Last Updated: 3/16/2023

This policy does not apply to our education users. If you are an education customer, please see our Education Privacy Policy at edu.sphero.com/child-policy.  

As a company focused on inspiring the creators of tomorrow, we are passionate about protecting your privacy. We have divided this policy into two parts; we start with a general overview of the key points and then provide more details on those concepts later in the policy. Our policy works in tandem with our Terms of Use, which we recommend you read as well. 

Overview

We limit the information we collect from those using our products and give parents control over their children’s information. If you have questions, please email support@sphero.com or Sphero’s Data Protection Officer at dpo@sphero.com.

Learn more about parental controls >

  

We collect information about you—such as your name, login details, and contact information—to provide our service, personalize it for you, and contact you in connection with your product or our service. Sometimes we collect data from our products, such as when they crash, in order to improve the product for you. We also collect information on how people interact with our site to help us improve the user experience and provide more relevant advertising. For our users outside the United States, we also want to flag for you that we may need to transfer your data back to the United States—which is where we are based.

Learn more about how we use data >

Learn more about the data we collect >

 

We believe in your privacy and keeping your data secure. So we have adopted measures to help us safeguard your information. For example, we put security measures in place to prevent our robots from being used in nefarious ways. Find or suspect a vulnerability in our system? Let us know at security@sphero.com.

Learn more about our security >

 

We don’t disclose your data often, but sometimes we provide it to (1) our vendors who help us make our website or products work better, (2) companies who help us tailor advertising to your interests, and (3) others in limited situations described below (such as when the law requires it). 

Learn more about when we disclose data >

 

We make sure you have control over your data and how we use it. If you don’t want to get messages from us or want to close an account, you can do so at any time. Plus, if you want to delete your in-app data from our systems, just email our team at support@sphero.com and we’ll take care of it (though we may still retain copies of your records in our routine backups). 

Learn more about your rights >

The Fine Print (aka the Full Policy)

Sphero, Inc. (“Sphero”, “we”, or “our”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, and disclose information from users of our products, websites (the “Site”), applications linking to this policy (the “Applications”), and services provided through the Site (together with the Site, products, and Applications, the “Services”).

This policy does not apply to websites, products, applications, or services that display or link to different privacy policies; in the event of a conflict or inconsistency between this policy and a product or application’s privacy policy, the latter will govern.

1. Collection

We collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process Personal Data you provide us, including from your device or use of the Services. The elements listed in each category are not an exhaustive list; they are examples we provide to help you better understand our practices.

We collect the following categories of Personal Data you provide to us:

  • Identity Data. First name, last name, age or birthday, and username/password
  • Contact Data. Email and mailing address
  • Payment Data. Credit card, bank account, or other information used in payments
  • Transaction History. Purchases and services
  • User Content. Text inputs, images, audio/videos recordings, or other content you provide while using the Services
  • Social Medial Data. Likes or demographic details from your social media profile (but only when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites)

We also collect the following categories of information (some of which is Personal Data) from your product or device:

  • Device Data. Data about the device you use to access our Services, e.g. device type, its software version, or carrier
  • Product Data. Data about your product, how the product or Application is used or operates, such as diagnostic data, MAC Address or device identifier depending on the product, accelerometer data from crashes, and the like
  • Usage Data. Data about the use of our Services, including analytics information, how you use our Services, e.g. clickstream data from our Site, information on how long you stay or what you do on our Site, whether a page or email was loaded/opened, and the like
  • User Controls. Audio or visual inputs (e.g. camera inputs) used to control a device

California requires we present this information to you in a slightly different format—using categories the state specifies. For our California residents, we collect the following categories of Personal Data: Identifiers, Customer Records, Commercial Information, Internet or Other Electronic Network Activity Information, Geolocation, and Sensory Information . 

2. Uses

We generally use your information to:

  • Provide our Services. We use your information as necessary to provide our Services or complete transactions you request. For example, we may use it to maintain your account, fulfill your orders, respond to your comments, provide requested support, and improve our services by understanding what you like (or don’t like). 
  • Operate our Products. Our products are interactive, and we are always working to improve our products and make sure everything works. For example, we may process user data to help you control the product, understand engagement with it, and personalize the content when you use it (such as greeting you by username or showing you age-appropriate content).
  • Improve our Offerings. We are always working to improve our Site and want to keep visitors informed about our offerings. For example, we may use your data to help us understand and improve our Site’s design and our Services’ functionality. 
  • Communicate with You. We use your contact information for promotional marketing if you have purchased a product or agreed to receive such emails. For example, when you provide us contact information, we may send you newsletters, surveys, offers, and other promotional materials related to our Services. 
  • Provide Relevant Advertisements. We, and certain third parties operating on or through our Site, may collect your information in order to provide you more relevant advertising on our Site and elsewhere on the internet. You can find more information our practices below in the Cookies and Similar Technologies section.

With your consent, we may also use your Personal Data for other reasons. We do not use your sensitive Personal Data for any reasons not permitted by California Civil Code section 1798.121(a) and the related regulations.

For our European customers, the law in Europe—the GDPR and similar United Kingdom legislation—requires we also tell you our legal bases for processing your information. We generally process your Personal Data based on our legitimate interests. These interests include: direct marketing, personalizing and providing the Services, evaluating marketing campaigns, securing and protecting our Services, looking into suspicious activity, investigating violations of our policies or Terms of Use, and preventing harm to you or others. But we rely on (1) legal necessity when we use your information to comply with legal obligations or (2) your consent when using non-essential cookies, transferring Personal Data to the United States, and engaging in other activities not addressed elsewhere in this policy.

3. Cookies and Similar Technologies

To make our Services more useful to you, we and our trusted partners may use cookies, web beacons, or similar technologies (collectively “Cookies”) to process Personal Data when you interact with our Site. Generally, we use Cookies to ensure our Site functions properly, gather analytics that helps us improve the Site, and provide you with relevant advertising. You can find more details on our use of Cookies by visiting our Cookie Policy here.

If we determine you are visiting our Site from Europe, we will seek your consent before using any non-essential Cookies. For our other users, you can opt out of certain Cookies by following the instructions in our Cookie Policy, exercising the rights described below, changing your browser’s settings, or visiting www.networkadvertising.org/choices/ or www.aboutads.info/choices. 

Please note, at this time, our Site does not respond to your browser’s do-not-track request or similar signals. 

4. Disclosures & Transfers

In the last 12 months, we have not disclosed your Personal Data to third parties, as that term is defined in applicable privacy laws. We may, however, disclose your information to the following recipients:

  • Vendors. We provide information to vendors we rely on to provide us certain services or process data on our behalf. Our vendors can only use the data pursuant to our instructions, and they are contractually bound to adhere to confidentiality and security obligations in a way that is consistent with this Policy
  • Affiliates. We provide information to our affiliates to help us streamline our operations, develop products, communicate with our customers, and carry out similar business functions.
  • Marketers. We provide information to marketing companies to help us deliver relevant advertisements. 

We may also disclose information to others: to comply with the law or court orders, in connection with appropriate investigations, as needed to protect our legal interests (such as advancing or defending claims), and in connection with a corporate reorganization (such as a merger or acquisition). It is possible that we will make these disclosures to recipients in locations that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. 

We do not give your information to third parties in exchange for money. As discussed more above, however, we allow trusted partners to collect some of your data so they can provide you targeted advertising based on your interactions with us and others online. Some states may consider this practice as us “selling” or “sharing” your information. In the last 12 months, we allowed companies to collect the following categories of personal data for targeted advertising: Internet or Other Electronic Network Activity Information. We do not have actual knowledge that we allowed those companies to collect information on anyone who is younger than 16 years old.

We are based in the United States. So, if you create or use an account in another country, you consent to your data being processed in and transferred to the United States.

5. Your Rights and Choices

You have the following rights concerning your Personal Data:  

  • Access. You can request that we provide you access to the Personal Data we have about you. Specifically, you can ask us to give you: the specific pieces of Personal Data we collected, the categories of that data we collected, the source of that data, our purpose for collecting it (and selling or sharing it, if applicable), the categories of data we disclosed to a third party for a business purpose (along with the categories of recipients), and the categories of data we sold or shared (along with the categories of recipients). You can also request that we provide you a copy of your Personal Data in a common, portable format.
  • Correct. You can request that we correct Personal Data we hold about you. You may be able to make changes to much of the information you provided via your account settings menu.
  • Delete. You can request that we delete your Personal Data.
  • Object. For our European customers, you can object to our processing of your Personal Data when we do so based on our legitimate interests. 
  • Opt-Out of Sales & Sharing. You can ask us to not sell or share your Personal Data. [As a reminder, the only “sale” or “sharing” we do is allowing our trusted partners to collect your information to deliver you more targeted advertising.] You can make this choice yourself by using our Cookie management function on our website.
  • Complain. You have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or other applicable regulator.
  • Withdraw Consent. If we are processing your Personal Data based on consent, you can withdraw your consent.

We will not discriminate against you for exercising these rights. Unless another method is explained above, you (or your parent/guardian if you are a child), can exercise your rights by emailing us at dpo@sphero.com or sending us a letter at:

Sphero, Inc.
Attn: DPO
7121 B Shelby Ave
Dock 85
Greenville, TX 75402

Additionally, our California customers can exercise their California Consumer Privacy Act rights by using the form located here or calling us at 1-888-977-4376. For some requests, we may need you to provide additional information, such as your email address. If you are asking to access, correct, or delete your data, we will send an email to your address and await your reply to confirm your identity before fulfilling the request. We do allow you to rely on an authorized agent to submit a request on your behalf, but they must first provide us your written authorization allowing them to make such a request on your behalf. 

6. Retention

We keep your data for as long as necessary to fulfil the purpose for why we collected it, complete any additional activities to which you consented, or comply with our legal obligations

7. Security

We use technical and organizational measures designed to protect your Personal Data. For example, we use SSL to encrypt data in transit and encrypt passwords at rest.

8. Other Privacy Policies

Some of our products and applications have their own privacy policy. The individual privacy policies are:

When you use those products or application, their policy will apply instead of this policy. 

9. Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision. If we make any changes to this Privacy Policy, we will change the “Last Updated” date at the top. If there are material changes to our Privacy Policy, we will obtain your consent and provide additional notice as required by law.

10. Contact & Controller Information

Sphero welcomes your comments or questions regarding this Privacy Policy. You can email us at legal@sphero.com or send us a letter at:

Sphero, Inc.
Attn: Legal, Privacy Policy
7121 B Shelby Ave
Dock 85
Greenville, TX 75402

For our customers in Europe, the data controller for your Personal Data is Sphero, Inc.  You can reach Sphero’s Data Protection Officer at dpo@sphero.com. Please include “Attention: Data Protection Officer” in your email.