Robotics: Smart Machine - Junior Privacy Policy

This is the Thames & Kosmos privacy policy (“Privacy Policy"), for the Thames & Kosmos - Junior iOS and Android App, hereinafter referred to as the “App”. All statements made within this Privacy Policy are in addition to the Privacy Policy for Thames & Kosmos, found at

  1. Introduction
    The App does not require an account of any kind. All data is processed and stored locally on the user's mobile device.

    Your personal information will only be processed when you contact Thames & Kosmos by email, phone or in another way for processing your request.

  1. Responsible Party

Thames & Kosmos, LLC.
89 Ship St.
Providence, RI 02903
Phone: 401-459-6787
Toll-free: 800-587-2872
Fax: 401-459-6775

  1. Details on the processing of data in our App

3.1 No exchange of personal data by the app
The App is configured so that it does not send any data to any Thames & Kosmos servers. This also includes metadata, i.e., IP-addresses, or data that may arise in the context of server log files.

All processing operations take place exclusively and locally on your device. Deletion of the App leads to the deletion of all data processing or previously processed within the user’s App.

3.2 Compliance with the Children’s Online Privacy Protection Act

The App takes precautions to protect our user’s privacy and ensure safe use by persons 12 years of age or younger. No sign-up is required to use the App. The App will not send any recorded data to Thames & Kosmos or any other entity associated with Thames & Kosmos.

The App complies with the Children’s Online Privacy Protection Act (“COPPA”). Thames & Kosmos does not knowingly collect personal information from children under the age of 13 in violation of COPPA, and if in the event that a user identifies himself or herself as a child of the age of 12 or younger through a support request, the App will not collect, store or use, and will delete in a secure manner, any personal information of such user, nor will Thames & Kosmos, or any other entity associated with Thames & Kosmos.

3.3 Use of Cookies
Our App does not use cookies or comparable technologies.

3.4 Sharing of information with third parties
Thames & Kosmos does not share personally identifiable information with other companies. Thames & Kosmos does not sell, trade, or otherwise transfer to outside parties the App user’s personally identifiable information.

3.5 Links to Third Parties
The App does not show links or advertised content associated with entities not related to Thames & Kosmos.

3.6 Access authorizations on your device
For the full functionality of the App it is necessary that the user grant access rights. While using the App, Thames & Kosmos guarantees that even if access rights are granted, no data is exchanged with associated systems.

The user retains all rights to decline or or consent to provided permissions while using the App. The granting of access rights allows the App to access certain features or data on users’ devices. Thames & Kosmos guarantees that this associated data will only be processed locally on your device through the App.

The user can revoke the granted access rights at any time, using the app permission settings functionality of the device containing the App. Depending on the user’s operating system, the rights management can be found in the settings under apps or authorizations. Thames & Kosmos does not guarantee the functionality of a user’s device or associated privacy management settings, and defers to manufacturer guidelines. You can find more detailed information on this in the operating instructions for your device or operating system.

Access to storage
The App needs access to a device’s storage to save data, e.g., images of files.

Access to and data transfer via Bluetooth
The App requires access to the Bluetooth interface in a user’s device. This is necessary to communicate data with the hardware, i.e., Junior robot.

Note on Bluetooth access in Android-based systems
When using Bluetooth on devices with the Android operating system, geolocation rights are required. This is not specified by the App, but by the operating system. The App does not perform any positioning at this point and does not process any geolocation data.

  1. Further information on processing personal data

    Processing of personal information when you contact us
    When a user sends Thames & Kosmos a message, e.g., by email, the information you provide is collected, including the message and any contact information included for the purpose of processing the request. Thames & Kosmos uses and retains such information to respond to requests, facilitate support, and to optimize support services. A representative of Thames & Kosmos will only respond once to messages from children under age 13, after which those associated messages are deleted alongside any personally identifiable information contained in them.
  2. Questions or requests on behalf this privacy policy
    If any user of the App has any questions about this Privacy Policy, please contact us. Thames & Kosmos is happy to answer your questions and provide the information you require.

Send an email to us at:

Or contact Us via postal mail at:
Thames & Kosmos
89 Ship St.
Providence, RI 02903

The following clauses (6., 7.) are specific intranational & international rights granted to specific users depending upon their location and citizenship. Thames & Kosmos guarantees the applicability of these rights to users who qualify, and will work to ensure the following guidelines are met for users of the App meeting the known criteria.

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  1. California Residents Privacy Rights (CCPA)
    As a California resident, you have certain rights regarding your personal information. These rights include:

Right to Know and Access Information:
You may request access to the personal information we maintain about you in the ordinary course of business. This may include what personal information we collect, use, or disclose about you. We may not fulfill some or all of your requests to access as permitted by applicable law.

Right to Deletion:
You may request that we delete your personal information. Depending on the scope of your request, we may refrain from granting your request, as permitted by applicable law. For example, we may be legally required to retain your information in our business records.

Right to Opt Out of the Sale of Your Personal Information:
California law considers certain uses of personal information, such as sharing your personal information with a third party in order to serve ads to you to be a “sale.” We do not sell personal information of children or students. However we do engage in some marketing behavior with data from adults that would be considered a “sale” under California law. You may request to opt-out of that use of your information by using the methods provided below or via this form.

In order to prevent unauthorized access to your information, we are required by law to verify your identity before we may address your request.

If You are a California resident and request information about how to exercise Your third party disclosure choices, You must send a request to the following address with a preference on how Our response to Your request should be sent (email or postal mail).

Send an email to us at:

Or contact Us via postal mail at:
Thames & Kosmos
89 Ship St.
Providence, RI 02903

All requests sent via postal mail must be labeled "Your California Privacy Rights" on the envelope or postcard and clearly stated on the actual request. For all requests, please include Your name, street address, city, state, and zip code. (Your street address is optional if You wish to receive a response to Your request via email. Please include Your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, notices that are illegible or do not have complete information.

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  1. EU Citizens GDPR Privacy (European Data Protection Regulation)

7.1 Legal basis for the processing of personal data
The legal bases for the processing of personal data are exceptional circumstances that allow the processing of personal data. The essential legal bases are shown in particular in Art. 6 GDPR. The legal bases according to which we process personal data are described in the individual processing operations in this data protection declaration.

Consent given (Art. 6 Para. 1 lit. a GDPR)
Consent is one of these legal bases and requires that the consenting person gives it in an informed manner and on a voluntary basis. Consent on the basis of Art. 6 Para. 1 lit a GDPR can be revoked at any time without giving reasons.

Contract-related data processing (Art. 6 Para. 1 lit. b GDPR)
The processing of personal data for the initiation or implementation of contracts is also a legal basis and is defined in Art. 6 Para. 1 lit. b GDPR.

Legal obligation (Art. 6 Para. 1 lit. c GDPR)
The exception of data processing due to a legal obligation can be found in Article 6 Para. 1 lit. c GDPR, for example we are obliged to comply with certain retention periods under commercial and tax law.

Legitimate interests (Art. 6 Para. 1 lit.f GDPR)
The processing of personal data on the basis of a weighing of interests in accordance with Art. 6 Para. 1 lit. f GDPR.

7.2 Your rights under the General Data Protection Regulation
Every natural person has certain rights, these are defined in Articles 15 to 21 and 77 of the GDPR. In principle, you have the following rights that you can claim from us.

Right to revoke a given consent according to Art. 7 Para. 3 GDPR
You can revoke your consent to us at any time without giving reasons with effect for the future.

Right to information according to Art. 15 GDPR (restrictions according to § 34 BDSG possible)
You have the right to request information about the data processed by you and the purposes of processing at any time.

Right to correction according to Art. 16 GDPR
If you discover that we are processing incorrect or incomplete personal data, you have the right to have it corrected.

Right to deletion according to Art. 17 GDPR (restrictions according to § 35 BDSG possible)
You have the right at any time to request the deletion of your personal data that we are processing about you. If complete deletion is not possible, for example because we must meet statutory retention requirements or we can assert legitimate interests for other reasons, we will restrict your data until these reasons no longer apply.

Right to restriction of processing according to Art. 18 GDPR
You have the right to request that the processing of your personal data be restricted. You can contact us at any time at the address given in the legal notice. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we usually need time to check this. For the duration of the test, you have the right to request that the processing of your personal data be restricted.
  • If the processing of your personal data happened / happens unlawfully, you can request the restriction of the data processing instead of the deletion.
  • If we no longer need your personal data, but you need them to exercise, defend or assert legal claims, you have the right to request that the processing of your personal data be restricted instead of being deleted.
  • If you have lodged an objection in accordance with Art. 21 Paragraph 1 GDPR, your interests and ours must be weighed up. If it is not yet clear whose interests prevail, you have the right to request that the processing of your personal data be restricted.

If you have restricted the processing of your personal data, these data - apart from their storage - may only be allowed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest processed by the European Union or a member state.

Right to data portability according to Art. 20 GDPR
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another responsible party, this will only be done if it is technically feasible.

Right to object to certain processing operations and direct mail in accordance with Art. 21 GDPR
If the data processing is based on Art. 6 Para. 1 lit. e or f GDPR, you have the right at any time to object to the processing of your personal data for reasons that arise from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this data protection declaration. If you object, we will no longer process your personal data concerned, unless we can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims ( Objection according to Art. 21 Paragraph 1 GDPR).
If your personal data are processed in order to operate direct mail, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising. If you object, your personal data will no longer be used for direct marketing purposes (objection according to Art. 21 Paragraph 2 GDPR).

Right of appeal to a supervisory authority according to Art. 77 GDPR
In the event of violations of the GDPR, the data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged violation. The right of appeal exists without prejudice to other administrative or judicial remedies.

Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

  1. Last Update

December 5, 2023