Sphero, Inc. (“Sphero”, "we" or “us”) is committed to protecting your and, where applicable, your child’s privacy.

This 
Privacy Policy describes how your and, where applicable, your child’s, data is collected, used, and disclosed by Sphero from the mobile application known as the Sphero Edu Jr™ App (the “Application”), toys controlled by the Application (the “Toy(s)”), and the services we offer through our Application and through the Toy (together with the Toys and the Application, the “Services”). This Policy does not apply to websites, applications, or services that display or link to different privacy policies. Any third parties described below that process your data may not adhere to this Privacy Policy; Sphero expressly disclaims any and all liability for unauthorized processing by such third parties. For subjects not covered in this Policy, the Main Sphero Privacy Policy controls.

1. Your Data and Sphero Edu Jr. The following types of data are involved in the use of the Application:
a. Mobile Data. If you download our Application, we may collect the type of mobile device and its software version.
b. Sensor Data: You may choose to use certain features of the Application that require access to the location data of your device.
c. Toy Data. Using Bluetooth, the Toy may transmit Toy Data to the Application such as Toy identifier, when a Toy connects to an Application, date/time stamps, non-personal diagnostic data regarding how you use the Application, MAC Address or device identifier depending on the Toy, accelerometer data, crashes, and the like. These examples of Data are illustrative and subject to change in Sphero’s sole discretion.

2. Use of Your Data. Subject to your Rights and Choices below, we use your Data as follows:
a. Contact Data. We use your Contact Data to provide support services if you contact us.  For example, if you contact us through customer service or support, we will use your Contact Data to respond to your comments and questions, and to provide customer service.
b. 
Sensor Data. We process this data on your device, not as part of an information society service. We will obtain consent in the Application before collecting this data, and you may cease collection of this data at any time by consulting your Application’s settings. However, some features of the Application or Toy may not function without the Sensor Data. We process this data to personalize your experience and to provide features in the Application. For example, we use Sensor Data from your location on Android Devices to enable Bluetooth functionality.
c.
 Mobile Data and Toy Data. We use the Toy Data and Mobile Data for our legitimate business interests in the improvement of our Application and Toys, and the creation of a personalized user experience, including in the following ways:
      • to understand a user’s engagement in an activity or feature, for example which activities on the Toy the user played, time spent on pages, and data about any crashes during use, to Sphero’s servers, which may be hosted by a Service Company.
      • to operate and improve our Application and Services, internal operations, and systems, along with the Service Companies;
      • to improve the quality of experience when you interact with our Application and Services;
      • to understand you and your preferences to enhance your experience and enjoyment using our Services;
      • to derive information about the demographics that use our Services; and
      • to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
The legitimate interests we rely on for this processing are:
      • to create, provide, support, and maintain innovative Toys, Applications, and features that enable people, including children, to enjoy Toys and Applications that promote their well-being; and
      • to secure our platform and network, investigate suspicious activity or violations of our terms or policies; and to protect the safety of Personal Data, including to prevent exploitation or other harms to which users may be particularly vulnerable.
 
d. Support. If you contact us for support through the Application, we may collect first and last name, email address, and any information you choose to include in your query.


3. 
Service Companies. We use third-party Service Companies to help provide and host the Application and the Service, to help with direct marketing, to help us automatically collect the Mobile and Toy data, to analyze the Toy Data, and to further our other legitimate business interests.

4. 
Rights and Choices. While personal data is not collected via this Application, you may choose to share data with us via other mechanisms (e.g. subscribing to email notifications on our web site or by contacting our Support team).  For all questions related to your rights and choices around personal data, please see the Main Sphero Privacy Policy.

5. 
Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision. If we make any changes to this Policy, we will change the "Last Revised" date above.