The iRobot Corporation Cookie and Privacy Policy
Last Updated: May 22, 2023
Contents
- What’s in this policy?
- What does this policy cover?
- How do you protect my personal information?
- What types of personal information does iRobot collect about me?
- How long will iRobot keep my personal information?
- How can iRobot use my personal information?
- When does iRobot share my personal information with others?
- Can children use iRobot’s services?
- What are my choices regarding my information?
- How does iRobot use cookies and similar tracking?
- How will I find out about changes to this policy?
- How can I contact iRobot?
Appendices
1. What’s in this policy?
This policy tells you:
- what information we might collect about you,
- how we might use that information,
- when we might use your details to contact you,
- what information of yours we might share with others,
- your choices about the personal information you give us, and
- your rights as they relate to your personal information.
Because this policy is lengthy and covers such a wide range of information,
we suggest that you take a few moments to review the following terms:
- “iRobot”, “we”, “us”, etc. = iRobot Corporation
- “robots” = non-stationary iRobot consumer floorcare products
- “devices” = all iRobot consumer products, including but not limited to, all robots, Aeris Air Purifiers and Klaara Air Purifiers
- “Website” / “websites” = www.iRobot.com and all related pages and subdomains
- “app” / “apps” = iRobot’s mobile applications which provide support for devices, including the iRobot Home application and the Aeris Air application
- “Service” / “services” = our websites, robots and apps
- “you”, “your”, etc. = anyone who interacts with iRobot’s services
- “personal information” = data that can be linked to a specific individual
- “sensitive personal information” = non-public data about a specific individual, such as account login credentials or precise geolocation
- “deidentification” = a process used to remove the ability to link data back to an individual; this process is able to be reversed
- “anonymization” = a subcategory of de-identification whereby data can never be re-identified, or linked back to the individual
- “automated decision making” = the activity of using computer programs to automatically analyze or assess personal behaviors, habits, interests, or hobbies, or financial, health, credit, or other status, and then to make decisions based on the analysis of such information.
2. What does this policy cover?
This policy covers all iRobot and Aeris Air websites, mobile applications,
services, and devices, with the exception of our educational robots.
iRobot Select and iRobot SmartCare subscription services data collections
are governed by this policy with specific exceptions noted below. For more
information about these services, please visit:
https://select.irobot.com/terms-of-service.
These are commercial services run by iRobot. iRobot will generally be the
controller of your information when you use these websites and apps.
It’s up to you to decide how much detail you want to know. We have
explanation “pop ups” that appear when we ask you to input your personal
information. As well as what’s in this Policy, a new feature or update might
include a short privacy notice. In that privacy notice, you can find key
information on what we do with your personal information when you use that
service.
If you are looking for more detailed information about key metrics and
digital governance and enforcement measures on iRobot’s services, iRobot
publishes its annual Transparency Report in June. The link will be available
here.
What’s not covered in this policy?
As stated in the previous section, our educational robots are not covered
under this policy.
- For privacy information related to iRobot’s educational robots, click here: https://edu.irobot.com/privacy-policy
Additionally, iRobot is not able to provide you with any information about
third party privacy policies. Our services sometimes link to other
companies’ services, like iRobot’s social media profiles on LinkedIn,
Facebook, or Instagram, or you may be able to access our services from other
places like third-party discount programs, e-commerce websites, etc. Those
companies have their own privacy and cookies policies, so remember that the
information you give them will follow their rules and not ours. Make sure to
check their privacy policy so you know how they will use your information.
3. How do you protect my personal information?
We’re strongly committed to keeping your information safe. And to do this we
design our services with your data protection and privacy in mind. Our
internal policies require us to separately store and restrict access to any
personal information that can be easily linked back to you, like your full
name and email address. We also have teams dedicated to looking after your
information security and privacy.
One way that we protect your personal information is by deidentification or
anonymization. We also encrypt personal information so only those authorized
to access personal data are able to do so.
At the same time, no service can be completely secure – if you have any
concerns that your iRobot account or personal information has been put at
risk, for example if someone could have found out your password, please
review this resource:
https://homesupport.irobot.com/s/article/15990.
Where we store your information
iRobot stores personal information in a secure cloud environment, with
strict access controls, data encryption at rest and in transit, and periodic
audits to ensure access is only given to those who require it.
Some companies that provide services to us operate their services from
locations outside where the data is collected. We only authorize these
service providers and data transfers if they meet our security requirements.
Keep in mind that when you give us personal information it could be
transferred to, stored, or processed in a location outside where the
information was collected. The place where your information is processed may
not have the same regulatory privacy protections as the place where it was
collected.
What happens if your information is compromised
If the personal data we have collected from you is compromised, we will
investigate the situation and notify you as required by applicable laws.
4. What types of personal information does iRobot collect about me?
We’ll give details about why we need your personal information and how we’ll
use it before we collect it, unless it’s obvious.
Information you provide
When you make an order, create an iRobot or Aeris Air account, sign-up for
offers or otherwise engage with our services, we may ask for certain
personal information such as your name, email address, username and
password, shipping address, billing information, and phone number.
Please note that by continuing to use iRobot’s services, you are
acknowledging that iRobot cannot guarantee the privacy of personal
information you choose to post publicly on the internet, including on
iRobot’s website or social media pages.
Information on your activities when you talk to us
We may ask for personal information when you call us, send us an email, or
provide us with comments, chat messages and opinions on our websites or
through our services.
Information on your activities when you talk about us
For example, if you “like” or “follow” our social media accounts, we’ll
collect your handle.
Information on your registered devices
When you register your device, we collect information about your device,
such as:
- identification number,
- serial number, and
- product code.
Information we receive from third parties
You may use third party social networks or authentication services, such as
Facebook or Google, to login to our website or apps. These services may
share your personal information with us, like your name and contact
information.
The data we receive from these third-party services is dependent upon your
privacy settings with the social network. You should always review and, if
necessary, adjust your privacy settings on third-party websites and services
before linking or connecting them to our Service.
You may interact with a link to or from a third party, or a social media
feature. If you follow a link to any of these websites, note that your
interactions with these companies are governed by their privacy policy, not
iRobot’s. We recommend that you review the policies and terms of use of any
third party before you submit any information to those websites.
If you follow a link to any of these websites, please note we do not accept
any responsibility or liability for their services or practices.
Please review your privacy settings on the applicable social media sites.
Depending on your cookie/tracking settings, these social media sites may
automatically record information about your browsing behavior every time you
visit a site that has a social media button, regardless of whether you click
on the button.
Information we collect from registered devices equipped with smart
technology
Some of our devices are equipped with “smart technology”, which essentially
means that they can wirelessly send us data. These devices include, but are
not limited to:
- Roomba Combo j7+
- Roomba s9+
- Roomba j7+
- Roomba j7
- Roomba i3+ EVO
- Roomba i4
- Braava jet m6
- aair Lite Small Room Air Purifier
- aair 3-in-1 Pro Air Purifier
If you have one of these devices, we may collect information like:
- device and app usage data (specifically things like name, device number, battery life, mission information, device health and operations data),
- device replenishment data (specifically things like the need for new filters or other robot device parts),
- device environment data (specifically things like level of dirt, Wi-Fi name/credentials/signal strength, robot movement, floorplan and room names, existence and type of objects, floor type, other iRobot devices),
- partner app information (specifically the names of smart home partner apps you have downloaded).
This data is stored in a deidentified state (separated from identifiable
information).
Unless your device is enrolled in the iRobot Select program, it will NOT
automatically transmit this information.
To be able to transmit, the device needs to be (1) registered online and (2)
connected to Wi-Fi, Bluetooth or the internet in some way. Apart from iRobot
Select and iRobot SmartCare devices that require connections to operate, you
can use our smart technology devices without
Wi-Fi or Bluetooth data transmission, simply by disconnecting your Wi-Fi or
Bluetooth from the device or by never connecting it at all. For more
information on how to disconnect your device from Wi-Fi or Bluetooth, please
see the section below “9. What are my choices regarding my information?”. ”.
Through the settings in your app, you may choose to not transmit map data to
us; you may also choose to send images of obstacles to help improve our
services.
You may also opt-in to connect your iRobot account with our smart home
partners and you may opt-in or opt-out of sharing related information with
us through the iRobot app.
Information you share as a part of the iRobot BETA Program
You may decide to be a part of the iRobot BETA Program which, when enabled
by you on the app, allows you to use additional, experimental device and/or
app functionality. By default, you are not enrolled in the BETA Program. If
you would like to participate, you must manually opt-in within the iRobot
app.
When available, some of the experimental features included in the BETA
Program may require more data than the typical use of the iRobot services to
work properly. To be sure that you are okay with sharing additional
information, you will need to opt-in to each experimental feature separately
prior to being able to use it.
The data required to support a BETA feature will be disclosed in the BETA
Program section of the app at the time that the new BETA feature is
released. You may choose not to participate with all or some of the BETA
features. If you decide not to participate in a BETA feature, any data
solely used to support that feature will not be collected.
Information collected as part of the BETA Program is subject to the same (or
functionally similar) physical, administrative, and technological safeguards
as other information collected under standard device use.
5. How long will iRobot keep my personal information?
When you give us any personal information, we only hold your information for
as long as we need it to do the activities we told you about or if we have a
valid reason to keep it. Some other criteria for holding on to your data
include:
- whether we have a current or ongoing relationship with you and are actively providing a service,
- what type of information it is, the amount collected, how sensitive it might be and any legal requirements,
- whether the personal information has been deidentified,
- whether we have a legal or compliance obligation that we must comply with, or
- whether holding on to the data is advisable based on our legal position (in terms of applicable statutes of limitations, litigation, or regulatory investigations).
We may hold on to your data if it is first anonymized to be used for our
records and/or for development purposes. If you would like your personal
information to be deleted from our systems, please see the section below “9. What are my choices regarding my information?”.
6. How can iRobot use my personal information?
We must have a valid reason to use your personal information. It’s called
the “lawful basis for processing”. Sometimes we might ask your permission to
do things. Other times, when you’d reasonably expect us to use your personal
information, we don’t ask your permission, but only when:
- the law says it’s fine to use it, and
- it fits with the data or privacy rights you have.
We use your information for these types of things:
- to process and ship orders, returns or repairs,
- to send you information about your orders,
-
to send you information about product sales, special offers and new site
features,
- This information will be sent according to your preferences which can be accessed either from your account on https://www.irobot.com or in the app.
- to operate and maintain features and functionalities of the devices and services we provide,
- to deal with your requests, complaints and inquiries,
- to detect and prevent fraud,
- to diagnose and fix technology problems,
- to improve our services and our device capabilities,
- to enable iRobot to research and innovate,
- to personalize your experience and our marketing communications,
- to help us understand what kind of services you might use,
- to recommend things we think might interest you,
- to send you emails with news, offers and promotions,
- to show you advertising on our services and to understand how effective it is,
- to market our products and services to you on social media, and
- to contact you about other issues, including password resets, relevant security notifications, and privacy updates.
7. When does iRobot share my personal information with others?
iRobot will never sell your information. We may share your information with
others in these ways:
a. When you make something public
Like post a comment which the public can see.
b. When we use other companies to power our services
In order for us to give you quality experiences and to understand how you’re
using our services, we often use other companies to process your personal
information on our behalf.
For example, for customer service, trouble-shooting robots, sending you
emails about things we think might interest you, or analyzing data on how
people use our digital services so we can improve them.
We work to ensure that your personal information is processed as if we were
handling it directly. We carefully select these companies, only share with
them what they need to do the work and we make sure they keep your
information secure.
c. When we share personal information with companies in our group
Other companies owned by, or that are owned by the same company as iRobot,
may access your data under the terms included in this Policy.
d. When you use another company's service that connects to us, like
voice-enabled devices and connected TV
We allow third parties to create apps and tools that work with our devices
and services, like Amazon Alexa and Google Assistant.
If you want to connect a third-party app with our devices or services, we
will let the third party collect information that is necessary to support
the connection. However, iRobot does not control the data collection and use
practices of these connected third parties. We recommend reviewing any
third-party privacy notices before connecting.
You may opt-in or -out of a third-party app or service integration at any
time through the app or by disabling your account directly with the
third-party providers.
e. When we share personal information with purchasers and third parties
in connection with a business transaction
We may share your personal information in connection with a transaction,
like the sale of company assets or shares, or acquisition.
f. When, by law, we have to pass on your information to other
organizations
We might also share your information if we have to by law, or when we need
to protect you or other people from harm.
g. When we have “anonymized” your data so that you cannot be
identified.
8. Can children use iRobot’s services?
We do not create content and services for anyone under 16, and we do not
intentionally collect or maintain information from persons under 16.
If you become aware that personal information about a person under 16 has
been provided to us, please immediately contact us at
dataprotectionofficer@irobot.com. That way, we can delete the information from our records.
9. What are my choices regarding my information?
You’re in control of your personal information. You have the right to:
- request a copy of your information,
- control device data collection,
- correct information that is wrong,
- ask us to delete your information or request that we only use it for certain purposes,
-
change your mind and ask us to stop using your information, and
- For example, unsubscribing from any marketing emails or turning off personalization.
- opt out from personalized advertising cookies and other tracking.
Requesting a copy of your information
If you would like to submit a request for a copy of your information, please
contact iRobot Customer Care. We require you to comply with a verification
process to ensure that you are the owner of the data you are asking us to
delete. If you have any questions or issues about your data subject rights,
please contact
dataprotectionofficer@irobot.com.
Controlling device data collection
You may be able to control or stop the collection of certain usage data from
your registered device, like when you opt-in or -out of certain features,
through the “Account” and “Product Settings” pages in the app. For features
that require you to opt-in before collecting device or usage data, opting
out of the feature will immediately halt any future data collection related
to that feature.
You may also control or stop the collection of usage data from your
registered device by disconnecting your device from Wi-Fi or Bluetooth via
the app.
- On the iRobot mobile app home page, you should follow this path to change your Wi-Fi connectivity: Product Settings > Wi-Fi Settings > Change Product Wi-Fi > Go to phone settings. In your phone’s settings, turn off iRobot’s access to local network, Wi-Fi and/or Bluetooth.
If you decide to turn back on iRobot’s access to Wi-Fi, the app will
automatically sync with the last known Wi-Fi network. If anything has
changed about your Wi-Fi settings since your app was last connected, you
will need to go back into the app to update that information.
Please contact
iRobot Customer Care
if you have questions about disconnecting your device.
Correcting information about you that is wrong
You may correct information about yourself by logging into the website or
the app. To make your corrections through the website, select the “My
Account” page; to do so through the app, select the “Account” page.
If you have any questions or issues, please contact
iRobot Customer Care.
Requesting the deletion of your information
If you would like to submit a request for us to delete your information, you
may do so in the app.
To submit a data deletion request via the app, you should follow this path:
Account > Your Name/Email (top row of
the page) > Kebab Menu (3 vertical dots at top right of
page) > ‘Request to delete account’ >
‘Delete Account’
If you have any questions or issues about your data subject rights, please
contact
dataprotectionofficer@irobot.com.
Controlling marketing communications
You may control your communication preferences through the “My Account” page
on our website or the “Account” page in the app. You may also click the
“unsubscribe” button on any promotional email communication we send you.
Note that you may not be able to unsubscribe or opt-out of non-promotional
messages regarding your account, such as account verification, order
confirmations, changes, or updates to features of the Service, or technical
and security notices.
Controlling personalized advertising cookies and other tracking
You may be able to avoid the collection of information through some cookies
or other tracking technologies by actively managing the settings on your
browser or mobile device. Please refer to “10. How does iRobot use cookies and similar tracking?” section below to learn about disabling or blocking cookies and tracking
technologies.
Jurisdictional Rights
Depending on your jurisdiction, you may be entitled to additional rights in
relation to your personal information.
10. How does iRobot use cookies and similar tracking?
What are cookies and tracking technologies?
Cookies are small text files which are transferred to your computer or
mobile when you visit a website or app.
There are also similar pieces of tracking information we collect, like web
beacons, embedded scripts, location-identifying technologies, file
information, and similar technology (collectively, “tracking technologies”).
When does iRobot collect information this way?
We may collect usage information when you visit our website or use our apps,
read our emails, or otherwise engage with us.
iRobot complies with all applicable laws related to cookies and other
tracking technologies.
Why do we use cookies and other tracking?
We use this information to do a few different things:
- to remember information about you, so you don’t have to give it to us again,
- to keep you signed in, even on different devices,
- to help us understand how people are using our services, so we can make them better,
- to deliver advertising,
- to help us personalize your use of iRobot’s services to you by remembering your preferences and settings,
- to find out if our emails have been read and if you find them useful.
We may also combine this information with your personal data. If we do
combine these data types, the combined information will be treated as
personal data.
What are the types of cookies?
Some cookies are always on when you visit us, and you can’t turn them off
unless you change your browser settings. We call these “strictly necessary
cookies”. We use them to make sure our digital services work correctly.
Examples include cookies that let you log into our website and add items to
your shopping cart.
We also use functional, performance and advertising cookies to make your
experience more enjoyable. You can switch these on or off at any time and
you can always change your mind.
Bear in mind there are some other cookies out there from other companies.
These "third-party cookies" might track how you use different websites,
including ours. For example, you might get a social media company’s cookie
when you see the option to share something. You can turn them off, but not
through us.
How long do cookies last?
Some are erased when you close the browser on your website or app. Others
stay longer, sometimes forever, and are saved onto your device so that
they’re there when you come back.
How do I control my cookies and tracking?
Strictly necessary cookies are always on when you visit us. On your first
visit to us, we’ll tell you about our other types of cookies and ask you to
choose which cookies we can use. You can always change your mind.
Keep in mind that stopping all cookies might mean you can’t access some
iRobot services, or that some of them might not work properly for you.
iRobot’s cookie consent banner
If you would like to reset your preferences via our cookie consent banner,
you should clear your cookies and relaunch our website.
iRobot’s cookie consent pop-up manager
If you would like to change your preferences via our cookie consent pop-up
manager, you may do so on iRobot.com via the link labelled ‘Cookie
Preferences’ on the bottom left-hand side of our universal web footer.
Your browser
You may change your browser settings to assist with cookies (typically found
in the “options” or “preferences” menu of your browser). Most browsers allow
you to:
- Set notifications to manually approve or reject received cookies;
- Disable existing cookies; and
- Automatically reject new cookies.
“Do Not Track” is a general web browser setting that informs other websites
that you do not want their tracking cookies. Although we do our best to
honor the privacy preferences of our users, we are unable to respond to “Do
Not Track” signals set by your browser at this time.
Your email
You may also set your email options to prevent the automatic downloading of
images that may contain technologies that would allow us to know whether you
have accessed our email and performed certain functions with it.
Your mobile device
For mobile users, you have controls in your device Operating System that
enable you to choose whether to allow cookies or share your advertising ID
(aka Identifier for Advertiser or “IDFA”) with companies like iRobot or our
advertising service providers.
- To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’.
- To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt Out of Ads Personalization’.
If you have any questions or issues about iRobot’s cookies and how to
exercise your consent preferences, please contact
dataprotectionofficer@irobot.com.
Where can I find more information on cookies and tracking
technologies?
To find out more about cookies, including how to see what cookies have been
set and how to manage and delete them, visit
https://allaboutcookies.org/.
To find out more about Google’s advertising products, including controlling
your preferences or to opt-out of certain products, visit the Google Ads
Preferences Manager at
https://google.com/ads/preferences, or by vising the Network Advertising Initiative’s online resources at
https://optout.networkadvertising.org/.
To opt-out of interest-based advertising by participating companies in the
following consumer choice mechanisms, please visit:
- Digital Advertising Alliance (DAA)’s self-regulatory opt-out page: https://optout.aboutads.info/
- DAA’s mobile application based “AppChoices” download page: https://youradchoices.com/appchoices
- European Interactive Digital Advertising Alliance’s consumer opt-out page: https://youronlinechoices.eu
- Network Advertising Initiative’s self-regulatory opt-out page: https://optout.networkadvertising.org/
Please note that some advertising opt-outs may not be effective unless your
browser is set to accept cookies. Furthermore, if you use a different
device, change browsers, or delete the opt-out cookies, you may need to
perform the opt-out task again.
11. How will I find out about changes to this policy?
We update this policy from time to time. If we make important changes, like
how we use your personal information, we’ll let you know. It might be a
notice, an email, or a message in your app. To see when we last updated this
policy, check out the “Last Updated” date at the top of this notice.
If you don’t agree to the changes, then you can always stop using our
services, delete your account and stop giving us any more personal
information. We’d be sorry to see you go.
12. How can I contact iRobot?
For any questions or comments about this policy, contact us at
dataprotectionofficer@irobot.com.
If you have an unresolved privacy or data use concern that we have not
addressed satisfactorily, please contact our U.S.-based third-party dispute
resolution provider (free of charge) at
https://feedback-form.truste.com/watchdog/request.
FOR RESIDENTS OF CALIFORNIA
This California Privacy Notice (“California Notice”) supplements the iRobot
Corporation Cookie and Privacy Policy. This California Notice applies to
applies to California residents whose personal information is processed by
iRobot pursuant to the California Consumer Privacy Act (“CCPA”), the
California Privacy Rights Act (“CPRA”) or other California privacy laws
described below. The California Notice describes how we protect the personal
information we process and control relating to California residents and
rights California residents may have in relation to their personal
information. For the purposes of this California Notice, “personal
information” has the meaning provided by the CCPA and does not include
information that is publicly available, that is deidentified or aggregated
such that it is not capable of being associated with you, or that is
excluded from the CCPA’s scope, such as personal information covered by
certain sector-specific US privacy laws, such as HIPAA, the FCRA, GLBA, or
the Driver's Privacy Protection Act of 1994.
Collection and use of personal information. We collect
personal information from and about you as described in the “4. What types of personal information does iRobot collect about me?” section above. To learn more about the categories of personal information
we have collected in the last 12 months and how we use this information,
please refer to
TABLE 1 - PERSONAL INFORMATION WE MAY COLLECT FROM DEVICES
and
TABLE 2 - PERSONAL INFORMATION WE MAY COLLECT FROM COOKIES AND OTHER
TRACKING TECHNOLOGY.
Disclosure of personal information. We share personal
information with service providers (as defined in the CCPA), and with third
parties for business purposes, in a manner that does not constitute a “sale”
(as defined in the CCPA - for example, at the direction of the consumer). As
defined in the CCPA, "sell" "selling”, "sale" or "sold is when the
organization sells, rents, releases, discloses, disseminates, makes
available, transfers, or otherwise communicates in any means, personal
information to a third party for monetary or other valuable consideration.
To learn more about how we disclose data to third parties, please refer to
the “7. When does iRobot share my personal information with others?” section above.
We allow certain third-party advertising partners to collect information
about the users of our Service for the purposes of serving ads that are more
relevant, for ad campaign measurement and analytics, and for fraud detection
and reporting. All cookies that are not strictly necessary (including
third-party) require prior, opt-in consent from California consumers, are
loaded per the consumer’s instructions and preferences, and do not involve
“sales” of personal information. To learn more about online advertising and
how you may be able to control some of this activity, please refer to the
“10. How does iRobot use cookies and similar tracking?” section above.
Your California Rights and Choices. As a California
resident, you may be able to exercise the following rights:
-
the right to know any or all of the following information
relating to your personal information we have collected and disclosed in
the last 12 months, upon verification of your identity:
- The specific pieces of personal information we have collected about you,
- The categories of personal information we have collected about you,
- The categories of sources of the personal information,
- The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed,
- The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
- The business or commercial purposes for collecting or selling personal information.
- the right to correct any inaccurate personal information we have about you.
- the right to request deletion of personal information we have collected from you, subject to certain exceptions.
-
the right to opt-out of the sale and/or the sharing of
your personal information and sensitive personal information to third
parties now or in the future.
- iRobot does not sell personal information.
You also have the right to be free of discrimination for exercising these
rights. However, please note that the exercise of these rights may limit our
ability to process personal information. For example, if you submit a
deletion request, we may no longer be able to provide you with our products
and services or engage with you in the same manner.
Limit the Use of Sensitive Personal Information. You also
have the right to request limitation of use and disclosure of your sensitive
personal information (as defined in the CCPA, as amended), subject to
certain exceptions. If you would like to limit the use of your sensitive
personal information, please contact us at
dataprotectionofficer@irobot.com.
Do Not Sell or Share My Personal Information. iRobot does
not sell personal information. If you would like to opt-out of the sharing
of your personal information for cross-context behavioral advertising,
please contact us at
dataprotectionofficer@irobot.com.
To submit your California Consumer Rights Requests. You may
submit a request to exercise your California Consumer Rights through one of
the mechanisms described below. We will need to verify your identity before
processing your request, which may require us to request additional personal
information from you or require you to log into your account, if you have
one. In certain circumstances, we may decline or limit your request,
particularly where we are unable to verify your identity or locate your
information in our systems, or as permitted by law.
To exercise your California Consumer Rights, please submit a request by
contacting us using the information provided in the “9. What are my choices regarding my information?” or the “12. How can I contact iRobot?” sections above. You can view and request deletion of your account
information by following the instructions on our Customer Care website.
Subject to certain restrictions, you can have an agent exercise your rights
for you. If you have an agent exercising your rights, we must be provided
with your written authorization allowing that person to make such a request
on your behalf. We reserve the right to deny the agent’s request if we are
not reasonably able to confirm proper authorization and/or verify your
identity as the requestor.
Appeal. You may appeal iRobot’s refusal to take action on a
request by emailing us at
dataprotectionofficer@irobot.com.
If your appeal is denied and you are a California resident, you may contact
the California Attorney General about the results of the appeal by
submitting a complaint by clicking here:
https://oag.ca.gov/contact/consumer-complaint-against-business-or-company.
California’s “Shine the Light” Law. California's "Shine the
Light" law (Civil Code Section §1798.83) provides certain rights to
California residents that have an established business relationship with us
with regard to the disclosure of certain types of personal information to
third parties for their direct marketing purposes. iRobot does not disclose
personal information to third parties for their direct marketing purposes
unless the customer first affirmatively agrees to that disclosure.
Return to “9. What are my choices regarding my information?”.
FOR RESIDENTS OF COLORADO, CONNECTICUT, UTAH, AND VIRGINIA
This non-California, United States Privacy Notice (“U.S. Notice”)
supplements the iRobot Corporation Cookie and Privacy Policy. This U.S.
Notice applies to Colorado, Connecticut, Utah and Virginia residents whose
personal information is processed by iRobot pursuant to applicable data
protection laws, including the Colorado Consumer Privacy Act, the
Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and the
Virginia Consumer Data Protection Act.
For information related to California residents, please see the
California Notice
above.
Collection and use of personal information. We collect
personal information from and about you as described in the “4. What types of personal information does iRobot collect about me?” section above. To learn more about the categories of personal information
we have collected in the last 12 months and how we use this information,
please refer to
TABLE 1 - PERSONAL INFORMATION WE MAY COLLECT FROM DEVICES
and
TABLE 2 - PERSONAL INFORMATION WE MAY COLLECT FROM COOKIES AND OTHER
TRACKING TECHNOLOGY.
Disclosure of personal information. We share personal
information with third parties for business purposes. To learn more about
how we disclose data to third parties, please refer to the “7. When does iRobot share my personal information with others?” section above.
We allow certain third-party advertising partners to collect information
about the users of our service for the purposes of serving ads that are more
relevant, for ad campaign measurement and analytics, and for fraud detection
and reporting. To learn more about online advertising and how you may be
able to control some of this activity, please refer to the “10. How does iRobot use cookies and similar tracking?” section above.
Your Rights and Choices. As a resident of Colorado,
Connecticut, Utah, or Virginia, you may be able to exercise the following
rights:
- the right to be informed about how your personal information is being used.
- the right to access the personal information we hold about you.
- the right to correct inaccurate or incomplete personal data we hold about you.
- the right to data portability to transfer the personal data you have provided to us to another controller in a structured, commonly used, machine-readable format.
- the right to request deletion of personal information we have collected from you, subject to certain exceptions.
-
the right to opt-out of the sale and/or the sharing of
your personal information and sensitive personal information to third
parties now or in the future.
- iRobot does not sell personal information.
- the right to object to targeted advertising.
- the right to object to automated decision making. You have the right to object to any processing of data that is carried out without human intervention.
You also have the right to be free of discrimination for exercising these
rights. However, please note that the exercise of these rights may limit our
ability to process personal information. For example, if you submit a
deletion request, we may no longer be able to provide you with our products
and services or engage with you in the same manner.
Sensitive data. If you are a resident of Colorado,
Connecticut, or Virginia, you also have the right to opt-in to the
processing of your sensitive personal information.
Deidentified data. iRobot practices collection purpose
limitation and data minimization practices when it comes to your personal
information. As such, deidentified data will not be re-identified.
To submit your Consumer Rights Requests. You may submit a
request to exercise your Colorado Consumer Rights through one of the
mechanisms described below. We will need to verify your identity before
processing your request, which may require us to request additional personal
information from you or require you to log into your account, if you have
one. In certain circumstances, we may decline or limit your request,
particularly where we are unable to verify your identity or locate your
information in our systems, or as permitted by law.
To exercise your rights, or if you have any questions relating to your
rights, please contact us using the details set out in the “9. What are my choices regarding my information?” or the “12. How can I contact iRobot?” sections above.
Subject to certain restrictions, you can have an agent exercise your rights
for you. If you have an agent exercising your rights, we must be provided
with your written authorization allowing that person to make such a request
on your behalf. We reserve the right to deny the agent’s request if we are
not reasonably able to confirm proper authorization and/or verify your
identity as the requestor.
Appeal. You may appeal iRobot’s refusal to take action on a
request by emailing us at
dataprotectionofficer@irobot.com.
If your appeal is denied and you are a Colorado resident, you may contact
the Colorado Attorney General about the results of the appeal by calling
1-800-222-4444, or by submitting a complaint by clicking here:
https://coag.gov/file-complaint/report-consumer-fraud/.
If your appeal is denied and you are a Virginia resident, you may contact
the Virginia Attorney General about the results of the appeal by calling
1-800-552-9963, or by submitting a complaint by clicking here:
https://www.oag.state.va.us/consumercomplaintform/form/.
Return to “9. What are my choices regarding my information?”.
FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA, UK, OR SWITZERLAND
This European Privacy Notice (“European Notice”) supplements the iRobot
Corporation Cookie and Privacy Policy. This European Notice applies to
applies to certain persons in the European Economic Area (“EEA”), the United
Kingdom (“UK”) or Switzerland whose personal information is processed by
iRobot pursuant to applicable data protection laws, including the EEA
General Data Protection Regulation, and the UK General Data Protection
Regulation.
Data subject rights. If you are an individual located in
the European Economic Area ("EEA"), UK or Switzerland, you have the
following rights in relation to your personal information:
- the right to be informed about how your personal information is being used.
- the right to access the personal information we hold about you and, in certain circumstances, to transfer the personal data you have provided to us to another controller in a structured, commonly used, machine-readable format.
- the right to correct inaccurate or incomplete personal data we hold about you without undue delay.
- the right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed, or where consent has been withdrawn (when consent is used as a lawful basis of data processing).
- the right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
- the right to object. You have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
- You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.
To otherwise exercise your rights, or if you have any questions relating to
your rights, please contact us using the details set out in the “9. What are my choices regarding my information?” or the “12. How can I contact iRobot?” sections above.
Subject to certain restrictions, you can have an agent exercise your rights
for you. If you have an agent exercising your rights, we must be provided
with your written authorization allowing that person to make such a request
on your behalf. We reserve the right to deny the agent’s request if we are
not reasonably able to confirm proper authorization and/or verify your
identity as the requestor.
Onward Transfers (Transfers to Third Parties). iRobot may
transfer personal information to certain third parties (as described in this
Privacy Policy). Where we transfer personal information to a third party, we
will take reasonable and appropriate steps to ensure the third-party
processes personal information for limited and specified purposes and in a
manner consistent with our legal obligations.
We allow certain third-party advertising partners to collect information
about the users of our Service for the purposes of serving ads that are more
relevant, for ad campaign measurement and analytics, and for fraud detection
and reporting. All cookies that are not strictly necessary (including
third-party) require prior, opt-in consent from individuals in the EEA, UK,
and Switzerland before loading. To learn more about online advertising and
how you may be able to control some of this activity, please refer to
“Third-Party Tracking and Online Advertising”.
Return to “9. What are my choices regarding my information?”
FOR INDIVIDUALS IN THE MIDDLE EAST AND NORTH AFRICA
This Middle East and North African Privacy Notice (“MENA Notice”)
supplements the iRobot Corporation Cookie and Privacy Policy. This MENA
Notice applies to certain persons in the Middle East and North Africa whose
personal information is processed by iRobot pursuant to applicable data
protection laws.
Data subject rights. If you are an individual located in
the Middle East or North Africa, you have the following rights in relation
to your personal information:
- the right to withdraw consent for consensual data processing.
- the right to modify inaccurate or incomplete personal data we hold about you without undue delay.
- the right to data portability to transfer the personal data you have provided to us to another controller in a structured, commonly used, machine-readable format.
- the right to erasure/destruction of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed, or where consent has been withdrawn (when consent is used as a lawful basis of data processing).
- the right to be notified of any breach or unlawful access to their personal data.
- the right to know how your personal information is being used.
- the right to request access to/copy of the personal information we hold about you.
- the right to limit/restriction of processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
- the right to object. You have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
- the right to object to direct marketing. You have the right to object to any processing of data for marketing purposes.
- the right to object to automated decision making. You have the right to object to any processing of data that is carried out without human intervention.
To otherwise exercise your rights, or if you have any questions relating to
your rights, please contact us using the details set out in the “9. What are my choices regarding my information?” or the “12. How can I contact iRobot?” sections above.
Data deletion practices. iRobot destroys records in
accordance with iRobot’s retention standards. Any physical records
containing personal information shall either be: redacted, pulverized,
shredded, or otherwise destroyed so that the data cannot practicably be read
or reconstructed. Any electronic records and other non-paper records
containing personal data shall be destroyed or erased using generally
accepted technical methods so that sensitive data cannot practicably be read
or reconstructed.
Data Protection Officer contact information. iRobot's
registered Data Protection Officer can be contacted by emailing
dataprotectionofficer@irobot.com.
Return to “9. What are my choices regarding my information?”.
FOR RESIDENTS OF PEOPLE’S REPUBLIC OF CHINA
This Personal Information Protection Law Privacy Notice (“PIPL Notice”)
supplements the iRobot Corporation Cookie and Privacy Policy. This PIPL
Notice applies to certain persons in the People's Republic of China ("PRC")
whose personal information is processed by iRobot pursuant to applicable
data protection laws, including the Personal Information Protection Law
(“PIPL”). For the purposes of this PIPL Notice, "PRC" shall refer to the
continental landmass under the direct control of the PRC, including the
islands of Hainan Province and five major autonomous regions (e.g., Tibet,
Inner Mongolia, Xinjiang, Ningxia and Guangxi), but excluding the Hong Kong
Special Autonomous Region (SAR), Macao SAR and Taiwan.
This PIPL Notice applies to you if:
- You are a person or data subject meaning a natural person, not a corporation, partnership, or other legal entity;
AND
- iRobot handles your personal information inside the borders of the PRC.
OR
- You are physically located in the PRC, and
- iRobot handles your personal information outside the borders of the PRC in order to 1) provide you goods or services, 2) analyze or assess your activities, or 3) comply with other circumstances as provided by laws or administrative regulations.
If you are located outside the PRC and you provide your personal information
to iRobot outside the PRC, this PIPL Notice does not apply to that
information.
Anonymization. For the purposes of PIPL, "anonymization"
refers to the process of personal information undergoing handling to make it
impossible to distinguish specific natural persons and impossible to
restore. Please note that iRobot may provide anonymized data developed from
personal information to third parties, and that such anonymized data is
outside the scope of this PIPL Notice.
Data subject rights. If you are a resident of China, you
have the following rights in relation to your personal information:
- the right to withdraw consent for consensual data processing.
- the right to consult or copy, except when it is necessary for iRobot to maintain confidentiality or when otherwise provided for by applicable law.
- the right to be informed about how your personal information is being used.
- the right to refuse automated decision making. You have the right to refuse any processing of data that is carried out without human intervention.
- the right to know and make decisions about the processing of your personal information, and the right to limit or refuse the handling of your personal information by others, unless otherwise provided for by law.
- the right to data portability to transfer the personal data you have provided to us to another controller in a structured, commonly used, machine-readable format.
- the right to amend inaccurate or incomplete personal data we hold about you without undue delay.
- the right to request deletion of personal information we have collected from you, subject to certain exceptions.
- the right to have the rules of processing explained. You have the right to request that iRobot explain to you the personal information handling rules.
- the right to file a lawsuit. If iRobot rejects your request to exercise your rights, you may file a lawsuit in a court of competent jurisdiction according to the law.
You also have the right to be free of discrimination for exercising these
rights. However, please note that the exercise of these rights may limit our
ability to process personal information. For example, if you submit a
deletion request, we may no longer be able to provide you with our products
and services or engage with you in the same manner.
Consent. If you provide consent and the purpose or method
of processing your personal information or the type of personal information
or who has access to your personal information changes, you will be notified
and asked to re-consent to the change(s).
Sensitive data. You also have the right to consent to the
processing of your sensitive personal information (as defined in PIPL).
Before iRobot processes your sensitive personal information, iRobot will ask
for your separate consent.
To exercise your rights. To exercise your rights, or if you
have any questions relating to your rights, please contact us using the
details set out in the “9. What are my choices regarding my information?” or the “12. How can I contact iRobot?” sections above.
In the event of a death, the next of kin of a deceased natural person may
exercise the rights of an individual provided in this PIPL Notice, such as
the right of consulting, copying, correcting, and or deleting personal
information of the deceased as detailed above, except where the deceased
natural person has arranged otherwise before their death.
Cross-Border Transfer of Personal Information. To operate
our business and for purposes described in section “4. What types of personal information does iRobot collect about me?”, as well as in
TABLE 1 – PERSONAL INFORMATION WE MAY COLLECT FROM DEVICES
and
TABLE 2 – PERSONAL INFORMATION WE MAY COLLECT THROUGH COOKIES AND OTHER
TRACKING TECHNOLOGY
of this iRobot Cookie and Privacy Policy, we may transfer your personal
information to our global entities or other third parties outside of China.
If applicable Chinese laws require us to provide you with further notice and
obtain your separate consent for the cross-border transfer, we will further
provide such notice and obtain your separate consent.
We will use lawful cross-border transfer mechanisms to transfer your
personal information overseas and adopt necessary measures to ensure the
overseas recipients can provide the same level of protection as required
under applicable Chinese laws.
Return to “9. What are my choices regarding my information?”.
TABLE 1 PERSONAL INFORMATION WE MAY COLLECT FROM DEVICES
| Category of Personal Information | How We Use It | Legal Basis for processing | |
|---|---|---|---|
| [Network activity information] Robot and App usage data. Information about how you use your Robot and the product Apps, such as the battery life and health, number of missions, device identifier and location mapping, App usage, feature usage, in-App transactions. | We use this information to process and ship orders. | The processing is necessary for the performance of a contract between you and us and to take steps prior to entering into a contract between you and us. | |
| We use this information to operate, maintain, and provide to you the features and functionality of the Service and Robots. | The processing is necessary for the performance of a contract between you and us, and to take steps prior to entering into a contract between you and us. | ||
| We use this information to provide customer service, including dealing with any enquiries or complaints. | The processing is necessary for our legitimate interests, namely administering the Service, for marketing purposes and communicating with users. | ||
| We use this information to process returns or repairs, and to diagnose and fix technology problems. | The processing is necessary for the performance of a contract between you and us and to take steps prior to entering into a contract between you and us. | ||
| We use this information to communicate directly with you, such as to send you information about your orders, product sales, special offers and new site features, in each case in accordance with your preferences. | The processing is necessary for our legitimate interests, namely administering the Service, for marketing purposes and communicating with users. | ||
| We use this information to tailor our Service and to develop new products and features available through our Service. | The processing is necessary for our legitimate interests, namely tailoring our Service to users, developing new products and features on the Service. | ||
| [Robot usage information: subscription services] which may include cleaning times/durations, bin empty events, bag replacements, tank refills, pad changes, and mission events. | We use this information to inform when to automatically ship filters, side brushes, bags and other accessories associated with subscribed services. | The processing is necessary for the performance of a contract between you and us. | |
| [Personal identifiers] Identification information, such as your national identity card or other proof of identity. | We may use this information to issue invoices for certain tax or legally required documents as needed. | The processing is necessary to comply with a legal obligation to which we are subject. | |
| We may request this information for account validation purposes when fulfilling your rights under applicable law, for example, if you request a portable copy of your personal information. | The processing is necessary to comply with a legal obligation to which we are subject. | ||
| [California Customer Records (Cal. Civ. Code §1798.80(e))] Customer Records, such as contact information and payment information. | We use this information to facilitate transactions and provide you with the Service. | The processing is necessary for the performance of a contract with you. | |
| We use this information to provide customer support. | The processing is necessary for our legitimate interests, namely administering the Service. | ||
| We use this information to detect and prevent fraud. | The processing is necessary for our legitimate interests, namely the detection and prevention of fraud. | ||
| [Protected classifications] Demographic information, such as your age, date of birth and gender. | We may collect this information in optional surveys in order to develop new products and features available through our Service or otherwise improve our Service. | The processing is necessary for our legitimate interests, namely developing and improving our Service and to inform our product development. | |
| We may collect this information in optional surveys in order to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | ||
| [Commercial information] Purchase and transaction information such as products purchased. If you register your device with us, we will also collect information about your Robot such as Robot ID, serial number or product code. | We use this information to process and ship orders. | The processing is necessary for the performance of a contract between you and us. | |
| We use this information to provide customer service, including dealing with any enquiries or complaints. | The processing is necessary for our legitimate interests, namely administering, developing and improving our Service. | ||
| We use this information to process returns or repairs. | The processing is necessary for the performance of a contract between you and us. | ||
| We use this information to determine products and services that may be of interest to you and to inform our product development. | The processing is necessary for our legitimate interests, namely informing our direct marketing and product development. | ||
| [Commercial information] Payment and billing information, such as your credit or debit card information, your billing address and purchase history. | We use this information to process and ship orders. | The processing is necessary for the performance of a contract between you and us. | |
| We use this information to detect and prevent fraud. | The processing is necessary for our legitimate interests, namely the detection and prevention of fraud. | ||
| [Geolocation] approximate location such as the time zone in which your Robot is located. We will not collect or track your precise location, including GPS coordinates, without your permission. If this information is ever required for a given feature, you will be able to opt in and out via the iRobot App. | We may use this information to ensure that the content on our Service is relevant to you, to provide new location-based features, and to help us provide customer service, including processing returns or repairs. | The processing is necessary for our legitimate interest, namely to tailor our Service to the user and to improve our Service generally. | |
| [Inferences] Consumer behavior such as products purchased, motivation for purchase, and other purchasing behavior and preferences. | We use this information to develop new products and features available through our Service or otherwise improve our Service. | The processing is necessary for our legitimate interests, namely developing and improving our Service and to inform our product development. | |
| We use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | ||
| [Other Personal Information] Demographic and lifestyle information, such as your leisure and other interests, number of children and number of pets, information about your home environment, and salary or other income information. | We may collect this information in optional user surveys in order to develop new products and features available through our Service or otherwise improve our Service. | The processing is necessary for our legitimate interests, namely developing and improving our Service and to inform our product development | |
| We may collect this information in optional user surveys in order to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | ||
|
[Other Personal Information] Comments, chat and opinions that you provide to us when you contact us directly, such as the content of any text messages or emails you send to us, or phone calls.
| We use this information to provide customer service, including dealing with any enquiries or complaints. | The processing is necessary for our legitimate interests, namely communicating with users and addressing users' comments and complaints. | |
| We use this information in connection with processing returns or repairs. | The processing is necessary for the performance of a contract between you and us. | ||
| We use this information to develop new products and features available through our Service or otherwise improve our Service. | The processing is necessary for our legitimate interests, namely developing and improving our Service and to inform our product development. | ||
| We use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | ||
| [Other Personal Information] Information received from third parties, such as social networks. If you connect a social network to our Service, or interact with our Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network. | We use this information to allow you to log-in to the Service and to tailor how the Service is presented to you. | The processing is necessary for our legitimate interest, namely to tailor our Service to the user. | |
| We use this information to communicate with you and to respond to your enquiries. | The processing is necessary for our legitimate interest, namely to communicate with users. | ||
| [Other Personal Information] Preferences set for notifications, marketing communications, how our Website or Apps are displayed and how you use the Service. | We use this information to display our Service to you in accordance with your preferences. | The processing is necessary for the performance of a contract between you and us. | |
| We use this information to provide only the notifications and to send only the marketing communications that you have agreed to receive. | The processing is necessary for compliance with a legal obligation to which we are subject. | ||
| [Other Personal Information] knowledge of the Apps on Your Phone. If you opt in, we may collect the names and app IDs of the smart home apps on your phone. | We use this information to surface personalized recommendations for smart home integrations and voice automations, and to prioritize future automation partners. | The lawful basis of processing is consent. The processing is necessary to tailor the Service to the user, and to develop new products and features. | |
| [Other Personal Information] device Information. If you opt in to certain features, we may collect device data, such as MAC address, device type, device name, identifier, serial number, product code, network bandwidth usage, and device location within and near the home. | We use this information to operate, maintain, and provide to you the features and functionality of the Service. | The processing is necessary for the performance of a contract between you and us. | |
| We use this information to develop new products and features available through our Service or otherwise improve our Service. | This processing is necessary for our legitimate interests, namely new product and feature development, and improving the Services. | ||
| We use this information to determine products and services that may be of interest to you and to inform our product development. | This processing is necessary for our legitimate interests, namely new product and feature development, and more personalized Services. | ||
| [Other Personal Information] Robot customization settings and preferences, such as robot name, room names, zone names, and scheduled start/stop times. | We use this information to operate, maintain, and provide to you the features and functionality of the Service. | The processing is necessary for the performance of a contract between you and us and to take steps prior to entering into a contract between you and us. | |
| We use this information to tailor our Service and to develop new products and features available through our Service. | The processing is necessary for our legitimate interests, namely to tailor our Service to the user, and to develop new products and features on the Service. | ||
| We use this information to provide certain features and functionalities of the device. | The processing is necessary for the performance of a contract between you and us and to take steps prior to entering into a contract between you and us. | ||
| We use this information to determine products and services that may be of interest to you. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | ||
| [Other Personal Information] Robot environment information. Information about the spaces where you use your Robot, such as floorplans, keep out zones and clean zones, types of objects (detected using the camera on your Robot) along with a corresponding confidence factor for that object and its location, the location and confidence factor of Wi-Fi devices connected to your local network, and Wi-Fi heat maps. | We use this information to diagnose and fix technology problems. | The processing is necessary for the performance of a contract between you and us and to take steps prior to entering into a contract between you and us. | |
| We use this information to tailor our Service in particular by improving the quality of the map that is generated and used by your Robot to allow it to operate effectively, and to develop new products and features available through our Service. | The processing is necessary for our legitimate interests, namely tailoring our Service to users, and developing new products and features. | ||
| We use this information to develop new products and features available through our Service. | The processing is necessary for our legitimate interests, namely developing new products and features on the Service. | ||
| We use this information to provide certain features and functionalities of the device. | The processing is necessary for the performance of a contract between you and us and to take steps prior to entering into a contract between you and us. | ||
| [Network activity information and others] Data collected as part of the iRobot Beta Program. Information transmitted by your Robot may be collected and processed as part of the feature or functionality within the iRobot Beta Program. | We use this information to test new features and functionalities of the Service where you have agreed to take part in the iRobot Beta Program. Specific information that is necessary for the Beta Program will be disclosed at the time of opt in, and may change depending on the beta feature offered. | The processing is necessary for our legitimate interests, namely for developing and testing new features and functionalities of the Service. We will only collect data to support the Beta Program when you opt in to the Beta Program. | |
| [Other Personal Information] Images from certain connected robots with camera-based navigation. If you opt in to image collection, we will collect images on your robot. These images will not be viewable by us unless and until you opt in both to image collection and to sharing each image with iRobot. | We use this information to help the robot clean more effectively over time, to learn to detect and avoid obstacles, and to recognize furniture, appliances, and other features of the home to aid in more precise cleaning. | The lawful basis of processing this data is consent. The processing is necessary in order to develop obstacle detection and avoidance technology, and to improve robot cleaning performance. | |
| [Other Personal Information] live streamed video. If you opt-in, we may stream video to partner apps that you select through your device, or to the iRobot Home app. Live stream video is not stored. | We do not use this information, as we do not collect or store it. We provide this as a service to you for home monitoring purposes. | N/A. No data is collected or stored. However, the feature is fully opt-in/consent-based. | |
TABLE 2 - PERSONAL INFORMATION WE MAY COLLECT FROM COOKIES AND OTHER TRACKING TECHNOLOGY
| Category of personal information | How we use it | Legal Basis for processing | |
|---|---|---|---|
| [Network activity information] Information about how you access and use the Service. For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Service, the time you access our Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, the links you click when browsing our Service or when you receive communications from us, and other actions you take on the Service. | We use this information to present our Service to you on your device. | The processing is necessary for the performance of a contract between you and us. | |
| We use this information to tailor how our Service is presented to you. | The processing is necessary for our legitimate interests, namely to tailor our Service to the user. | ||
| We use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | ||
| We use this information to monitor and improve our Service and business, including diagnosing and fixing technology problems and developing new products and services. | The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally. | ||
| [Network activity information] Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, model and manufacturer, unique device identifying numbers (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, mobile device operating system brand and model and phone number, browsers and applications connected to our Service through the device, your Internet service provider, your IP address and your device’s telephone number (if it has one). | We use this information to present our Service to you on your device. | The processing is necessary for the performance of a contract between you and us. | |
| We use this information to tailor how our Service is presented to you. | The processing is necessary for our legitimate interests, namely to tailor our Service to the user. | ||
| We use this information to determine products and services that may be of interest to you for marketing purposes. | The processing is necessary for our legitimate interests, namely to inform our direct marketing. | ||
| We use this information to monitor and improve our Service and business, including diagnosing and fixing technology problems and developing new products and services. | The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally. | ||