Privacy Policy

iRobot – Greece

PRIVACY POLICY

iRobot Corporation (“iRobot,” “we”, “us” or “our”) is committed to protecting your privacy.  This Privacy Policy explains how information about you or associated with you (“personal information”) is collected, used and disclosed by iRobot.  This Privacy Policy applies to our websites and service, including global.irobot.com (the “Web Site”), as well as to consumer devices you register with our service and to the online applications (“Apps”) which provide support for those consumer devices (collectively, our “Service”).

For the purposes of data protection laws, iRobot Corporation is the data controller of personal information we hold about you.

1.            How we collect and use information

2.            Your choices regarding your information

3.            Security and storage of information

4.            Children’s privacy

5.            Links to third party websites

6.            Jurisdiction and Enforcement

7.            Updates to this policy

8.            Notice to you

9.            Contact us

10.          Last revision date

Data security

At iRobot, we take the security of our products very seriously. If you’re an iRobot customer, and you use our connected products, here is all the information you need to know about iRobot’s product security principles. Visit our Data Security page.

1.              HOW WE COLLECT AND USE INFORMATION

Generally.

We collect personal information to provide you with a personalised, useful and efficient experience.

  • Information you provide. We collect and store personal information that you provide to us directly when you register for an iRobot account, use the iRobot Service, shop online, sign up for offers, or communicate with us. If you register your device online or through mail or another registration means, we also collect information about your iRobot device, such as the device ID, serial number or product code. 
  • Information we receive from third parties. If you interact with our Web Site or Apps through various social media, such as when you Like or Follow us on various social networks, or access our Service through a third party connection or log in, we may receive information from the social network. The data we receive 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. 

The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.  

Information We Collect from Registered iRobot Devices.

Some of our iRobot devices are equipped with smart technology which allows the iRobot devices to transmit data wirelessly to the Service.  Our iRobot devices do not transmit this information unless you register your device online and connect to Wi-Fi or to another device via Bluetooth.  It is possible to use our smart technology iRobot 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. 

The table at Annex 2 sets out the categories of personal information we collect about you and your iRobot device when you allow your iRobot device to transmit such information to us, and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.  

Use of cookies and other technology to collect information.

We use cookies and similar technologies such as clear gifs (also known as web beacons) to collect information indirectly about how you access and use the Service and information about the device you use to access the Service.

The table at Annex 3 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.

Cookies

Cookies are text files that are placed on your computer or other mobile or handheld device (such as smartphones or tablets) when you visit certain pages on the internet. They are used to “remember” when your computer or device accesses this website.

We use the following types of cookies:

(i)         Strictly necessary cookies. These are cookies that are required for the operation of our Web Site. They include, for example, cookies that enable you to log into areas of our Web Site and to add items into your shopping basket.

(ii)        Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Web Site when they are using it. This helps us to improve the way our Web Site works, for example, by ensuring that users are finding what they are looking for easily.

(iii)       Functionality cookies. These are used to recognise you when you return to our Web Site so that we can offer you a better shopping experience on this Web Site. For instance, this enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

(iv)       Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.

(v)        Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our website. These third parties are responsible for setting out their own cookie and privacy policies.

Most web browsers allow some control of most cookies through the browser settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. To make full use of the online shopping and personalised features on the Web Site, your computer, phone or tablet will need to accept cookies.

These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details. (opens in a new window - please note that we can't be responsible for the content of external websites.)

(i)         Cookie settings in Internet Explorer

(ii)        Cookie settings in Firefox

(iii)       Cookie settings in Chrome

(iv)       Cookie settings in Safari web and iOS.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org (opens in a new window - please note that we can't be responsible for the content of external websites).

Other technologies

In addition, we may also use clear gifs in HTML-based emails sent to our Customers to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.  You may set your e-mail options to prevent the automatic downloading of images that may contain these technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.

To find out more about other similar technologies, such as clear gifs / web beacons, you may wish to visit www.allaboutcookies.org or the Network Advertising Initiative’s online resources, at www.networkadvertising.org (opens in a new window - please note that we can't be responsible for the content of external websites).

2.              YOUR CHOICES REGARDING YOUR INFORMATION

Access, correct and update personal information.

You have the following rights in relation to your personal information:

(i) the right to be informed about how your personal information is being used;

(ii) the right to access the personal information we hold about you and to transfer the personal data you have provided to us to another controller;

(iii) the right to request the correction of inaccurate or incomplete personal data we hold about you without undue delay;

(iv) 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; and

(v) 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.

You can access, correct and update certain personal information that you have provided to us by clicking on “My Account” on our Web Site. You may access, correct and update personal information that is not available though “My Account” by writing to us at the contact address set out below.  Please provide as much information as you can about the personal information you are looking for and we will be happy to try and help you find it.

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 “Contacting Us” section below.

You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Marketing communications.  From time to time we may contact you with information about our products and services. Most marketing messages we send will be by email or through our Apps.  If you do not want to receive marketing messages from us, you will usually be able to tell us by selecting certain boxes on forms we use when we first collect your contact details.

You can control your communication preferences through the “My Account” page on our Web Site or App.  You can 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, change or updates to features of the Service, or technical and security notices. 

Where you have given us permission to do so, we may share your contact details with selected third parties so that they can provide you with information about products and services that they believe may be of interest to you. If you decide you no longer want us to share your contact details with selected third parties for marketing purposes, you can let us know by contacting us using our contact details near the end of this Privacy Policy.

Device collection. You can control or stop the collection of usage data from your registered iRobot device by disconnecting your Wi-Fi or Bluetooth from the app, for example, by changing your Wi-Fi password.  Please contact us at global.irobot.com if you have questions about disconnecting your iRobot device.

Online advertising. We, or our third party advertising partners, may show advertisements to you on our Web Site or our Apps.  To do this we, or our advertising partners, may collect information about how you use or connect to our Web Site, our Apps or the types of other web pages, social media service, content and ads you, or others who are using the device you connect to our Web Site or our Apps with, interact with, visit or view.  The information collected might also include the IP address of the device you connect to our Web Site or our Apps.

We, or our advertising partners, use the information that is collected to make sure the adverts you see either on our Web Site, our Apps and other parties’ websites and apps (where our partners have advertising space) are more relevant to you.

Typically cookies and similar technologies are used to provide this type of advertising.  Please see above for more information about how to manage cookies.

You may “opt-out” of the collection of information through some cookies or similar technologies by actively managing the settings on your browser or mobile device. 

You can opt-out of many network advertising programs that track your activities across multiple websites to deliver personalised advertising content to you by visiting:

(i)         Your Online Choices (http://www.youronlinechoices.com/ )

(ii)        Network Advertising Initiative (http://www.networkadvertising.org/)

(iii)       Digital Advertising Alliance (http://www.aboutads.info/consumers)

Deleting browser cookies can remove your opt out preferences, so you should use these tools periodically to ensure that your preferences are up-to-date.   

3.              SECURITY AND STORAGE OF INFORMATION

Security. iRobot cares about the security of your information and uses physical, administrative, and technological safeguards to help to preserve the integrity and security of all personal information we collect and that we share with our service providers.  Please refer to our security policy for more information about how your data is secured.

However, no security system is impenetrable and we cannot guarantee the security of our systems 100%.  In the event that any personal information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose personal information may have been compromised and take other steps, in accordance with any applicable laws and regulations.  If you wish to change your password, or if you become aware of any loss, theft or unauthorised use of your password, please contact us at global.irobot.com or by phone at +1-800-727-9077. 

International Transfers. iRobot may process your personal information on servers not in your home country. If you are accessing the Web Site or Service from outside the United States, please be advised that United States law or the laws of any other jurisdiction where we or our service providers process your personal information may not offer the same privacy protections as the law of your jurisdiction.

Privacy Shield. We comply with the EU-U.S. Privacy Shield framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information received from European Union countries and Switzerland (the “Privacy Shield”). We have certified that we adhere to the Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement and liability (“Principles”). If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/.  For more information regarding our Privacy Shield certification, please see:  https://www.privacyshield.gov/list.

If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy policy.

Onward Transfers (Transfers to Third Parties). iRobot may transfer personal information to certain third parties (as described in the Annexes to 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 Privacy Shield obligations. Where the transfer is to a third party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations and we are responsible for the event giving rise to the damage.

4.               CHILDREN’S PRIVACY

Our Service is not directed to persons under 13 and we do not intentionally collect or maintain information from persons under 13.  If you become aware that personal information about a person under 13 has been provided to us, please immediately contact us using the details below.

5.               LINKS TO THIRD PARTY WEBSITES

The Services may, from time to time, contain links to and from third party websites of our partner networks, advertisers, partner merchants, retailers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies.  Please check the individual policies before you submit any information to those websites. 

Additionally, our Web Site may include social media features such as Facebook, Twitter and Pinterest buttons (such as “Like,” “Tweet” or “Pin”).  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.  Your interactions with these features are governed by the privacy policy of the company providing the feature, not by our Privacy Policy. Please review your privacy settings on social media sites.

6.               JURISDICTION AND ENFORCEMENT

As part of our participation, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC). You also have the right to lodge a complaint to your local data protection authority.

In compliance with the Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us using the contact information listed below.

We have further committed to refer unresolved privacy complaints under the Principles to an independent dispute resolution mechanism, the JAMS EU-U.S. Privacy Shield Program. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.           

7.               UPDATES TO THIS POLICY

We reserve the right to modify this Privacy Policy from time to time. If we make any changes to this Privacy Policy, we will change the "Last Revision" date below and will post the updated Privacy Policy on this page.

8.              NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you.  We will usually do this through email or by placing a notice on our Service.  The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.

9.              CONTACTING US

If you are based in the European Union, our representative is iRobot UK Ltd. Regardless of your location, if you have questions or comments about this Privacy Policy or our privacy practices, please contact us at global.irobot.com or by writing to us at:

In the United States:

8 Crosby Drive

Bedford, MA 01730

In the European Union:

111 Buckingham Palace Road

London, England SW1W 0SR

United Kingdom

10.          LAST REVISION DATE

This Policy was last revised on, and effective as of, July 10, 2018.

 

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

Category of personal information

How we use it

Legal basis for processing

Categories of recipients

International transfer

Retention period

Contact and account information, such as your name, title, occupation, home address, country of residence, nationality, home telephone number, mobile telephone number, email address, unique customer number, account username and password.

We use this information to:

  • process and ship orders;
  • operate, maintain, and provide to you the features and functionality of the Service;
  • provide customer service, including dealing with any enquiries or complaints and processing returns or repairs;
  • 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:

  • the performance of a contract and to take steps prior to entering into a contract; and
  • our legitimate interests, namely administering the Service, for marketing purposes and communicating with users.

As required in accordance with how we use it, we will share your personal information with the following:

Group companies. Other companies owned by or under common ownership as iRobot, including our subsidiaries (i.e., any organization we own or control) and our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy.

Service providers. Third party vendors and other service providers that perform services for us or on our behalf, solely to carry out their work for us, which may include identifying and serving targeted advertisements, providing e-commerce services, content or service fulfillment, billing, web site operation, mailing, email or chat services, payment processing and authorization, customer service, fraud prevention, web hosting or data analytics services. For additional information on the way in which these organizations treat your personal information, you may contact us using the details set out above.

Professional Advisors. Third party service providers that provide tax, accounting and legal services.

Select third parties. With your consent, to selected third parties who we think may offer you products or services you may enjoy.

Third parties at your request. For example, you may have the option to Like or Follow us on social media and that action may be posted to your timeline, visible to your friends or followers or otherwise shared publicly.

Purchasers and third parties in connection with a business transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.

Law enforcement, regulators and other parties for legal reasons. Third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce or investigate violations of any terms of our agreement with you (including our Terms of Service), (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of iRobot, its customers or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

This personal information is transferred to the USA:

  • to the extent necessary for the performance of a contract between you and iRobot or the implementation of pre-contractual measures taken at your request; or
  • in accordance with the Privacy Shield.

 

We will retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with our users and provide the Services; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)

 

Purchase and transaction information, such as products purchased. If you register your device with us, we will also collect information about your iRobot device such as device ID, serial number or product code.

We use this information to:

  • process and ship orders;
  • provide customer service, including dealing with any enquiries or complaints and processing returns or repairs;
  • determine products and services that may be of interest to you.

The processing is necessary for:

  • the performance of a contract;
  • our legitimate interests, namely developing and improving our Service, developing new products and for marketing purposes.

This personal information is transferred to the USA:

  • to the extent necessary for the performance of a contract between you and iRobot or the implementation of pre-contractual measures taken at your request; or
  • in accordance with the Privacy Shield.

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 and to detect and prevent fraud.

The processing is necessary for:

  • the performance of a contract;
  • our legitimate interests, namely the detection of fraud.

This personal information is transferred to the USA:

  • to the extent necessary for the performance of a contract between you and iRobot or the implementation of pre-contractual measures taken at your request; or
  • in accordance with the Privacy Shield.

Consumer behaviour, 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;
  • determine products and services that may be of interest to you;
  • send you marketing communications in accordance with your preferences.

The processing is necessary for our legitimate interests, namely developing and improving our Service, developing new products and for marketing purposes.

This personal information is transferred to the USA in accordance with the Privacy Shield.

 

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.

We use this information to:

  • provide customer service, including dealing with any enquiries or complaints and processing returns or repairs;
  • develop new products and features available through our Service or otherwise improve our Service;
  • determine products and services that may be of interest to you;
  • send you marketing communications in accordance with your preferences.

The processing is necessary for our legitimate interests, namely communicating with users, developing and improving our Service, developing new products and for marketing purposes.

This personal information is transferred to the USA in accordance with the Privacy Shield.

 

Identification information, such as your national identity card or other proof of identity.

We use this information to:

  • detect and prevent fraud;
  • issue invoices and other legally required documents.

The processing is necessary for:

  • our legitimate interests, namely preventing and detecting fraud and ensuring compliance with our terms and conditions; and
  • compliance with a legal obligation.

This personal information is transferred to the USA in accordance with the Privacy Shield.

 

Demographic and lifestyle information, such as your age, date of birth, gender, salary or other income, leisure and other interests, number of children and number of pets, information about your home environment.

We use this information to:

  • develop new products and features available through our Service or otherwise improve our Service;
  • determine products and services that may be of interest to you;
  • send you marketing communications in accordance with your preferences.

The processing is necessary for our legitimate interests, namely developing and improving our Service, developing new products and for marketing purposes.

This personal information is transferred to the USA in accordance with the Privacy Shield.

 

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;
  • communicate with you and to respond to your enquiries.

 

The processing is necessary for our legitimate interest, namely to tailor our Service to the user, and to communicate with users.

This personal information is transferred to the USA in accordance with the Privacy Shield.

 

Preferences set for notifications, marketing communications, how our Web Site or Apps are displayed and how you use the Service.

We use this information to provide notifications, send marketing communications and display our Service in accordance with your choices.

The processing is necessary for:

  • our legitimate interests, namely ensuring the user receives the correct marketing and other communications;
  • compliance with a legal obligation; and
  • the performance of a contract.

This personal information is transferred to the USA in accordance with the Privacy Shield.

 

Location. We will not collect or track your exact location without your consent. Where necessary we will seek your consent before using information, including GPS coordinates, about your exact location.

We may use an approximate location (such as the time zone in which your iRobot device is located) to ensure that the content on our Service is relevant to you 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.

This personal information is transferred to the USA in accordance with the Privacy Shield.

 

All personal information set out above.

We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Service, to communicate with you, to monitor and improve our Service and business and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely to administer and improve the Service.

This personal information is transferred to the USA in accordance with the Privacy Shield.

 

 

 

 

 

 

ANNEX 2 – INFORMATION TRANSMITTED BY YOUR IROBOT DEVICE

 

Category of personal information

How we use it

Legal basis for processing

Categories of recipients

International transfer

Retention period

Robot customisation settings and preferences, such as robot name, room names, scheduled start/stop times.

 

We use this information to:

  • operate, maintain, and provide to you the features and functionality of the Service;
  • diagnose and fix technology problems;
  • develop new products and features available through our Service;
  • enhance device performance and improve user experience;
  • determine products and services that may be of interest to you;
  • send you marketing communications in accordance with your preferences.

The processing is necessary for:

  • the performance of a contract and to take steps prior to entering into a contract; and
  • our legitimate interests, namely administering the Service, tailoring our Service to users, developing new products and features, and for marketing purposes.

As required in accordance with how we use it, we will share your personal information with the following:

Group companies. Other companies owned by or under common ownership as iRobot, including our subsidiaries (i.e., any organization we own or control) and our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy.

Service providers. Third party vendors and other service providers that perform services for us or on our behalf, solely to carry out their work for us, which may include identifying and serving targeted advertisements, providing e-commerce services, content or service fulfillment, billing, web site operation, mailing, email or chat services, payment processing and authorization, customer service, fraud prevention, web hosting or data analytics services. For additional information on the way in which these organizations treat your personal information, you may contact us using the details set out above.

Professional Advisors. Third party service providers that provide tax, accounting and legal services.

Select third parties. With your consent, to selected third parties who we think may offer you products or services you may enjoy.

Third parties at your request. For example, you may have the option to Like or Follow us on social media and that action may be posted to your timeline, visible to your friends or followers or otherwise shared publicly.

Purchasers and third parties in connection with a business transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.

Law enforcement, regulators and other parties for legal reasons. Third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce or investigate violations of any terms of our agreement with you (including our Terms of Service), (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of iRobot, its customers or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

This personal information is transferred to the USA:

  • to the extent necessary for the performance of a contract between you and iRobot or the implementation of pre-contractual measures taken at your request; or
  • in accordance with the Privacy Shield.

We will retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with our users and provide the Services; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)

 

Robot and App usage data. Information about how you use your iRobot device 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:

  • diagnose and fix technology problems;
  • develop new products and features available through our Service;
  • enhance device performance and improve user experience.

The processing is necessary for:

  • the performance of a contract and to take steps prior to entering into a contract; and
  • our legitimate interests, namely administering the Service, tailoring our Service to users, developing new products and features, and for marketing purposes.

Robot environment information. Information about the spaces where you use your iRobot device, such as floorplans, object detection, wifi heat maps and images.

We use this information to:

  • diagnose and fix technology problems;
  • develop new products and features available through our Service;
  • enhance device performance and improve user experience.

The processing is necessary for:

  • the performance of a contract and to take steps prior to entering into a contract; and
  • our legitimate interests, namely administering the Service, tailoring our Service to users, developing new products and features, and for marketing purposes.

As required in accordance with how we use it, we will share your personal information with the following:

Group companies. Other companies owned by or under common ownership as iRobot, including our subsidiaries (i.e., any organization we own or control) and our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy.

Service providers. Third party vendors and other service providers that perform services for us or on our behalf, solely to carry out their work for us, which may include identifying and serving targeted advertisements, providing e-commerce services, content or service fulfillment, billing, web site operation, mailing, email or chat services, payment processing and authorization, customer service, fraud prevention, web hosting or data analytics services. For additional information on the way in which these organizations treat your personal information, you may contact us using the details set out above.

Purchasers and third parties in connection with a business transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.

Law enforcement, regulators and other parties for legal reasons. Third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce or investigate violations of any terms of our agreement with you (including our Terms of Service), (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of iRobot, its customers or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

 

 

 

 

ANNEX 3 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Category of personal information

How we use it

Legal basis for processing

Categories of recipients

International transfer

Retention period

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;
  • determine products and services that may be of interest to you for marketing purposes; and
  • 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 tailor our Service to the user and to improve our Service generally; to monitor and resolve issues; for marketing purposes; to communicate with users; to contact users; and for the detection and prevention of fraud.

As required in accordance with how we use it, we will share your personal information with the following:

Group companies. Other companies owned by or under common ownership as iRobot, including our subsidiaries (i.e., any organization we own or control) and our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy.

Service providers. Third party vendors and other service providers that perform services for us or on our behalf, solely to carry out their work for us, which may include identifying and serving targeted advertisements, providing e-commerce services, content or service fulfillment, billing, web site operation, mailing, email or chat services, payment processing and authorization, customer service, fraud prevention, web hosting or data analytics services. For additional information on the way in which these organizations treat your personal information, you may contact us using the details set out above.

Professional Advisors. Third party service providers that provide tax, accounting and legal services.

Select third parties. With your consent, to selected third parties who we think may offer you products or services you may enjoy.

Third parties at your request. For example, you may have the option to Like or Follow us on social media and that action may be posted to your timeline, visible to your friends or followers or otherwise shared publicly.

Purchasers and third parties in connection with a business transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.

Law enforcement, regulators and other parties for legal reasons. Third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce or investigate violations of any terms of our agreement with you (including our Terms of Service), (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of iRobot, its customers or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

This personal information is transferred to the USA:

  • to the extent necessary for the performance of a contract between you and iRobot or the implementation of pre-contractual measures taken at your request; or
  • in accordance with the Privacy Shield.

We will retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with our users and provide the Services; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)

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).