Privacy policy

StarApps Studio LLP is incorporated under the laws of India with its registered office at WeWork Eleven West, Survey No. 25, Pan Card Club Road, Baner, Pune, Maharashtra 411045 (hereinafter referred to as “StarApps”, which expression shall mean and include its partners, affiliates, successors and permitted assigns). StarApps Studio is an online platform, owned and operated by StarApps, that assists eCommerce brands (“Merchants”) in creating world-class shopping experiences through its range of Shopify applications (“Apps”). 

The Apps are made available through the Shopify app store (“Shopify App Store”) and are installed by Merchants within their respective Shopify stores and Shopify administration interfaces (“Merchant Store”) and used by end-users through such Merchant Store. Platform, in this Policy, shall refer to the Apps made available on the Shopify App Store and installed within Merchants' Shopify stores, as well as the informational website www.starapps.io (“Website”),unless the context implies otherwise. 

Please read this Privacy Policy (“Policy”) carefully, as it describes the privacy practices of StarApps in relation to the Website and Apps. For the purposes of this Policy, (“Users” / “you” / “your”) means (i) Merchants who install, access, authorise, integrate or use the Apps, including their duly authorised representatives acting on their behalf; and (ii) individuals who access or use the Website, to the extent applicable to such access or use.

For the avoidance of doubt, shoppers, customers or other end-users who merely visit, browse or make purchases through a Merchant Store (“Customers”) shall not be considered Users or parties to the Terms of Service solely by reason of such activities. Their interactions with the Merchant Store are governed by the Merchant’s applicable terms and policies. This exclusion does not affect any rights or obligations relating to the processing of Customers’ Personal Information under Applicable Law or this Policy.  

By clicking “Install”, “Add App”, “Authorize”, or otherwise downloading, accessing or integrating any of the Apps through the Shopify App Store, the Merchant or its duly authorised representative, as applicable, expressly acknowledges and agrees to be bound by StarApps’ Terms of Service and this Policy, to the extent applicable. This digital action constitutes an electronic record of acceptance of the Terms of Service and this Policy, to the extent recognised under Applicable Law. A Customer’s use of a Merchant Store does not, by itself, constitute acceptance of the Terms of Service or create a contractual relationship between that Customer and StarApps under those Terms.

This Policy covers the Platform’s privacy practices in general matters and describes how StarApps collects and uses your personal data through the Platform. It also describes the rights and options available to Users and, where applicable, Customers whose Personal Information is processed by StarApps through the Apps or for other purposes permitted under Applicable Law.  The Merchant may have additional privacy policies explaining its own specific privacy practices and use related to personal data collected from end-user shoppers ("Customers"). For the purposes of this Policy, where StarApps processes Customers’ Personal Information through the Apps on behalf of a Merchant and in accordance with that Merchant’s documented instructions, StarApps acts as a data processor or service provider, as applicable under Applicable Law, and the Merchant remains responsible for determining the purposes and means of such processing as the relevant data controller or business. StarApps processes such Customer data only to provide, operate, maintain, secure and support the Apps and to comply with applicable legal obligations. Separately, StarApps may process Personal Information relating to Merchants and their representatives for its own business purposes, including account administration, service delivery, security, compliance and communications, in which case StarApps acts as an independent data controller or business, as applicable under Applicable Law. 

StarApps is committed to comply with the extant applicable privacy and data protection laws of India, the European Union (“EU”) and the United States of America (“USA”), including the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023 (“DPDP Act”)  the General Data Protection Regulation (“GDPR”) and applicable UK data protection laws, and US federal and state privacy legislation (including the California Consumer Privacy Act (CCPA)) (together the “Applicable Law”). The Users are advised to read this Policy, along with StarApps’ Terms of Service (“Terms”), before using / accessing / browsing the Website or Apps provided by StarApps.

1. GENERAL

1.1) By using / accessing / browsing the Website or by installing the Apps via the Shopify App Store (as defined hereunder), you confirm that you have the capacity to enter into a legally binding contract and that you have read, understood and agreed to the practices and policies outlined in this Policy and StarApps’ Terms of Service (together the “Agreement”). 

1.2) Change to this Privacy Policy

StarApps reserves the right to amend, modify, add, delete or remove any portion of this Policy as required under any Applicable Law or if required, to enhance and improve the Users’ experience of its Platform. Usage of Information shall be governed by the last updated or revised Policy which shall be available on the Platform. Your continued use of the Apps or Website constitutes acceptance of the revised Policy.after any such amendment or modification. Where required by Applicable Law, StarApps will notify you of material changes and obtain any additional consent required for the relevant processing. If you do not agree with this Policy at any time, in part or as a whole, you may uninstall the Apps and cease accessing the Website.

2. INFORMATION BEING COLLECTED

2.1) StarApps may collect the following types of information, as applicable, relating to Users, Customers and Merchant Store operations: ;  (i) Merchant Account Information; (ii) Cookies; (iii) Behavioural Information; (iv) Indirect Information; and (v) Analytical Information (each of which have been defined below, and collectively, “Information”). StarApps may collect Information when you visit the Website or contact StarApps, or indirectly via Shopify's APIs based on the permissions granted upon App installation. In relation to the Apps, Merchant data and associated Customer data is received through Shopify, subject to the permissions authorised by the Merchant at the time of installation and any subsequent changes to those permissions. The collection or processing of Customer data through the Apps does not, by itself, make a Customer a User or a party to the Terms of Service. 

The following Information, may be collected by StarApps:

a) Merchant account details received from Shopify upon installation, including store name, store owner name, email address, physical address, phone number, and store domain;

b) StarApps also stores cookies on the Website to: (i) track user activity, behaviour and movement  on the Platform; (ii) analyse user patterns and trends; (iii) track the sections, links, tabs or pages that are most visited by the Users; and (iv) to build a database of user preferences (“Cookies”). Non-essential Cookies will be activated only after obtaining consent where required by Applicable Law. Please refer to Section 5.3 for further details.

c) StarApps may also collect information about how Users use the Platform and information about your device, server, software, usage statistics, traffic data, internet protocol (IP) address, browser and operating system type, domain names, access times, URLs, location and location-based information, and details regarding the parts of the Platform that you access (“Behavioural Information”); 

d) Information processed through Third-Party Services or integrations connected with the Platform (“Indirect Information”);

e) StarApps may also collect statistical and analytical information about your use of the Platform, including: the IP address from which you accessed the Platform, time and date of access, type of browser used, language use, links clicked, and actions taken while using the Platform (“Analytical Information”).

2.2) While StarApps may collect  Cookies, Behavioural Information and Indirect Information when you access or use the Platform, StarApps collects Personal Information only from you or via Shopify API authorizations with your prior consent unless there are other legal grounds for doing so, as further specified in this Policy. For Merchant data received through Shopify, StarApps processes the data made available to it in accordance with the permissions authorised by the Merchant, the applicable Shopify requirements and Applicable Law. Where required, StarApps will ensure that an appropriate lawful basis exists for the relevant processing. In relation to Personal Information of Customers received through Shopify, StarApps processes such information on behalf of the relevant Merchant and in accordance with the Merchant’s authorised instructions, the permissions granted through Shopify and Applicable Law, except where StarApps processes the information for a separate purpose for which it independently determines the purposes and means of processing. Where StarApps acts as a processor or service provider, the Merchant is responsible for ensuring that it has an appropriate lawful basis for making the relevant Personal Information available to StarApps and for providing any notices or obtaining any consents required under Applicable Law. Where StarApps processes Personal Information for its own business purposes, StarApps is responsible for identifying and complying with the applicable legal requirements for that processing. .

3. CONSENT

3.1) You acknowledge that Information may be provided by you voluntarily or made available to StarApps through Shopify in accordance with the permissions authorised by the Merchant at the time of App installation. StarApps collects, uses, processes and discloses Personal Information on the basis of consent or another lawful basis permitted under Applicable Law, as applicable to the relevant processing. Where consent is required, StarApps will obtain it through an appropriate affirmative action (such as approving Shopify installation scopes or cookie permission banners) and will not rely solely on your use of or access to the Platform as consent. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, the Merchant is responsible for obtaining any consent and providing any notices required from Customers under Applicable Law, and StarApps will process such information in accordance with the Merchant’s authorised instructions and applicable legal requirements. Where StarApps processes Personal Information for its own business purposes, StarApps will identify and rely on an appropriate lawful basis for that processing. For the avoidance of doubt, where StarApps processes Customers’ Personal Information on behalf of a Merchant, the Merchant is responsible for obtaining any consent and providing any notices required from Customers under Applicable Law, as applicable. A Customer’s provision of Personal Information or use of a Merchant Store does not, by itself, constitute acceptance of the Terms of Service. StarApps will process such information in accordance with the Merchant’s authorised instructions and applicable legal requirements.

3.2) In the event of a change in the Applicable Law, StarApps will review StarApps’ data collection, use, storage and disclosure practices to ensure compliance with the amended Applicable Law. StarApps may reach out to you for obtaining additional consents and approvals, if you choose not to provide such consents, StarApps may be unable to provide certain features or services that depend on such consent, and you may  discontinue use / access of the relevant parts of the Platform.

3.3) You may choose to not provide StarApps with or withdraw any or all information being Personal Information, but in the event that you do so, StarApps may be unable to allow you to use / access / browse the Platform or parts or features thereof, for which your Personal Information is being collected or processed. You can also withdraw your consent by writing to StarApps at support@starapps.studio  . Please note that the revocation of consent is only effective for future collection, usage, disclosure, retention and processing of the Personal Information. Collection, usage, disclosure, retention and processing of the Personal Information that took place before the revocation will not be affected, to the extent permitted by Applicable Law. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, requests to withdraw consent or otherwise exercise rights relating to that information may also be directed to the relevant Merchant, and StarApps will reasonably assist the Merchant in handling such requests in accordance with Applicable Law and applicable Shopify requirements. 

4. USE OF PERSONAL INFORMATION

4.1) StarApps uses your Information: (i) to provide its Apps and services to you inside your Shopify store; (ii) to operate and improve the Platform in order to foster a positive user experience; (iii) for analysing data, understanding usage trends and improving the functionality, performance and features of the Apps and Platform;(iv) to conduct audits and quality assessment procedures; and (v) to analyse the use of StarApps’ resources and troubleshooting problems in relation to the Platform. Where the Information relates to Customers and is processed by StarApps on behalf of a Merchant, StarApps uses that Information only as necessary to provide, operate, maintain, secure and support the relevant Apps, comply with applicable Shopify requirements and follow the Merchant’s authorised instructions, subject to Applicable Law. StarApps does not use Customers’ Personal Information received in this capacity for its own unrelated business purposes.

4.2) In addition to the above, StarApps also uses your Information, including Personal Information: (i) for internal operational purpose such as record keeping, accounting and compliance with Applicable Laws; (ii) for recording information including dates, time and locations at which the Platform has been accessed by using various tracking technologies and thereby improve the Platform and your experience by providing you with relevant information based on the above. Your disabling of tracking features on the Platform by changing settings on your device and / or web browser may result in your inability to use the Platform optimally or entirely; (iii) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or as otherwise required by law; and (iv)  to respond to any queries that you may have, and to communicate information to you. StarApps will not use Personal Information for unrelated purposes that are incompatible with the purposes for which it was collected, unless permitted or required by Applicable Law. Where a new purpose requires consent, StarApps will obtain that consent before processing. The purposes described in this Clause 4.2 apply to Personal Information processed by StarApps for its own business purposes. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, StarApps will not independently use that information for its own analytics, marketing or other business purposes unless such processing is separately authorised, supported by an appropriate lawful basis and permitted under Applicable Law. StarApps may use aggregated or anonymised information for analysis and improvement, provided that such information does not identify an individual and its use complies with Applicable Law.

4.3) Where StarApps sends you optional marketing communications, you may opt out at any time by following the unsubscribe instructions in the relevant communication or by contacting StarApps at support@starapps.studio. This does not affect service-related communications that are necessary for the operation or security of the Apps or Platform.

5. YOUR RIGHTS

5.1) You may review, correct, update, or change your Personal Information collected by StarApps by sending an email at support@starapps.studio. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, Customers may exercise their applicable rights through the relevant Merchant. StarApps will reasonably assist the Merchant in responding to such requests in accordance with Applicable Law and applicable Shopify requirements.

5.2) If you wish to delete your Personal Information provided to StarApps, you can always do so by sending a request to StarApps at support@starapps.studio. Where the Information relates to a Merchant's Shopify store or a shopper whose data is made available to StarApps through Shopify, deletion requests may also be handled through Shopify's applicable data request and deletion processes, as described in Clause 7 (Retention and Erasure of Information).

5.3) You may disable the browser cookies before using / accessing / browsing the Platform. However, if you do so, you may not be able to access certain features of the Platform. Certain cookies or similar technologies may be necessary for the Website to function properly. Where required by Applicable Law, non-essential cookies will only be activated after the necessary consent has been obtained. Where required by Applicable Law, StarApps will provide an appropriate cookie consent mechanism that allows visitors to accept or reject non-essential Cookies and manage their preferences. Essential Cookies may be used where necessary for the operation and security of the Website.

5.4) You may choose not to provide StarApps with information for non-mandatory fields.

5.5) You may note that correction or deletion of certain Information and / or Personal Information or data may lead to cancellation of your access to the Platform or to certain features thereof. You also agree and acknowledge that certain data or Information cannot be corrected or deleted and / or may be prohibited from being deleted under any applicable law or in lieu of law enforcement requests or under any judicial proceedings.

5.6) Where applicable under Applicable Law, you may have the right to receive your Personal Information in a structured, commonly used and machine-readable format and to request its transmission to another data controller. You may exercise these rights, where available, by contacting StarApps at support@starapps.studio .

5.7) If you are in the EU or the UK, you have the specific rights under the GDPR and UK GDPR, such as the right to access and receive a copy of your personal information, right to rectify inaccurate personal information, right to easily and at any time withdraw your consent, right to data portability, right to object, right to restrict processing your personal information and the right to be forgotten. These rights are subject to the conditions and limitations prescribed by the applicable law. If you wish to exercise any of these rights, please contact StarApps as stated above. You may also have the right to lodge a complaint with the relevant data protection supervisory authority. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, the relevant Merchant is generally responsible for responding to requests to exercise these rights. StarApps will reasonably assist the Merchant in responding to such requests, as required under Applicable Law. Where StarApps acts as an independent data controller, requests may be submitted directly to StarApps.

5.8) If you are a resident of California or another US state with applicable privacy statutes, you have the specific rights under the California Privacy Rights Act (CPRA / CCPA) and state privacy laws, such as the right to know what personal information is collected about you, right to deletion, right to correct inaccurate personal information, right to opt out of data sales/sharing and the right for protection against discrimination. If you wish to exercise any of these rights, please contact StarApps as stated above. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, StarApps will assist the relevant Merchant in responding to applicable privacy requests and will comply with any obligations directly applicable to StarApps under relevant US privacy laws.

5.9) If you are located in India, you may exercise the rights available to you under the DPDP Act, Information Technology Act, 2000 and other applicable Indian laws, to the extent those provisions are in force and applicable to the relevant processing (including the right to grievance redressal, right to nominate, and right to access summary of personal data). Requests may be submitted to support@starapps.studio. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, StarApps will reasonably assist the relevant Merchant in addressing applicable data principal requests, in accordance with Applicable Law.

6. TRANSFER AND STORAGE

6.1) You consent to and acknowledge that your Personal Information may be transferred to or maintained on computers or servers located in the United States of America or other international cloud server infrastructure utilized by StarApps, subject to Applicable Law and the safeguards described in this Clause 6.

6.2) When StarApps transfers your information from within the EU or UK to the United States of America or other countries, which are not recognized by the European commission as having adequate protection for personal data, StarApps will endeavor to do so while using adequate safeguards determined by the European commission (such as Standard Contractual Clauses or applicable Data Privacy Frameworks).

7. RETENTION AND ERASURE OF INFORMATION

7.1) StarApps retains your Information, including Personal Information to provide you with its products and services or in lieu of the parties dealings thereof or as is reasonably necessary for the purposes listed in this Policy, including pursuing its legitimate business interests, conducting audits, complying with any legal, regulatory, tax or accounting requirements, preventing any illegal activities or suspected fraud and so on. Further, StarApps may retain your Information excluding Personal Information for the purposes of analysing data, tracking trends, building algorithms, creating databases, derivative data, rating systems, recommendations engines, so on and so forth. However, it is hereby clarified that StarApps shall be the sole owner of any databases, derivative and analytical data, algorithms, analysis or systems created or maintained by StarApps, subject to Applicable Law and any rights of third parties in the underlying data. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, retention will be limited to the period necessary to provide the relevant Apps and services, follow the Merchant’s authorised instructions and comply with Applicable Law. StarApps will not retain such Personal Information for its own independent business purposes except where separately authorised and legally permitted.  

7.2) StarApps processes and stores Personal Information only for as long as is reasonably necessary to fulfil the purposes for which it was collected, subject to Applicable Law and any applicable legal retention obligations. Where Personal Information is no longer required for those purposes, it will be deleted or anonymised, unless retention is required or permitted by Applicable Law.

7.3) For data relating to a Merchant's Shopify store, StarApps receives and processes data through Shopify in accordance with the permissions authorised by the Merchant at installation and any subsequent changes to those permissions. When a Merchant uninstalls an App from their Shopify admin, Shopify sends StarApps a mandatory webhook request to delete that store's data 48 hours after uninstallation. StarApps automatically processes and executes that data deletion request in accordance with Shopify's developer requirements and applicable technical procedures.

7.4) Shopify also sends mandatory GDPR/privacy requests relating to Customers’ Personal Information, including requests to access or delete such data, when requested by a Customer. StarApps will process these requests in accordance with Shopify's applicable requirements and Applicable Law. Where deletion is required, the relevant Personal Information will be deleted from StarApps’ systems, subject to any applicable legal retention obligations.

7.5) Where data must be retained for legal, regulatory, security or other lawful purposes, StarApps will retain only the data necessary for that purpose and for the applicable retention period. Any retention of aggregated or anonymised information will be subject to Applicable Law and the information no longer identifying an individual.

8. DISCLOSURE

8.1) StarApps does not disclose any Personal Information to any individual or entity except as provided in this Policy. StarApps may disclose such Personal Information only when required under an applicable law to any authority authorized to collect such information and only to the extent necessary. 

8.2) StarApps shall not share the Merchant’s or Customer’s information with third parties, except in the following events listed below or when the Merchant or Customer provides StarApps their explicit and informed consent:

a) StarApps shall, at its sole discretion, disclose the Personal Information of its Users to its employees, agents and service providers who need to know that information in order to process it for StarApps, and who are subject to strict contractual confidentiality obligations. Where such disclosure involves Customers’ Personal Information processed on behalf of a Merchant, StarApps will ensure that the relevant employees, agents and service providers are authorised to process that information only as necessary to provide or support the Apps and in accordance with Applicable Law and the applicable contractual obligations.

b) If the User has breached the Terms of Service of the Platform, this Policy or any other agreement they have with StarApps, abused their rights to use the Platform, or violated any applicable law- Their Information will be shared with third parties (such as legal counsels and advisors), who handle the matter on behalf of StarApps, or with competent authorities;

c) If StarApps organizes its operation within a different framework, or via another legal structure or entity, for instance, due to a merger or an acquisition, StarApps shall share the User’s Information to facilitate  structural change. The receiving party shall be bound by this Policy and any applicable confidentiality and data protection obligations;

d) StarApps may share Information with service providers and other authorised third parties where reasonably necessary to operate, maintain, secure, analyse or improve its Apps and Platform, subject to appropriate contractual obligations and Applicable Law. StarApps will not share Personal Information with third parties for their independent direct marketing purposes without an appropriate lawful basis and any consent required by Applicable Law. 

e) StarApps does not sell or trade in any form or manner, the Personal Information of its Users to any third party.

f) StarApps may disclose Information to Shopify as necessary for the operation of the Apps and to comply with Shopify's applicable platform requirements, including data access and deletion requests.

8.3) In the event that StarApps discloses the Personal Information of its Users to any third party, it ensures that such third party is bound by confidentiality obligations similar to the confidentiality obligations of StarApps under this Policy, prior to such disclosure to such third party. Where required by Applicable Law, StarApps will also enter into appropriate data processing or data protection agreements with relevant service providers and processors.

9. SECURITY

StarApps is committed to ensure that your Information, including Personal Information is secure with StarApps. To ensure the security and protection from any unauthorized access or disclosure StarApps has in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information, including Personal Information StarApps collects on the Platform or during StarApps’ dealings with you. Where StarApps processes Customers’ Personal Information on behalf of a Merchant, StarApps will implement appropriate technical and organisational security measures, taking into account the nature of the information processed and the risks associated with the processing, as required under Applicable Law. StarApps will also provide reasonable assistance to the relevant Merchant in meeting applicable data protection and security obligations. StarApps does not retain any Personal Information collected from you for any period longer than reasonably required by StarApps for the purpose of providing its products or services or its dealings with you, or such period as may be required by Applicable Law. However, please be informed that despite the stringent security measures being adopted by StarApps, there may still exist the risk of potential security breaches which are inherent in the use of the internet. Further, StarApps shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond StarApps’ reasonable control, including but not limited to, acts of god, natural calamities, war, terrorism, acts of government, hacking, cyber terrorism, unauthorised access to any Information, Personal Information or data or other electronic devices and storage devices, device crashes, breach of security and encryption, so on and so forth, subject always to any liability that cannot be excluded or limited under Applicable Law.

10. THIRD PARTY LINKS

10.1) The Platform may host links to third party websites and services (“Third Party Links”). StarApps has no control over such Third Party Links, which are provided by persons or companies other than StarApps. StarApps is not responsible for any collection or disclosure of any of your Information or Personal Information by such companies or persons on such Third Party Links thereof.

10.2) You agree and acknowledge to that Third Party Links have their own privacy policies governing the collection, storage, transfer, retention and / or disclosure of your information or personal information and that you access such Third Party Links at your own risk.

11. DISCLAIMER

Although StarApps is committed to protecting your privacy, StarApps does not make any promise to the effect that your Information, including Personal Information, or private communications will always remain private or be disclosed in ways not otherwise described in this Policy. You assume all responsibility and risk for: (i) your use of the Platform; (ii) use of the internet generally; (iii) the Information you provide to StarApps; and (iv) your conduct on and off the Platform. Further, StarApps assumes no liability for any actions of third parties with regard to your Information and / or Personal Information which you may have disclosed to such third parties by accessing or visiting Third Party Links. StarApps shall disclaim any and all liability arising out of your use of Third Party Links or any other dealings with such third parties, subject to any liability that cannot be excluded or limited under Applicable Law. 

12. GOVERNING LAW

This Policy shall, in all respects, be governed by and construed in all respect in accordance with the laws of India. The Parties agree to submit to the exclusive jurisdiction of the courts in Pune, Maharashtra, India in connection with any dispute arising out of or in connection with this Policy.

13. NOTICE OF CLAIMS AND ACTIONS

The User hereby agrees and undertakes to notify StarApps, in writing, at least 30 (thirty) days prior to initiating any suit, action, claim or proceedings against StarApps before any court, tribunal or any other authority having jurisdiction in relation to any matters relating to or arising from this Policy.

14. GRIEVANCE REDRESSAL

If you are based in the EU or UK, you can report your questions, comments, suggestions or grievance with the European Representative of StarApps at support@starapps.studio.

If you have questions, comments, suggestions or grievance with respect to the Policy, please contact StarApps at any of the following:

StarApps Studio LLP : support@starapps.studio .

Or

Utpal Sharma 

Data Protection Officer

Email: support@starapps.studio