Privacy Policy

Embodied, Inc. Privacy Policy

Updated:  January 18, 2023

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 (G.R.L.) children’s website www.globalroboticslab.com (the “G.R.L. 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, our online store, more information about Moxie and our AI, are available at embodied.com. Parents and purchasers must be 18 or older to shop online or register through the Parent App.

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. Moxie is 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 Embodied 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. 

 

PRIVO Verified Page

 

 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 full verifiable 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's 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.

Note to Library Lending Program Participants: Participants in our Library Lending Program will be subject to additional privacy practices while using Moxie during our trial with the Library. Please see Section 3(G) below which outlines additional privacy practices that Embodied has in place for the Library Lending Program.

TABLE OF CONTENTS

1. SECURITY
2. YOUR PRIVACY RIGHTS
   A. California Privacy Rights
3. WHAT INFORMATION DO WE COLLECT DURING SETUP OF THE MOXIE PARENT APP AND MOXIE?
   A. When Do the Parent App and Moxie Collect Data?
   B. What Information Does the Parent App Collect and Why Does the Parent App Collect It?
   C. What Information Does Moxie Collect and Why Does Moxie Collect It?
   D. Recovering Data and Troubleshooting
   E. The Parent App and Moxie Share Information with The Following Third Parties
   F. Mobile App Store

G.  Retention Timeframes

H. Library Program

4. WHAT INFORMATION DO WE COLLECT WHEN A PARENT PURCHASES MOXIE?
   A. What Information Do We Collect at Our eCommerce Site?
      1. Cookies and Technology – The eCommerce Site utilizes the following cookies.
   B. When Do We Collect Information at Our eCommerce Site?
   C. Why Do We Collect Information at Our eCommerce Site?
   D. What Personal Information is Shared at Our eCommerce Site?
   E. Choices and Controls of Personal Information on eCommerce Site 
5. WHAT INFORMATION DO WE COLLECT AT G.R.L. SITE?
   A. Personal Information the G.R.L. Site Collects
   B. When Does the G.R.L. Site Collect Personal Information?
   C. Why Does the G.R.L. Site Collect Information? 
6. CERTIFICATIONS
7. CONTACT US WITH YOUR QUESTIONS

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 personal information and other information about users or the device into separate databases, which are secured and encrypted. When you set up an account in the Parent App, a recovery key is automatically assigned to you. This key is unique to you and not accessible to Embodied. You will need your recovery key to access your data if you change devices through which you pair Moxie, or need a new Moxie.

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. Embodied will never ask you for the recovery key, and the recovery key should only be used by the account holder.

2. YOUR 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 below.

Do Not Sell: Subject to certain exceptions, California residents have the right to opt out of the "sale" of their 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 G.R.L. 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) request 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. If you have a Moxie robot but lost your recovery key or access to the Parent App, we are unable to fulfill requests to delete all Moxie data because of the steps we have taken to minimize our ability to link to personal information in our system.

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. If you have a Moxie robot but lost your recovery key or access to the Parent App, we are unable to fulfill requests to access all Moxie data because of the steps we have taken to minimize our ability to link to personal information in our system.

You may also contact Embodied at (855 945-3411) 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, a number of speakers, an inertial motion unit (to determine direction and velocity) 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 other interactions, such as if a child is touching or hugging Moxie, if Moxie has been picked up and moved, and what direction and velocity Moxie may have been moved. Embodied utilizes our proprietary AI platform (SocialX™) to analyze data, 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 described in detail below, to use Moxie, parents must set up a Parent App account and provide certain information, like the parent’s 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 partner, PRIVO, to complete the parental verification process and start using Moxie. Until a parent provides verifiable parental consent (VPC) through the PRIVO process, the account will not be active and your child will not be able to engage with Moxie. In limited circumstances an Embodied trained operative may complete the parental verification process using video conferencing software Personal information collected to verify parents will be retained as long as necessary to provide the service and can be deleted on request.


PRIVO is a leading privacy solutions expert as well as an FTC-approved COPPA Safe Harbor with an identity and consent management platform. All information collected for verification is stored securely and not used for any other purpose. For more information on PRIVO please see here: https://www.privo.com/platform-privacy-policy. Please note: the information PRIVO uses to conduct the parental verification process is not shared with Embodied.


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, inertial motion unit (IMU), sensors and/or cameras.

The Parent App and Moxie do not utilize cookies or similar technologies to track individuals, but data is automatically collected through the microphones, IMU, sensors, and/or cameras.

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 for Moxie 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. Audio Data is transmitted in encrypted form to Google’s Automatic Speech Recognition (ASR) server (which is waiting to hear the commands “Hello Moxie” or “Moxie, Please Wake-Up”). No Audio Transcript Data will be generated or stored until a wake-up command is used, and 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. Moxie is equipped with mechanisms for parents and children to know when it is on. In operational mode, if the LED bar is blue, Moxie is listening for input. If the LED bar is pulsing blue, Moxie is processing the input it received. If the LED bar is pulsing pink, 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 a child finishes interacting with Moxie and says “Moxie, Please Go to Sleep”, Moxie will go into standby mode. In standby mode, the LED bar will be lavender but the screen will be off. While in standby mode, Moxie is only listening for the “Hello Moxie” command. Audio Data is collected by the microphones when Moxie is in standby mode 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 and audio and video collection will activate.

 

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 birthdays of family members or appointments.

Whether or not you are selecting Moxie operation features such as no sound effects, no visual effects, slowed down speech, longer pauses for input, and/or limited heads-up display.

 

Embodied also collects information about the device you’re using to access the Parent App, like your device ID and IP address. We also collect anonymized information about page views in the Parent App and about pages in the Parent App that malfunction or crash. This information helps us analyze usage and update and improve our services.

The Parent App does not utilize cookies. 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 cloud server utilizes Google Firebase to generate Parent App usage analytics for Embodied regarding the parent’s use of the parent app, including minutes the Parent App is being utilized, which menu screens parents utilize and/or other Parent App usage statistics. The Parent App usage analytics are aggregated for all parents utilizing the Parent App. The Parent App usage analytics are encrypted and stored in the cloud server. You can read more about how Google uses your personal information here: https://policies.google.com/privacy.

The cloud server utilizes Crashlytics to store an anonymized number of page views and page crashes or malfunctions in the Parent App and to report on that data to Embodied.

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. In limited circumstances an Embodied trained operative may complete the parental verification process using video conferencing software Personal information collected to verify parents will be retained as long as necessary to provide the service and can be deleted on request.

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. The Parent App may receive the following information from Moxie about your child once an account is established and Moxie is paired with the Parent App: Activity Data (such as books read, calculated reading comprehension, calculated vocabulary level, amount of time spent interacting or reading, badges or trophies received, activity patterns) and Insight Data (data generated through the AI engine that provides insights on your child’s developmental progress). This data is encrypted and stored on Moxie as well as the cloud server and may be accessed by the Parent App.

Parents will need a recovery 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). Information on how to save the recovery key is provided in the Parent App when the recovery key is assigned. When Moxie is paired with the Parent App, an Analytics User ID (AUID) is automatically assigned by the robot and is the vehicle by which the Parent App is able to retrieve information about the child’s progress with Moxie. The AUID is not known to Embodied. Moxie shares the AUID with the parent app through a channel encrypted with the recovery key (also not accessible by Embodied) when paired with the Parent App to allow Moxie to interact with your child in a way that is not identifiable to Embodied. That is why a parent must either be using the Parent App or have the recovery key to request access to or deletion of a child’s personal information; without it, Embodied is unable to identify which data, such as Audio Transcript Data, Primary User Datapoints, and Facial Expression Datapoints, relates to a specific individual or Moxie. Within the Parent App we have added a feature that allows the parent to click on a button to share the AUID so Embodied can assist in troubleshooting. Please see Recovering Data and Troubleshooting.

Please note: if you change devices or email accounts, you must have the recovery key to access prior data.

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 Moxie in the form of video files and audio files and is linked to the AUID. 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 and Audio Transcript Data - The recorded Audio Data is encrypted and sent to our cloud service provider, Google Cloud STT, who automatically transcribes the audio files to create audio transcription files and deletes the audio recording after creating the audio transcription file. This file is the Audio Transcript Data. The Audio Transcript Data is securely transmitted to Moxie and used to interact with the user, and then transmitted through Moxie to a separate cloud storage area. In certain circumstances, e.g., like when specific questions are asked to Moxie about subjects not able to be handled by the natural language processing on the Embodied Cloud Servers, some audio transcript data may be communicated to our third-party cloud natural language processing (NLP) provider, OpenAI. The third-party NLP provider may provide responsive Transcript Data that is utilized (after filtering by Embodied) to respond to the child. The audio transcript data communicated to our third-party NLP provider does not include
the AUID so the third-party NLP provider cannot link the received Audio Transcript Data to any particular user. The third-party NLP provider does not store the received Audio Transcript Data. Our cloud storage service provider does not have access to the Audio Transcript Data; only Embodied has access. The Audio Transcript Data are used by Embodied to understand the content of the recorded Audio Data, respond to the child, and improve the AI. The Audio Transcript Data will remain on a secure and encrypted server after data collection has been completed. The Audio Transcript Data may be stored for 18 months. Embodied has access to the Audio Transcript Data, but cannot link the Audio Transcript Data to any particular user, account or device. Parents must either be using the Parent App with access to the AUID or have the Recovery Key to access or delete the Audio Transcript Data associated with their child; the Audio Data is deleted when the transcripts are made.

Video Data -  The recorded Video Data will be automatically processed locally on the Moxie device to create facial expression datapoints. 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.

Facial Expression Datapoints - The Facial Expression Datapoints 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 Datapoints 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 18 months. Embodied has access to the Facial Expression Datapoints, but cannot link it to any particular user, account or device. Parents must either be using the Parent App or have the Recovery Key to view or access data associated with their child.

Primary User Images - The camera on Moxie will initially capture images of the primary user (your child) during their interaction with Moxie. Moxie will generate Primary User Image Datapoints from the Primary User Image(s). The Primary User Image is then deleted from Moxie. The Primary User Image Datapoints are utilized by Moxie to verify that Moxie is speaking to the primary user during conversation interactions, and to respond appropriately to the primary user. Please note: During interaction with Moxie, images of other individuals may be captured if they are within the field of view of the camera. Moxie may process these images to determine if this individual is the Primary User, and may ask “who are you,” or “are you my mentor” to confirm.

If another user asks Moxie to remember them, that user’s image will be captured. Moxie will create the other user’s image datapoints and discard the other user’s image. Audio transcripts will be generated from any conversation the other user has with Moxie. The other user’s image datapoints and audio transcripts will be stored in the primary user’s account because Moxie is setup for the primary user.

The Primary User Image Datapoints will be encrypted and securely transmitted to the cloud storage service provider. Embodied has access to the Primary User Image Datapoint, but cannot link it to any particular user, account or device. Parents must have the Recovery Key to view or access data associated with their child. 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. Primary User Datapoints are deleted if an account is inactive for 36 months.

Parents must either be using the Parent App or have the Recovery Key to view or access data associated with their child. Embodied does not have access to the information as it is encrypted using the Recovery Key, but Embodied can link it to the user or device and can therefore delete Primary User Image Datapoints if requested by a parent.

Activity Data - Moxie collects certain Activity Data, such as how long children are using Moxie, if children read a book with the robot, how many missions the children have completed with Moxie, badges and trophies earned, and other information to help parent’s track a child’s general activities and progress. The Activity Data is generally summary information about the child’s activities. Data on children’s interactions with Moxie and activities and progress are encrypted and stored with the cloud service provider, but in a separate database from the Audio Transcript Data, Facial Expression Datapoints, Primary User Image Datapoints, Moxie Interaction Data, Insight Data, and other personal information. The Activity Data on a particular child’s interactions and progress is accessible through the Parent App or with the recovery key and linked to the robot ID accessibly by Embodied. Activity data is deleted after 36 months. 

Moxie Interaction Data - Moxie Interaction Data is data associated with the child’s interactions with Moxie, such as the Audio Transcript Data (collected through Moxie’s microphones), Facial Expression Datapoints and Primary User Image Datapoints (collected through Moxie’s camera), whether and where other objects or persons may be located in a room (collected through Moxie’s camera), responses communicated to Moxie, and/or what Moxie facial animations are utilized. In addition, touch sensors are utilized to determine if a child is touching or hugging Moxie. The Moxie Interaction Data is collected and processed on Moxie and is utilized to enhance the child’s interaction with Moxie and is associated with the AUID. The Moxie Interaction Data is then encrypted and transmitted to the cloud service provider and stored in the same account as the anonymized Insight Data, Audio Transcript Data, and Facial Expression and Primary User Image Datapoints. The Moxie Interaction Data is stored for three months with precise timestamps, and for eighteen months with relative timestamps. Parents can request to access or delete Moxie Interaction Data using the Parent App or with the recovery key.

Insight Data – Insight Data is data derived from the Embodied proprietary AI engine that analyzes how the child is doing in achieving missions and goals and progress towards achieving those goals, such as improvements in language skills, how long the child was engaged with the robot, number of words read per minute. Insight Data is just that: it is data derived from the Moxie Interaction Data, Facial Expression Datapoints, Audio Transcript Data and other data to provide an analytical assessment of the child’s progress. Activity Data and Insight Data are available to parents while using the Parent App or with the recovery key. The Insight Data is maintained for the life of the account. For inactive accounts, this Insight data is stored 36 months, then it is deleted.  

Moxie Sensor and Telemetry Data – Embodied collects computer sensor and telemetry data from Moxie to troubleshoot problems and improve hardware and software operations. This data is associated with the robot ID but stored separately from other data for three months.

Parents can request access to review or delete their and their child’s information, and refuse to permit further collection or use of their child's information by contacting us.   If you would like us to delete your child’s personal information, please contact customer support at support@embodied.com for more information on how you can delete your child’s personal information. 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. If you have a Moxie robot but lost your recovery key or access to the Parent App, we are unable to fulfill requests to delete all Moxie data because of the steps we have taken to minimize our ability to link to your child’s personal information in our system. Access Requests: If you would like to access your child’s 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. If you have a Moxie robot but lost your recovery key or access to the Parent App, we are unable to fulfill requests to access all Moxie data because of the steps we have taken to minimize our ability to link to your child’s personal information in our system.

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


D. Recovering Data and Troubleshooting

Moxie is a complex product that has been designed with privacy and security in mind. Embodied needs access to certain information to provide services, allow children to interact with Moxie, help children engage in activities and work towards achieving goals, and deploy the AI to provide insights to the parent. Embodied has built the Parent App to allow parents to see their child’s activities and progress. Embodied’s data management procedures are designed to restrict Embodied’s access to most data associated with an identifiable child, but we also want to assist parents in troubleshooting issues or answering questions. That is why we have created a process that allows a parent elect to share the AUID with customer service.

As a reminder, the AUID is an encrypted ID created on Moxie and sent during initial pairing with Moxie and the Parent App. The AUID is linked to the recovery key, but both are unknown to Embodied. Embodied will never ask a parent for the recovery key or analytical user ID (AUID), unless a customer reports a problem, then Embodied will ask the customer for permission to “add a share my AUID” button on the help page of the Parent App. Having a mechanism to allow Embodied to access the AUID in the Parent App allows Embodied to work with the parent to troubleshoot problems, or respond to requests to access or delete information. When the customer receives the “share my AUID” button, and affirmatively clicks on the button, Embodied personnel can access the Moxie Interaction Data, Facial Expression Datapoints, Audio Transcript Data, and Insight Data associated with the AUID to assist the customer with the request. Access is limited to the help session and this data is otherwise not visible to Embodied in a way that is linked to a particular child.

E. 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 raw voice data with Google to perform speech recognition of your child’s voice. You can read more about how Google uses your personal information here: https://policies.google.com/privacy.

Embodied shares some Audio Transcript Data with our third-party natural language processor (NLP), OpenAI. You can read more about how OpenAI uses your personal information here: https://openai.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 requests for information we receive, or to otherwise protect our rights, the rights of parents and children using Moxie or other third 
parties.

F. 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.

G. Retention Timeframes

Below is a chart with Embodied’s Data Retention Timeframes for the Different Categories of Data Collected by Moxie.

Type of Data Retention Period
Raw Audio Data Deleted After Speech-to-Text Conversion
Raw Video Data Deleted after the Facial Expression
Datapoints have been created.
Audio Transcript Data Stored for 18 months
Facial Expression Datapoints Stored for 18 months
Primary User Image Datapoints Stored for life of account unless account is inactive for 36 months
Activity Data Activity Data is stored for 36 months
Moxie Interaction Data Stored for 3 months with precise timestamps, and for 18 months with relative timestamps.
Insight Data Stored for 36 months
Moxie Sensor and Telemetry Data Stored for 3 months

H. Library Program

  1. The individual who borrows Moxie from the Library (“Library”) will be referred to as the Borrower.  The Borrower will be required to provide verifiable parental consent via PRIVO.  The remaining sections of Embodied’s Privacy Policy also applies to the Borrower’s use of Moxie.  The additional privacy practices for Borrowers are identified immediately in this Section 3G.
  2. When the Borrower returns Moxie to the Library, the Borrower should unpair Moxie.  The steps for unpairing Moxie are provided to Borrower in a handout provided by the Library when Moxie is borrowed.  Please refer to this handout.  Briefly, the procedure is to: 1) While connected to WiFi at home, turn Moxie on via the power switch; 2) Open the parent app and select the Moxie tab; 3) Scroll to the bottom of the Moxie tab and select the Unpair button; 4) In the app pop-up, confirm you would like to unpair with the restore factory settings option; 5) Verify the unpairing has completed by viewing the QR code on the display of Moxie; and 6) Turn Moxie off.  
  3. Embodied will retain the Borrower’s Primary User Image Datapoints, Activity Data, and Insight Data for a period of 18 months in case the Borrower borrows the unit from the Library at another time in the future and/or purchases a new Moxie.  Embodied will retain the Borrower’s Moxie Sensor and Telemetry Data and Moxie Interaction Data for three months.  Embodied will also keep the Borrower’s account active.  The Borrower can then utilize the Recovery Key to access their account and restore the above-identified data to the newly borrowed Moxie or the newly purchased Moxie.  
  4. Please note that because the Borrower has unpaired Moxie, there is no chance a New Borrower will ever be able to access, even accidentally, the prior Borrower’s personal data.  Embodied will also be verifying with the Library that the Moxie has been successfully unpaired in order to provide additional protection.


      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 obtain billing address, payment method and other information, but do not receive credit card information from our eCommerce Site partner.

      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.

      When you visit our eCommerce Site, you may be offered the opportunity to sign up for SMS updates at your mobile telephone number by providing Embodied with your mobile telephone number (“SMS Program”). By providing Embodied with your mobile telephone number, you are authorizing Embodied to contact you via SMS updates at your mobile telephone number. Your mobile telephone number will be utilized to allow Embodied to provide you news updates and alerts on pre-order availability, customer service information, promotions or other marketing or sales opportunities, or blog posts or other Moxie-related social media activity. You will also be able to opt-out of SMS updates. Embodied respects your privacy and will only use the mobile telephone number to transmit your messages, and respond to you if necessary. This includes, but is not limited to, sharing information with our platform provider and phone companies who assist us in the delivery of SMS messages.

      We will not sell, rent, loan, trade, lease or transfer for profit any phone number collected through this SMS Program to any third party. Embodied does reserve the right to disclose the information to satisfy any law, regulation or government request, to avoid liability, or to protect our rights or property. When you supply Embodied with your mobile telephone number, you agree not to use a false or misleading name or a name that you are not authorized to use. If Embodied believes, in our sole discretion, that any such information is untrue, inaccurate, or incomplete, or you have opted into the SMS Program under false pretenses or for an ulterior purpose, Embodied may refuse you access to this SMS Program and pursue appropriate legal remedies. If you area resident of California, California Civil Code Section 1798.83 permits users for this program to request information regarding our disclosure of this information. To make such a request, please contact us at the following address or email: Embodied, Inc., 385 E. Colorado Blvd., Suite 110, Pasadena, CA 91101or support@embodied.com


      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 or pre-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.  

      Embodied utilizes reCharge Payments to process our recurring payments and reCharge Payments receive you billing information.  You can read more about how reCharge Payments uses your Personal Information at https://rechargepayments.com/privacy-policy/. 

      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.

      The eCommerce Site may use Google Fonts to source fonts to be utilized on the eCommerce Site. Google Fonts may share an IP address with Google.  For more information about Google Fonts 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, Pinterest Pixel, TikTok Pixel, and/or Facebook 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 more information about Pinterest’s privacy practices, please visit https://policy.pinterest.com/en/privacy-policy.   For information about Meta Platform’s (previously Facebook’s) privacy practices, please visit https://www.facebook.com/about/privacy or https://www.facebook.com/privacy/explanation/. For information about Tik Tok's privacy practices, please visit www.tiktok.com/legal/privacy-policy-us. Please refer to Google, Bing’s TikTok'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, TikTok, 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 G.R.L. SITE

      The G.R.L. Site allows your child to engage in activities, play self-contained games and to learn about the history and backstory of Moxie.

      A. Personal Information the G.R.L. Site Collects

      You do not need to own a Moxie to visit the G.R.L. Site to explore characters, games and activities. If you do not own a Moxie and your child visits the G.R.L. Site, the G.R.L. Site will not collect personal information about your child.

      If you own a Moxie and visit the G.R.L. Site, the G.R.L. Site utilizes a persistent authentication cookie to connect the G.R.L. Site your child uses with the Moxie robot your child interacts with and to let the G.R.L. Site know it is the same user logging in with the same Moxie.  . 

      The persistent authentication cookie allows your child to not have to go through the connection process repeatedly.  The G.R.L Site has access to the operating system of the computing device that is connecting to the G.R.L. Site.  

      The G.R.L. Site will communicate with Embodied cloud servers to determine an age range of the child engaging in games on the G.R.L. site.  The age range will be provided after authentication and login to the G.R.L. site.  This age range information is used to provide age-related levels of games located on the G.R.L. site and is not stored on the G.R.L. site after the session is over.  

      Embodied utilizes Google Analytics to collect aggregated and anonymized information about activity on the G.R.L. Site. Included in this information is data regarding operating systems of mobile devices connecting to the G.R.L. Site.  This operating system information is aggregate information which is anonymized.  For example, the information collected may be that ten users have visited page A and ten users have visited page B on a certain day. However, no information is collected regarding who the users are. This information is only utilized by Embodied personnel.


      B. When Does the G.R.L. Site Collect Personal Information

      At the G.R.L. Site, the persistent authentication cookie collects information when a Moxie owner logs into or enters the G.R.L. Site to support the activities and enable reports to parents.

      Google Analytics is utilized as users visit the G.R.L. Site.

      C. Why Does the G.R.L. Site Collect Information

      The G.R.L. Site utilizes a first-party authentication cookie to allow for easier login.

      Google Analytics is utilized to improve the performance and design of the G.R.L. Site.


      6. CERTIFICATIONS

      Moxie is fully COPPA (Children’s Online Privacy Protection Act) Safe Harbor certified by PRIVO.


      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

      For Frequently Asked Questions about Artificial Intelligence and Moxie, you can view our FAQ here.