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Last Reviewed: January 2023
TABLE OF CONTENTS
Who We Are
What Type of Information is Collected
The Legal Grounds and Purposes for Processing Your Personal Information and How We Use It
Disclosure of Information to Third Parties
Security for Personally Identifiable Information
Updating/Correcting Your Personal Information and Contacting Us
The Websites Are General Audience Websites
Consent to Transfer
Your Rights in Relation to Your Personal Information
Third Party Content and Links to Other Websites
Social Media Sites and tracking
Nevada Privacy Rights
Privacy Notice for California Residents
1. Who We Are
Owlet Baby Care, Inc.
Email address: email@example.com
Postal address: 3300 N. Ashton Boulevard, Suite 300, Lehi, UT 84043
If you are in the EU, you have the right to make a complaint at any time to your data protection authority responsible for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.
2. What Type of Information is Collected?
Information You Provide Us:
You may provide information to us through our Services, which may include:
When you purchase our Products or our Services, we may collect personal information or personal data, which is information that could reasonably be used to identify you personally, such as your name, address, zip code, e-mail address, credit card number, telephone and fax number(s).
When you use our Products or our Services, we may collect information about you or your baby, including [images you upload, success stories and other content you upload or provide us, your child’s first names and health condition, and demographic information, such as gender, race, or similar information, baby heart rate, average oxygen, oxygen saturation, room temperature, room humidity, baby movement, sleep and wake window.
When you communicate with us in any form, for example when you fill out forms, email or chat with us through our Websites or applications, respond to surveys or inquiries concerning our Services, or apply for a job, we may collect personal information such as your name, phone number, and email address.
When you participate in sweepstakes, contests, promotions, or surveys we may collect personal information such as your name, email address, date of birth, shipping address, phone number, social media usernames.
Information Collected from You Automatically
We may collect personal information automatically when you use our Website or Services as follows:
Website Usage Information & Device Identifiers: We may receive and store certain types of usage information whenever you visit or interact with the Websites. For example, we may collect information about the page served, the time spent on a page, the source and terms used to request or find a page, the type of browser making the request, the preceding and subsequent page viewed and other similar information. We may also collect your internet protocol (IP) address or some other unique numeric identifier for the particular device you use to access the internet, as applicable (collectively referred to as a "Device Identifier "). A Device Identifier is a number that is automatically assigned to your computer, your mobile device, or other device used to access the internet, and our computers identify your device by its Device Identifier. We may associate your Device Identifier with other information you provide. When analyzed, Website usage information helps us determine how visitors arrive at the Websites, what type of content is most popular, what type of content you may find most relevant, and what type of visitors are interested in particular kinds of content and advertising.
Cookies: Our web pages may utilize cookies, which are small data files placed and possibly stored on your computer (or other Internet-accessing device) when you visit a Website. A cookie file can contain various types of information, such as a user ID that identifies your computer or browser to the Websites. Cookies may be used for many purposes, including, without limitation, as a mechanism for creating a user "session," tracking a user as he or she moves among pages of the Websites, or to identify a user in a database. The cookies used on our Websites fall into the following categories:
Essential Cookies: These cookies are necessary for Our Website to work correctly and to allow you to use some of its features and are always enabled. You can set your browser to block these cookies, but this may impact your experience on Our Website.
Analytics Cookies: These cookies allow Us to understand how you use Our Website, so we can improve Our Website’s content and performance.
Marketing Cookies: These cookies help Us understand your interests so that We can provide you with a more personalized experience across Our digital and in-person interactions.
Advertising Cookies: These cookies help Us ensure that the ads you see are more relevant to you.
Web Beacons: The Websites and our e-mail messages may also utilize web beacons, pixel tags or similar technologies (as they become available), which are small graphic images or other web programming code (also known as "1x1 GIFs" or "clear GIFs" or “pixel tags” or “single-pixel gifs”) that allow monitoring and collection of information about the user of a web page, web-based document or message sent by the Websites or in emails or other electronic communications, such as the type of browser/device and software accessing the Websites. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons and similar technologies may be used for a variety of purposes, including, without limitation, to serve users with relevant content at the Websites, count Website visitors, and monitor Website traffic patterns.
Scripts: Our Websites may use programming code that collects information about a user’s interactions with the Websites, such as what pages are visited, how many times they are visited, and for how long. This code is downloaded onto your computer from our web server or a third-party service provider, is active only while you are connected to the Websites and does not operate unless you are on the Website.
Mobile Device Identifiers: Certain mobile service providers uniquely identify mobile devices and we or our third-party service providers may receive such device information if you access the Websites through mobile devices or mobile device applications. Certain features of the Websites may require collection of mobile phone numbers and location identification data (i.e., your global positioning system location) and we may associate that information to your mobile device identification information. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, we and our third-party service providers may receive this information. We may also be provided this information in connection with your use of Social Media Sites, but you may be able to restrict that data using settings in those Social Media Sites.
Information Collected from Third Parties or Publicly Available Sources
We may receive personal information about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers like Google based in the United States and the European Union; and
search information providers such as Tealium based in the United States
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Shopify and Paypal based in the United States and the European Union.
3. The Legal Grounds and Purposes for Processing Your Personal Information and How We Use It
We have set out below, in a table format, a description of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer, manage your account or authorize or decline a new account request
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Provide financing options
(d) Communicate with you on orders
(e) Provide access to certain functionalities and features of our Services, including to monitor heart rate, sleeping patterns, heart rate, spO2, movement, noise, video stream, room temperature, room humidity development tracking for your baby
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Contact you regarding comments, questions, or requests that you may have
(e) Send you newsletters, emails and other non-transactional communications you have consented to receive
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) Consent, where applicable
To enable you to partake in a sweepstake, contest or promotion or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of business restructuring)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you, including by interacting with you on other websites that are designed to enhance interpersonal, business to consumer and consumer to consumer interactions such as Facebook®, Twitter®, Google®, YouTube®, Pinterest® and other similar sites (in this policy, "Social Media Site(s)")
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
4. Disclosure of Information to Third Parties.
We may disclose the information we collect about you to third parties as described below:
Legal Protections and Law Enforcement: We may disclose your information, including personally identifiable information, by compulsion of law, in response to a court or administrative order, regulation, search warrant, subpoena, discovery request or other valid law enforcement measure, to comply with a legal obligation, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the policies governing the Services and applicable laws, or to protect the legal rights, interests, or safety of the Websites, our users or others. We may also use Device Identifiers 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. Such disclosures may be carried out without notice to you.
Third Parties Providing Services on Our Behalf: We employ third parties to perform functions on our behalf. Examples include the companies hosting or operating the Services, processing and/or fulfilling orders for products, sending e-mail and/or other communications, maintaining customer and user information and databases, and credit card payment processing. These third parties may have access to your personal information in connection with performing such functions.
Sweepstakes, Contests and Promotions: We may offer sweepstakes, contests and other promotions through the Websites that may require registration. If you choose to enter a sweepstakes, contest or other promotion, your personal information may be disclosed to third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfilment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.
Business Transfers: We may share the information collected through the Services with and among our affiliates and divisions. If we transfer any of our business, either by selling our assets, merging, consolidating, divestiture, restructuring, reorganizing, dissolution, or by other means such as by a stock sale or other sales or transaction in which we effectively transfers all or a portion of our business, or other corporate change (including, without limitation, during the course of any due diligence process), we reserve the right to disclose and transfer our assets, including, without limitation, the Services, all information you have provided or we have otherwise collected, and its customer and sales files.
EEOC: In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission ("EEOC"), the Office of Federal Contract Compliance Programs ("OFCCP") and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information, such as gender and ethnicity. Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information to the EEOC, the OFCCP, and similar state and local regulatory agencies for business-related purposes, including, but not limited to responding to information requests, fulfilling regulatory reporting requirements and defending against employment-related complaints.
Aggregate Information: We may also provide third parties aggregate information, such as aggregate information regarding users of the Services, aggregate demographic information, and aggregated or anonymized information collected from the Services without restriction. For example, third parties may have access to information regarding the number of unique page requests, unique users of our Websites, and aggregate information on the types of activities users conducted while on our Websites.
5. Third-Party Ad Serving and Traffic Analysis and Measurement Services.
6. Security for Personally Identifiable Information.
We use reasonable efforts to protect and secure your personal information against unauthorized access or accidental loss. Although we do our best to protect your personal information, please remember that the security measures taken are not fool proof; no Website can guarantee that personally identifiable information will be protected in all situations. Therefore, we can only state that we will make a reasonable effort to protect from unauthorized access the information that you provide, including, but not limited to, through the use of firewalls and various access controls. All information you transmit to us via the Websites is at your own risk. We encourage you to use caution when using the Internet. This includes not sharing your passwords.
7. Updating/Correcting Your Personal Information and Contacting Us.
The Websites may contain web pages through which you can change your preferences or update the personal information you have provided to us through the Websites. If you register to receive e-mail or other electronic communications from one of our divisions, you may unsubscribe by following the instructions provided to you in the applicable communication. You can contact us in order to: (i) update or correct the personally identifiable information that we store about you; or (ii) direct us to render inactive on our systems all personally identifiable information that refers or relates to you. Please note that if you request us to render inactive personally identifiable information that you provided, we may still use aggregate non-personal information and some personally identifiable information that you provided may continue to reside on backup tapes and other non-active systems used for data restoration purposes. We will not manually delete personally identifiable information that you provided from such backup media. If we reasonably determine that we owe a legal obligation to retain your information despite your request, we will retain your information, but only so far and to the extent that we reasonably determine that we are required to do so to comply with law. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
8. The Websites Are General Audience Websites.
The Websites are general audience Websites and not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Websites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
9. Consent to Transfer.
In the course of interacting with you through our Services, we will transfer your personal information outside of the EU, principally to offices and servers in the United States; this means that your personal information will not have the automatic protection of EU data protection laws (including the GDPR). In these circumstances, in order to ensure that your personal data continues to have adequate protection when it is transferred out of the EEA, your personal data will only be transferred on one of the following bases:
where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (for example, standard data protection clauses adopted by the European Commission);
a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent).
You can obtain more details of the protection given to your personal data when it is transferred outside the EU by contacting us using the details set out below.
10. Your Rights in Relation to Your Personal Information.
This section is for consumers located in the EU. For California residents or for residents of states with their own comprehensive data privacy or protection laws, please visit our Privacy Notice for California Residents, available below.
Under the GDPR, you have the following rights in relation to our processing of your personal data. Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply:
to obtain access to, and copies of, the personal data that we hold about you;
to require us to correct the personal data we hold about you if it is incorrect;
to require us to erase your personal data in certain circumstances;
to require us to restrict our data processing activities in certain circumstances;
to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on you;
to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.
Note: If you have given your consent and you wish to withdraw it, please contact us using the contact details set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our Services to you and/or it may affect the provision of those Services.
11. Third Party Content and Links to Other Websites.
12. Social Media Sites and tracking.
We may make use of Social Media Sites to communicate with you, to provide you information, and to receive information from you. In some cases, this information exchange may be automated. For example, when you "Like" us on Facebook®, Facebook® may automatically make changes to our Facebook® site, include parts of your profile in our timeline, and may notify your friends that you have liked us. We do not control how Facebook®, or any other Social Media Site, uses your information, and your privacy is determined by those sites (for help with respect to opting out, see https://www.facebook.com/settings/?tab=privacy or http://www.aboutads.info/choices/). Some Social Media Sites may use "tracking" technology—they may be able to know that you have visited us, and they remain active even after you leave our Websites. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store.
14. Nevada Privacy Rights
Nevada law (SB 220) permits customers in Nevada to opt-out of the sale of certain kinds of personal information. As mentioned below, we do not sell your personal information to third parties. If you are a Nevada resident and have questions, please contact us at email@example.com
Privacy Notice for California Residents
Information We Collect
As discussed in further detail in section 1 above, we collect personal information from consumers.
In particular, the chart below provides information on the categories of personal information collected from consumers, the categories of third parties we have disclosed the information to for business purposes and the purpose for the business disclosure, within the last twelve (12) months:
Third Parties Disclosed
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
L. Sensitive Personal Information
Personal information that reveals a consumer’s: social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; or genetic data; the contents of a consumer’s mail, email, and text messages unless the we are the intended recipient of the communication; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.
We do not share the personal information of anyone under 16 years of age for purposes of cross context behavioral advertising.
We obtain the categories of personal information listed above from the following categories of sources
Directly from you. For example, when you contact our customer service department (which may be recorded) or provide your information to us at a tradeshow or via social media.
Directly and indirectly from activity on our Websites. For example, from observing your actions on our Website or when you create an account on our Websites, order a product from our online store, or submit a question on our Contact Us webpage.
From third-parties that interact with us in connection with the services we perform. For example, from customer concern call centers or background check services or advertising vendors.
Use of Personal Information
We may use or disclose the personal information as described in Section 2 above.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing/Selling Personal Information
In the preceding twelve (12) months, we have not sold any personal information.
In the preceding twelve (12) months, we shared the following categories of personal information to the following categories of third parties: identifiers, California Customer Records personal information categories, and internet or other similar network activity to third-party analytics and advertisement service providers for the purpose of providing services, such as, analytics, marketing, and targeted behavioral advertising services. To opt out, you may contact us directly at firstname.lastname@example.org.
Your Rights and Choices
The CCPA and CPRA provides certain consumers, including California residents, with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
Sales or sharing of information, identifying the personal information categories that each category of recipient purchased or received for targeted behavioral advertising; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies.
We will delete or deidentify personal information not subject to any exceptions from our records and will direct our service providers to take similar action.
Your Right to Correct
You have the right to request correction of any inaccurate personal information we may hold about you. In considering this request, we may take into the account the nature of the personal information and the processing purposes when determining whether or not to correct the information. We will use commercially reasonable efforts to correct inaccurate personal information once we receive the request.
Exercising Your Rights to Know, Delete, or Correct
To exercise your rights to know, delete, or correct described above, please submit a request by either:
Emailing us at email@example.com
Filling out a request on our Contact Us webpage
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete or correct related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know, delete, or correct must:
a valid power of attorney designating the representative
a document signed by you that grants the representative permission to make requests on your behalf
you providing the information mentioned above directly to us
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
For instructions on exercising your right to opt-out of the sharing of your personal information for cross-context behavioral advertising purposes, please contact firstname.lastname@example.org.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Changes to Our Privacy Notice
Postal Address: Owlet Baby Care, Inc. 3300 N. Ashton Blvd., Suite 300, Lehi, UT 84043