Croli
This Privacy Policy explains how STARRYY PRIVATE LIMITED (“STARRYY,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal data when you use Croli, including our website, web application, desktop software, and related services (collectively, the “Services”).
1 What Personal Information We Collect
1.1 Information You Provide
1.1.1 Task Information
When you create or run a task, we collect and process the task information that you select or make available to the Services, which may include project and session identifiers, project files, source code and documents within the selected workspace, your queries and instructions, Agent messages and outputs, commands and terminal output, execution traces, file changes and diffs, review comments, preview content, visual annotations, and task status and notification events. We use this information to execute the task and provide the workspace, file, terminal, diff, review, preview and notification functions. We limit the Task Information we collect to what is reasonably necessary to perform the task you request and you should avoid making credentials available to the Services where they are not necessary for the task.
To better protect your privacy, you may use the “Context switch” setting to decide whether to authorize us to process your local project files (including workspace files and task execution data) and information about your device and environment (collectively, “Context”) for the purpose of enhancing the performance of the agent. If you turn off this setting before initiating a task, we will not vectorize your Context or use it to improve retrieval performance.
1.1.2 Customer Service and Communications
When you contact us for inquiries, complaints, or assistance through our customer service channels, we collect your name, email address, and other information you provide in communications with us.
1.2 Information From Other Sources
1.2.1 Account Information
When you register for an account using Google or GitHub Sign-In, we receive the information made available by Google or GitHub for authentication, such as your Google or GitHub account identifier, email address, display name and profile image.
1.3 Information We Collect Automatically
When you access or use the Services, we automatically collect technical information from your device and our systems, including IP address, device model and operating system, application version and configuration, language and time zone, access, event and security logs, crash reports and diagnostic data, and feature usage statistics. We use this information to operate, secure, troubleshoot and improve the Services.
2. How We Use Your Information
2.1 Legal Bases in General
We will only use your personal data when the applicable laws allow us to. Our legal bases for collecting and using the personal data described in this Policy depend on the personal data we collect and the specific context in which we collect the information:
2.1.1 We need to perform a contract with you;
2.1.2 You have given us consent to do so;
2.1.3 In specific jurisdictions, processing your personal data is in our legitimate interests, including
- providing and maintaining our Services;
- detecting, preventing and enforcing violations of our Terms of Service including misuse of Services, fraud, abuse, and other trust and safety protocols; and
- protecting our legal rights and the rights of others.
If legitimate interest is not an available legal base in a particular jurisdiction, we will engage in the processing activities described above on a legal base that is available in that particular Jurisdiction;
We need to comply with our legal obligations under the applicable laws.
2.2 Purposes and Legal Bases for Processing
The purposes for which we process personal data, subject to applicable laws, and the legal base on which we perform such processing, are as follows:
| Purpose | Type of Personal Data | Legal Basis |
|---|---|---|
| To provide user account management and authentication | Account Information | Contract |
| To provide and facilitate the Services with you | Account Information Task Information | Contract |
| To provide customer support | Account Information Communications Information | Contract |
| To identify the abnormal status, ensure the stability and security of our Services, and to meet governmental and institutional policy obligations. | Account Information Task Information | Legitimate interests & Legal obligations |
| To investigate and resolve security issues, and to enforce our Terms of Service. | Account Information Task Information | Legal obligation & Contract |
3 How We Use Cookies and Similar Technologies
3.1 To ensure that our website works properly, we store small data files called cookies on your computer or mobile device, which usually contain an identifier, the name of the site, and some numbers and characters. The primary function of cookies is to facilitate your use of the site's products and services, as well as to help the site, for example, count the number of unique visitors.
3.2 When you use the Service, we will send cookies to your device, and we allow cookies (or other anonymous identifiers) to be sent to our servers when you interact with services that we provide to our partners.
3.3 We do not use cookies for any purpose other than those stated in this Privacy Policy. You can manage or delete cookies according to your own preferences.
4. How We Share, Transfer, and Disclose Your Personal Information
4.1 We only disclose your personal information as described in this Privacy Policy. Unless otherwise described, we will never sell your personal information to anyone for monetary consideration.
4.2 In certain circumstances, we may disclose your personal information to third parties for the purposes described in this Privacy Policy, including:
- Affiliates and corporate partners. We disclose the categories of personal information described above between and among our affiliates and related entities, for legitimate business purposes and the operation of the Services, in accordance with applicable laws.
- Service providers and business partners. Third-party service providers who provide us with information technology services and business support may need to process your data. These third parties will process your personal information on our behalf under relevant contracts.
- Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our Terms of Services and other terms, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by applicable laws (including exchanging information with other companies and organizations for the purposes of fraud protection).
- Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.
5. How We Transfer Your Data Around The World
Your personal data may be processed or transferred outside the country or region where you reside. Currently, your personal data will be stored in our servers located in Singapore. Due to the international nature of our business, your personal data may also be accessed remotely by our operations and technical support personnel, affiliates and third-party service providers located in Mainland China, solely for the purposes of operating, maintaining, supporting and securing the Services as set out in this Policy, and subject to access controls, least-privilege access rights and confidentiality obligations. Accordingly, your personal data may be transferred to and processed in jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located.
Besides, in the event of an international transfer of personal information, when required by applicable laws, we will provide an adequate level of protection for your personal information using various means, including implementing Standard Contractual Clauses or data transfer agreements that comply with applicable laws between our affiliates and third parties or any other lawful approach that permits the lawful transfer of personal data from those countries.
6 How We Store and Protect Your Personal Information
6.1 We will keep your personal information for the duration of your use of the Service. If you cancel your account or voluntarily delete the above information, we will delete or anonymize your personal data, unless otherwise required or permitted by applicable laws or regulations.
6.2 We attach great importance to information security. We will take appropriate industry-standard security measures and technical means to store and protect your personal information to prevent loss, unauthorized access, public disclosure, use, destruction, loss or leakage of your information. We will take all reasonably practicable steps to protect your personal information.
6.3 We also ask you to understand that in the Internet industry, due to the limitations and rapid development of technology and the possible existence of a variety of malicious means of attack, even if we do our best to strengthen the security measures, it is not always possible to ensure that the information is 100% secure.
6.4 The Services interoperate with third-party Agents, models and other services selected by you. Depending on the integration, your personal data may be transmitted directly from you to the provider under your account, please review the provider's privacy policy, data controls, retention settings and processing locations before connecting it.
7 Children's Privacy
7.1 We take the protection of minors' information very seriously. Our Services are not provided towards, and we do not knowingly collect any information about minors, as defined under applicable laws in the jurisdiction where the user is located.
7.2 If you become aware that a minor has provided any personal data to us while using our Services, please contact us at hellostarryy@croli.net and we will try to delete the relevant data as soon as possible.
8. Your Rights
Subject to applicable laws and depending on where you reside, you may have some rights regarding your personal information, as described further below. If you have any other requests related to accessing your personal information, please contact us using the details provided in the Section “Contact Us”. After receiving your request and completing any necessary verification, we will respond within the time frame required by law.
8.1 Data Access
You may have the right to know what personal information we process about you, including the categories of personal information, the business or commercial purposes for collection, the categories of third parties to whom we disclose it and other information according to the applicable law.
You may have right to access and obtain a copy of your personal information in accordance with the applicable laws. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
8.2 Data Correction
You may have the right to request that we correct inaccurate personal information that we retain about you, subject to certain exceptions.
8.3 Account Cancellation
You have the right to cancel your account by sending an email to hellostarryy@croli.net. Before processing your cancellation request, we will verify your identity, and you agree to provide accurate information as requested.
Please note that, once your account is canceled, we will stop providing services to you, and your account will be permanently disabled. According to the applicable laws and regulations, all associated historical records and data will be deleted or anonymized. This action is irreversible, so please proceed with caution when choosing to cancel your account.
8.4 Data Deletion
Upon cancellation of your account, we will delete or anonymize your personal information, unless otherwise required by laws and regulations. Additionally, you may also request deletion of the personal information you provide by contacting us. If some of your personal information cannot be deleted or anonymized, we will inform you of the reasons for not taking action.
Please note that, in accordance with applicable laws, we reserve the right to retain certain personal information in specific circumstances.
8.5 Withdrawal of Consent and Change the Scope of Consent
Each function requires some basic personal information to function properly. For any additional personal information collected, you can provide or withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal, but we will stop processing the relevant personal information going forward.
8.6 Objection to the Processing
Subject to applicable laws, you may object to the processing of your personal information based on our legitimate interests where there are grounds relating to your particular situation by contacting us. Please note that we may have an overriding legitimate interest to keep processing your personal information, but we will let you know where this is the case. In specific jurisdictions, you may only have the right to request the objection of processing your personal information under certain circumstances.
8.7 Restriction to the Processing
If you would like to restrict our processing of your personal information, you may contact us. In specific jurisdictions, you may only have the right to request the restriction of processing your personal information under certain circumstances.
8.8 Lodge a complaint with your local data protection authority
Subject to applicable data protection laws, you may have the right to submit your complaint to the local data protection authority where you reside if you consider that the processing of your personal information infringes any applicable data protection laws.
8.9 Other rights
Depending on your region and applicable laws, you may have additional personal information rights not mentioned above. You can exercise these rights by contacting us through the contact details provided in the Section “Contact Us”.
For United States residents, please find more details of your rights in Section 9 below.
9. Additional U.S. Residents Disclosures
We collect personal information from and about you in the preceding 12 months as described in Section 1 above.
We disclose personal information with third parties for business purposes in the preceding 12 months as below. You also have the right to request for a list of third parties to which we have disclosed your personal information under certain State data protection laws.
| Categories of personal information | Disclosed to which categories of third parties |
|---|---|
| All categories detailed in Section 1 above | Our affiliates |
To the extent provided for by local law and subject to applicable exceptions, you may have the following rights:
- Limit the Use of Sensitive Personal Information. You also have the right to request limitation of use and disclosure of your sensitive personal information, subject to certain exceptions. If you would like to limit the use of your sensitive personal information, please contact us by using the contact details provided in the “Contact Us” Section below. We do not “sell” or “share” (as defined under applicable State data protection laws) your sensitive personal information.
- Do Not Sell or Share My Personal Information. Based on the definition of “sell” and “share” under applicable State data protection laws, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.
- Appeal. You may appeal our refusal to take action on a request by contacting us using the contact details provided in “Contact Us” Section below.
- Direct Marketing. We do not disclose personal information to third parties for their direct marketing purposes.
- The Right to Non-discrimination. You have a right to not be discriminated against for exercising any of your rights.
If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in the “Contact Us” Section below. According to applicable laws, we may request you to provide documents such as application form and proof of identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under the applicable laws.
10. Updates to This Privacy Policy
10.1 Please understand that we may revise the contents of this Privacy Policy from time to time. For material changes that would materially diminish your rights under the Privacy Policy, we will notify you on the main exposure page of the Services or by postal mail, e-mail, or other appropriate means of reaching you prior to the effective date of the change. If you do not agree to such changes, you may stop using the Service, and by continuing to use our Services, you agree to be bound by the Privacy Policy as amended.
10.2 Material changes within the meaning of the Privacy Policy include, but are not limited to:
- 10.2.1 A material changes in our service model. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;
- 10.2.2 Significant changes in our ownership structure, organizational structure, etc. For example, a change in ownership due to business restructuring, bankruptcy, merger and acquisition, and so on;
- 10.2.3 Significant changes in your rights to participate in the handling of personal information and the manner in which they are exercised;
- 10.2.4 When there is a change in the department responsible for handling the security of personal information, contact information and complaint channels;
- 10.2.5 When a data protection impact assessment indicates that there is a high risk.
11 Contact Us
If you have any questions, concerns, or feedback about our Privacy Policy, please contact us:
Controller: STARRYY PRIVATE LIMITED, 3 Temasek Avenue, #27-02 Centennial Tower, Singapore
Contact Details: hellostarryy@croli.net.
Data Protection Officer: Croli Data Protection Team, hellostarryy@croli.net
We are committed to addressing your inquiries and will strive to respond as promptly as possible.