Privacy Policy

Effective as of December 2019

ROYBI, Inc. (“ROYBI”, “we”, “us”, or “our”) develops ROYBI Robot, a product designed to ensure that children learn at their own pace and focus on their individual interests, abilities, and strengths through evidence-supported practices.

This Privacy Policy describes our practices regarding information we collect through our websites, including www.roybirobot.com, mobile applications, and any other interactive features or services owned or controlled by ROYBI to this Privacy Policy (each, a “Service” and collectively, the “Services”), as well as any information we collect offline and combine in our databases. Certain features discussed in this Privacy Policy may not be offered on each Service at any particular time. Note that we may combine the information we collect from you through all of our Services to use information gathered in the classroom to better inform families about their child’s development.

Note about Children: As required by applicable law and our Terms of Services children under the age of 13 in the U.S. (and a higher age if required by the applicable law in another country) may only use our Services with the express prior consent of a parent or legal guardian. If you are a Teacher or Administrator, you must obtain all necessary parental consents before allowing students to use the Services.

1. What is this policy?

WE FULLY DESCRIBE OUR PRIVACY PRACTICES BELOW IN THIS PRIVACY POLICY. THIS SUMMARY PROVIDES AN OVERVIEW OF SOME IMPORTANT INFORMATION REGARDING OUR USE AND SHARING OF YOUR INFORMATION. PLEASE READ THE ENTIRE PRIVACY POLICY VERY CAREFULLY. BY USING ANY SERVICE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY IN ITS ENTIRETY.

Information Sharing: Remember that if you create a Profile (as defined below) or share Personal Information with other users on the Services, your information may be visible to others. Note that we do not share your Personal Information with third parties for their marketing purposes; however, we may share your Personal Information under certain limited circumstances. For more details, please review the section below entitled “Will ROYBI share any of the information it collects?”

Third parties : We work with Amazon Web Services to provide us with information regarding traffic on the Services, including the frequency of use and the actions users take when visiting the Services and to provide us with information regarding the use of the Services.

2. What information does ROYBI collect?

Information Shared With Us

Registration and Other Information You Provide

The Services may collect “Personal Information” (which is information that can reasonably be used alone or in combination with other reasonably available information, to identify or contact a specific individual). Personal Information includes, but is not limited to, user (including child and parent/guardian) data, metadata, and user content. This may include a name, birthday, gender, email address, password, assessment data or usage information. Any information combined with Personal Information will be treated as Personal Information.

Your Account

Your Account Page: Note that children do not create accounts; however, certain information about children is collected through the Parent/Guardian Account as listed below.

First Name
Last Name
Username or nickname you create
Birthday
Gender
Relationship to Account Holder
Audio/video recordings of child during child’s lesson (only collected with the parent/guardian’s approval)

Third Party Services and Information Third Parties Provide About You

The Services may permit interactions between the Services and a third-party feature or service. These third parties may provide us with information about you. Similarly, if you publicly post information on a third-party platform, such as a social media site, that references ROYBI or one of the Services, your post may be published on our Services in accordance with that third party’s terms. These features may collect your IP address or other unique identifier, which page you are visiting on our website, and may set a cookie to enable the third-party feature to function properly. When you use a third-party feature through the Services, the third party may also have access to information about you and your use of our Services. Your interactions with third-party links and features are governed by the privacy policies of the third parties.

The information we collect is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website and service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected in compliance with all applicable laws.

Information We Collect Automatically

Like other websites and online services, we and our analytics providers, vendors and other third-party service providers may automatically collect certain “Usage Information” whenever you access and use the Services. For example, we may collect information regarding how often a user accesses certain features.

Usage Information may include the browser and operating system you are using, the URL that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit, and the time of day you used the Services, among other information. We may use Usage Information for a variety of purposes, including to select appropriate content to display to you and to enhance or otherwise improve the Services and our products.

In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone or other device (any, a “Device”) you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.

Usage Information is collected via tracking technologies.

Cookies

Like many other websites and apps, we use “cookies” (a small file sent to your computer by a website or device to allow the website or app to store information which uniquely identifies you) or other similar software to collect data in order to assist our users and provide them with a more personal experience visits in our Website or apps. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them. You can always disable cookies at your browser or device’s settings, but please note that if you do so, some (or all) of the features and functionality of our Services may not be available to you.

How We Respond To Do Not Track Signals:

Please note that your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online service you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about “Do Not Track”, please visit http://www.allaboutdnt.com.

3. How does ROYBI use the information it collects?

We may use information about you, including Personal Information, the information you provide in your Profile, User Content, and Usage Information for the following purposes:

To provide the Services. We use your personal information to verify your registration, allow you to participate in features we offer and contact you regarding the Services
To operate the websites. Your personal information may be used to tailor content, recommendations and offers we display to you, both on the Services and elsewhere online, as well as to maintain or improve our Services.
To send marketing communications. Anyone may sign up to receive communications from us regarding new or existing offerings or other materials that may be of interest. Recipients who have opted-in to such communications may unsubscribe at any time by clicking on the unsubscribe link in any email. Children under the age of 18 are prohibited from signing up for these communications and we will unsubscribe any person under the age of 18 that we become aware of signing up to receive these communications
To create anonymous data for analytics. We may make information anonymous by excluding information that makes it personally identifiable to you, and use that anonymous data for our lawful business purposes.
For compliance, fraud prevention, and safety. We use your Personal Information as we believe is necessary or appropriate to (a) enforce our terms and conditions; (b) protect our rights, privacy, safety or property, and that of you or others; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
To comply with law. We use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
With your consent. In some cases, we may ask for your consent to collect, use, or share your personal information, such as when required by law or agreements with third parties.

Please note that information submitted on the Services via a “Contact Us” or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise.

4. Will ROYBI share any of the information it collects?

ROYBI does not share your Personal Information with third parties for their marketing purposes in compliance with all applicable laws. ROYBI may share non-Personal Information, such as aggregate or de-identified user statistics, demographic information and Usage Information with third parties.

We also may share your Personal Information with third parties with your consent (if permissible under applicable law), as disclosed at the time you provide us with information, and as described below or otherwise in this Privacy Policy:

Service Providers

We will share your Personal Information with third parties to provide services to us or you in connection with the Services, but subject to confidentiality obligations, which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, sending our emails, or offering customer service. Consumer payments are primarily processed via third party services and we only receive the last four digits of the credit card number used for such transaction. In the event of a product return, we may collect full credit card numbers and other necessary information to issue a charge in the event that a product is not returned. We will only retain such information for as long as is necessary for our legitimate business purposes.

Administrative, Legal Reasons & Academic Integrity Investigations

We may also disclose your information, including Personal Information, in response to a subpoena, court order, or when otherwise required by law; in response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to provide information to a claimed owner of intellectual property who claims that content you have provided to us infringes on their rights; upon request of or as otherwise authorized by an academic institution connected to an investigation into academic integrity; to protect and/or defend any applicable Terms of Service or other policies applicable to the Services; or to protect the personal safety, rights, property or security of any organization or individual.

We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without your consent or without notice to you.

Business Transitions

ROYBI may share Personal Information with its parent, subsidiaries and affiliates, and investors primarily for business and operational purposes so long as any recipient agrees to comply with this Privacy Policy and applicable law with regard to such Personal Information. In the event that ROYBI goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, your information, including Personal Information, will likely be among the assets transferred.

You will be notified via email and/or a prominent notice on Services of any completed change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information. This Privacy Policy will become binding upon the new owner of the information until amended.

Testimonials

We may display personal testimonials of satisfied adult users on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us.

5. How does ROYBI work with third parties?

Third-Party Advertising

ROYBI does not currently use any user data to target advertisements or marketing to children. We do not mine user data for any purposes other than those agreed to by the parties. Data mining or scanning of user content for the purpose of advertising or marketing to children is prohibited.

Third-Party Sign-In

You may choose to connect the Services to your email account or other third party services, such as Facebook or Apple. We do not control these third parties’ use of your personal information. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website and service.

Third-Party Providers

We work with service providers like Amazon Web Services and similar organizations to provide us with information regarding traffic on the Services, including the features used when visiting the Services and to provide us with information regarding the use of the Services.

Third-Party Content, Links to Other Sites, and ROYBI Content Found Outside of the Services

Certain content provided through the Services may be hosted and served by third parties. In addition, the Services may link to third party websites or content over which ROYBI has no control and which are governed by the privacy policies and business practices of those third parties.

Please also note that ROYBI content may be included on web pages and websites that are not associated with us and over which we have no control. These third parties may independently collect data. ROYBI is not responsible or liable for the privacy practices or business practices of any third party.

For more information about data we receive from third parties, please refer to “Third Party Services, Social Media Platforms, and Information Third Parties Provide About You above.

6. What happens if I access ROYBI’s services through a mobile device?

If you use the Services through a mobile device or one of our mobile applications, you agree that ROYBI may store and use that information for security purposes (for example, for user verification or authentication).

7. How does ROYBI protect children’s information?

Protecting the privacy of young children is especially important to ROYBI. For that reason, we created certain features designed to help protect Personal Information relating to children who are less than 13 years of age or older if required by applicable law (“Child Users”).

ROYBI does not knowingly permit Child Users to use our Services without prior, express consent from a parent or legal guardian, except as permitted under the Children’s Online Privacy Protection Rule (COPPA). If we learn that Personal Information of a Child User has been collected on our Services without prior parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian (“Parent”) and discover that your child under the age of 13 (or a higher age if required by applicable law) has a registered account with our Services without your consent, please contact ROYBI to request that we delete that child’s personal information from our systems.

How does a child use the services?

Child Users cannot access or use the Services without their parent or guardian first creating an account. Parents or guardians must sign up for personal accounts and pay applicable fees before their children may access or use the Services.

What children’s information is visible to others?

No student’s profile is made available or visible to the public through ROYBI.

8. How does ROYBI protect and store my information?

ROYBI takes data security very seriously. ROYBI takes commercially reasonable technical, physical, and administrative security measures designed to protect the Personal Information submitted to us, both during transmission and upon receipt, and at rest. Such measures vary depending on the sensitivity of the information at issue. Measures taken to protect your data include the following:

We store your information in a database that is regularly backed up.
Only users can access and retrieve their own information.
For audio/visual recordings ROYBI stores this data encrypted and only the user can view their own information.
We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
We continually develop and implement features to keep your personal information safe – for example, all traffic to and from our application is over secure, encrypted protocols (SSL/TLS).
We ensure passwords are stored securely using encryption and salted one-way hashing.
Administrators are knowledgeable of security practices and harden the infrastructure with necessary patches.
Our technical infrastructure is designed to prevent unauthorized access to protected information at multiple points in every transaction.

Please note that no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.

How will ROYBI handle a data breach or security incident?

In the event that ROYBI becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage or elsewhere on the Service, and may email you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

ROYBI has procedures in place that are designed to stop threats that may expose personally identifiable information, restore Services to full functionality, and document and take proactive steps to ensure the incident cannot be repeated. ROYBI will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, ROYBI will follow its internal procedures, which articulates how to report the problem to internal and external stakeholders. The notification process includes any information that can identify which customers and children may have been impacted, the data that may have been accessed, ROYBI’s process to inform affected customers, and steps to prevent the incident from happening again as appropriate.

In the unlikely event of an unauthorized disclosure of Data, ROYBI has implemented a process for responding to incidents and notifying affected individuals and, if applicable, law enforcement personnel.

If you have any questions about security on our Services, you can contact us at hello@roybirobot.com.

9. How can I opt-out of sharing, providing, or receiving certain information?

Providing Personal Information: You can always decline to share personal information with us, or even block all cookies. However, it’s important to remember that many of ROYBI’s features may not be accessible, or may not function properly – for example, we may not be able to remember your language preferences for you.

Email Communication: You can opt-out of receiving further communications by clicking the unsubscribe button at the bottom of an email. ROYBI may continue to send you Service-related emails as we believe necessary to provide the Services. ROYBI will never email children.

10. What is your AI Ethics policy?

When developing technology products and services, including those using artificial intelligence and machine learning, our organization adheres to the principles of human dignity, non-discrimination, fair treatment, health and safety, good governance, fair labor practice, fair competition, environmental protection, animal welfare, business integrity, ethical business, anti-corruption, social responsibility, economic sustainability and the rule of law.

11. How can I access and manage my Personal Information?

You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information. Note that certain accounts may have limitations regarding the ability to delete information. Even after information is deleted, we may maintain it in backup or archive form unless you request permanent deletion or the account is terminated.

12. What communications will I receive from ROYBI and how do I limit them?

ROYBI may post notices on the homepage.

ROYBI may send adult users information by email. You may choose to stop receiving certain emails from ROYBI by using the unsubscribe button at the bottom of the ROYBI email. However, we reserve the right to send you information on our behalf and on behalf of third parties in connection with providing the Services. If you no longer want to receive information from us, you will need to close your account for that Service.

13. How do I close my account?

If you have a consumer account and you wish to close your account with one of our Services, please contact ROYBI’s customer service at hello@roybirobot.com and we will remove your Personal Information and Profile, if applicable, from the active databases for the Service(s) you request. Please let us know which Service(s) you wish to close and, if applicable, send your request using an email account that you have registered with ROYBI under your name. You typically will receive a response to a request sent to this account within five business days of our receiving it. You will be required to provide your screen name information and relevant account information. ROYBI’s customer service will verify the device information and account information, then ask a randomly generated question about the user profile/ROYBI usage to verify the user again. ROYBI will never ask for credit card information over the phone.

14. How long does ROYBI keep my information?

Upon termination of your Account, ROYBI will take commercially reasonable steps to delete any Personal Information, excluding information relating to messages you sent to active users, from our live databases in a reasonable amount of time not to exceed ninety (90) days. You understand and agree that ROYBI may continue to have Personal Information in archive files or similar databases. You further agree that ROYBI has no obligation to delete aggregated or de-identified information. ROYBI may retain and use aggregated and de-identified information for any purpose consistent with laws and regulations.

Even if your account is closed, information may remain in backup or archive records and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, account recovery or if required by law. All retained data will continue to be subject to the applicable privacy policy for the Service.

15. How will ROYBI notify me of changes to this policy?

We will notify you of material changes to the Privacy Policy on our Website and/or by email and make additional efforts to notify customers of material changes that impact the treatment of data collected through our Services.

ROYBI may update this Privacy Policy at any time and any changes will be effective upon posting. Upon any update the date at the top of this policy will be updated. In the event that there are material changes to the way we treat your Personal Information, you are responsible for regularly reviewing this Privacy Policy and your ROYBI account for notice of such modifications. Your continued use of the Services following an update to this Privacy Policy will constitute your acceptance of the updated Privacy Policy.

16. What if I am a resident of California?

If you are a resident of the state of California, you have certain data protection rights. ROYBI to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. This section describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your Rights

In certain circumstances, you have the following data protection rights

You can request the following information about how we have collected and used your or your child’s Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
You can request a copy of the Personal Information that we have collected about you during the past 12 months.
You can ask us to delete the Personal Information that we have collected from you.
Opt-out of sales. We do not currently sell Personal Information. If we plan to sell your or your child’s Personal Information, you will be notified and you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
Opt-in. We do not currently sell Personal Information. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Services.

How to Exercise Your Rights

You may exercise your California privacy rights described above as follows:

Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
- visiting https://roybirobot.com
- emailing hello@roybirobot.com
Right to opt-out of the “sale” of your Personal Information. We currently do not sell your or your child’s Personal Information. If we plan to sell your or your child’s information, you will be notified, and you can request to opt-out out of this “sale” of your personal information as directed at that time.

We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by reference to the categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy.

Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

We have not sold your personal information in the preceding 12 months.

Category of personal information (PI)	PI we collect	Source of PI	Business/ commercial purpose for collection	Categories of third parties to whom we “disclose” PI for a business purpose	Categories of third parties to whom we “sell” PI
Identifiers	· Contact data · Identity data · Data about others	· You · Business partners	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Advertising partners · Professional advisors · Authorities and others · Business transferees	None
Commercial Information	· Contact data · Identity data · Transaction data · Communications · Marketing data	· You	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None
Financial Information	· Financial data	· You · Business partners	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Advertising partners · Professional advisors · Authorities and others · Business transferees	None
Online Identifiers	· Device data · Identity data	· Automatic collection	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None
Internet or Network Information	· Device data · Online activity data	· Automatic collection	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None
Geolocation Data	· Device data	· Automatic collection	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None
Inferences	May be derived from your: · Device data · Online activity data	· Automatic collection	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None
Protected Classification Characteristics	We do not intentionally collect this information but it may be revealed in identity data or other information we collect	· You · Public sources · Business partners	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None
Education Information	· Contact data · Identity data	· You	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None
Biometric Information	· Facial recognition · Voice recognition · Audio/video recordings	· You (we do not collect this data without permission from the parent/ guardian account holder)	· Service delivery · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None
Sensory Information	· Your content	· You	· Service delivery · Research & development · Marketing · Compliance & Operations	· Affiliates · Professional advisors · Authorities and others · Business transferees	None

17. What if I don’t live in the U.S.?

Consent to Transfer

The Services are operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

Important Information for Users in the European Economic Area

The following information only applies to users in the European Economic Area (EEA), provided that we are the controller of your personal information as described below.

Controller

If you use the Services through your employer, school or another organization, that organization is the controller of your personal information and all questions or requests regarding your rights under European data protection legislation (including the rights described under Your rights below) or the processing of your personal information, should be directed to the organization. ROYBI is the organization’s processor and uses your personal information only as instructed by the organization and to the extent necessary to comply with applicable law.

If you do not use the Services through an organization, ROYBI is the controller of your personal information and can be reached using the contact details in “How can I contact ROYBI with questions” section.

Legal bases for processing

We process your personal information on the following legal bases:

*Processing purpose* (click link for details)	*Legal basis*
To provide the Services.	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to requesting the Services.
To operate the websites. To send marketing communications. To create anonymous data for analytics. For compliance, fraud prevention, and safety.	These processing activities constitute our legitimate interests. We consider and balance the potential impact on our rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where your data protection interests override these legitimate interests (unless we have your consent or are otherwise required or permitted to by law).
To comply with law	Processing is necessary to comply with our legal obligations.
With your consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated at the time consent is requested.

Cross-border data transfer

Whenever we transfer your personal information out of the European Economic Area (“EEA”) to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the EEA’s data protection laws. Such safeguards may include applying the European Commission model contracts for the transfer of personal data to third countries described here. Please contact us for further information about any such transfers or the specific safeguards applied.

Your rights

You may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Correct. Update or correct inaccuracies in your personal information.

Delete. Delete your personal information.

Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

Restrict. Restrict the processing of your personal information.

Object. Object to our reliance on our legitimate interests as the legal basis of our processing your personal information, where that processing adversely impacts your legal rights.

You may send us these requests by contacting us at hello@roybirobot.com. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to reject part or all of your request. If we reject your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to continue providing the Services to active users you sent information to and for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

18. How can I contact ROYBI?

If you have questions or comments about this Privacy Policy, please contact us via email at hello@roybirobot.com or by mail at 3566 Stevens Creek Blvd, San Jose, CA 95117