XStarter Privacy Policy

What does this Privacy Notice cover?

This Privacy Notice provides information regarding the processing of your personal data when using services of Studio X LLC (“Studio X” or “we”) whether as:

  1. a Studio X platform subscriber; and/or
  2. a visitor to a Studio X website ('Website' or 'Studio X Website').

This Privacy Notice complements and supplements the privacy notices available on the Shell group of companies website at https://www.shell.com/privacy.html.

Bespoke notices and supplementary privacy statements may contain further information about how Studio X is processing your personal data. In such cases, additional privacy notices will be communicated to you separately.

This Privacy Notice explains what personal data are processed about you; why we are processing your personal data and for which purposes; for how long we hold your personal data for; how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.

Special Notice - if you are under 16 years old. Processing children’s personal data

If you are under 16 years old (or a different age to reflect local legal requirements in your location) please do not send us your personal data, for example your name, address and email address. If you wish to contact Studio X in a way which requires you to submit your personal data (such as for education or innovation events) please get your parent or guardian to do so on your behalf.

What personal data do we process about you? Collection of information

We collect information, including personal data about you, as a Studio X platform subscriber, and/or visitor to a Studio X Website or Studio X administered social media page (‘Studio X Social Media Page’). This information may be either:

  • Information that you provide to us - when creating a Studio X account profile, we will ask for your name, e-mail address, your contact preferences and information necessary for answering any security questions. In order to complete your profile on the Studio X platform, you will have the option to upload a profile picture and additional information about your professional background and interests. If you decide to take part to any of the Studio X offerings, we may ask you to provide further personal data necessary for offering-related activities and/or authentication such as date of birth, nationality, primary address and bank account details.
  • Information that we obtain through your use of the Studio X platform - we will also collect information about how and when you use the Studio X platform. Such information may include electronic device information, IP addresses, log information, browser type and preferences, location information, online identifiers to enable ‘cookies’ and similar technologies.
  • Information gathered through social media pages - When you communicate with us through a Studio X Social Media Page (for example, when you comment on, share or react to a post, upload media, send a personal message or subscribe to a Studio X Social Media Page), we may receive personal data about you such as your user name, profile picture, hometown, email address and gender. We will use any personal data received from social media in accordance with this Privacy Notice.

Why do we process your personal data?

The personal data covered by this Privacy Notice are only processed:

  • with your explicit consent;
  • where it is necessary to conclude a transaction with you (such as payment information);
  • where it is necessary for the purposes of the legitimate interests pursued by Studio X, except where such interests are overridden by your interests or fundamental rights and freedoms; or
  • where it is necessary for Studio X to comply with a legal obligation.

Where the processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.

What are the consequences of not providing your personal data?

Where you choose not to provide us with information set out above for the purposes of using the Studio X platform or any of its offerings, the only consequence is that it will affect your ability to fully navigate through the Studio X platform and/or to fully participate in the Studio X offerings.

Who is responsible for any personal data collected?

Studio X LLC will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.

For what purposes do we process your personal data?

We process your personal data for the purposes of:

  • perform activities related to your participation in any of the Studio X offerings, such as XEEK challenges, XCOVER assignments or XSTARTER incubation programs;
  • managing relationships and marketing such as maintaining and promoting contact with you;
  • account management including account verification (that is, ensuring that only you or someone you have authorized can access your account and information);
  • user support and development of our offerings;
  • performance of and analysis of market surveys and marketing strategies;
  • promotions and contests offered to Studio X subscribers, including offering you digital rewards to recognize you as a valued member of the Studio X community;
  • health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of Studio X and staff, authentication of individual status and access rights;
  • legal and/or regulatory compliance - including compliance with legal or regulatory requirements and performing necessary screening to meet such requirements;

or for a secondary purpose where it is closely related, such as:

  • storing, deleting or anonymizing your personal data;
  • audits, investigations, dispute resolution or insurance purposes, litigation or defense of claims; or
  • statistical, historical or scientific research.

Communication and marketing - your choices

If you have consented to receive communications from Studio X, you may receive offers that are tailored towards your preferences based on the information gathered about you from the various sources described above in order to provide you with better opportunities and increasingly tailored offers.

We may send you service updates and notifications without your advance consent only where such updates and/or notifications are necessary for the proper functioning of Studio X any of the Studio X offerings that you take part in.

You may receive pertinent offers and communications by different channels, and you may update your subscription preferences via your personal profile settings anytime or use the unsubscribe functionality for the different digital channels.

Your rights in relation to your personal data

We aim to keep our information as accurate as possible. You can request:

  • access to your personal data;
  • correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose such as completing a retail transaction);
  • that you no longer receive marketing communications;
  • that the processing of your personal data is restricted;
  • combining of your personal data from different sources to create a personal profile no longer takes place; and/or
  • that you receive personal data that you have provided to Studio X, in a structured, digital form to be transmitted to another party, if this is technically feasible.

To make any of these requests please contact us at privacy@x.studio in this respect.

Who can you contact if you have a query, concern or complaint about your personal data?

If you have any issues, queries or complaints regarding the processing of your personal data, please contact us  at privacy@x.studio for further information or for submitting such requests.

You may also contact the Shell Group Chief Privacy Office at Shell International B.V. The Hague, The Netherlands - Trade Register No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague, at privacy-office-SI@shell.com.

If you are unsatisfied with the handling of your personal data by Studio X, then you have the right to lodge a complaint to your local data protection authority (if there is one) or the Dutch Data Protection Authority whose address is Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.

Cookies and similar technologies

Studio X uses cookies and similar technologies that collect and store information when you visit a Studio X Website. This is to enable Studio X to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). You can control and manage your cookies preferences by adjusting your browser settings or using the Studio X cookies preference tool on Studio X Websites – for more information, please refer to the Studio X Cookie Policy at https://app.termly.io/document/cookie-policy/b0cd0a89-ed19-44a0-a827-0e8107ceb19d

Security of your personal data

We have implemented technology and policies with the objective of protecting your privacy from unauthorized access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification process for access to the Studio X platform and we regularly test, assess and evaluate the effectiveness of our security measures.

Who will we share your personal data with?

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

  • Other companies within the Shell group of companies, including to those which may be located outside of your location;
  • Authorized agents, licensees, service providers, external auditors and/or subcontractors of Studio X;
  • A competent public authority, government, regulatory, supervisory, investigative or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which Studio X is subject to or as permitted by applicable law; or
  • Any person to whom Studio X proposes to transfer any of its rights and/or duties.

Transfers of your personal data to other countries

Where your personal data have been transferred to companies within the Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Shell group and for Shell companies in the European Union, European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of Shell Binding Corporate Rules at https://www.shell.com/privacy.html or by contacting privacy-office SI@shell.com.

Interacting with Studio X through social media

If you choose to interact with Studio X through social media on a Studio X administered social media page (‘Studio X Social Media Page’) such as Facebook, Instagram, Twitter or LinkedIn, your personal data (such as your name, your profile picture and the fact that you are interested in Studio X) will be visible to all visitors of your personal webpage depending on your privacy settings on the relevant social media platform, and will also be visible to Studio X. You can delete any information that you share on these sites at any time through your relevant social media platform’s account. Studio X does not track your activity across the different social media sites that you use. If you send a message to Studio X via any messenger service on a social media platform, these messages are held for no longer than one month after receipt. Please contact Studio X if you wish to make a request that you are unable to action yourself and which relates to a Studio X Social Media Page - see the section below.

Additionally and to the extent Studio X is jointly responsible with a social media platform of a Studio X Social Media Page, Studio X will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on Studio X Social Media Pages. For more information on how your personal data are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.

How long do we hold your personal data for?

Personal data processed by Studio X in line with this Privacy Notice will be deleted or rendered anonymous (such that it will no longer be possible to identify you);

  1. every 5 years where you remain a customer during this period;
  2. without undue delay upon you requesting that your Studio X account profile is deleted or to discontinue your participation to the Studio X platform; or
  3. after 3 years for all subscribed services from our last interaction with you (that is where you have not used our services for 3 years).

In relation to any financial transactions, your personal data will be held for 10 years from the transaction.

In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where the individual objects to the processing of their personal data and there is no longer a legitimate business purpose to retain it.

Changes to this Privacy Notice

This Privacy Notice may be changed over time. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in June 2020.