Last Revised: September 4, 2018
Sphero, Inc. (“Sphero”, "we" or “us”) is committed to protecting your and, where applicable, your child’s privacy.
- Data We Collect. We collect Identity Data, Contact Data, Sensor Data, Mobile Data (together with Identity Data, Contact Data, and Sensor Data, “Personal Data”), and Toy Data, each as defined below.
- Identity Data: Your age
- Contact Data: If you are over 13 (or such age as local law dictates), you may choose to provide your email address.
- Sensor Data: You may choose to use certain features of the Application that require access to the microphone, camera, or location data of your device.
- Mobile Data. If you download our Application, we may collect the type of mobile device and its software version.
- 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.
- Use of Your Data. Subject to your Rights and Choices below, we use your Data as follows.
- 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.
- For non-child users, if you have chosen to provide your Contact Data within the Application, we may send you newsletters, surveys, offers, and other promotional materials related to our Services, and for other direct marketing purposes. We may share your Contact Data with a Service Company (defined below) for this purpose. We do this to promote our products and issue our direct marketing.
- We use Sensor Data from your microphone to enable the Scream Drive feature.
- We use Sensor Data from your camera for Face Drive™. We may ask for write permission to your phone’s memory, but do not collect camera data.
- We use Sensor Data from your location on Android Devices to enable Bluetooth functionality.
- 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.
- Rights and Choices. You may exercise the below Rights and Choices by emailing Sphero’s Data Protection Officer at email@example.com with a copy to firstname.lastname@example.org. Our mailing address is Sphero, Inc., Attn: DPO, 4772 Walnut St., Suite 206, Boulder, CO 80301.