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Embodied, Inc. Privacy Policy


April 28, 2020

Embodied, Inc. (Embodied) cares about your privacy and wants you to be fully informed of the information we collect and how we use it to offer our products and services, including Moxie, our interactive smart assistive robot. Along with our companion eCommerce and corporate website embodied.com (eCommerce Site), Parent Application (Parent App), Embodied’s Global Robotics Laboratory (GRL) children’s website www.globalroboticslab.com (the “GRL site”), and Embodied’s proprietary Artificial Intelligence (AI) SocialX™ platform, Moxie was designed with the help of child development experts to support the emotional and social development of children ages 5 - 10. Corporate information about Embodied and our online store are available at embodied.com


Embodied is committed to compliance with the Children’s Online Privacy Protection Act (COPPA) and is working with PRIVO®, a COPPA Safe Harbor organization, to obtain verifiable parental consent for their child to use Moxie. We intend that Moxie will be fully COPPA (Child Online Privacy Protection Act) Safe Harbor certified. COPPA’s purpose is to provide parents control in protecting their children’s privacy online and our certification means that parents can feel safe knowing that Embodied abides by leading data integrity and security procedures.

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 privacy@embodied.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

Our Children’s Privacy Statement may be found at embodied.com/pages/childrens-privacy-policy.

Protecting your privacy and the security of the data entrusted to us are at the heart of how we develop our products, services and platform. We also want you to know how to exercise your right to access, correct or delete the information you entrust to us. During setup and registration of the Parent App and Moxie, you will be asked to provide parental consent to Embodied’s data collection practices, which are described herein. During setup parents will receive a unique recovery key. The recovery key is utilized to assist in recovering data if lost for any reason. In addition, the recovery key is also used in generating the encryption key. The recovery key is only accessible by you; Embodied does not have access to this. Accordingly, if you lose the recovery key, Embodied cannot recover your data.

You can opt-out of parental consent to Embodied’s data collection practices at any time although this may mean that some of the Embodied Services will not be operational. If you opt-out of the data collection practices, Moxie will become non-operational because Moxie operation relies on audio and video data processing.

Note to Pioneer Mentor Program Participants: Participants in our pre-launch Pioneer Mentor Program are subject to specific privacy practices while using Moxie during our beta test period outlined in the Pioneer Mentor Program Informed Consent Agreement (“Program Agreement”). The Participants will have provided verifiable parental consent to participate in the Program by executing that Program Agreement. Please refer to the Program Agreement for details.

1. SECURITY


The Embodied Products were developed with security in mind.

Where possible, data collected by Moxie is processed and stored locally. Embodied takes steps to protect and secure data that cannot be limited to on-device processing during transmission and in the cloud through encryption and other measures. We take steps to securely send and store data, and only work with business partners and cloud service providers who provide assurances that they will do the same.

Embodied segregates certain personally identifiable information and other information about users or the device into separate databases, which are secured and encrypted.

Embodied strives to protect the information provided to and/or collected by us when you use the Embodied Services through commercially reasonable administrative, technical, and organizational safeguards. While Embodied works hard to protect your information, no security method is 100% secure. Thus, Embodied cannot guarantee that the security methods and/or precautions we take are failure proof.

We recommend that you learn about and use security tools, habits, and practices to protect the online security of you and your family members, such as protecting your recovery key from others and having a backup copy of the recovery key in a safe and secure location.

2. CUSTOMER PRIVACY RIGHTS


If you are a resident of California or a resident of Nevada, you have certain privacy rights as described in this section.

A. California Privacy Rights

If you reside in California, we are required to provide additional information to you about how we use and disclose your information. You may also have additional rights with regard to how we use your information. We have included this California-specific information below.

Uses and Disclosure of Your Information - Consistent with Sections 3, 4 and 5 of this Privacy Policy, we collect certain categories and specific pieces of information about individuals that are considered "personal information" in California. As detailed below, we may collect this personal information from you and other third parties. We may collect, share and disclose personal information for the business and commercial purposes described detail below.

Do Not Sell: Subject to certain exceptions, California residents have the right to opt out of the "sale" of your personal information. We do not sell Personal Information of children or information collected from our Parent App to third parties for their advertising or marketing purposes. We do not monetize the information you provide; however, we work with third party advertisers on our eCommerce site to provide relevant advertising, which may be considered a “sale.” Please review our Cookie Policy below for information on third parties we work with. To exercise your Do Not Sell rights, please contact Embodied at (855) 945-3411 or support@embodied.com. Only the eCommerce Site includes marketing and remarketing cookies. The Parent App, the Moxie and the GRL Site do not utilize these cookies. To opt out of sharing your information and receiving personalized ads at our e-Commerce site through our third party advertising partners, you may contact them directly or use the opt-out tools available from the Digital Advertising Alliance at https://optout.aboutads.info/?c=2&lang=EN or the Network Advertising Initiative at https://optout.networkadvertising.org/?c=1. Opt-outs are browser and device-specific. If you decide to opt out, ads may still be delivered, but they might be less relevant to you and your interests. Whatever decision you make, you can change it at any time.

Deletion, Access and Information Requests - Subject to certain exceptions, as a California resident, you have the right to: (i) obtain deletion of your personal information; (ii) obtain access to your personal information; and (iii) receive information about the categories of personal information about you that we have "sold" (as that term is defined under California law) to "third parties" (as that term is defined under California law) and also that we have disclosed for a "business purpose" (as that term is defined under California law). This Privacy Policy describes the categories of information we collect.

Deletion Requests: If you would like us to delete your personal information, please contact customer support at support@embodied.com for more information on how you can exercise these rights. You will need to provide us certain information, including your email address, so that we may verify your request and communicate with you regarding your request.

Access Requests: If you would like to access your personal information, please contact customer support at support@embodied.com for more information on how you can exercise these rights. You will need to provide us with certain information, including your email address, so that we may verify your request and communicate with you regarding your request.

You may also contact Embodied at (855 945-3411) or support@embodied.com for assistance in exercising any of the California rights described above.

Should you wish to request the exercise of these rights as detailed above, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.

California Shine the Light - Under California Civil Code § 1798.83, as a California resident, you may opt out of companies disclosing personal information to third parties for their direct marketing purposes. Embodied does not disclose personal information to third parties for their direct marketing purposes.

Nevada Privacy Rights - Subject to certain exceptions, under Nevada Revised Statutes 603A, Nevada residents may opt out of the “sale” of personal information covered under the statute. Embodied does not sell personal information that is covered by this statute.

Do Not Track - At this time, we do not take steps to respond to do not track signals available on some browsers. You can manage your cookie preferences using your own browser settings to accept or block some or all cookies or receive notice so you can consent to cookies. If you block all cookies, some features of the Embodied Services may be unavailable to you.


3. WHAT INFORMATION DO WE COLLECT DURING SETUP OF THE MOXIE PARENT APP AND MOXIE?


No child can begin interacting with Moxie until a parent has provided verifiable parental consent. Moxie is equipped with a camera, microphones and other sensors to interact with your child. Moxie captures video and audio of your child. The sensors are utilized to identify if and where other objects or persons may be located in a room or if a child is touching or hugging Moxie. Embodied utilizes our proprietary AI platform (SocialX™) to analyze data and to provide and improve our services, and to develop new content, features, services and products. Embodied has implemented strong measures to secure personal data to offer your child the benefits of Moxie. Where possible, data is processed and stored locally on the Moxie device to avoid sending personally identifiable information into the cloud. Embodied takes steps to protect and secure data that cannot be limited to on-device processing during transmission and in the cloud through encryption and other measures.

As will be described in detail below, to use Moxie, parents must set up a Parent App account and provide certain information, like name and email address, and child’s first name and birthdate. Once you set up the account, parents may click the Grant Consent button to visit our COPPA Safe Harbor partner, PRIVO, to complete the parental verification process and start using Moxie. Until a parent provides verifiable parental consent, the account will not be active and your child will not be able to engage with Moxie.

The Parent App allows parents to set focus on developmental goals for their child, including cognitive, social, and emotional developmental goals, and to track their child’s progress with Moxie. This Parent App account data is securely stored separately from other data.

We describe below when the Parent App and Moxie collect data and what data is collected.

A. When Does The Parent App And Moxie Collect Data?

We collect information from you in the following circumstances: 1) when you share it voluntarily; and 2) when we collect it automatically via Moxie’s microphones, sensors and/or cameras.

The Parent App and Moxie do not utilize cookies or similar technologies to automatically collect data.

The Parent App collects personal information from you when you establish your account. The personal information collected is detailed below in the section entitled “What Information Does the Parent App Collect and Why Does the Parent App Collect It”

When Moxie is turned on using the power switch on its base, it will take some time to start up and get ready. Several icons will appear on the screen, after which Moxie’s screen will turn purple showing Moxie’s eyes closed. During this period, Moxie will begin collecting and using audio data. The audio data will be encrypted and transmitted to Google’s Automatic Speech Recognition (ASR) server (which is waiting to hear the commands “Hello Moxie” or “Moxie, Please Wake-Up”). No audio transcription files will be generated or stored during this period. Moxie will not collect and use video data during this period. When Moxie is ready to begin interacting, dream bubbles will appear on the screen. When Moxie hears the commands “Hello Moxie” or “Moxie, Please Wake Up”, its eyes will open and it will then be in operational mode.

In operational mode, Moxie collects audio data and video data utilizing its camera, microphones, and sensors. In operational mode, if the LED bar is Light Blue, Moxie is listening for input. If the LED bar is Blue, Moxie is processing the input it received. If the LED bar is White, Moxie is speaking. The data collection practices during operational mode are discussed below in the Section entitled “What Data Does Moxie Collect and Why Does Moxie Collect It.”

After interacting with Moxie and saying “Moxie, Please Go to Sleep”, Moxie will go into standby mode. In standby mode, the LED bar and a heart LED will pulse slowly but the screen will be off. While in standby mode, Moxie is only listening for the “Hello Moxie” command and is not collecting audio data or video data. The audio data is collected by the microphones but is not transmitted to the Google ASR servers because the voice recognition of the “Hello Moxie” command is performed on the Moxie device. The collected audio data is not stored. Once it receives the “Hello Moxie” command, Moxie returns to operational mode.

B. What Information Does the Parent App Collect and Why Does the Parent App Collect It

Moxie is designed to put parents in control of your child’s experience and use. The child cannot use Moxie unless the parent has provided verifiable parental consent. The Parent App collects information from you to serve your needs, communicate with you, manage our content, allow you to track your child’s progress in meeting developmental goals you set, and improve Embodied Services and products. The Parent App may collect the following information from you:


Login information for accessing your account

Personal contact information to allow Embodied to contact you, including your name and email address.

Child’s first name and birthdate.

Child developmental goal information that you choose to input to the Parent App.

Event information such as parent’s birthdays or appointments.

The Parent App does not utilize cookies and thus does not automatically collect information from you. The online app stores from where the Parent App may be downloaded may collect the number of times the Parent App is downloaded and application usage.

The Parent App may receive the following information from Moxie about your child.

Children Interaction Performance Data (such as books read, calculated reading comprehension, calculated vocabulary level, amount of time spent interacting or reading, badges or trophies received, activity patterns). This data is encrypted and stored on Moxie as well as the cloud and may be accessed by the Parent App.

The Parent App may receive or collect an identity verification indicator from PRIVO to verify your identity and that you are a parent or guardian. We do not collect or receive any of the information you provide to PRIVO to verify your identity.

We may also collect authentication information (for example, to verify that you are an authorized purchaser) from our eCommerce vendor, Shopify to confirm your purchase.

Using the Parent App, parents may access their child’s personal information, update their or their child’s personal information, or change and update goals for their child. Parents may activate or deactivate notifications received from Moxie regarding Moxie’s status or new missions available for your child. Parents may view a recover key to recover data in case Moxie is replaced and the data needs to be reloaded. The recovery key is stored in the device running the Parent App (e.g., the device’s flash drive or hard drive).

A parent may also revoke consent in the Parent App to allow Embodied to collect their child’s data; through Moxie but this will render Moxie inoperable.

A parent may deactivate the parent account in the Parent App. When you delete or deactivate the parent account, you and your child’s personal information is deleted. The aggregated, anonymized data collected when Moxie is operational is not deleted.


C. What Information Does Moxie Collect and Why Does Moxie Collect It

Moxie may collect the following information from your child when interacting with the robot.

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, who 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 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 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.

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.

Anonymized Usage Patterns of Moxie - Moxie collects fully anonymized usage patterns of robot activities and operations to improve hardware and software operations. The anonymized usage patterns of robot activities and operations is communicated to the cloud storage service provider and will be stored with the cloud storage service provider, but in a different account from the audio transcription data and the facial expression datapoints. The anonymized usage patterns will be stored indefinitely.

Moxie also collects information about the device you’re using to access the Parent App, like your device ID and IP address. This information helps us analyze usage and update and improve our services.

D. The Parent App and Moxie Share Information with The Following Third Parties

The Parent App utilizes Privacy Vaults Online (“PRIVO”) to verify your identity and also to confirm that you have provided verifiable parental consent pursuant to COPPA. To do that you must share certain information with PRIVO. You may learn more about PRIVO’s privacy policy at https://www.privo.com/privo-privacy-policy. Embodied does not receive the information you provided to PRIVO for identity verification but is notified that you have provided verifiable parental consent.

Moxie shares voice data with Google to 1) perform speech recognition of your child’s voice and 2) as our cloud-based storage provider. You can read more about how Google uses your personal information here: https://policies.google.com/privacy.

The Parent App and Moxie do not allow links to social networks.

The Parent App and Moxie do not share personal information with third parties for marketing purposes.

Finally, we may share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful requires for information we receive, or to otherwise protect our rights, the rights of parents and children using Moxie or other third parties.

E. Mobile App Stores

You may be required to register with and/or log onto a third-party mobile app store before you can download the Embodied Parent App. When downloading the Parent App, the app store provider may also collect certain device and app-related information. Embodied does not control the privacy policies or requirements of the app stores. Therefore, you should review the terms of use and privacy policies of the app stores before downloading and then using the Parent App and check your device settings for control options.


4. What Information Do We Collect When a Parent Purchases Moxie?


Parents may purchase Moxie by visiting our eCommerce Site. We work with a third-party eCommerce vendor, Shopify, to handle transactions. We do not receive or process your credit card details.

A. What Information Do We Collect at Our eCommerce Site?

The eCommerce Site collects login information, personal contact information, and shipping information.

Our eCommerce Site partner collects contact information, billing information, shipping information. We do not receive billing information, such as credit card information.

1. Cookies and Technology – The eCommerce Site utilizes the following cookies.

Operationally Necessary Cookies – We may use technologies that are necessary to the operation of our eCommerce Site. This includes technologies that allow you to access our eCommerce Site; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of functions such as shopping carts, saved search or similar functions.

Performance Related Cookies – We may use technologies to assess the performance of our e-commerce Site, including as part of our analytic practice to help us understand how our visitors use our eCommerce Site, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services or tools.

Functional Cookies – We may use Technologies that allow us to offer you enhanced functionality when accessing or using eCommerce Site. This may include identifying you when you sign into our eCommerce Site or keeping track of your specified preferences, interests or past items viewed so that we may enhance the presentation of content on our eCommerce Site.

Advertising or Targeting Cookies - We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our eCommerce Site or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement or searched for our products, services or company.

B. When Do We Collect Information at Our eCommerce Site?

We collect information from you at our eCommerce Site in the following circumstances: 1) when you share it voluntarily; 2) to fulfill a transaction; and 3) automatically utilizing Cookies or similar technology.

When a customer places an order for Moxie, you can share personal contact information, login information, billing information and shipping information about you when you purchase Moxie or register for your account. We may also collect authentication information (for example, to verify that you are an authorized purchaser) from our eCommerce vendor, Shopify, but never get your credit card details.

When a customer places an order for Moxie, we collect order information associated with the transaction. Customers may register for an account on the eCommerce site when they place an order for Moxie and will enter user id / password information (“login information”). When registered customers place future orders for robots / accessories, they can identify themselves with this login information.

When you visit our eCommerce Site, we automatically collect information utilizing cookies or other tracking technologies, including device information, IP address, and web site pages visited, to allow you to access or interact with the e-Commerce Site, when you use or visit them.

C. Why Do We Collect Information at Our eCommerce Site?

We collect information from you to serve your needs and fulfill your request and to operate efficiently. We collect information to fulfill and complete a transaction, to confirm your order and to provide you with updates about your order. We collect information to understand our visitors to the eCommerce Site.

D. What Personal Information is Shared at Our eCommerce Site?

We share your personal information with third-party partners who help us to provide the eCommerce Site, who manage your purchase transactions and process and fulfill your orders and requests. We do not receive, process or store your credit card information. Embodied utilizes Shopify to power our online store and receive your billing information. You can read more about how Shopify uses your Personal information here: https://www.shopify.com/legal/privacy.

We share your personal information with third-party partners to better understand our visitors to the eCommerce Site.

The eCommerce Site may use Google Analytics to collect information regarding visitor behavior and visitor demographics on our eCommerce Site and to develop website content. For more information about Google Analytics privacy practices, please visit www.google.com/policies/privacy/partners.

Embodied may partner with third-party advertising networks to either display advertising on the eCommerce Site or to manage our advertising on other websites. We may and/or our advertising network partners may use cookies and web beacons to collect personal information about your activities on our eCommerce Site to provide you targeted advertising based upon your interests. These partners may be Google Remarketing, Bing Remarketing and/or Google Pixel. For information about Google’s privacy practices, please visit www.google.com/policies/privacy/partners. For information about Bing Remarketing’s privacy practices, please visit https://privacy.microsoft.com/en-us. For information about Facebook’s privacy practices, please visit https://www.facebook.com/about/privacy. Please refer to Google, Bing’s and Facebook’s privacy policies to determine how to opt-out of their respective collection or processing of data.

Social Media Widgets – The eCommerce Site may include social media widgets, such as links to Facebook, Instagram, Twitter, YouTube and LinkedIn (the widgets include share buttons, interactive mini-programs). The widgets may collect your IP address, the page you are visiting on the eCommerce Site and may establish a cookie to enable the widget to function properly. This data may be transferred to the third-party social media platform, but any subsequent use of your personal information by the third-party social media platform is governed by the social media platform. Embodied is not responsible for any personal information about you that is collected and stored by third parties.

E. Choices and Controls of Personal Information on eCommerce Site

The parent or guardian may change their account information including name, contact information, billing information, shipping information and/or payment information.


5. WHAT INFORMATION DO WE COLLECT AT GRL SITE


The GRL Site allow your child to engage in activities, play self-contained games and to learn about the history and backstory of Moxie.

A. Personal Information the GRL Site Collects

You do not need to own a Moxie to visit the GRL Site to explore characters, games and activities. If you do not own a Moxie and your child visits the GRL Site, the GRL Site will not collect personal information about your child. If you have any questions regarding the GRL Site, please contact us at grlsupport@embodied.com.

If you own a Moxie and visit the GRL Site, the GRL Site utilizes a persistent authentication cookie to connect the GRL Site your child uses with the Moxie robot your child interacts with and to track who has logged onto your account. The information collected includes the IP address, the mobile device ID and operating system. The persistent authentication cookie allows your child to not have to go through the connection process repeatedly.

B. When Does the GRL Site Collect Personal Information

At the GRL Site, the persistent authentication cookie collects its information when the child logs into or enters the GRL Site if you own a Moxie robot.

C. Why Does the GRL Site Collect Information

The GRL Site utilizes a first-party authentication cookie to allow for easier login.


6. CERTIFICATIONS

Embodied is intending that Moxie will be fully COPPA (Child Online Privacy Protection Act) Safe Harbor certified. Thus, we anticipate having PRIVO’S seal on the Embodied Services.


7. CONTACT US WITH YOUR QUESTIONS

If you have any questions, please don’t hesitate to contact us!

Embodied, Inc.
Attn: Privacy
385 E. Colorado Blvd., Suite 110
Pasadena, CA 91101
privacy@embodied.com