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 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
How We Use Your Personal Information
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.
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.
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.
- 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.
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 firstname.lastname@example.org. 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 email@example.com 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.
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 firstname.lastname@example.org.
You can direct any questions or complaints about the use or disclosure of your personal data to us at email@example.com. 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