Privacy policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

  • We, us, our: Starship Holding International, LLC; Starship Gaming, LLC

  • Our representative: Starship Gaming, LLC, 165 Ponce de Leon Ave, Suite 201, San Juan, PR 00917

  • Our data protection officer: Jesse Haskins, 10437 Canary Isle Drive, Tampa, FL 33647

  • Personal information: Any information relating to an identified or identifiable individual

Personal Information We Collect About You

We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

  • Categories of Personal Information: Specific Types of Personal Information Collected

  • Identifiers: Name, alias, address, online identifiers, Internet Protocol address, email address, account name

  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information: Telephone number, e-mail

  • Internet or other electronic network activity information (e.g. browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement): Browsing history and cookies

This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.

How Your Personal Information is Collected

We collect most of this personal information directly from you—in person, by telephone, text or email, and/or our website. However, we may also collect information:

  • From publicly accessible sources (e.g. property records);

  • Directly from a third party (e.g. sanctions screening providers, credit reporting agencies, or customer due diligence providers);

  • From a third party with your consent (e.g. your bank);

  • From cookies on our website; and

  • Via our IT systems, including:

    • Door entry systems and reception logs;

    • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; and

    • Google

    • Square Space

    • Sumsub

    • Typeform

How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • To comply with our legal and regulatory obligations;

  • For the performance of our contract with you or to take steps at your request before entering into a contract;

  • For our legitimate interests or those of a third party; or

  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The bullets below explain what we use (process) your personal information for and our reasons for doing so:

  • What we use your personal information for: Our reasons

  • To provide products and/or services to you: For the performance of our contract with you or to take steps at your request before entering into a contract

  • To prevent and detect fraud against you or us: For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you

  • Conducting checks to identify our customers and verify their identity; screening for financial and other sanctions or embargoes: To comply with our legal and regulatory obligations

  • Ensuring business policies are adhered to, e.g. policies covering security and internet use: For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you

  • Operational reasons, such as improving efficiency, training and quality control: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

  • Ensuring the confidentiality of commercially sensitive information: For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information; to comply with our legal and regulatory obligations

  • Statistical analysis to help us manage our business, e.g. in relation to our performance, customer base, and other efficiency measures: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you.

  • Preventing unauthorized access and modifications to systems: For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you; to comply with our legal and regulatory obligations

  • Updating and enhancing customer records: For the performance of our contract with you or to take steps at your request before entering into a contract; to comply with our legal and regulatory obligations; for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

  • Statutory returns: To comply with our legal and regulatory obligations

  • Ensuring safe working practices, staff administration and assessments: To comply with our legal and regulatory obligations; for our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

  • External audits and quality checks: For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards; to comply with our legal and regulatory obligations

Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Information With

We routinely share personal information with:

  • Our affiliates, including companies within Starship’s group

  • Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies

  • Other third parties we use to help us run our business, such as marketing agencies or website hosts

  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers

  • Credit reporting agencies

  • Our insurers and brokers

  • Our bank[s]

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

Where Your Personal Information is Held

Information may be held at our offices and those of our information technology vendors, website maintenance vendors, other third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties are based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;

  • To show that we treated you fairly; or

  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

Transferring Your Personal Information Out of the EEA

To deliver services to you, it is necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • Within our organizations and offices located outside of the EEA;

  • With your and our service providers located outside the EEA;

  • If you are based outside the EEA; or

  • Where there is an international dimension to the services we are providing to you.

These transfers may be subject to special rules under European and UK data protection law.

If you would like further information, please contact us.

If you are a resident of the EEA, your rights Under the GDPR are summarized below:

  • Right to Access: The right to be provided with a copy of your personal information (the right of access)

  • Right to Rectification: The right to require us to correct any mistakes in your personal information

  • Right to be Forgotten: The right to require us to delete your personal information—in certain situations

  • Right to Restriction of Processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

  • Right to Data Portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

  • Right to Object: The right to object at any time to your personal information being processed for direct marketing (including profiling); the right to object in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

  • Right Not to be Subject to Automated Individual Decision-Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please:

  • Call us at 727-371-9731 or

  • E-mail us at jesse@deploystarship.com

If you choose to contact directly by email, you will need to provide us with:

  • Enough information to identify you [(e.g. your full name, address and customer or matter reference number))];

  • Proof of your identity and address (e.g. a copy of your driving license or passport and a recent utility or credit card bill); and

  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

How to File a GDPR Complaint

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Changes to This Privacy Notice

This privacy notice was published on 24 November 2022 and last updated on 24 November 2022.

We may change this privacy notice from time to time–when we do, we will inform you via changes to this policy on our website.

How to Contact Us

Please contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details
Starship Gaming, LLC
165 Ponce de Leon Ave
Suite 201
San Juan, PR 00917
marketing@deploystarship.com
727-739-4405

Our Data Protection Officer's contact details
Jesse Haskins
J Haskins Law, PA
10437 Canary Isle Drive
Tampa, FL 33647
jesse@jhaskinslaw.com
727-371-9731

Do You Need Extra Help

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).