Sphero Academy Privacy Policy
Last Revised: December 14, 2018

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 services we offer through Sphero Academy (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. Data We Collect.  We collect Identity Data, Contact Data, Payment Data, Video Data (together with Identity Data, Contact Data, and Payment Data, “Personal Data”), and Other Data, each as defined below.

a. Data You Provide to Us Upon Sphero Academy Signup.
• Identity Data: Participant’s age range, first name; parent’s first and last name and any notes parent chooses to provide
• Contact Data: Parent’s email and phone number
• Payment Data: Credit card number, zip code, payor name
• Other Data: Robot to be used in training, controller device, survey information

b. Data Collected during Sphero Academy. The examples of Data given below are illustrative and subject to change in Sphero’s sole discretion.
• Video Data: Your child’s voice, appearance, and whatever else is displayed on the screen during the Services. If the Participant is a child under the applicable local law, we will notify the Parent and seek any required consent to collect this Data. We do not collect Video Data on children without a parent’s or guardian’s consent.
• Edu Data. You or your child will be required to use the Sphero Edu application during the Services, available at edu.sphero.com. That application collects Personal Data in accordance with the Sphero Edu Privacy Policy. Please read that policy for more information on how Sphero Edu collects, uses, and shares data.

2. Use of Your Data. Subject to your Rights and Choices below, we use your Data as follows.

a. Identity Data. We use your Identity Data to comply with applicable privacy law and to communicate with you or your child regarding the Service. Specifically, we use your Identity Data to tell whether the Participant is a child, as defined by local law. We use your child’s first name to address them and to identify the children for which parental consent has been obtained.

b. 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.
• We may solicit feedback from you about the Service using your Contact Data.

c. Payment Data. We process this data to obtain payment for the Service. We do not use this data for any other purpose.

d. Other Data. We use the Other Data for our legitimate business interests in the improvement of our Service and the creation of a personalized user experience, including in the following ways:
• to understand how to teach the Sphero Academy participant on their own device and robot;
• to operate and improve our application and Services, internal operations, and systems, along with the Service Companies (defined below);
• to improve the quality of experience when you interact with our Service;
• understand you and your preferences to enhance your experience and enjoyment using our Service;
• to derive information about the demographics that use our Service; 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.

e. 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.

f. Video Data. In order to teach the Participant to code, we need to see the Participant. We will use a video feed to speak with them and teach them how to code, and to otherwise provide the Service. Sphero does not record or store this video feed.

3. Service Companies. We use third-party Service Companies to help provide and host the the Service, to help us collect the data we collect, to analyze it, and to further our other legitimate business interests. We provide Personal Data to our Service Companies or other trusted businesses or persons to process it for us, based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. If Sphero is involved in a merger, acquisition, or asset sale, we will continue to ensure the confidentiality of any Personal Data and give affected users notice before Personal Data is transferred or becomes subject to a different privacy policy.

a. Payment Data: We share Payment Data with Braintree, a PayPal service. Please see Braintree’s Privacy Policy for more information.

b. Video Data. We share Video Data with Zoom. We use Zoom to provide the videoconferencing capability for the Service. Please see Zoom’s Privacy Policy for more information.

c. Identity Data, Contact Data, and Other Data. We share Identity Data, Contact Data, and Other Data with Acuity Scheduling. We use Acuity Scheduling to host signup and intake for the Service, and as a scheduling platform. Please see Acuity’s Privacy Policy for more information.

d. For more details on how Service Companies handle your Personal Data and a list of those Service Companies, please see our Main Sphero Privacy Policy.

4. Rights and Choices. You may exercise the below Rights and Choices by emailing Sphero’s Data Protection Officer at dpo@sphero.com with a copy to support@sphero.com. Our mailing address is Sphero, Inc., Attn: DPO, 4772 Walnut St., Suite 206, Boulder, CO 80301.

a. Access. You may receive a list of your Personal Data that we process to the extent required and permitted by law.

b. Rectification. You may correct any Personal Data that we hold about you to the extent required and permitted by law.

c. Erasure and Objection to Processing. To the extent required by applicable law, you may request that we delete your Personal Data from our systems. You can stop future collection of all Data by the Application by uninstalling it.

d. Data Export. To the extent required by applicable law, we will send you a copy of the Personal Data we hold from you in a common portable format of our choice.

e. Regulator Contact. 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 consumer protection authority.

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 Updated” date above.

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