Global Privacy Policy

Global Privacy Policy

 

Last Modified on 11 May 2022

 

Starship Technologies Privacy Policy

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 or services.

Starship is providing a delivery service using a fleet of autonomous robots. The robots operate in a variety of urban and suburban environments. They have been designed to be safe both for people and for all types of traffic. Our service and the delivery robots comply with safety and privacy laws and regulations of all countries, municipalities and environments where the service is provided.

Who does this policy apply to?

This Policy applies to Starship services, application and website (together “Services”). It provides you with guidance on your rights and obligations in relation to your personal information.

Starship’s Privacy Policy (the “Privacy Policy”) establishes and communicates the key principles that Starship follows in protecting the personal information that we collect. 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.

Who is the Controller or Processor of your personal data?

According to the EU General Data Protection Regulation 2016/679 (hereinafter “GDPR”) 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. A processor is a natural or legal person or public authority which processes personal data on behalf of the controller.

Starship could be either the controller or processor of your data. When you subscribe directly to the Services, then Starship is the controller of your personal data processed in the context of providing you the Services. Where the seller of food or groceries processes your personal data (e.g., in order to fulfil the sales agreement entered into between you and the seller), the seller is the controller of your personal data and this Privacy Policy does not apply to such processing. The seller’s privacy policy can be reached by visiting the seller’s website or otherwise as made available by the seller.

When you access our Services through a Starship partner, the controller of your personal data is the partner and Starship is the processor. 

If you use any of the Services in Estonia, the provider of the Services (and the controller or processor as applicable, as set forth above) 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 Finland, the provider of the Services (and the controller or processor as applicable, as set forth above) is Starship Technologies Oy, registry code 2837415-1, registered at Laivakatu 3 00150 Helsinki Finland. 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 Office of the Data Protection Ombudsman at www.tietosuoja.fi. 

If you use any of the Services in the U.K., the provider of the Services (and the controller or processor as applicable, as set forth above) 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.

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

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.

+ Information You Provide to Us

Your location

We need to know and store your address or delivery location for the robot to deliver you the food or groceries. 

Your phone number 

We need to know your phone number in order to notify you about the delivery, and for contacting you about any problems or questions related to the service. The phone number also serves as the primary identification of you as a customer, allowing you to get a consistent service and retain your preferences and payment methods in case you would switch the device that you use for the service. 

Your email address

We need to know your email address in order to send you receipts of your orders and payments. 

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 payment card and other payment method 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 being sold and delivered by our services have legally mandated age limits. For orders containing such items, we must validate and store the age of a corresponding customer. This requires us to request, validate and store a visual copy of your identity documents.

Required data

As a general rule, submission of personal data by you is required in order to conclude the agreement between us or for the provision of the Services to you. For example – we need your e-mail address in order to provide you the Services. Therefore, if such personal data is not provided, we cannot provide the Services to you. However, if the submission of personal data is not made mandatory in the app (or otherwise) then the submission of such personal data is not required (it is voluntary) and non-submission does not have any direct adverse consequences for you, although some functionalities of the Services may be limited.

+ Information We Collect Automatically

Log and usage data

We log some technical information when you access and use the Services. This may include your IP address, data about your device and your web browser. 

Information collected from cookies and tracking technologies

We use cookies on our website and similar technologies in our app. We use this information to improve your experience and improve the quality of our Services. 

Images and videos captured by Starship robots

Our robots are equipped with multiple cameras and other sensors that allow them to drive around and to detect obstacles, traffic and pedestrians around them. Some of this imagery may be transmitted to Starship operations centres or stored for later analysis in order to enhance the safety and efficiency of our robots in the traffic.

We do our best to not collect or store any personal information or identifiable images of people on those videos. We blur all images of people on those videos, and we blur the video feed from robot cameras when the robots are driven with the assistance of an operator.

Starship robots don’t record or capture any conversations or audio data.

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

Data Purpose of processing Lawful base of processing
Your location

Your phone number 

Your email address

Your transactional and payment method data

 Order placement and processing, and delivering you the requested products Fulfilment of contract
Your order history and service preferences Providing you a faster, convenient service Fulfilment of contract
Your age verification and identity document data To verify your age when selling age-limited items Legal obligation 

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 personal information about you. Please see the list below to see what rights these are and how to exercise them.

Starship never sells personal information to third parties.

The rights listed and described below are mandated by GDPR in Europe (EU, EEA and the UK) and CCPA in California. We are making those options available to all our users and customers regardless of their geographic location of residence.

+ Right to be informed

You have the right to receive information about what data we capture, process and store about you. 

Information requests typically include:

  • The categories or specific types of personal information we have collected.
  • The business purpose for collecting, disclosing, and/or selling the information.
  • The sources from which personal information was collected.
  • The categories of third parties with whom we share personal information.
  • The criteria used to determine the time that personal information will be held.
  • The existence of automated decision-making, including profiling that uses your personal information.
  • The safeguards we’ve applied to protect your information when it is transferred internationally.

+ Right of access 

You have the right to access your personal information in order to review or update it, and to correct any inaccuracies. 

+ 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 or outdated.

+ Right to deletion

You have the right to request deletion of your personal data that is being stored by Starship. Please keep in mind that we cannot delete any data that we process to fulfil contractual or legal obligations.

+ Right to data portability

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

+ Right to lodge a complaint to a data protection supervisory authority

If you reside in the EU or the UK when using our services, you have a right to lodge a complaint to a data protection supervisory authority.

+ Equal service and price

You have the right not to be discriminated against when you exercise your rights under GDPR or CCPA. When you exercise your right we will not deny you goods or services, charge a different price, impose penalties, provide a different level or quality of service, or suggest a different price or rate or different level or quality of goods or services.

+ Other rights

As stipulated by the GDPR, you also have a right to: i) request restriction of processing of your personal data; ii) object to the processing of your personal data; and iii) withdraw consent (in circumstances where we ask for consent from you for processing your personal data). 

+ How to exercise your rights?

To exercise any of the rights listed above and make a request regarding your personal information, please send us an e-mail to data-protection@starship.co with your request and full name. You can also contact Starship via our customer support channels available on our website or in our application. 

Please be aware that in order to accommodate some requests, we must verify your identity before we can respond to a privacy request and this may require you to provide photographic identity information to Starship. Because your personal information—for example, your email address—is often required to use Starship services, we retain personal information as long as your account is active. Please note that some personal information may be retained in our systems, where requested by law.

 

Who do we share your data with?

To support the purposes of processing listed in Section 5 Starship may share or disclose personal information to:

  • Starship’s subsidiaries, affiliates, and other related companies for the purposes listed in Section 5.
  • Service providers and business partners for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, payment processing, and for other legitimate purposes permitted by applicable law or otherwise with your consent.

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 (i.e., adverse parties and their counsel and other agents) 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. Starship will not provide personal information to third parties for their own marketing purposes without your consent.

 

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 and jurisdictions around the world. By using our Services, where applicable law permits, you acknowledge the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.

Starship safeguards and enables the global transfer of personal information in a number of ways:

+ EU Commission Standard Contractual Clauses

The Standard Contractual Clauses are one of several mechanisms approved by the European Commission to ensure adequate safeguards for personal information transferred from the EU to countries which the European Commission has not found to offer adequate protection for personal information. In some circumstances, Starship will rely upon Standard Contractual Clauses to lawfully transfer personal information.

+ EU Commission Adequacy Decisions

According to EU Regulation, international transfers may take place when there is an adequate level of protection to the fundamental right of individuals to data protection. The European Commission has determined that several countries ensure an adequate level of protection. In some circumstances, Starship will rely upon an adequacy decision to lawfully transfer personal information.

+ United Kingdom

The United Kingdom exited from the European Union which means that according to the GDPR, the United Kingdom needs to have in place adequate safeguards for transfer of personal information from and to the EU. In June 2021 the European Commission approved the UK adequacy which means that personal data can be sent from the UK to EEA state without any further safeguard being necessary.

 

Do we keep your data secure?

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

Any personal information that Starship is collecting or exchanging is only transmitted over secure, authenticated and encrypted data transfer channels. Access to any personal information within our systems and offices is protected with mandatory role-based access control and strong multi-factor authentication. We comply with the industry standards and practices of securing our systems and storage. We are also making sure that all our employees are aware of the rules and requirements regarding the handling and protecting personal information of our customers.

 

How long do we keep your personal information?

Starship will retain your personal information as needed to fulfil the purposes for which it was collected as listed in Section 5. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

 

Cookies we use 

We only use ‘Strictly Necessary’ cookies on our website. These are cookies that are required for proper functioning of the website. 

Changes to Policy

Starship reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. If we make material changes to our Privacy Policy, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our app or sending you a notification. 

 

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 Starship Deliveries application, or at our legal address available from our website.