Global Privacy Policy

Starship Technologies Privacy Policy

Last updated May 9, 2023

 

Starship Technologies, Inc. and its subsidiaries and affiliates (collectively “Starship,” “us,” “we,” or “our”) are committed to protecting your privacy and providing you with a positive experience while using our websites and services.

About this policy 

This Privacy Policy explains the types of information that Starship collects about you, how we use, share, and protect this information, and the choices you can make about how we use and share this information. This Privacy Policy governs information collected by Starship by any means, including, but not limited to, websites, mobile applications, and other online services that refer or link to this Privacy Policy, as well as information collected by other business functions of Starship, such as through our customer loyalty programs or when you speak with a customer service representative (collectively, the “Services”).

It is important that you read this Privacy Policy carefully, because any time you use our Services you consent to the practices we describe in this Privacy Policy. In the event of any inconsistencies between the English-language version of this Privacy Policy and any local language version that we make available, the English-language version will prevail.

As permissible by law, Starship reserves the right to make changes to this Privacy Policy. If changes are made, updates will be reflected by the Last Updated date at the top of this Privacy Policy. These changes will take effect immediately upon posting. By continuing to use the Services following such changes, you will be deemed to have agreed to such changes.

Our Services may link to third-party websites and services that are outside our control.  We are not responsible for the security or privacy of any information collected by such third parties.  You should exercise caution, and review the privacy statements applicable to such third parties.

Please note that some privacy rights and obligations may differ in certain locations based on local law, in which case we will comply with the local legal requirements.

What data do we collect?

Starship only collects personal information for an appropriate lawful reason. We use, process, and share it only for the purposes for which it was collected. Types of data we may process include but are not limited to the following:

+ Information You Provide to Us

Your location

We need to know your location to better show you information about merchants nearby. We also need to know and store your address or delivery location so our robots can deliver you food or groceries. 

Your identity and contact information

We need to know your phone number in order to communicate with you about the delivery, and to contact you about any problems or questions related to the service. Your phone number also serves as our primary identifier of you as a customer, allowing you to get consistent service and retain your preferences and payment method in case you switch the device that you use for the service. 

We need to know your email address in order to send you receipts. We’ll also use your email address to show you marketing and special offers, if we’ve received any necessary consent. We may occasionally send you surveys or other requests for feedback.

Your order and payment history

We will keep information about your past orders, payments, and preferences in order to make future orders faster and more convenient.

Your name, billing address, payment card and other payment information

We will keep your payment card details in order to make paying for future orders faster and more secure. 

Starship does not access or store the full credit data itself. We use secure payment processing partners who are certified according to the Payment Card Industry Data Security Standard to process and store all credit card data of our customers. 

Your age verification data

Certain items we deliver have legally-mandated age restrictions. If you place an order for such items, we must validate your age. To do so, our service provider Veriff may request and validate the following categories of information:

  • Information extracted from your identification document, for example name, sex, national identification number, date of birth, estimated age;
  • Document details, such as the name of the document, issuing country, number, expiration;
  • Photos (selfies) you provide of yourself and your document;
  • Data, such as face scans and other measurements, extracted from the photos you provide which are used to authenticate you or compare your face to identity document photos; and
  • Technical data about your device, including but not limited to information about your activity in the Services, IP address, software and hardware attributes of your device, and general geographic location (e.g. city, state, country).

We may store your information in order to make your future orders of age-restricted items faster and more convenient.

Other information you provide 

You may provide information about yourself when you communicate with us for customer support purposes, when you give us feedback or interact with us on social media, when participating in our loyalty programs, or when communicating with us to assist our investigation into incidents involving a robot.

You can choose not to provide us with certain types of information but doing so may affect your ability to use some of the Services.

+ Information We Collect Automatically

Device data

We log some technical information when you access and use the Services. This may include, for example, your web browser, your operating system, your push notification token, your IP address, your device service area, your device ID and other data that uniquely identifies your device. 

Interaction data

This is information about your interaction with our Services; for example, your browsing or shopping behavior when using our Services, the amount of time you spent on a page, the buttons and links you click, where you came to our website or app from, and where you go when you leave. We may also collect data on your interaction with our online marketing, such as whether you click on Starship advertisements while browsing the internet, or open emails from Starship.  

Cookies and tracking technologies

We and our service providers use cookies on our website and similar technologies such as SDKs in our app. We may also share information about your use of our website and app with our social media, advertising, and analytics service providers. We use this information to improve your experience, improve the quality of our Services, measure the effectiveness of our marketing communications, and provide you with relevant online advertising, including by using social media. By using our online Services, you are consenting to our use of the technologies described in this Privacy Policy. 

Our key service providers are listed below with information about the services they provide to us. This list is not exhaustive, but rather includes partners whose cookie and similar technologies are most frequently deployed through our Services. 

  1. Analytics and personalization of our Services: Google Analytics, Amplitude, Appsflyer
  2. Marketing via social media: Meta Inc.
  3. Function of our Services: Google Maps, Zendesk

Cookies vary in how long they last. “Session Cookies” terminate shortly after you terminate your internet session. “Persistent Cookies” are stored on your device until a set expiration date. We use both Session Cookies and Persistent Cookies on our website.

We may collect additional information about you in accordance with applicable law. All the information we collect about you may be combined to help us enhance and improve our products and services and tailor our communications to you.

Images and videos captured by Starship robots

In order to drive autonomously and avoid obstacles, Starship robots use various sensors, including cameras. Some of these cameras capture video data from the robot’s delivery journey on sidewalks. This data comes in two basic forms: (1) a live-streaming video feed and (2) a recording of video footage onto the robot’s hard drive. The live-streaming video feed (obfuscated as described below) is occasionally accessed by remote assistants to navigate the robot in the event the robot encounters an unexpected situation. The recording is used for software testing and improvements, for incident analysis, and to continuously enhance the safety of the robot’s operation. 

Starship is sensitive to the importance of privacy.  The objective of the technology within the robots is to enable obstacle detection and navigation. Starship does not need or wish to proactively identify individuals. For this reason, we’ve implemented features aimed at minimizing any incidental recording of identifiable people, including low resolution quality recordings, fixed cameras showing only knee level and below, and various obfuscation techniques. Most images collected by the robots are deleted after 60 days; we may retain a tiny minority of data collected for a longer period to allow for further analysis.  Starship’s robots don’t capture or record any conversations or audio data.

In certain situations involving the prevention or detection of a crime, we may share limited data collected from our robots with law enforcement officials, subject to applicable law and Starship policy.

What purposes and lawful bases do we have for personal data processing?

Data Purpose of processing Lawful basis of processing
Your location, identity, and contact information

Your payment card and other payment data

Order placement and processing, and delivering you the requested products Performance of contract
Your order and payment history  Providing you a faster, more convenient service Performance of contract
Your age verification and identity document data, including device signature information and extracted biometric data we use for identification To verify your age and identity when selling you age-restricted items Legal obligation 
Your email address To send you marketing emails and to otherwise advertise to you Consent
Device and interaction data To advertise to you, customize your experience with our Services, improve your shopping experience, and conduct internal analyzes Legitimate interests
Incidental recordings of identifiable individuals In rare cases, our robots may collect images of someone who might be identifiable from the images. While this is not the purpose of the technology, this may constitute personal data processing under applicable law Legitimate interests

What are your rights?

We always strive to make sure that our information about our customers is reliable, accurate, and up-to-date. You have rights concerning your personal information including but not limited to the rights listed below.

The rights listed and described below are mandated by GDPR in Europe (EEA and the UK)

+ Right of access 

You have the right to ask us for a copy of your personal information.

+ Right to rectification

You have the right to ask us to rectify personal information that you think is inaccurate. This also includes the right to ask us to complete information you think is incomplete.

+ Right to deletion

You have the right to request deletion of your personal data. You can do this by clicking “Request to delete my info” in the “My details” section in the app. You can also e-mail data-protection@starship.co with your request and full name. 

Please keep in mind that we cannot delete any data that we process to fulfill contractual or legal obligations.

+ Right to data portability

You have the right to request to port your data to a similar service or to yourself to the extent this is technically feasible.

+ Right to withdraw consent

In circumstances where we ask for consent from you for processing your personal data, you have the right to withdraw consent. You can do this by clicking the “Unsubscribe” link in any marketing emails we send and/or by opting out of marketing emails and push notifications in “Marketing Preferences” in the app.

+ Other rights

As stipulated by the GDPR, you also have a right to: i) request restriction of processing of your personal data and ii) object to the processing of your personal data. 

+ How to exercise your rights?

To exercise any of the rights listed above, please take the steps described or e-mail data-protection@starship.co with your request and full name. 

Please be aware that in order to accommodate some requests, we must verify your identity before we can respond. 

Who do we share your data with?

Starship may share personal information with:

  • Starship’s subsidiaries, affiliates, and other related companies for the purposes listed above.
  • Service providers and business partners for the purposes of operating our business, improving and customizing our Services, sending marketing and other communications, payment processing, and for other legitimate purposes permitted by applicable law, or otherwise with your consent. 
  • If permitted by applicable law and with your consent where required, we may provide your information to third parties who may send you marketing relating to their products and services.

There may also be instances when Starship discloses your personal information to:

  • comply with the law or in response to a court order, government request, or other legal process;
  • protect the interests, rights, safety, or property of Starship or others;
  • protect against fraud or for risk management purposes;
  • respond to adverse third parties in the context of litigation.

In addition, if Starship sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, you acknowledge that Starship may transfer your personal information to a third party as part of that transaction.

In all cases Starship requires all unaffiliated third parties to treat personal information as confidential. 

Do we transfer your data across borders?

As a global organization, we may transfer your personal information to Starship affiliates, agents, contractors, service providers, and to third parties in various countries around the world. Please note that other countries’ data protection and other laws may not be as comprehensive as those in your country. In accordance with applicable law, we implement measures such as standard data protection clauses to ensure that any transferred personal information remains protected and secure. Where relevant, we may also rely upon adequacy decisions to lawfully transfer personal information.

Do we keep your data secure?

Starship has physical, administrative, and technical safeguards in place to help protect your personal information. While there is no such thing as perfect security on the Internet, we will take reasonable steps to keep your personal information secure.

How long do we keep your personal information?

Starship takes steps to retain your personal information only for so long as is needed to fulfill the purposes for which it was collected, as required under contract, or as required by or as permissible under applicable law. 

Do-Not-Track Signals and Similar Mechanisms 

Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. Starship currently does not take action in response to these signals. 

Contact Information

Starship can be contacted any time by e-mail at data-protection@starship.co

We can also be contacted by our customer support channels available in our mobile application, or by mail at Starship Technologies, Inc., 535 Mission St 14th FL, San Francisco, CA 94105

According to the EU General Data Protection Regulation 2016/679, we must let you know the controller of your personal data. Controller is a natural or legal person or public authority which determines the purposes and means of the processing of personal data.

If you use any of the Services in Estonia, the provider of the Services and the controller is Starship Technologies OÜ, registry code 12673365, registered at Estonia, Tallinn, Teaduspargi street 8, 12618. We’d like the chance to resolve any concern you have; however, should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Estonian Data Protection Inspectorate (in Estonian: Andmekaitse Inspektsioon; https://www.aki.ee/et). 

If you use any of the Services in the U.K., the provider of the Services and the controller is Starship Technologies Ltd., a company incorporated in England & Wales (registered no. 10071803), whose registered office is at Units B3/C+E, Denbigh Business Park Building B 23 First Avenue, Milton Keynes, Bucks, MK1 1DN. We’d like the chance to resolve any concern you have; however, should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the U.K. Information Commissioner’s Office at ico.org.uk.