Estonia Privacy Policy

Last Modified on September, 2018

 

Who we are

Starship Technologies OÜ (“Starship EE,” “we,” “us” or “our”) is the heart of the Starship Group (“Starship Group”). Various members of the Starship Group offer package delivery and other related services in various countries across the globe via autonomous robots – as of now in Germany, Great Britain, Switzerland, Netherlands, Finland and Estonia. Most of these robots are operated from the Starship EE operations center in Tallinn, Estonia.

Our Privacy Commitment

 

Starship EE is committed to respecting the privacy rights and concerns of all users of websites and mobile applications deployed by various Starship Group members (websites and mobile applications collectively named as the “App”) and the services made available by various Starship Group members and their partners (collectively with the App, the “Service”). While Starship EE rarely provides the Service directly to you we feel that is only right that we provide an overview of how your personal data is processed.

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:

  • How do we collect data about you?
  • 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?

How do we collect data about you?

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.

Starship EE collects your personal data in one of two possible ways:

  • directly from you in cases where Starship EE is providing a Service to you directly by App;
  • from other Starship Group members or partners of Starship EE where the Services are made available by various Starship Group members or their partners.

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.

The types of personal data we may collect from you include your name, email address, billing address, phone number, and credit card type or other payment information. We may also collect non-personal information such as your mobile device type, when you accessed the Service and from what location you access the Service.

The cameras and sensors on Starship robots do not allow recording in sufficient quality to allow identification of any natural persons, and as such the robots themselves do not record or process personal data. Even so, Starship EE takes upmost care to guarantee safety and confidentiality of any images or location data collected via the robots.

Third-Party Privacy Policies

Through the Service, you may be able to access technology, software and services owned and controlled by third parties (“Third-Party Features”) by clicking on a third-party logo or URL displayed via the Service. Third-Party Features may collect information about you when you communicate with them. Such use of Third-Party Features and submission of information through Third-Party Features will be subject to applicable third party’s terms of use, terms of service and privacy policy. In this case our Privacy Policy and Terms of Use no longer apply. You agree to approach only the relevant third party and not  Starship EE to enforce your rights in relation to your personal information.

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. This includes package delivery; 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. If it is not stated in this Privacy Policy or if we do not have your consent, we will not share your personal information with any person or entity other than entities belonging to the Starship Group, 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.

Before we use your personal information for a purpose that is substantially 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.

We may use anonymized data about your orders and use of Services for Analytical purposes (the “Analytical Data”), for example, 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.

Log Information

Our servers automatically record information that your device sends whenever you use the Service. This information includes, among other things, your Internet Protocol (IP) address and device type, 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: these help us to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the Service. Logs may also be monitored for unauthorized activities.

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

The personal information we have gathered about you will be shared only with authorized persons under the following circumstances:

  • Service Providers. We share your personal information with service providers (including members of Starship Group 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.
  • 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 EE operates robots in Germany, Finland, Netherlands, Great Britain and Switzerland. While providing support services for us, these group members may access your personal information.
  • Logistics Partners. We share your personal information with reputable business partners to whom we provide carriage service either in a testing or service capacity.
  • 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, legal process, such as a court order, or a request by law enforcement or governmental authorities; (ii) such action is appropriate to enforce our Terms of Use for the Service (where applicable), including any investigation of potential violations thereof; (iii) such action is necessary to detect, prevent, or otherwise deal with fraud, security or technical issues associated with the Service; or (iv) such action is appropriate to protect the rights, property or safety of Starship EE, its employees, users of the Service or others.
  • Asset Transfers. If we become involved in a merger, acquisition or other transaction involving the transfer of some or all of Starship’s assets, the information collected from you 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). Where applicable, we will enter into written agreements with such third parties.

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. 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 Tallinn, Estonia, 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. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. Nevertheless, once we receive a transmission from you, we will endeavor to maintain its security on our systems.

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.

Data Protection Officer – Questions or Complaints

Starship EE has appointed a Data Protection Officer (“DPO”) to mediate any questions or complaints you may have and also to facilitate the usage of data subject rights under the GDPR. You can contact the DPO by writing to us at data-protection@starship.xyz.

You can direct any questions or complaints about the use or disclosure of your personal 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 personal data within thirty (30) days of receiving your complaint.

Notification of Changes

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

Terms of Use

Please read the Terms of Use governing the use of the Service (where applicable).