CHILDREN’S PRIVACY STATEMENT
Last Updated: July 24, 2020
Effective Date: October 5, 2020
Moxie is designed with privacy, security and parental control in mind. Embodied takes special steps to protect children. A parent must provide verifiable parent consent before a child can interact with Moxie.
Embodied is committed to be in compliance with the Children’s Online Privacy Protection Act (“COPPA”), a federal law designed to protect Children online. We take Children's privacy seriously and encourage parents or guardians to protect their Children's online privacy at all times. Embodied is working with PRIVO, an FTC approved Children’s Online Privacy Protection Act (COPPA) Safe Harbor organization, to safeguard the Personal Information of your child, ensure the safety of your child’s data and help us meet the high standards set by COPPA.
EMBODIED is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program (“the Program”). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children’s personal information collected online. The PRIVO COPPA certification Seal posted on this page indicates COMPANY has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at (855) 945-3411 or firstname.lastname@example.org. If you have further concerns after you have contacted us, you can contact PRIVO directly at email@example.com.
Protecting Children’s Privacy
Embodied takes special steps to protect children as defined in this Children’s Privacy Statement in our sites and services directed to children. Embodied does not condition a child’s participation in an activity or online service on the disclosure of more personal information than necessary and full verifiable parental consent is required for a child to interact with Moxie.
Please help us protect your children’s privacy by teaching your child to never provide personal information without your permission.
Collection and Use of Children’s Information
G.R.L. Site - Children do not need to own a Moxie to visit the G.R.L. website to explore characters, games and activities. If the child or parent does not own Moxie, the G.R.L. Site does not collect the child’s personal information.
If the child or parent owns the Moxie and has connected Moxie with the Parent App, the G.R.L. Site utilizes a first-party authentication cookie to allow Moxie users to more easily log in after the initial log in to the G.R.L. Site.
Google Analytics is utilized as users visit the G.R.L. Site.
Embodied utilizes Google Analytics to collected aggregated and anonymized information about activity on the G.R.L. Site. For example, the information collected may be that ten users have visited page A and ten users have visited page B on a certain day. However, no information is collected regarding who the users are. This information is only utilized by Embodied personnel.
Google Analytics is utilized to improve the performance and design of the G.R.L. Site.
Data will be automatically recorded by the Moxie in the form of video files and audio files and may be linked to a unique identifier for your robot. Anyone in range of the video or audio recording capabilities of Moxie may be recorded, including your child, members of your family or others in the home at the time the robot is recording.
Audio Data - The recorded audio data is encrypted and sent to our cloud service provider, Google Cloud ASR, which automatically transcribes the audio files to create audio transcription files. The audio transcription files will enhance Moxie’s abilities to process the files and understand the content of the recorded audio data. Moxie uses the audio transcription files to prepare responses to the child. The cloud service provider will delete the audio files after creating the audio transcription files. The audio transcription files will be transmitted to the cloud storage service provider. Our cloud storage service provider does not have access to the audio transcription files; only Embodied has access. The audio transcription files will remain on a secure and encrypted server after data collection has been completed. The audio transcription files may be stored for three years.
Video Data - The recorded video data will be automatically processed locally at Moxie to create facial expression datapoints. The facial expression datapoints will allow Embodied to determine facial expressions of the child and/or analyze the emotion of the child in order to enhance the interaction between Moxie and child. The facial expression data points will be transmitted to the cloud storage service provider and are encrypted during transmission and storage. The facial expression datapoints are only accessible to Embodied and are not accessible by the cloud service provider. The facial expression datapoints may be stored for three years. The recorded video data does not leave Moxie, is utilized to create the facial expression datapoints, and is deleted after the facial expression datapoints have been created. The recorded video data is not transmitted from Moxie.
Primary User Images - The camera on Moxie will initially capture images of the primary user (your child) during their first interaction with Moxie. The primary user images are utilized by Moxie to verify that Moxie is speaking to the primary user during conversation interactions. The primary user images are used to recognize and respond appropriately to the primary user. The primary user images will be encrypted and securely transmitted to the cloud storage service provider. Only parents will have access to the encrypted primary user image. During interaction with Moxie, please note that images of other individuals may be captured if they are within the field of view of the camera. Moxie may compare these images to the images of the primary user to determine if this individual is the primary child user. Moxie may communicate with the other individuals, but Moxie is designed to call only the primary child user by name. This comparison is performed within Moxie and there is no communication with the cloud storage service provider.
Developmental Data – Moxie collects developmental data to understand how children improve their skills over time. For example, the subset of developmental data includes how long children using Moxie engages with the robot, how many books the children read with the robot, how many missions the children have completed, what pronouns the children utilize, and other information to track developmental goals. The Moxies user developmental data will be encrypted and stored on the cloud server service provider and linked with the parents account. The Moxie user developmental data will be stored for the life of the parent account.
Anonymized Developmental Data - Moxie collects an anonymized subset of developmental data to understand how children improve their skills over time. For example, the anonymized subset of developmental data includes how long children using Moxie engage with the robot, how many books the children read with the robot, how many missions the children have completed, what pronouns the children utilize, and other information to track developmental goals. The anonymized subset of developmental data will be encrypted and stored with the cloud storage service provider, but in a different account from the audio transcription data and the facial expression datapoints and other personal information. The anonymized subset of developmental data will be stored indefinitely.
Sensor Data – Moxie includes sensors that are utilized to identify if and where other objects or persons may be located in a room. In addition, the sensors are utilized to determine if a child is touching or hugging Moxie. The sensor data is collected and processed on Moxie and is utilized to enhance the child’s interaction with Moxie. The sensor data is then anonymized, encrypted and transmitted to the cloud service provider and stored in the same account as the anonymized developmental data. The anonymized sensor data is stored for three years.
Parental Access to Information
Even after the parent or guardian has provided Embodied consent to collect and user her Child’s personal information, the parent or guardian can 1) review, correct and/or delete the Child’s personal information and/or 2) stop collection or use of the Child’s personal information. To do so, please send your request to the following address at Embodied or email us at firstname.lastname@example.org. Be sure to include your email address and/or contact information. We will let you know what additional information we require to verify that you are a parent.
Attn: Customer Support
385 E. Colorado Blvd., Suite 110
Pasadena, CA 91101