy Policy and Terms of Use no longer applies and you must read the terms of use, terms of service and privacy policy of the third party to see how your personal information will be handled on their website.

 

How We Use Your Personal Information

 

The personal information you provide to us will allow us to communicate with you and provide the Service to you, depending on the aspects of the Service for which you register. This includes processing orders; handling your customer service questions or issues; alerting you of new products, services, features, or enhancements to the Service; verifying your identity; requesting feedback; and distributing newsletters. We may also use your email address as part of the Service in sending you messages about the Service and other general announcements. We keep track of your interactions with us, including but not limited to your activity within the Service. Except as set forth in this Privacy Policy, or unless we have your consent, we will not share your personal information with any person or entity other than those affiliated with us, entities acting on our behalf, and relevant third parties such as those needed to collect and maintain our servers and perform technology and related services.

 

We may use your personal information with non-personal information that we have collected in a manner such that the end-product does not personally identify you or any other user of the Service. We may make your personal information non-personally identifiable by either combining it with information about other users (aggregating your personal information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information. You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your personal information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect in providing the Service (the “Analytical Data”). We are expressly authorized to make any commercial use of the Analytical Data, including without limitation, sharing the Analytical Data with third parties, provided that we do not sell, trade, or otherwise transfer from us any part of the Analytical Data that personally identifies any Service users.

Segment

 

Starship uses Segment to help us learn about who uses the Service and how they use it.

Log Information

 

Our servers automatically record information that your mobile device sends whenever you utilize the Service. This information includes, among other things, your Internet Protocol address and mobile device operating system, which aspects of the Service you use and from where, and when and how long you use them. We use this information to monitor and analyze how users use the Service, to provide customer service and to maintain and improve the Service. We may also collect similar information from emails we may send to you which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

Children’s Privacy

 

We do not knowingly collect personal information from children under 13, or allow them to access the Service. We take children’s privacy seriously, and encourage parents to play an active role in their children’s online experience at all times.

 

Will We Share Your Personal Information with Third Parties?

Sharing Your Information

 

We use your personal information to provide the Service to you, deliver products and services you request, complete transactions, handle your customer service questions or issues and send communications to you about promotions, updates, or special offers from Starship that may be of interest to you. The personal information uploaded by you through the Service will be shared only with authorized persons to whom you specifically grant access. We may also use your depersonalized personal information to provide analyses of our users in the aggregate (including Analytical Data subject to the terms of this Privacy Policy) to prospective partners and other third parties. We will also share the personal information we collect from you under the following circumstances, and you expressly authorize us to share your information as follows:

 

  • Service Providers. We may share your personal information with service providers (including our affiliates that provide services on our behalf) that we engage for the purpose of processing information on our and your behalf. Additionally, we may partner with other companies to process, analyze, and/or store data, including, but not limited to, Analytical Data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these parties to comply with this Privacy Policy and appropriate confidentiality and security measures. Where required by the Privacy Shield (as defined below), we enter into written agreements with such service providers requiring them to (i) provide the same level of protection the Privacy Shield requires and (ii) limit their use of the data to the specified services provided on our behalf.
  • Other Starship Group Members. Starship group members provide support services for each other, which are necessary for providing services to you. This includes cases where Starship operates robots in the EU or vice versa. While providing support services for us, these group members may access your personal information. To the extent applicable, we require these parties to comply with this Privacy Policy and appropriate confidentiality and security measures. Where required by the Privacy Shield (as defined below), we enter into written agreements with group members requiring them to (i) provide the same level of protection the Privacy Shield requires and (ii) limit their use of the data to the specified services provided on our behalf.
  • Pilot Program and Other Business Partners. We may share your personal information with pilot program partners or other reputable business partners whose products or services may be of value to you. To the extent applicable, we require these parties to comply with this Privacy Policy and appropriate confidentiality and security measures. Where required by the Privacy Shield, we will enter into written contracts with any such unaffiliated third-party data controllers requiring them to (i) provide the same level of protection for your personal information the Privacy Shield requires and (ii) limit their use of your personal information so that it is consistent with any consent you have provided and with the notices you have received.
  • Protection of Rights. We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce our Terms of Use for the Service, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iv) such action is appropriate to protect the rights, property or safety of Starship, its employees, users of the Service or others.
  • Asset Transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of Starship’s assets, user information, including personal information collected from you through your use of the Service, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you through email and/or a prominent notice displayed via the App.

 

Where we do share your information with third parties, we will require such third parties to comply with this Privacy Policy and maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with regulatory authorities or courts). In addition, we take reasonable and appropriate steps to ensure that third parties process your personal information in accordance with our Privacy Shield obligations, where applicable, and to stop and remediate any unauthorized processing of your personal information. Before we use your personal information for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. In such a case we will notify you about those activities and offer to opt out via email. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf with respect to their handling of personal information that we transfer to them pursuant to the Privacy Shield.

Additional Information You Should Know About Third Parties

The Service may contain direct links to websites operated by our partners and other entities. These third-party websites may collect information about you when you visit them or otherwise communicate with them. This Privacy Policy does not cover the information practices of third-party websites accessible through the Service. Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information. You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.

What Choices Do You Have About the Collection and Use of Your Personal Information? 

Control of Your Information

 

You may update or request rectification or deletion of your personal information stored by Starship by writing to us at data-protection@starship.xyz. Additionally, you may have the right to access the Privacy Shield Data (as defined below) that we hold about you, provided that granting such access is not unreasonably burdensome or expensive under the circumstances and that it would not violate the rights of someone other than the individual requesting access. If you would like to request access to your Privacy Shield Data, you can submit a written request to the email address provided above. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Opting Out of Receiving Communications From Us

 

If you no longer want to receive our newsletter, emails or other announcements, you may unsubscribe by writing to us at info@starship.xyz or following the “unsubscribe” link at the bottom of our emails. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account.

Mediation

 

You agree that, in the event any dispute or claim arises out of or relating to this Privacy Policy, you and Starship will attempt in good faith to negotiate a written resolution of the matter directly between the parties. You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Los Angeles, California, United States of America or Tallinn, Estonia, whichever is closest to you, with a mutually agreed mediator in an attempt to resolve the dispute. Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorneys’ fees, even if you would otherwise be entitled to them.

 

What Security Measures Do We Take to Safeguard Your Personal Information?

The personal information that you provide to us is stored on servers which are located in secured facilities with restricted access, and protected by protocols and procedures designed to ensure the security of such information. We restrict access to personal information to Starship employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Service. Access to such personal information is minimized whenever possible. Logs are kept of access to application data. Logs include information on individual page views and user level. Logs can be monitored for unauthorized activities. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of the Service and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems. Additionally, we do not receive payment information such as your credit card number, and only retain the secure token relating to your payment information provided by our payment processor for a limited period after a transaction is completed.

 

In the event that personal information you provide to us is compromised as a result of a breach of security, when appropriate we will take reasonable steps to investigate the situation, notify you and take the necessary steps to comply with any applicable laws and regulations.

 

Robot Data Processing Policy

While we do not process any visual personal data we still maintain a high standard for storing and using any video material the robots may collect in their operation.

 

Access to customers’ personal information is limited by high grade commercial cryptography with mutual certificate-based authentication to the server that also provides transport security between our operators and the Service. No customer data is ever transferred on data carriers and is digitally transferred only through digital transport mechanisms that guarantee transport security.

 

Starship’s robots have on-board low level technical telemetry and sensors (including medium-resolution visual sensors) that serve as a black box, which will allow reconstruction and improvement based on possible incidents. The retaining horizon of visual sensor data is no longer than four hours. The vast majority (98-99.5%) of data is not retained.

 

Medium-resolution images are only retained in brief slices (typically 2-20 seconds) in a fraction of cases to improve robot safety and behavior. The Amazon S3 data is encrypted using a strong encryption algorithm (currently AES256) with Amazon EC2 providing encryption and key management (storing and protecting keys). These are used for system training in segregated environments and all annotation is done based on obfuscated images. Very low resolution obfuscated video allows basic analysis without details being distinguishable.

 

In case of legal requests (as such term is generally understood under the laws of the European Union) or in rare cases of Starship’s valid business reasons that cannot be solved by other means, medium-resolution unobfuscated images may be retrieved by authorized personnel and an audit trail will be kept. During driving, low-resolution images are transmitted to the robot operator for the purposes of safe operation. These images have low quality and they are obfuscated above the horizon during sidewalk driving, making people unidentifiable. During road crossings, obfuscation is disabled for added safety.

Privacy Shield

 

Starship recognizes that the European Economic Area and Switzerland (collectively, the “Privacy Shield Jurisdictions”) have established strict protections regarding the handling of certain personally identifiable information that we receive in the US from the Privacy Shield Jurisdictions (“Privacy Shield Data”), including requirements to provide adequate protection for Privacy Shield Data transferred outside of the Privacy Shield Jurisdictions. To provide adequate protection for certain Privacy Shield Data about consumers and suppliers received in the US, Starship has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, in each case administered by the US Department of Commerce (collectively, the “Privacy Shield”). Starship adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

 

For purposes of enforcing compliance with the Privacy Shield, Starship is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at www.privacyshield.gov. To review Starship’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at www.privacyshield.gov/list.

Questions or Complaints

 

You can direct any questions or complaints about the use or disclosure of your Privacy Shield Data to us at data-protection@starship.xyz. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Privacy Shield Data (a “Privacy Shield Complaint”) within forty-five (45) days of receiving your complaint. Notwithstanding anything to the contrary contained in this Privacy Policy, we have agreed to cooperate with JAMS with respect to any unresolved Privacy Shield Complaints. If you are unsatisfied with the resolution of your complaint, you may contact JAMS at www.jamsadr.com/eu-us-privacy-shield for further information and assistance. You may have the option to select binding arbitration for the resolution of your Privacy Shield Complaint under certain circumstances, provided you have taken the following steps: (1) raised your Privacy Shield Complaint directly with Starship and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism provided through JAMS as identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Notification of Changes

This Privacy Policy may change from time to time and we will post all changes via the App.

Questions? Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at data-protection@starship.xyz.

Terms of Use

Please read the Terms of Use governing the use of the Service.