Privacy Policy

Welcome to Snorble®, an engaging and intelligent buddy that helps children and families develop healthy habits and bedtime routines. Snorble Incorporated, including any current or future affiliates and subsidiaries (collectively, “Snorble”) is thrilled you’re placing your trust in our service. Snorble knows that you and your Child’s personal information is important, and we will take every reasonable measure to secure that information. In the unlikely event that we suspect information has been leaked, you’ll be notified as soon as possible. We also will take reasonable actions to ensure that the hardware and software used in our Products and/or Services are secure and free from malicious software that could compromise your privacy or security.

This Privacy Policy is meant to provide you with some transparency by helping you understand the information we collect, why we collect it, and how you can manage it, so you know what to expect. This Policy applies to our websites at https://snorble.com/ and https://www.facebook.com/TeamSnorble/ (the “Sites”), our Snorble doll (the “Product”) and any related products, services, communications, or apps (collectively, together with the Sites and Products, the “Services”). You may interact with many of our Services, and many of these Services are built to interact with one another. For example, changing your bedtime routine in the app affects how the Snorble doll behaves when you say, “Hey, Snorble. It’s bedtime.” By using our Services, you are acknowledging that you have read, understood, and accept this Privacy Policy and our Terms and Conditions.

In this Privacy Policy, any use of the words “you,” “yours,” or similar expressions refers to users of our Services, as well as any other individuals whose information we collect and process. References to “we,” “us,” “our” or similar expressions refer to Snorble.

This Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after our Sites, and which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.

Subject to the laws of your country of residence, Children may utilize the Product through an account established by a parent or legal guardian.  The Sites are to be used solely by a parent or legal guardian and are not intended for use by Children. In accordance with the requirements of the Children’s Online Privacy and Protection Rule (“COPPA”), Snorble seeks parental approval of a Child’s use of the Product through methods approved under applicable law.  We may (a) ask the parent for payment card information; (b) contact the parent with an email address or other contact information supplied by the Child to confirm, refuse or modify a Child’s registration; and/or (c) ask the parent to provide additional documentation or perform additional actions as part of the approval process as consistent with applicable law. Snorble reserves the right to refuse access to the Product pending confirmation and activation by the Child’s parent or guardian. Use of the Product by Children must take place under the responsibility of their parents or legal guardians, and any use of the Product is assumed to have been validated by them.

In the event that you permit your Child to use the Product, you agree on behalf of yourself and your Child to our data handling practices as described in this Privacy Policy. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

At any time, parents or legal guardians can refuse to permit us to collect further personal information from their Children in association with a particular account, can request to review their Child’s information and can request that we delete from our records the personal information we have collected in connection with that account. If such information is necessary to participate in the Services, however, such a request may lead to a termination of an account or other service.

Information We Collect

  1. Children.
    1. “Child” or “Children” as used throughout is defined as anyone under the age of 13. If a Child resides in the state of California, this term is defined as anyone under the age of 18.
    2. Children can access many parts of Services and their content and use many of its features without providing us with personal information. However, some content and features are available only to registered users and/or require us to collect certain information, including personal information, from them.
    3. We only collect as much information about a Child as is reasonably necessary for the Child to participate in an activity, and we do not condition her or his participation on the disclosure of more personal information than is reasonably necessary.
    4. You may agree to the collection and use of your Child’s information without agreeing to any disclosures to third parties, so long as disclosure to such third parties is not necessary for the provision of our Services.  
  2. Information We Collect and Receive. In order for you or your Child to use our Services, we need to collect and process certain types of information. Depending on your use of our Services, this may include:
    1. Information you provide to us by completing forms on our websites: For example, your name, contact, and address information, and any other information you may provide in the forms on our websites;
    2. Information you provide to us by contacting us: Any personal information you may provide to us when you email or call us, such as name, phone number, and any other details you provide in your communications. Snorble may also request your contact information for the purposes of having someone contact you for additional information, or in response to your request for information from us;
    3. Transaction information when you purchase Services from us: For example, if you make purchases with your credit card, we may use your credit card information for shipping, billing, and credit card validation purposes;
    4. Login information, such as username and password, that you may use in connection with our Services;
    5. Information from third-party social media services. Snorble allows you to create an account and log in to use the Services though Google, Facebook, Twitter, and LinkedIn. If you decide to register through or otherwise grant us access to a third-party social media service, we may collect personal data that is already associated with your third-party social media service, such as your name, email address, or activities, associated with that account. You may also have the option of sharing additional information with Snorble through your third-party social media service’s account. If you choose to provide such information during registration or otherwise, you are giving Snorble permission to use, share, and store it in a manner consistent with this Privacy Policy. When you visit or link to our social media pages, data is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers.  Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.
    6. You must provide us with the following information to register your child with our Services: the Child’s first name, birth date, and a parent’s email address. We also require you to create a username and password that is connected to each Product. We may request additional information from you about your Child, but this information is optional. We specify whether information is required or optional when we request it.
    7. Information about you or your Child’s activity through our Services, including device information, such as IP address, the type of device or browser used, mobile operating system used, and actions taken.
  3. Audio File Collection, Use, and Deletion Policy.

    We will listen and get to know you. Scary, right?

    For you and your child to interact with our Services, our Services may use a microphone to listen for keywords and sometimes send recordings to the cloud. We process and retain your interactions, like voice commands, favorite games, and app usage, to provide and improve our Services and only to provide and improve our Services.

    All voice data is stored on the Product as our Product has a feature that can identify a person that is interacting with it.  This is used by the Product to address the Child by their name and identify one user from another group (your Child and their classmates, for example). A factory reset and/or account deletion removes all voice data from the Product.

    Voice data is only pushed to the cloud if the permission to share is enabled.

    Voice data pushed to the cloud does not include information that can be traced back to a particular person.

    We will only use personal information to provide you with information and  Services you have requested, or for other purposes set out in this Policy. Personal information does not include aggregate information from which individual identities have been removed.
  4. Cookies and Tracers. We may use cookies and similar technologies (e.g., web beacons, pixels, and device identifiers) to recognize you, your Child, and/or your device(s) on, off and across the Sites and different Services and devices. 

    Unlike the food that quickly disappears around children, this type of cookie is a small file that is placed onto a device (e.g., computer, smartphone or other electronic device) that stores information when you visit a website. However, you can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising. Neither the Sites nor the Services respond to Do Not Track signals.

    Snorble uses cookies and related technologies on our websites to help us recognize you or your Child’s device as a repeat visitor, and enable certain website features and functionalities. Some of this data will be aggregated or statistical, which means that we will not be able to identify you or your Child individually.

    Specifically, we use cookies and other similar technologies on our websites to:
    Recognize you whenever you visit our websites (this speeds up your access to the website as you do not have to log in each time);
    1. Support security and any authentication features on our websites;
    2. Obtain information about your preferences and use of our websites;
    3. Carry out research and statistical analysis to help improve our content and Services, and to help us better understand our customers’ requirements;
    4. Improve the speed and performance of our  Services;
    5. Make your online experience more enjoyable and efficient; and
    6. Keep track of the items stored in your shopping basket and take you through the checkout process.
  5. Types of Cookies: The cookies we place on your device fall into one of the following two categories:
    1. Session cookies: these allow our websites to link your actions during a particular browser session. These expire each time you close your browser and do not remain on your device afterwards.
    2. Persistent cookies: these are stored on your device in between browser sessions. These allow your preferences or actions across our websites to be remembered. These will remain on your device until they expire, or you delete them from your cache.

      The cookies that we place on your device may also be:
      1. Strictly necessary cookies: these cookies are essential for you to be able to navigate our websites and use their features. Without these cookies, we could not provide you with the Services you have requested.
      2. Performance cookies: these cookies collect information about how you use our websites, for example, which pages you go to most often. These cookies do not collect personally identifiable information about you. All information collected by these cookies is aggregated and anonymous, and is only used to improve how our websites work.
      3. Functionality cookies: these cookies allow our websites to remember the choices you make (such as your user name, language, last action, and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.
      4. Analytics cookies: We use Google Analytics, a web analytics service of Google Inc. (“Google”) which uses cookies to identify the frequency of use of certain areas of our Services and to identify preferences. For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. The information regarding your use of this website that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the Services, compile reports on activity for us, and perform further services associated with the Sites and Internet use. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here:  https://tools.google.com/dlpage/gaoptout?hl=en.
      5. Facebook Insights: We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about our users. For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period. Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services. For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation.
    3. Controlling Cookies: Your browser may give you the ability to control some types of cookies. If you do not want to accept the kinds of cookies you can control, you can change your browser settings so that certain types of cookies are not accepted. To control flash cookies, which cannot be disabled through your browser, please go to: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

      If you turn off any cookies, please be aware that you may lose some of the functionality of our websites. For more information about cookies and how to disable them please check one or more of the following resources: http://www.allaboutcookies.org/
    4. Consent to Use Cookies: The first time you visit our websites, a cookie notice may be displayed describing our use of cookies, and linking to this Cookie Policy. As described in that notice, the cookie choices you make the first time you visit our Sites will be used for your future use of the Sites.

How We Use Information

Snorble may use the personal information we collect for the following purposes:

  1. To deliver, maintain, and improve our Services;
  2. To allow you to log into, access, and manage your account;
  3. To provide customer service and our support services;
  4. To process any financial transactions you make on our Services and fulfill your orders for Services;
  5. To keep your information secure such as by detecting security incidents, and to be able to verify your identity and contact information;
  6. To alert you  about product updates, special offers, functionalities, security updates, updated information, and other news and services from Snorble;
  7. To track or store your Child’s performance in games, bedtime habits, exercise habits, preferences, and educational or other activities, allowing us to customize the content according to individual interests;
  8. To ensure our Services are relevant to you/your Child’s interests;
  9. To assist in business transfers, such as if Snorble is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Snorble's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event;
  10. To identify usage trends, and determine effectiveness of our promotional campaigns;
  11. To help us create and publish content most relevant to you or your Child;
  12. To contact you in response to sign up forms or requests such as our Contact Us feature; and
  13. For other legitimate business purposes

How Information May Be Shared

In connection with the provision of our Services, we may share your or your Child’s information with certain trusted third-party services who perform services on our behalf to help us provide, improve, promote, or protect our Services, including without limitation our online store hosting provider, payment processors, email delivery provider, customer service tools, cloud hosting provider and professional advisors. Whenever we share data with third-party services, we seek written commitments from such third parties that that they will protect the data with safeguards that are substantially equivalent to those used by Snorble.

Notwithstanding the generality of the foregoing, we use Shopify to host our online store. Their Privacy Policy can be viewed at https://www.shopify.com/legal/privacy.

We have entered into agreements with Facebook that define the terms for use of our Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php. Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

We also reserve the right to disclose personal information when it is reasonably necessary to protect the safety of a Child, conduct our business, protect Snorble’s legal rights, security, and property, and to comply with the law. Otherwise, you or your Child’s personal information is not shared with any individual or other organization.

In addition, if Snorble is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Snorble's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

We may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.  

Protection of your Personal Information

We take the security of your personal information seriously and follow industry-standard practices to protect the data we collect and process. Snorble has therefore put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the personal information that Snorble collects. Access to personal information will be restricted to our authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is necessary for the performance of those duties.

Remember, the safety and security of your information also depends on you. Where you have chosen, or where we have given you a username and password for access to certain parts of the Services, you are responsible for keeping the username and password confidential. No method of transmission over the internet or electronic storage is completely secure, so Snorble cannot guarantee its absolute security.

  1. Data Transfers for Users Outside the United States

    Because Snorble is a US-based company, your information may be collected and processed in the United States. Additionally, as part of the Services offered to you, the information which we collect about you may be transferred to, and stored in, one or more countries other than where you currently reside. For example, this may occur if any of our servers or third-party service providers are located in a country other than yours. These countries may have different data protection laws that are similar to your current residence. However, if we transfer your information in this way, we will put in place appropriate requirements to comply with applicable law.
  2. Basis for Processing - European Residents

    Data protection law in the European Economic Area (EEA) requires a lawful basis for collecting and retaining personal information from residents. Our lawful bases for processing personal information include:
    1. Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligations, such as to deliver our Services and answer any questions you may have.
    2. Consent: we may ask your consent to process your personal information in certain situations.
    3. Legal compliance: Sometimes the law requires us to collect, store, or use your data for legal purposes.
    4. Legitimate interests: This is a term in data protection law that allows us to process your personal information if we have a legitimate reason to use your data, and only if we do so in ways which do not hurt your interests and rights. For example, we sometimes process your data to pursue our legitimate interests in running our business, including for delivering our Products and/or Services, protecting you from fraud, quality assurance, and marketing purposes. However, we also ensure that our legitimate use of your data does not materially infringe your rights, freedoms, or interests when compared to the processing.
  3. Email and Mobile Device Notifications

    We try to keep email communications to a minimum, and give you the ability to opt-in/opt-out to any marketing communications we may send. For example, we may send you email relating to the Services we offer. You may also elect to receive certain marketing communications in accordance with your preferences, and from which you may opt-out at any time. You can always opt-out of receiving marketing emails or mobile device notifications from Snorble (other than certain required communications, such as messages confirming orders, and notifying you of any privacy policy updates, and the like), by logging into the app and adjusting your user preferences in your account profile, or by sending us an email at support@snorble.com stating your request. If we have sent you a promotional email or mobile device notification, you may send us a return email or mobile device communication asking to be omitted from future optional notices.
  4. Retention

    We will hold your personal information on our systems for as long as is necessary to perform the relevant processing activity for that information, or as long as is set out in any relevant contract you hold with us. The relevant retention period is determined on a case-by-case basis because it depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. For example, we may retain your data for as long as you are a customer of ours so that we may process and complete any orders you may make with us. We may also be required to hold some types of information to fulfill legal purposes. We review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data, such that the data is not personally identifiable.

    We do not store payment card information; rather we utilize payment processors and store only an electronic receipt that sets forth confirming payment details, such as purchase date, the expiration date of the payment card and the payment ID, but not complete payment card information.
  5. Personal Information Requests  
    1. Honoring Your Requests. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, and we will do our best to honor your requests subject to any legal and contractual obligations. Except where an exception or exemption applies, these rights may include the ability to request disclosure of the information we have collected about you, as well as the right to review our data collection practices related to you, the ability to request deletion of your personal information, and the right not to be discriminated against due to your exercise of any of the preceding rights. To ensure that your personal information is accurate and complete, please contact us through the email address below regarding any errors or updates affecting the personal information that we may hold.
    2. Children. At any time, you may review the Child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the Child's information.
    3. How to Request Access to, Correction, or Deletion of Personal Information. You may call us at 516-259-3948, email us at support@snorble.com, or log into your account to request access to, correct, or delete any personal information that we hold about you or your Child. To protect your privacy and security, Snorble may take reasonable steps to verify your identity before granting access to, correcting, or deleting data. Subject to applicable law, we will generally respond to your request for information within 30 days, unless, for reasons beyond our control, a longer response time is necessary, in which case, you will be advised accordingly. Please note that we may retain certain information as required by law or as necessary for our legitimate business purposes.
    4. Your European Privacy Rights and Choices.  If you are located in the European Union, the United Kingdom or another jurisdiction that has adopted laws substantially similar to the General Data Protection Regulation (GDPR), your privacy rights include the following:
      • Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
      • Right of access, correction, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations.  
      • Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
      • Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations.  Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.  
      • Right to data portability. You have the right to data portability of your own personal data by contacting us.
      • Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.
      • Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the GDPR, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
  6. California Disclosures. California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed.  If you are a California resident and want such a list, please send us a written request by email to support@snorble.com with “California Shine The Light Rights” in the subject line.  

    California Do Not Track Disclosure: We do not respond to Do Not Track browser settings. 

    California Consumer Privacy Act (CCPA) Disclosures: Snorble is not a “business” subject to the CCPA.
  7. Links to Other Sites

    Our Services may contain links to other websites for your convenience or information.  These websites may be operated by companies unaffiliated with us, and we are not responsible for the content or privacy practices of those websites.  Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.  
  8. Questions, Comments, or Complaints

    If you have questions or comments about this Privacy Policy, or if you are not completely satisfied with this Privacy Policy or its application by us, we invite you to convey your concerns or suggestions via email to us at contact@snorble.com or by mail to us at

    Snorble, Inc.
    1221 College Park Dr., Suite 116
    Dover, DE 19904

    If you have an applicable disability, you may also contact us at the above email address to request access to this Privacy Policy in an alternative format. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken in order to address your concern or implement the suggestion.
  9. Updates and Changes to this Privacy Policy

    This Privacy Policy is effective as of October 6th, 2022. We may update this Privacy Policy from time to time. If we do, we’ll let you know about any material changes, either by notifying you on the Sites or by sending you an email. Any updates to this Privacy Policy will apply to data already collected and to be collected. Your continued use of the Services after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy.  Please review this Privacy Policy periodically and especially before you provide personal data to us.

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