Last Modified on September, 2018
SCOPE OF POLICY
- Starship Technologies Ltd (we or us) is committed to protecting and respecting your privacy. Please read the following carefully to understand our rules and practices regarding processing your personal data
- This policy is effective as of the date set forth above and applies where we process personal data, which is information relating to natural persons.
DATA CONTROLLER AND DATA PROTECTION OFFICER
3. For the purpose of clarity, the data controller is Starship Technologies Ltd of 65 Glasshill Street, London, United Kingdom (company number: 10071803).
4. All questions, comments and requests regarding data processing are welcomed and should be addressed to our data protection officer at firstname.lastname@example.org.
WHY AND WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS
5. We collect your personal data from you for the following purposes:
- selling goods to you via our app (App) or providing services to you otherwise (e.g. if our services are made available to you by our partners or through other platforms; collectively with the App, the Services). This includes implementing security measures to protect you, us and the Services;
- communicating and providing customer support to you in relation to the Services;
- alerting you of products, services, features or enhancements to our Services by notifications and e-mail which includes retaining your shopping cart history which allows us to provide a better shopping experience to you;
- providing a personalised and enhanced service to you which includes retaining your shopping cart history which allows us to provide a better shopping experience to you;
- improving the Services and our business;
- enforcing and defending our legal rights;
- complying with legal or regulatory obligations or requests.
6. We collect and process the following personal data:
- location of the delivery, service details (e.g. shopping cart history), phone number, e-mail, device ID (user tag) (for purposes stated in sections 1-5.2, 5.6-5.7);
- service details (e.g. shopping cart history), your location data, e-mail and device ID (user tag) (for the purpose stated in section 3);
- service details (e.g. shopping cart history) and device ID (user tag) (for the purpose stated in section 4);
- your activity in the App (e.g. how much time you spend on a specific page of the App) (for the purpose stated in section 5).
7. For the sake of clarity, we assure you that the cameras and sensors on our robots do not allow recording in sufficient quality to allow identification of any natural persons. Even so, we take upmost care to guarantee safety and confidentiality of any images or location data collected via the robots – as a principle, we apply the same security and confidentiality standards to the video feed as to personal data.
8. Moreover, we do not receive any personal data related to payment information such as your credit card number, and only retain the secure token relating to your payment information.
LEGAL BASIS FOR PROCESSING PERSONAL DATA
9. We process your personal data because it is necessary for the fulfilment of a contract which is concluded between you and us or between you and our partner (see sections 1, 5.2, 5.4); or for taking steps at your request prior to entering into a contract (see section 5.2). In such a case the legal basis for processing data is also the contract concluded between you and us or you and our partner; or your request prior to entering into a contract.
10. We process your personal data for sending you marketing notifications and e-mails under legitimate interest pursued by us (see section 3). It is our legitimate interest to inform you as our client of any products, services, features or enhancements to our Services. This in turn allows for us to provide the best offers and services to you.
11. We process your personal data for maintaining and improving the Services under legitimate interest pursued by us (see section 5). It is our legitimate interest to continuously improve the quality of our Services. This in turn allows for us to provide a better Service to you.
12. We process your personal data for enforcing and defending our legal rights under legitimate interest pursued by us (see section 6). It is our legitimate interest to enforce and defend our legal rights if we see it as necessary.
13. We process your personal data for complying with legal or regulatory obligations or requests as the processing is necessary for compliance with legal obligation to which we are subject (see section 7).
14. We retain the history of your shopping carts to better understand your preferences and by that send you tailor-made marketing notifications and e-mails. We assure that such activity does not entail any legal or otherwise significant effects concerning you.
DISCLOSING YOUR PERSONAL DATA
15. We will not transfer your personal data to third parties except for the following cases:
- to companies which provide us customer support service (e.g. Zendesk, Inc., USA) – managing all our relationships and interactions with our customers and potential customers. Zendesk, Inc. has joined the EU-U.S. Privacy Shield Framework which ensures the same level protection for personal data as set in the European Union (for more detailed information see: https://www.zendesk.com/company/customers-partners/privacy-policy/);
- to companies which provide cloud computing services in which we store and process personal data (e.g. Amazon Web Services, Inc.; server located in the EU);
- any member of our group, which means our subsidiaries and our ultimate holding company and its subsidiaries, where it is necessary for the sale of goods to you – in particular Starship EE (Starship Technologies OÜ) and Starship US (STARSHIP TECHNOLOGIES HOLDINGS, INC. and Starship Technologies, Inc.).
16. We take steps to verify that processors who we appoint to process personal data on our behalf will protect that personal data as required under data protection law.
17. We also have the right to disclose your personal data to the following persons in the following cases:
- to a respective seller or buyer, in the event that we sell or buy any business or assets;
- to a third party acquiring our company (Starship Technologies Ltd) or substantially all of our assets, if such acquisition should take place and in which case personal data held by us about our customers will be one of the transferred assets;
- to a relevant institution requiring your personal data, if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
- to other companies and organisations for the purposes of fraud protection and credit risk reduction, in order to protect the rights, property or safety of our business, our customers or others.
HOW LONG DO WE STORE YOUR PERSONAL DATA
18. We only process and store your personal data for as long as it is necessary to fulfil the purpose for which it is processed – once the purpose has ceased, your personal data will be erased or anonymised.
19. Your personal data will be stored:
- up to 3 years after the last delivery to you, where we process your personal data regarding selling goods to you via our App or providing Services to you otherwise (see section 1);
- up to 3 years after last contact with you, where we process your personal data regarding communicating and providing customer support (see section 2);
- up to 3 years after the last delivery to you, where we process your personal data regarding alerting you of products, services, features or enhancements to our Services by notifications and e-mail (see section 3);
- up to 3 years after the last delivery to you, where we process your personal data regarding providing a personalised and enhanced service (see section 4);
- up to 3 years after the last time you used the Services, where we process your personal data regarding improving the Services and our business (see section 5);
- up to 3 years after the last time you used the Services, where we process your personal data regarding enforcing and defending our legal rights (see section 6) and complying with legal or regulatory obligations or requests (see section 5.7).
20. Personal data contained in any accounting documents (e.g. invoices) shall be stored for 6 years from the end of the last financial year they relate to.
21. You have the right to contact our data protection officer at email@example.com to exercise your rights concerning processing of personal data. Such rights include the:
- right to request access of personal data;
- right to request rectification of personal data;
- right to request erasure of personal data;
- right to request restriction of processing of personal data;
- right to object to processing of personal data;
- right to request portability of personal data;
- right that decisions are not taken concerning you which are based on automated decision-making (as regards to sending you tailor-made marketing notifications and e-mails based on your shopping cart history);
- right to withdraw a consent;
- right to lodge a complaint with a supervisory authority (Information Commissioner’s Office – https://ico.org.uk/make-a-complaint/).
22. Our App may, from time to time, contain links to and from the websites and apps of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our company is advertised). If you follow a link to any of these websites or apps, please note that these websites, apps and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites, apps or services, such as contact and location data. Please check these policies before you submit any personal data to these websites, apps or use these services.
23. We do not knowingly collect personal information from children under 13 or allow them to access the Services. We take children’s privacy seriously and encourage parents to play an active role in their children’s online experience at all times.