Privacy Policy for vívofit jr. App

Last updated: June 6, 2019

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Your privacy is important to Garmin. We developed this Privacy Policy to provide you with information on how we process personal data when you use the parent-controlled vívofit jr. application (“vívofit jr. app”).

Other Garmin websites, apps and products that do not include a link to this Privacy Policy and include a link to a different Garmin privacy policy are governed by that privacy policy.

“Personal data” is information relating to an identified or identifiable natural person.

To jump to a specific section of this Privacy Policy, please click on a link below:

Categories of Personal Data Processed by Garmin

Personal data that is processed when you create a Garmin account:

When you create a Garmin account, we ask you to provide your email address and name. You can choose to provide only your first name or a nickname instead of your full name if you wish.

Purposes and Legal Grounds:

(a) Garmin processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on Garmin’s legitimate interest in protecting the security of your account.

(b) Garmin also processes your email address for the purpose of sending you important information about your Garmin products, apps or account, such as important safety information or material changes to this Privacy Policy. The name you provide is associated with your account profile. The legal ground for processing your email address and name for these purposes is Garmin’s legitimate interest in providing you important safety or other information about your Garmin products, apps or account or material changes to this Privacy Policy.

(c) If you provide your opt-in consent to receiving marketing information from Garmin, Garmin will also process your email address for the purpose of sending you marketing information about Garmin products and apps. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your Garmin account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from Garmin are based on the preferences you provide in your Garmin account, the locale indicated by your IP address, the types of Garmin devices you have added to your Garmin account and any subscriptions included in your Garmin account. The legal ground for processing this data for this purpose is Garmin’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.

(d) Garmin also processes your email address to associate it with your Garmin account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.

(:Additional personal data that is processed when you download the vívofit jr. app and create your profile:

When you create your profile in the vívofit jr. app, your Garmin Connect name will be used as your Admin name in the vívofit jr. app. You also will be asked to provide a name for your Family and a name for each of your children whose vívofit jr. devices you add to your profile. You do not need to give your Family’s actual name or your children’s full names or even your children’s actual names in the “name” fields. There will be a default wake and bed time for each of your children whose vívofit jr. devices you add to your profile. You can, but are not required to, change the default wake and bed times. In addition, you can, but are not required to, type in a location for your Family (which can be anything you choose, such as a country, state, city, etc.) and your children’s ages and genders. You can leave those fields blank if you wish.

You will be asked to provide a display text for each of your children whose vívofit jr. device you add to your profile. The display text you choose will be shown on your child’s vívofit jr. device and may be shown when your child engages in Toe-to-Toe challenges, depending on your settings, as described below in more detail under *“Personal data that is processed when your child uses the Toe-to-Toe challenge feature.” *

If you choose to invite another parent or guardian to use the vívofit jr. app, we will collect the name and email address of that person.

Purposes and Legal Grounds:

(a) We process your Garmin Connect name and use it as your Admin name, and we process the name you use for your Family name in the vívofit jr. app so your friends and family members can search for you and add you or your Family as Connections. This enables you and your Family members to participate in challenges with other Families if you wish. The legal ground for this processing is our legitimate interest in enabling you and other users to find Connections and engage in challenges.

(b) We process the names you use for your children in your vívofit jr. app profile so you can use the vívofit jr. app’s features such as reviewing and managing each child’s activities, chores and rewards. The legal ground for this processing is your consent. You can withdraw your consent by using text other than your child’s name in the name field.

(c) We process the name or other text you input into the display text field so you can choose the name or other text that is shown on your child’s vívofit jr. device and when your child participates in a Toe-to-Toe challenge, depending on your settings. The legal ground for processing your child’s name for this purpose, if you choose to use your child’s name in the display text field, is your consent. You can withdraw your consent at any time by changing the display text to some text other than your child’s name.

(d) We process information you give us for a second parent or guardian for the purpose of sending the second guardian an invitation to download the vívofit jr. app and “join your family.” The legal ground for processing this information for these purposes is our legitimate interest in enabling users to add a second parent or guardian to the vívofit jr. app.

Personal data that is processed when you upload data from the vívofit jr. device to Garmin:

When you sync the vívofit jr. device with the vívofit jr. app, you will upload to Garmin information about your child’s activity (chores, rewards, steps, distance, activity time and sleep).

Purpose and Legal Ground:

Garmin processes your child’s activity data to enable you to see and analyze your child’s activity data. The legal ground for this processing is your consent. You can withdraw your consent to upload your child’s activity data to Garmin at any time by not syncing the vívofit jr. device with your vívofit jr. app.

Additional personal data that is processed when you sync your Garmin device:

When you sync your device through the vívofit jr. app, we also log data about the transmission, such as the IP address used when syncing, the sync time and date, crash/diagnostic logs, geographic location of your mobile device, information about the network used to sync (e.g., Wi-Fi® or cellular) and device battery level.

Purpose and Legal Ground:

We process this information to help identify and resolve errors or syncing issues. The legal ground for processing this information for this purpose is Garmin’s legitimate interest in resolving errors or syncing issues and providing quality product support.

Personal data that may be processed when your child uses the Toe-to-Toe challenge feature:

The display text you choose to input in the display text field in your vívofit jr. app, together with the total number of steps taken by your child during the duration of the challenge, will be shown on the devices of your child’s friends or family members if your child engages in a Toe-to-Toe step challenge with them, and it will be shown in the vívofit jr. apps of the parents of such friends and family members and in the Garmin Connect account of friends or family members who use other Garmin devices to engage in a Toe-to-Toe step challenge with your child. If you do not want your child’s actual name to be shown on the devices of other users or the vívofit jr. apps of their parents or Garmin Connect accounts of others when your child participates in a Toe-to-Toe challenge, then you can use any text other than your child’s name that you wish in the display text field. If you do not wish for the display text to be shown on the devices of other users or the vívofit jr. apps of their parents or Garmin Connect accounts of others when your child participates in a Toe-to-Toe challenge even if the display text is not your child’s name, then in your vívofit jr. app, you can change the settings for this to anonymous, in which case the display text shown on the devices of other users or the vívofit jr. apps of their parents or Garmin Connect accounts of others when your child participates in a Toe-to-Toe challenge will be changed to a generic “JR2” or similar generic and anonymous display text.

Purpose and Legal Ground:

If you provide your child’s name in the display text field, we process it for purposes of displaying it on your child’s device. The legal ground for this processing is your consent, which you can withdraw at any time by changing the display text to something other than your child’s name. If you provide your child’s name in the display text field, we also process it for purposes of displaying it on the devices and apps of others when your child engages in a Toe-to-Toe challenge. The legal ground for this processing is your consent, which you can withdraw at any time by changing the display text to something other than your child’s name or by changing the setting to anonymous.

Personal data that is processed when you communicate with Garmin:

When you interact with our customer support representatives via email, telephone, online or in person, we collect personal data such as your name, mailing address, phone number, email address and contact preferences; and information about the Garmin products you own, such as their serial numbers and dates of purchase. We also may create event logs that are useful in diagnosing product or app performance-related issues and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives and analyze any feedback provided to us through voluntary customer surveys. With your consent, our customer support representatives may sign in to your Garmin account, if appropriate, to help troubleshoot and resolve your issue.

Purpose and Legal Ground:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is Garmin’s legitimate interests in providing quality product support. The legal ground for signing in to your Garmin account, if appropriate, to help troubleshoot and resolve your issue is consent, which you may withdraw.

Categories of Recipients of Personal Data

Other Garmin users:

Other vívofit jr. app users will be able to see your profile. Users who are not your Connections will be able to see the Family name you choose in your profile, your Admin name, the name of any additional parent or guardian you have added to your profile and the number of children you have added to your profile. Users who are your Connections will be able to see the same information plus the names you have provided for your children in your profile. You can challenge another Family to a steps challenge, and you can set up an intrafamily steps challenge for your Family. When you engage in a steps challenge with another Family, the total steps taken during the duration of the challenge by each participating member of your Family, the names of the participating members of your Family and comments submitted through your vívofit jr. app by participating members of your Family will be shown in the vívofit jr. app of the other Family’s Admin.

Other service providers:

Garmin uses cloud services from third parties such as Adobe and Emarsys to assist in sending emails. Those services track the activities associated with these emails, such as whether they were opened, whether links in the emails were clicked on and whether purchases were made following clicks on those links. Garmin uses this data to analyze the level of engagement with its emails. Garmin uses third-party service providers to help us better understand usage of Garmin Express and our websites and apps.

Other disclosures:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Garmin’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data to will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Transfers of Personal Data

Garmin is a global business. To offer and update our products, apps and services, we may need to transfer your personal data to other Garmin companies in other countries. View Garmin-owned companies. When you create a Garmin account, add personal data in your account profile, or upload data to your Garmin account, your personal data will be collected and stored on Garmin International Inc.’s servers in the U.S. Personal data regarding individuals who reside in a country in the European Economic Area (“EEA”), the United Kingdom (“U.K.”), or Switzerland is controlled by Garmin Würzburg GmbH and processed on its behalf by Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc.

Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. comply with the EU-U.S. and Swiss-U.S. Privacy Shield principles regarding the collection, use, sharing, and retention of personal information from the EEA, U.K., and Switzerland, as described in our EU-U.S. Privacy Shield certification and Swiss-U.S. Privacy Shield certification. Learn more about Privacy Shield here.

Garmin International, Inc., Garmin Services, Inc., and Garmin AT, Inc. are subject to the oversight of the U.S. Federal Trade Commission and remain responsible for personal data transferred to third parties that process it on our behalf. If you have a complaint about our Privacy Shield compliance, please contact us at [email protected]. You can also refer a complaint to our chosen independent dispute resolution body, JAMS, and in certain circumstances, invoke the Privacy Shield arbitration process.

All Garmin companies are required to follow the privacy practices set forth in this Privacy Statement.

Cookies and Similar Technologies

We collect data from users about their usage of the vívofit jr. app. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the mobile device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information and information relating to how the app functions. Garmin uses this data to improve the quality and functionality of the vívofit jr. app and other Garmin apps; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.

The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our apps so we can enhance the user experience and functionality of our products, apps and websites.

Children

The vívofit jr. app is not directed to individuals under the age of 13 in the U.S. and under the age of 16 in the rest of the world, and individuals under the age of 13 in the U.S. or under 16 in the rest of the world are prohibited from downloading the vívofit jr. app. Although the vívofit jr. device is designed to be worn by a child, our licensee with respect to the vívofit jr. app is the parent/guardian who has downloaded the vívofit jr. app and who uses the vívofit jr. app to sync the data from the vívofit jr. device to the parent’s/guardian’s account.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the Garmin Connect website or through the vívofit jr. app

Retention of Personal Data

We will retain your personal data as long as your Garmin account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

If you reside in a country in the EEA, U.K., or Switzerland, then your personal data collected by Garmin is controlled by Garmin Würzburg GmbH, which is located at Beethovenstraße 1a+b, 97080 Würzburg, Germany. Garmin’s EU Data Protection Officer is located at the same address and can also be reached by email at [email protected].

If you reside outside of the EEA, U.K., and Switzerland, then the personal data collected by Garmin is controlled by Garmin International, Inc., 1200 E. 151st St., Olathe, Kansas 66062, which you can also contact by email at [email protected].

Your Rights

If you reside in the European Union or U.K., you have the right under the General Data Protection Regulation (“GDPR”) or UK Data Protection Act 2018 to request from Garmin access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. For more information about these rights, please visit the European Commission’s “My Rights” page relating to GDPR, which can be displayed in a number of languages. If you reside outside of the European Union and U.K., you may have similar rights under your local laws.

To request access to or rectification, portability or erasure of your personal data, or to delete your Garmin account, visit Account Management Center.

If you live in the European Union or U.K. and you wish to exercise your right to restriction of processing or your right to object to processing, contact Garmin’s EU Data Protection Officer at Garmin Würzburg GmbH at Beethovenstraße 1a+b, 97080 Würzburg, Germany, or by email at [email protected]. If you do not live in the European Union and U.K. but you believe you have a right to restriction of processing or a right to object to processing under your local laws, please contact Garmin International, Inc. at [email protected].

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