Privacy Notice

Polaro Customer Privacy Notice

Your privacy is and will always be of utmost importance to us. Our Privacy Notice is designed to provide transparency into our data practices in a format that is easy to read and navigate. Please read the sections below to understand how we collect, use, share, and safeguard your information in order to offer you the most seamless device and music experience imaginable.

Privacy From Day One

Your Polaro device generates device, diagnostic, infotainment system, and AI Music Assist data. To protect your privacy from the moment you start using it, Polaro does not associate the device data generated by your playing with your identity or account by default. As a result, no one but you would have knowledge of your activities, location or a history of where you’ve been. Your in-device experiences are also protected. From features such as voice commands, to surfing the web on your touchscreen, your information is kept private and secure, ensuring the infotainment data collected is not linked to your identity or account.

Polaro devices are equipped with a suite of sensors designed from the ground up to protect your privacy while providing advanced features such as AI Music Assist. To recognize things like note sequences, rhythm patterns, and chord progressions, AI Music Assist data from the sensor suite is processed directly without leaving your device by default. In order for sensor recordings for fleet learning to be shared with Polaro, your consent for Data Sharing is required and can be controlled through the device’s touchscreen at any time. Even if you choose to opt-in, unless we receive the data as a result of a safety event (a device malfunction or significant error) — sensor recordings remain anonymous and are not linked to you or your device.

Use of Creative Commons Media Assets

Polaro acknowledges and respects the intellectual property rights of creators. As part of our commitment to fostering creativity and innovation, we may utilize media assets, including but not limited to videos and images, which were originally published under the Creative Commons License. Specifically, assets used by Polaro may fall under the Creative Commons Attribution 3.0 Unported License (CC BY 3.0). Further details about this license, as well as its full legal code, can be found at https://creativecommons.org/licenses/by/3.0/legalcode. Notwithstanding the aforementioned, all assets, videos, images, audio, and text utilized by Polaro, whether derived from Creative Commons sources or otherwise, remain the proprietary assets of Polaro, Inc. Any modification, reproduction, or use of these assets without the express permission of Polaro, Inc. is strictly prohibited.
CGI and Design Models in Promotional Materials

At Polaro, we strive to provide our customers with a realistic and transparent representation of our products. However, it is important for our users to understand the following regarding our promotional content:

Use of CGI and Design Models: Some of the images, videos, and other visual content (hereinafter referred to as “Promotional Materials”) used in our advertisements, website, and other marketing channels for our product, Polaro, may incorporate computer-generated imagery (CGI) and design models.
Purpose of CGI: The CGI and design models are utilized to showcase the conceptual design, potential features, and functionalities of the Polaro product. These representations are created to provide a visual approximation of what we envision for the final product.
Difference from Final Product: We wish to clarify that these Promotional Materials are artistic renditions and may not perfectly mirror the actual appearance, design, or functionality of the final Polaro product. The final version of the Polaro product may undergo modifications due to design optimization, technological advancements, manufacturing constraints, or other factors.
Informed Decision Making: We encourage our customers to make informed decisions. While we endeavor to make our Promotional Materials as accurate as possible, we advise considering the possibility of variations in the final product when making a purchase decision.
Updates and Changes: Polaro reserves the right to update or change the design and specifications of the Polaro product at any time, without prior notice. We commit to keeping our customers informed about significant changes that may impact their use or perception of the product.
By using our website, engaging with our promotional content, or purchasing our products, you acknowledge and agree to the terms outlined in this disclaimer.

Information We May Collect

We may collect three main types of information related to you or your use of our products and services:

Information from or about you
Information from or about your Polaro device
Information from or about your Polaro products and services

Depending on the Polaro products and services you request, own, or use, not all of these types of information may be applicable to you.

When You Interact With Us Before Purchase

When you visit our website, stores and galleries, attend a Polaro event, perform a test play, contact us with questions or for product information (in person, online, telephone, and email), we may collect a variety of information from or about you, your device, devices, or from third parties. For example, data we collect may include:

Contact Information: Your name, address, region, email, phone number, contact preference
Communications or interactions: Your requests for information, calls, emails, or in person communications, tours, newsletter, Polaro events, and test plays
Network activity information: Your device model, browser type, operating system, region, IP address, pixel tags, cookies

When You Are a Polaro Customer

If you are a Polaro product or service owner, we may also collect other information from or about you, your Polaro device, other product, or from third parties. We may collect such information either through remote access or in person (for example, during a support appointment). Depending on which of our products and services you request or use, not all of these types of information may be applicable to you.

Polaro Account: Customers who purchase certain Polaro products may also create a Polaro Account, which is hosted on our website. You can access your Polaro Account to update the information from or about you in that account at any time. The information contained in your account includes:

The status of your order
Your customer registration information
Warranty and other documentation for your Polaro products
Learning history
Payment method information
Other general information about your Polaro products (for example, device identification number or other product serial numbers, service plan information, or learning package), financing agreements, and similar information.

Information from or about your Polaro device

Device type: Device year, make, model, device identification number, configuration
Device data: Telemetry regarding performance, usage, operation, and health of your device
Diagnostic data: Logs for identifying and troubleshooting unexpected software or connectivity issues, and other debugging log reports
PianoOS system data: Analytics regarding PianoOS usage such as function successfully or unsuccessfully loaded
Polaro mobile app information: Analytics regarding mobile app usage such as function successfully or unsuccessfully loaded
AI Music Assist data: Device equipped sensor suite that provides advanced features such as AI Music Assist
Polaro service and support history: estimate and cost, parts details, and other similar information

There are four categories of data generated by your Polaro device: Device Data, Diagnostic Data, PianoOS Infotainment System Data, and AI Music Assist Data.

Device Data

In order to support your device’s continuous performance, predictive maintenance, and improved functionality and experience, your Polaro collects and processes device data related to the usage, operation, and condition of your device. This information is used to triage and fix potential issues, and continuously improve your device and services to you. To protect your privacy, by default, this device data is either in a form that is not associated with your account or VIN, is stored in an encrypted format that Polaro cannot decrypt, or remains inaccessible unless a specific event is triggered.

Diagnostic Data

Polaro uses diagnostic logs to keep our products and services up to date, troubleshoot or debug problems, and make continuous improvements. We aim to collect the minimum level of diagnostic data necessary to help keep your device or products reliable, secure, and operating normally.

PianoOS System Data

When using your device’s touchscreen, Polaro may collect certain usage analytics that are either stored on the device itself, or if shared with us, is not associated with your account or VIN by default. Usage analytics may include, for example, aggregated counts of the features or apps used, playback and browsing metadata (such as radio listening time and channel), and approximate location for local radio options.

AI Music Assist Data

Polaro devices make use of a sensor suite that provides advanced features such as AI Music Assist. Sensor functionality has been designed from the ground up to protect your privacy. Polaro does not capture continuous recordings or have live-view functionality. By default, advanced music features that rely on the external sensors are processed without ever leaving your device. There are two types of sensor recordings that are eligible to be transmitted from your device to Polaro: Safety Event and Fleet Learning sensor recordings.

How Polaro Utilizes Your Data

We may employ the data we gather to:

Interact with you
Deliver our goods and services
Enhance and develop our offerings

This involves reaching out to you with crucial safety-related information, showcasing products and offers suited to your needs, or addressing your queries and fulfilling your requests for product information, Polaro updates, and other events.

When you reach out to us for information or make a purchase, we may use the collected data for various purposes. Here are some examples of how we may use your personal data to provide the best device and music experience possible.

Reasons for Processing

Interact with you
Respond to your queries and fulfill your requests
Provide you with information on contests, events, and promotions and manage these activities
Share administrative information with you, such as changes to our terms, conditions, and policies
Educate and raise awareness on topics that interest you
Inform you of crucial safety-related information about your device or other products
Conduct research, surveys, and gather your feedback
Deliver our goods and services
Complete your purchase, process your request for product leasing or financing, and ensure your order is installed or delivered to you
Process your payment for a product or service
Assist and provide related customer support
Monitor your Polaro product’s performance and provide related services, including over-the-air updates
Understand, address, and resolve issues or concerns with products and services
Enhance and develop our goods and services
Conduct research, develop and promote new products and services, and improve or modify our existing services
Analyze and improve the safety and security of our products and services
For business purposes such as data analytics, audits, fraud monitoring and prevention, business planning, determining effectiveness of campaigns, reporting, and forecasting
Other circumstances
Fulfill contractual obligations with third parties, agents, and affiliates
Analyze, reconstruct, investigate or otherwise determine the cause of a device-related incident
Comply with legal obligations, law enforcement, and other government requests
Establish, exercise, or defend legal claims
As otherwise permitted or directed by you

Polaro retains personal data only as long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Notice, in our service-specific notices, or as required by law. The criteria for determining data retention may include consideration of its use, our relationship with you, whether there is an existing contract for services, whether you have provided your consent, or if there is a legal requirement to retain certain data. We carefully examine whether it is necessary to retain the personal data collected and work to ensure that the data is retained for the shortest period possible.

When we process personal data about you, we do so with your consent and/or as required to provide the products or services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems, products and our customers, or fulfill other legitimate interests of Polaro. We do not share information that personally identifies you with third parties for their marketing purposes unless you opt-in to that sharing. For more details regarding which legal justification Polaro relies on for each data processing activity, see "Purpose and Legal Basis" in the above section "Information We May Collect".

We may also use and disclose information about you if we believe in good faith that that the law requires it for purposes of security, fulfilling our legal obligations (such subpoenas or court orders), law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also share information about you, where there are legal grounds to do so, if we determine that disclosure is reasonably necessary to enforce our Terms of Use or protect our operations or customers. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, change of control, or sale we may transfer any personal data we collect to the relevant third party.

Collection and Use of Non-Personal Data Except as described here, Polaro may also collect, use, and share information that does not, on its own, personally identify you. Such information may be used for any purpose, including for example, for operational or research purposes, for industry analysis, to improve or modify our products and services, to better tailor our products and services to your needs, and where legally required.

Sharing Your Information We may share information with:

Our service providers, business partners, and affiliates
Third parties you authorize
Other third parties as required by law

We limit how, and with whom, we share your personal data. Examples of when we may share your information include, payment processing, order fulfillment, product installation, customer service, marketing, financing, service or repair, and other similar services.

We do not sell your personal data to anyone for any purpose, period. The information below illustrates who Polaro may share your personal data with depending on your interactions with us or purchases you make.

Our service providers, business partners, and affiliates Categories of Recipients Description Reason for Sharing Affiliates and subsidiaries Companies that are owned or controlled by Polaro, or where we have a substantial ownership interest To assist, operate, enhance, and fulfill services on our behalf based on our legitimate interests to outsource certain operations Service providers and business partners Companies we’ve hired to provide services like customer support, product financing, repair estimate providers, infrastructure, and other professional service providers To assist, operate, and fulfill services on our behalf based on our legitimate interests to outsource certain operations Payment processors Companies we contract with to securely process your payment details To enable payment processing based on our contract with you, and fraud prevention in line with our legitimate interests

Other third parties as required by law or other circumstances Categories of Recipients Description Reason for Sharing Law enforcement and government authorities Disclosure of information as required by law, or when otherwise appropriate To comply with applicable laws based on our legal obligation or legitimate interests Government-offered incentive or credit programs Disclosure of information as required by the program such as device id To comply with the participation terms of the offered program based on our legitimate interests

The personal data we collect may be shared between Polaro and our subsidiaries, affiliates (companies that are owned or controlled by Polaro, or where we have a substantial ownership interest), third party software and hardware providers, channel partners, suppliers, and others when necessary to perform services on our or on your behalf. For example, companies we've hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our privacy and data protection requirements and are not allowed to use personal data they receive from us for any other purpose.

In addition, we may share information with:

Third party service providers and channel partners to provide services such as website hosting, data analysis and storage, payment processing, order fulfillment and product installation, wireless connectivity to Polaro products, information technology and related infrastructure, customer service, product design, product diagnostics, maintenance or related services, email delivery, credit card processing, auditing, marketing, voice command processing, and other similar services.
Subsidiaries and affiliates to develop new and improve existing products and services, perform data analysis, and reporting.
Other third party business partners to the extent that they are involved in the purchase, lease, or service of your Polaro products. We share limited information from or about you or your Polaro products to allow you to take advantage of those services if you elect to utilize them, with such partners as finance institutions, leasing, registration, permitting authorities and insurance companies.
Third parties you authorize, such as:
- With third party service centers or providers, if you choose to utilize them. Note that some information about you is stored on certain Polaro products and may be accessible directly to the third party service centers or providers that you choose to utilize to diagnose or service your Polaro product.
- Third-party sponsors of contests and similar promotions, if you elect to participate; With your social media account provider, if you connect your Polaro Account and your social media account. If you do so, you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by the social media account provider’s privacy notice.

Third parties when required by law or other circumstances, such as:

To comply with a legal obligation (such as subpoenas or other court orders); in response to a lawful request by governmental authorities conducting an investigation, including to comply with law enforcement requirements and regulator inquiries; to verify or enforce our policies and procedures; to respond to an emergency; to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable; or to protect the rights, property, safety, or security of our products and services, Polaro, third parties, visitors, or the public, as determined by us in our sole discretion.
With your employer or other fleet operator or the owner of the Polaro product, if you do not directly own it, as authorized by local law.
With a third party in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any insolvency or similar proceedings).

Choice and Transparency

We enable you to obtain access and control the data that we collect, use, and share. Through device permissions, in-app settings, communication preferences, your Polaro Account, and in-vehicle data sharing controls — you are in the driver’s seat, even when it comes to your data.

Rights and Choices

Polaro provides you with the ability to access, correct, and delete your personal data. You also have the right to object to certain processing of your personal data. Please note that some requests may impact your ability to use our products and services.

Security

We use administrative, technical, and physical safeguards designed to safeguard the information that we collect. However, no information system can be 100% secure. This means that we cannot guarantee the absolute security of your personal data. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.

California Privacy Statement

Residents of California have the right to be informed about, access, and request deletion of their personal data under the California Consumer Privacy Act. They also have the right to refuse the sale of their personal data by a business and the right to not be discriminated against for exercising their privacy rights. Polaro does not sell your personal data to any entity for any reason, and does not discriminate in response to privacy rights requests.

Polaro provides information about our data practices in this Privacy Notice. This includes details about the personal data we collect, where it comes from, and why we use it, as well as whether Polaro discloses that personal data and if so, the types of third parties to whom it is disclosed. California residents who have purchased a Polaro product or service can exercise their rights directly (or through an authorized agent) by logging into their Polaro Account and making a data privacy request. If you are a California resident without a Polaro Account and you wish to exercise your privacy rights, requests can also be made by:

Emailing us at privacy@polaro.com Writing to us at Polaro Inc, Attn: Polaro Legal – Privacy, 8 THE GRN STE E DOVER, DE 19901, United States.

If you don't have a Polaro account, Polaro may ask you for information which we deem necessary to verify your identity for security and to prevent fraud. This information may include your name, contact details, and information related to your transaction or relationship with Polaro, but the specific information requested may vary depending on the circumstances of your request for your security and to protect privacy rights. If you request deletion of your personal data, please note, that we will both render certain personal data about you permanently unrecoverable and also de-identify certain personal data.

Protection of Personal Data Polaro employs administrative, technical, and physical safeguards to protect your personal data, considering the nature of the data and the threats posed. Polaro has implemented a range of safety and security features to consistently protect your information. For instance, your Polaro Account includes owners resources, guides and important documents, so we offer multi-factor authentication to protect your account. Each Polaro vehicle also includes a feature called Pin to Play allowing you to set a secure four-digit verification code that must be entered before the Polaro is used. Additionally, if you sell or transfer your device to another person, Polaro makes it easy to perform a factory reset and remove your personal data before handing your device to a new owner (Settings > Device > Factory Reset).

We also implement other suitable technical and organizational measures to help safeguard and secure your personal data. Regrettably, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure or compromised, please immediately notify us using the contact information below.

This Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which we may link to on this Notice. The inclusion of such a link does not imply endorsement of the linked site or service by us or by our affiliates, nor does it imply an affiliation with the third party. Additionally, we are not responsible for the collection, use, or disclosure policies and practices (including the data security practices) of other organizations, such as any other app developer, app provider, social media platform provider, operating system provider, or wireless service provider, including any information you disclose to other organizations through or in connection with our software applications or social media pages. Furthermore, our products and services are not directed to individuals under the age of sixteen, and we request that such individuals not provide any information to Polaro.

Google Analytics Advertising Features
Our website utilizes Google Analytics Advertising Features to enhance our marketing efforts and improve your user experience. These features include: Remarketing with Google Analytics, Google Display Network, Impression Reporting, Google Analytics Demographics and Interest Reporting, Integrated services for advertising purposes which involve the collection of data via advertising cookies and identifiers.
Data Collection and Use: By enabling these Advertising Features, we allow Google Analytics to gather data about our site traffic through Google advertising cookies and identifiers, in addition to the standard data collection methods. As the user of these features, we are the sole controller of the data under applicable data protection laws.
User Privacy and Consent. In accordance with Google's policies, we: Do not merge personally identifiable information with data gathered from Google's advertising products or features without obtaining explicit, affirmative consent from users. Avoid any attempt to disaggregate data that Google provides in aggregate. Adhere to the European Union and Japan User Consent Policies, ensuring necessary user consents are obtained where required.
Visitor Choices. You, as a visitor, have options regarding the data collection: Opt-out of Google Analytics Advertising Features through Ads Settings, Ad Settings for mobile apps, or any other available means (e.g., the NAI's consumer opt-out). Visit Google Analytics' opt-outs for the web for additional opt-out options. https://tools.google.com/dlpage/gaoptout/
Interest-Based Advertising. If we enable interest-based advertising, including Remarketing, we comply with Google's related policies, such as the Google Ads Policy for Personalized advertising. We do not use Google Analytics to collect sensitive information about our visitors for interest-based advertising purposes.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Notice, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of our websites or sending you an email notification).