Last Updated: March  2026

1. Welcome

Owlet Baby Care, Inc. (“Owlet,” “we,” “us,” or “our”) is committed to protecting your privacy. At Owlet, our mission is to empower parents with technology that helps them care for their children confidently and safely. We know that trust is essential to that mission. Protecting your family’s privacy is a vital part of building and maintaining that trust.

This Global Privacy Policy explains how we collect, use, share, and protect personal information when you use our websites, mobile applications, connected devices, customer support services, and other products and services (collectively, the “Services”).

This Privacy Policy applies only to the activities of Owlet and does not extend to companies or individuals that we do not own, control, or manage. We are not responsible for the privacy practices, policies, or content of third parties, including any information, products, or services they may provide or that may be accessible through our Services. 

When we engage trusted service providers to process personal information on our behalf, we require them to protect that information and use it only for the purposes we specify, in accordance with applicable data protection laws. Where required by law, we remain responsible for the processing carried out by these providers.

2. How to Use This Notice

This Privacy Policy applies to all users worldwide. However, because privacy laws vary by location, we have provided additional details for specific regions. To ensure you have all the necessary information for where you live, please review Section 15. Regional and Local Privacy Disclosures for information that may apply to you.

3. Information We Collect

We may collect the following categories of information:

Information You Provide

We collect information that you provide to us when you interact with our Services. This includes:

Purchases and Account Registration
When you purchase our Services, or create an account, we may collect personal information that can reasonably identify you, such as your name, email address, mailing address, phone number, payment information, and other contact details.

Product and Service Use
When you use our Services, we may collect information about you and your baby. This may include:

• Data you provide, such as photos, stories, or other content you upload

• Your child’s first name, health information, and demographic information (for example, gender or age)

• Device and sensor data, such as heart rate, oxygen levels, sleep and wake patterns, movement, and environmental information like room temperature or humidity

Communication With Us
When you interact with us through email, chat, surveys, customer support, or profile updates, we may collect information such as your name, email address, and phone number.

Promotions, Contests, and Surveys
If you participate in sweepstakes, contests, promotions, or surveys, we may collect information including your name, email address, phone number, shipping address, date of birth, and social media usernames.

Information Collected Automatically

When you interact with our Services, we may automatically collect information about your device and usage through cookies, pixels, tags, and similar technologies (collectively, "Cookies"). This helps us understand how you use our websites and App so we can improve your experience. We may also allow third-party partners (such as Google) to place Cookies on our digital properties to collect data about your online activities over time and across different websites. These partners use this information to provide you with relevant advertisements tailored to your interests. For detailed information on the specific technologies we use and how to manage your preferences, please review our Cookie Policy.

Examples include:

• Device identifiers

• App usage data

• IP address

• Log files

• Cookies and similar technologies

Information from Third Parties

We may receive personal information about you from third parties to help us operate our business and provide our Services. These third parties may include service providers, distributors and retail partners, affiliated companies, marketing and analytics partners, payment processors, and technology providers that support our products and applications.

We may also receive information from platforms or services that you choose to connect to your account, such as mobile operating systems, app stores, or social media services. In some cases, we may obtain information from publicly available sources or from business partners in connection with events, promotions, or joint offerings.

4. How We Use The Information We Collect

We use the information we collect to provide, operate, and improve our Services, ensure their safety and security, and create a personalized experience for you and your family. For example, we may use your information to deliver the Services you request, manage your account, process purchases and subscriptions, respond to inquiries, provide support, and communicate important updates or offers. We also use information from your devices, such as wellness and sensor data, to help you understand your baby’s trends and activity, personalize your experience, and improve the accuracy and functionality of our Services.

In addition, we may use aggregated, de-identified, or anonymized data to conduct research and analytics, enhance product development, identify trends, and support innovation to the extent permitted under applicable laws. This may include using de-identified data to develop and train artificial intelligence and machine learning models, explore new features, and collaborate with trusted research partners to advance infant wellness and related insights. All such research is conducted in ways that do not identify you personally unless you have provided explicit consent.

We may also use your information to communicate with you about our Services, including sending personalized updates, offers, promotions, or recommendations where permitted by law. To help deliver these communications, we may work with trusted advertising or marketing partners and use cookies or similar technologies to understand how you interact with our websites, communications, and online services. You can manage your marketing preferences, including opting out of interest-based advertising, at any time.

Finally, we use personal information to protect the security of our Services, comply with legal obligations, carry out business operations, detect and prevent fraud or harmful activity, and safeguard the rights, privacy, and property of Owlet, our users, and others. This includes enforcing our agreements, responding to legal requests, and auditing internal processes to ensure compliance with applicable laws and policies.

5. How We Share Information

We may share your personal information with third parties in the circumstances described below. We do not sell your personal information, and we only share it when necessary to operate our business, provide our Services, comply with the law, or protect our users and company.

Service Providers

We work with trusted third-party companies that perform services on our behalf, such as hosting and operating our platforms, processing payments, fulfilling orders, delivering communications, providing customer support, maintaining databases, and performing analytics. These providers may access personal information only as needed to perform their services for us and are required to protect it and use it solely for authorized purposes.

Legal Requirements and Protection of Rights

We may disclose personal information when required to do so by law or when we believe such disclosure is necessary to comply with a legal obligation or lawful process, including a court order, subpoena, warrant, or regulatory request. We may also disclose personal information to respond to requests from government or law enforcement authorities, to enforce our terms, policies, or agreements, to detect, investigate, or prevent fraud, security incidents, or other unlawful activity, or to protect the rights, property, safety, and security of our Company, our users, or others. Where permitted by law, we may make such disclosures without prior notice.

Promotions and Contests

If you choose to participate in sweepstakes, contests, or other promotions we offer, we may share your information with third parties involved in administering the promotion, including sponsors, prize providers, or fulfillment partners. These third parties may use your information to select winners, deliver prizes, comply with legal requirements, or carry out the promotion in accordance with its official rules. Participation is voluntary, and promotions may have additional terms governing the use of your information.

Business Transfers

If we undergo a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets, personal information may be disclosed to prospective or actual buyers and transferred as part of that transaction. We will take steps to ensure that any successor entity continues to protect your information in a manner consistent with this Privacy Policy.

Employment and Regulatory Reporting

If you apply for employment or otherwise provide information in connection with workforce-related activities, we may collect voluntary demographic information (such as gender or ethnicity) to comply with applicable laws and regulations. Where required, we may share this information with government agencies or regulators for reporting, compliance, or legal defense purposes.

Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. This information may be used for research, analytics, product improvement, industry insights, or other lawful business purposes without restriction to the extent permitted under applicable laws.

Text Messaging Data

Text messaging originator opt-in data and consent will not be shared with third parties, except as necessary to provide the messaging services you have requested (for example, through telecommunications providers).

6. Cookies and Tracking Technologies

Our page may utilize cookies when you visit our Website. Cookies are small text files transferred to your device to improve your overall experience, remember your preferences, and help us analyze site usage. They allow us to authenticate your logins, recall regional or language settings, and tailor content to your specific device.

Types of Cookies

• Session cookies: Temporary files that are erased the moment you close your browser.

• Persistent cookies: Stored for a longer duration to remember you on future visits.

• First party cookies: Set directly by the website you are visiting.

• Third party cookies: Set by vetted external partners for specific services.

Categories of Cookies on Our Site

• Essential: Required for basic navigation and site functionality. These cannot be disabled.

• Analytical: Track website usage statistics to help us improve our services.

• Functional: Provide enhanced website features and personalization.

• Social Media: Allow you to share content with your networks and build interest profiles.

• Targeting or Advertising: Serve relevant advertisements based on your browsing habits.

Managing Your Preferences

Essential cookies are always active to ensure the site works properly. You can manage your preferences for all other cookie types upon your first visit and update them anytime using the cookie icon on your screen. You can also block or restrict cookies directly through your specific web browser settings, though doing so may limit your ability to use certain website features.

Opting Out of Targeted Ads

You can opt out of Google Analytics tracking and interest based advertising through platforms like the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI). If you choose to opt out, you will still see advertisements online, but they will no longer be personalized to your interests.

Please refer to our complete cookie policy for more information, including direct links for browser management and external partner opt out pages.

We use cookies and similar technologies to operate our Services, analyze usage, and personalize content. You can manage cookies through your browser settings or our cookie preference tools. Some regions require opt-in consent for certain cookies.

7. International Transfers

Owlet is a global company and your personal information may be transferred to, stored, and processed in countries other than your own. This includes transfers to our offices and servers in the United States and other locations where our service providers operate. Please be aware that data protection laws in these countries may differ from those in your place of residence.

When we transfer personal information across borders, we implement appropriate safeguards to ensure your data remains protected in accordance with this Privacy Policy and applicable law. These safeguards may include: (i) Standard Contractual Clauses (SCCs) approved by the European Commission under GDPR Article 46(2)(c); (ii) the International Data Transfer Agreement (IDTA) or UK Addendum approved by the UK Information Commissioner’s Office for transfers from the United Kingdom; (iii) adequacy decisions issued by the European Commission or the UK Secretary of State recognizing a country as providing an adequate level of protection; or (iv) your explicit consent where required and no other transfer mechanism is available. You may request more information about the specific protections applied to your data transfers by contacting us using the information in Section 13. Contact Us of this Policy.

8. Security and Data Retention

We take the privacy and security of your information seriously and have implemented physical, technical, organizational, and administrative measures to help protect it. These measures are designed to safeguard your personal information, including data from your Owlet devices, accounts, and interactions with our Services. While we work hard to protect your data, no system is completely secure, and we cannot guarantee that your information will never be accessed, disclosed, altered, or destroyed in ways that violate the law or our policies.

We retain information for as long as necessary to provide our Services, fulfill the purposes described in this Privacy Policy, or comply with legal obligations, such as accounting, tax, or regulatory requirements. When personal information is no longer needed, we take steps to securely delete, de-identify, or aggregate it, unless retaining it longer is permitted or required by law.

9. General Audience Websites

The Websites are general audience Websites and not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Websites. We do not knowingly collect personal information from children under 13 on our Websites.  If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. 

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

10. Owlet Account Deletion

If you use an Owlet mobile application, you can request deletion of your account in either of the following ways:

• Select the “Delete Account” option within the app settings, or

• Follow the instructions set out in Section 12. How to Exercise Your Rights of this Policy.

When your account is deleted, your User ID will be removed from our active account systems, and you will no longer be able to access your account or the information associated with it. If you choose to create a new account in the future, you may do so using any email address, but information associated with your previous account will not be available.

For your security, only you or a person legally authorized to act on your behalf may request deletion of your account. We may retain certain information as required or permitted by law, including for legal, security, or operational purposes.

11. Other Rights You May Have Under HIPAA

Owlet may enter into relationships with a number of institutions or health care providers, such as clinicians, researchers, clinics, or others, for whom Owlet will act as a “business associate” under the federal Privacy and Security Rules issued under the Health Information Portability and Accountability Act (“HIPAA”). 

As a business associate, Owlet will be processing and transmitting data on behalf of these institutions or other providers. Owlet does not create or maintain an electronic medical record or designated record set for the institution or provider, or on your behalf. If your child is a patient prescribed our device for remote patient monitoring at one of these institutions or other providers, or are participating in a research study conducted by one of these organizations that uses an Owlet device, Owlet may have additional obligations to the institution or provider under HIPAA and Owlet’s business associate contract with the institution or provider. 

These obligations might affect the information about you that the institution or provider receives from Owlet. In some cases, these business associate relationships will affect information in your Owlet account. Because Owlet does not store protected health information in a designated record set (as defined by HIPAA), Owlet will redirect all individual HIPAA privacy requests for access, amendment, or correction to the covered entity or business associate that maintains your designated record set. Some of the Services Owlet provides to you through the mobile applications are covered by HIPAA and are subject to Owlet’s HIPAA Policy. This means that if we are providing HIPAA-covered services, we will not use your protected health information for marketing, sale, licensing, or other prohibited uses, without your express authorization. Other non-HIPAA-Covered Services that Owlet provides to you through the mobile applications are provided on your behalf and are subject to our Privacy Policy and Owlet’s Terms and Conditions. 

We may request that you sign a HIPAA Authorization to continue using our mobile applications after remote patient monitoring has ended in order to provide Services directly on your behalf. If you are a patient of one of these institutions or providers and experience any service disruptions with our mobile applications, interoperability, or a health, safety, or security complaint, please contact Owlet Customer Service at our dedicated BabySat number 1 877-420-0734. For any customer service complaints about  your remote patient monitoring platform, please contact your remote patient monitoring contact or health care provider directly. If you are experiencing a medical emergency, please contact 911.

12. How to Exercise Your Rights

To exercise your rights listed within this Policy,  including requests made on behalf of your child, please submit a request using one of the following methods:

• Email us at [email protected]

• Where available, submit a request via our Privacy Request Form found on the Privacy Request tab of our Website.

For your protection, we must verify your identity before fulfilling most requests. We may ask you to provide information such as your name, email address, account id, or other details necessary for us to confirm you are the person or an authorized representative related to the personal information. If you are using an authorized agent, we will require written proof of their permission to act on your behalf. We will only use the information provided in your request to verify your identity or authority.

Please note that we may be limited in our ability to respond if we cannot verify your identity or if legal exceptions apply. For more information on opting out of the sharing of your data for targeted advertising, please contact us using the information described in Section 13. Contact Us of this Policy.

13. Contact Us

For privacy questions or complaints:

Owlet Baby Care, Inc.
2940 W. Maple Loop Dr.
Suite 203
Lehi, Utah 84048
Email: [email protected]

EU Representative: 

Osano International Compliance Services Limited
ATTN: SPZT
25 North Wall Quay
Dublin 1, D01 H104
Ireland

UK Representative: 

Osano UK Compliance LTD
ATTN: SPZT
42–46 Fountain Street
Belfast, Antrim
BT1 5EF
United Kingdom

14. Data Protection Officer

For users located in the European Economic Area (EEA), the United Kingdom (UK), Switzerland, and any other jurisdiction that requires designation of a Data Protection Officer (DPO), Owlet has appointed a DPO pursuant to Article 37(1)(c) of the GDPR. This designation is required given that Owlet processes special category health. The DPO is responsible for advising on and overseeing Owlet’s compliance with applicable data protection law and serves as the primary point of contact for data subjects and supervisory authorities.

The DPO may be contacted at: [email protected] (subject line: “DPO Inquiry”), or in writing to: Owlet Baby Care, Inc., 2940 W. Maple Loop Dr., Suite 203, Lehi, Utah 84048, Attn: Data Protection Officer.

15. Regional and Local Privacy Disclosures

15.1 United States

This section supplements the rest of this Privacy Policy and applies to residents of U.S. states that provide specific privacy rights, including California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, and other states with similar laws.

These laws grant residents certain rights regarding personal information that identifies, relates to, describes, or could reasonably be linked to an individual or household.

Categories of personal information

Information about the categories of personal information we collect, the sources of that information, the purposes for which we use it, and the categories of third parties with whom we share it is described in the relevant sections of this Privacy Policy above.

We collect personal information directly from you, automatically from your use of our Services, and from third parties that support our business operations.

Your privacy rights

Depending on your state of residence, you may have the following rights, subject to legal limitations and exceptions:

Right to know / access

You may request confirmation of whether we process your personal information and request access to that information, including:

• The categories of personal information we collect

• The sources from which the information was collected

• The purposes for which the information is used

• The categories of third parties with whom it is shared

• The specific pieces of personal information we maintain about you

Where required by law, we will provide this information for a defined look-back period (for example, the prior 12 months in California).

Right to data portability

You may request a copy of certain personal information in a portable and, to the extent technically feasible, readily usable format.

Right to deletion

You may request deletion of personal information we have collected from you, subject to exceptions permitted by law, including where the information is necessary to:

• Provide requested products or services

• Complete transactions

• Detect security incidents or prevent fraud

• Comply with legal obligations

• Exercise or defend legal claims

• Maintain internal operations

• Protect safety or integrity

• Conduct research permitted by law

If deletion is granted, we will also direct applicable service providers to delete the information where required.

Right to correction

You may request correction of inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes of processing.

Right to opt out of certain processing

Residents of some states may opt out of certain uses of personal information, including:

• Sale of personal information

• Sharing of personal information for cross-context behavioral advertising

• Targeted advertising

• Profiling in furtherance of decisions that produce legal or similarly significant effects

We do not sell personal information for monetary compensation. However, certain disclosures of personal information to advertising or analytics partners may be considered a “sale,” “sharing,” or “targeted advertising” under applicable state privacy laws, depending on how those laws define such terms. Where required by law, we provide individuals with the right to opt out of these disclosures.

You may exercise opt-out rights by:

• Using available cookie or privacy preference controls on our websites

• Adjusting device or browser settings

• Contacting us using the information below

Where supported, we also honor legally recognized browser-based opt-out signals, such as Global Privacy Control (GPC), for applicable activities.

Right to limit use of sensitive personal information (California)

California residents have the right to request limits on the use and disclosure of sensitive personal information where such use goes beyond what is necessary to provide requested services.

Owlet uses sensitive personal information only as permitted by law and primarily to provide and improve the Services.

Right to non-discrimination

We will not discriminate against you for exercising your privacy rights. Unless permitted by law, we will not:

• Deny goods or services

• Charge different prices or rates

• Provide a different level or quality of service

• Suggest that you will receive different treatment

Right to appeal (certain states)

Residents of Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Virginia, and other applicable states may appeal a decision we make regarding a privacy request. Instructions for submitting an appeal will be provided if your request is denied.

How to exercise your rights

To exercise any of the rights described above, please refer to Section 12. How to Exercise Your Rights of this Privacy Policy, which sets out how to submit requests, the identity-verification process, authorized-agent procedures, and applicable response timeframes.

California-specific disclosures

“Sale” and “sharing” of personal information

In the preceding 12 months, we have not sold personal information for monetary compensation. We may share personal information with service providers, analytics providers, and advertising partners for business purposes, which may be considered “sharing” under California law.

We do not knowingly sell or share the personal information of individuals under 16 years of age for cross-context behavioral advertising.

15.2 Canada

If you reside in Canada, this section applies to you and supplements the rest of this Privacy Policy. Owlet handles personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

Consent

We collect, use, and disclose personal information with your knowledge and consent, except where otherwise permitted or required by law. In some circumstances, your consent may be implied by your actions, such as when you provide information to use our products or Services.

You may withdraw your consent to certain uses or disclosures of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may affect our ability to provide certain Services. If you are a resident of Quebec, additional rights may apply under Act 25 (S.Q. 2021, c. 25) (“Law 25”), including rights relating to automated decision-making, data portability, and privacy impact assessments. Please contact us at [email protected] for Quebec-specific inquiries.

Your Privacy Rights 

You may have the following rights under applicable Canadian privacy laws, including PIPEDA:

Right of Access

You have the right to request access to the personal information we hold about you and to receive information about how it has been used or disclosed, subject to limitations permitted by law.

Right to Correction

You have the right to request correction of personal information that you believe is inaccurate or incomplete. Where appropriate, we will amend the information as required by applicable law.

Cross-Border Transfers

For information about cross border transfers of your personal data, please see Section 7. International Transfers section of this Policy. We use appropriate safeguards to protect personal information in accordance with applicable legal requirements.

Complaints

If you have questions or concerns about how we handle personal information, you may contact us using the details provided in Section 13. Contact Us of this Privacy Policy. If you are not satisfied with our response, you may have the right to file a complaint with the Office of the Privacy Commissioner of Canada.

15.3 Mexico

If you reside in Mexico, this section applies to you and supplements the rest of this Privacy Policy. Owlet processes personal data in accordance with the Mexican Federal Law on Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares, “LFPDPPP”) and its Regulations (Reglamento de la LFPDPPP).

Your Privacy Rights

You may have the following rights under applicable Mexican privacy laws, including LFPDPPP:

Access and Rectification

You have the right to access the personal data we hold about you and request details on how it is being used. If any of your information is inaccurate or incomplete, you have the right to request that we correct it.

Deletion and Opposition

You have the right to request that we delete your personal data when you believe it is no longer necessary for the purposes outlined in this policy. You may also oppose the processing of your data for specific purposes or in certain situations where you have a legitimate reason to do so.

Revocation of Consent and Limitation of Use

Where you have provided consent for us to process your data, you have the right to revoke that consent at any time. You may also request to limit how your personal data is used or disclosed. Please note that revoking consent may impact your ability to use certain features of our Services.

How to Exercise Your Rights

To exercise your rights or revoke your consent, please follow the steps outlined in Section 12. How to Exercise Your Rights of this Policy. In accordance with Mexican law, we will respond to your request within 20 business days of receipt.

International Transfers and Complaints

For information about cross border transfers of your personal data, please see Section 7. International Transfers of this Policy. Transfers outside Mexico are conducted in accordance with applicable law, including through the use of data transfer agreements where required. 

Complaints

If you are not satisfied with our response to a privacy request, you may lodge a complaint with the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI).

15.4 United Kingdom and European Union

This section applies if you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK). It supplements the information in the main Privacy Policy.

Who is responsible for your information

Owlet Baby Care, Inc. is the controller of the personal data described in this Privacy Policy when you use our Services.

Because Owlet is based in the United States, we have appointed representatives in the European Union and the United Kingdom to act on our behalf for data protection matters.

European Union Representative
Osano International Compliance Services Limited
ATTN: SPZT
25 North Wall Quay
Dublin 1, D01 H104
Ireland

United Kingdom Representative
Osano UK Compliance LTD
ATTN: SPZT
42–46 Fountain Street
Belfast, Antrim
BT1 5EF
United Kingdom

You may contact these representatives or Owlet directly using the contact details provided in Section 13. Contact Us of this Privacy Policy.

How we use your personal data (lawful bases)

European and UK data protection laws require us to have a valid legal basis for processing personal data. Depending on how you use our Services, we rely on one or more of the following:

Performance of a contract
We process your information as necessary to provide the Services you request. This includes creating and managing your account, operating connected devices, delivering insights about your child’s sleep or environment, processing purchases, and providing customer support.

Legitimate interests
We may process information where it is reasonably necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. This includes improving and developing our products, maintaining service reliability and security, conducting analytics, preventing fraud, and communicating with you about your use of the Services.

Consent
In certain situations, particularly when processing sensitive information or sending marketing communications where required by law, we rely on your consent. You may withdraw consent at any time through your account settings or by contacting us. Withdrawal does not affect processing carried out before consent was withdrawn.

Legal obligations
We may process personal data to comply with applicable laws, regulations, court orders, or governmental requests.

Sensitive data and child-related information

Some information processed through our Products may relate to health, wellness, or physiological measurements of an infant or child. Where this information is considered a special category of personal data under applicable law, we process it only when permitted, including where:

• You have provided explicit consent

• Processing is necessary to provide the services you requested

• The data has been de-identified or aggregated

• Another lawful basis applies under applicable law

You can manage certain data collection features through your device settings or application preferences.

Research, product development, and other  features

To improve our products and develop new features, we may analyze usage patterns and device data. Where possible, we use aggregated, de-identified, or pseudonymized information. As permitted by law, we may also use such information for research, analytics, or to develop automated or AI-enabled tools designed to enhance safety insights, personalization, and product performance. Where required by law, we will obtain your consent before using personal data for these purposes.

Marketing communications

We may send you service-related messages necessary to operate your account and provide the Services. With your permission where required, we may also send marketing communications about products, features, or offers that may interest you. You can opt out of marketing communications at any time by using the unsubscribe link or adjusting your preferences.

Data retention

We retain personal data only for as long as necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on the nature of the data, how it is used, and applicable legal requirements.

Your Privacy Rights in Europe and the UK

Depending on your county of residence, you may have the following rights, subject to legal limitations and exceptions:

Right to access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data, along with information about how it is used, shared, and retained.

Right to rectification

You have the right to request correction of inaccurate or incomplete personal data we hold about you. You can update certain account details directly through your account settings. If you believe other information is incorrect, please contact us and we will review your request.

Right to erasure (right to be forgotten)

You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent and no other legal basis applies. We may retain certain information where required by law, to resolve disputes, enforce agreements, protect safety, or for other legitimate purposes permitted by law.

Deleting your account will generally remove access to associated data, although some information may be retained in backup systems or in de-identified form.

Right to restrict processing

You have the right to request that we limit how we use your personal data in certain situations, including:

• If you contest the accuracy of the data

• If you have objected to processing and we are evaluating your request

While processing is restricted, we will store your data but will not use it except as permitted by law.

Right to data portability

You have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format, and to request that it be transferred to another service provider where technically feasible. This right applies only to data processed by automated means based on your consent or a contract..

Right to object

You have the right to object to processing based on legitimate interests, including profiling, where your particular situation gives rise to the objection. You also have the right to object at any time to the use of your personal data for direct marketing. If you object to marketing, we will stop using your data for that purpose.

Right to withdraw consent

Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn. Depending on the service, withdrawing consent may limit certain features or functionality. You can withdraw consent through your account settings where available or by contacting us.

Rights related to automated decision-making

You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant impacts, except where permitted by law.

Right to lodge a complaint

If you believe your privacy rights have been violated, you have the right to lodge a complaint with a data protection authority in your country of residence, place of work, or where an alleged infringement occurred. We encourage you to contact us first so we can try to resolve your concerns.

How to Exercise Your Rights

To exercise your rights, please follow the steps outlined in Section 12. How to Exercise Your  Rights of this Policy. 

15.5 Australia and New Zealand

If you reside in Australia or New Zealand, this section applies to you and supplements the rest of this Privacy Policy. Owlet handles personal information in accordance with the Australian Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), and the New Zealand Privacy Act 2020, as applicable.

Collection and Use of Personal Information

Information about the categories of personal information we collect, the purposes for which we use it, and how we disclose it is described in the relevant sections of this Privacy Policy above.

Where required by law, we will collect sensitive information (including health information) only with your consent or where otherwise permitted by applicable law.

Overseas Disclosures

For information about how Owlet discloses personal information to overseas recipients and the safeguards we apply, please see Section 7. International Transfers of this Privacy Policy. When disclosing personal information overseas, Owlet takes reasonable steps to ensure the recipient handles that information consistently with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), or is otherwise subject to a comparable privacy regime.

Your Privacy Rights 

Depending on your residence, you may have the following rights, subject to legal limitations and exceptions:

Access

You have the right to request access to personal information we hold about you. 

Correction

You have the right to request correction of that information if you believe it is inaccurate, incomplete, or outdated. We may decline access or correction requests in circumstances permitted by applicable law, and if we do so, we will provide reasons. If you are located in New Zealand and we decline to correct information as requested, you may request that we attach a statement of correction to the relevant record.

Complaints

If you have questions or concerns about how we handle personal information, you may contact us using the details provided in Section 13. Contact Us of this Privacy Policy. We will investigate and respond to complaints within a reasonable timeframe in accordance with applicable law.

If you are not satisfied with our response:

• In Australia, you may contact the Office of the Australian Information Commissioner (OAIC).

• In New Zealand, you may contact the Office of the Privacy Commissioner.

How to Exercise Your Rights

To exercise your rights, please follow the steps outlined in Section 12. How to Exercise Your  Rights of this Policy.

15.6 South Africa

If you reside in South Africa, this section applies to you and supplements the rest of this Privacy Policy. Owlet processes personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA).

Your Privacy Rights 

Depending on your residence, you may have the following rights, subject to legal limitations and exceptions:

Access 

You have the right to be informed about the collection and use of your personal information as described in this Privacy Policy. You may request access to the personal information we hold about you.

Correction

You have the right to request the correction, deletion, or destruction of information that is inaccurate, incomplete, misleading, excessive, or unlawfully obtained, subject to applicable legal limitations.

Objection to Processing

In certain circumstances, you have the right to object to the processing of your personal information. This includes the right to object at any time to the processing of your personal information for direct marketing purposes.

Security and Breach Notification

We implement appropriate technical and organizational measures to protect your personal information. If your personal information is accessed or acquired by an unauthorized person, we will notify you as required by applicable law.

Provision of Personal Information

Where the provision of personal information is necessary for us to provide our Services, failure to provide such information may limit our ability to provide certain features or functions.

International Data Transfers

For information about how Owlet transfers personal information across borders and the safeguards we use, please see Section 7. International Transfers of this Privacy Policy. All cross border transfers of personal information are conducted in compliance with the applicable requirements of POPIA.

Complaints

If you have concerns about how we process your personal information, please contact us using the details provided in Section 13. Contact Us of this Policy. You also have the right to lodge a complaint with the Information Regulator (South Africa) or to seek appropriate relief in a competent court.

How to Exercise Your Rights

To exercise your rights, please follow the steps outlined in Section 12. How to Exercise Your Rights of this Policy.

15.7 Gulf Corporation Council (GCC) Region

If you reside in a member state of the Gulf Cooperation Council (GCC) including the United Arab Emirates (UAE), the Kingdom of Saudi Arabia (KSA), Qatar, Kuwait, Bahrain, or Oman, this section applies to you. Owlet processes personal data in accordance with applicable national laws, such as the UAE Personal Data Protection Law and the Saudi Personal Data Protection Law.

Consent and Withdrawal

In many cases, we rely on your explicit consent to process your information, particularly for marketing or health-related data. You have the right to withdraw this consent at any time. We make the process of withdrawing consent as easy as the process for providing it, typically through your account settings or by contacting us directly using the methods described in Section 13. Contact Us of this Privacy Policy.

Processing of Sensitive Data

Under regional laws like the Saudi PDPL and UAE Data Protection Law, certain types of information such as health data or information related to children are classified as sensitive. When we process this data, we apply security measures and ensure we have a valid legal basis, such as your explicit consent or a specific regulatory requirement, to perform the processing.

International Data Transfers

For information about how Owlet transfers personal information across borders and the safeguards we use, please see Section 7. International Transfers of this Privacy Policy.

Your Privacy Rights 

Depending on your country of residence, you may have the following rights, subject to legal limitations and exceptions:

Access

You have the right to request access to your personal data and obtain a copy of it in a clear and readable format.

Correction and Destruction

You may also request that we correct any inaccurate information or destroy your personal data when it is no longer needed for the purposes for which it was collected.

Limitation and Objection

You have the right to request that we limit the processing of your data to specific purposes or object to processing that causes you harm or is used for direct marketing. In the UAE and KSA, you may also request to stop processing if the data is no longer accurate or is being handled unlawfully.

Complaints

If you have concerns about how we handle your personal information, we encourage you to contact us using the information provided in Section 13. Contact Us of this Policy so we can address your request. You also have the legal right to lodge a formal complaint with the relevant local authority, such as the Saudi Data and Artificial Intelligence Authority (SDAIA) in KSA or the UAE Data Office.

How to Exercise Your Rights

To exercise your rights, please follow the steps outlined in Section 12. How to Exercise Your Rights of this Policy.

15.8 India

If you reside in India, this section applies to you and supplements the rest of this Privacy Policy. Owlet acts as a “Data Fiduciary” under the Digital Personal Data Protection Act, 2023 (DPDP Act).

Personal Data We Process

Information about the categories of personal data we collect, the purposes for which we process it, and how we share it is described in the relevant sections of this Privacy Policy above. We process personal data only for lawful purposes and based on your consent or other legal grounds permitted under applicable law.

Your Rights

Subject to the DPDP Act and applicable law, you have the following rights:

Right to Access

You have the right to request a summary of the personal data we process about you, along with information about the processing activities undertaken with respect to that data and the categories of third parties with whom it has been shared.

Right to Correction and Updating

You may request correction of inaccurate or misleading personal data, completion of incomplete personal data, or updating of your personal data.

Right to Erasure

You may also request erasure of your personal data where the purpose for which it was collected is no longer being served or where you withdraw your consent and no other legal basis applies. We may retain certain information where required by law or for legitimate business purposes permitted under applicable law.

Right to Withdraw Consent

Where we rely on your consent to process personal data, you may withdraw your consent at any time. Withdrawal of consent will not affect processing carried out prior to withdrawal. If you withdraw consent, certain features of our Services may no longer be available.

Right to Nominate

You have the right to nominate another individual who may exercise your rights under applicable law in the event of your death or incapacity.

Grievance Redressal

If you have any questions, concerns, or complaints regarding our processing of personal data, you may contact us using the information provided in Section 13. Contact Us of this Privacy Policy. We will acknowledge and respond to your grievance within the time period prescribed under applicable law. If you are not satisfied with our response, you may approach the Data Protection Board of India.

Cross-Border Transfers

For information about how Owlet transfers personal information across borders and the safeguards we use, please see Section 7. International Transfers of this Privacy Policy.

Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes described in Section 8. Security and Data Retention of this Privacy Policy, unless a longer retention period is required by applicable law.

Duties of Users

Under applicable law, you agree to provide accurate and authentic personal data, not to impersonate another person while providing personal data, not to file false or frivolous grievances, and to comply with applicable laws when exercising your rights.

Children’s Data 

Under Indian law, individuals under the age of 18 are considered children. Owlet processes children’s Personal Data only with verifiable consent from a parent or lawful guardian and in compliance with applicable law. We do not engage in tracking, behavioral monitoring, or targeted advertising directed at children in a manner prohibited under Indian law.

How to Exercise Your Rights

To exercise your rights, please follow the steps outlined in Section 12. How to Exercise Your Rights of this Policy.

15.9 Israel

If you reside in Israel, this section applies to you and supplements the rest of this Privacy Policy. Owlet processes personal data in accordance with the Israeli Protection of Privacy Law, 5741-1981 and applicable regulations.

Your Rights

Under Israeli law, you have the right to review personal data about you that is maintained in our databases. If you find that personal data is incorrect, incomplete, unclear, or outdated, you may request that we correct or delete it in accordance with applicable law.

How to Exercise Your Rights

To exercise your rights, please follow the steps outlined in Section 12. How to Exercise Your Rights of this Policy.

15.10 Singapore

If you reside in Singapore, this section applies to you and supplements the rest of this Privacy Policy. Owlet processes personal data in accordance with the Personal Data Protection Act 2012 (PDPA).

Your Privacy Rights 

Depending on your residence, you may have the following rights, subject to legal limitations and exceptions:

Access

You have the right to request a copy of the personal data we hold about you and information about how we have used or disclosed that data within the past year. 

Correction

You also have the right to request that we correct any errors or omissions in your personal data.

Withdrawal of Consent

You may withdraw your consent for the collection, use, or disclosure of your personal data at any time by giving us reasonable notice. Upon receiving your request, we will inform you of the likely consequences of the withdrawal, such as any impact on your ability to use the Owlet app or services.

Accuracy and Protection

We take reasonable steps to ensure that the personal data we collect is accurate and complete, especially if it is likely to be used to make a decision that affects you. We also maintain security arrangements to protect your data from unauthorized access or similar risks, as described in Section 8.  Security and Data Retention of this Privacy Policy.

International Data Transfers

When we transfer personal data outside of Singapore, we ensure that the receiving party provides a standard of protection that is comparable to the protection under the PDPA. For more details on these transfers, please see Section 7. International Transfers of this Privacy Policy.

Data Protection Officer and Complaints

If you have any questions or complaints regarding our data protection practices, you may contact our Data Protection Officer. We have designated a DPO who is reachable via email at [email protected]. You also have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) if you believe your rights under the PDPA have been infringed.

16. Definitions

The following terms have the meanings given below when used in this Privacy Policy:

“Aggregated Data” means data that has been combined and summarized such that it cannot reasonably be used to identify any individual.

“Anonymized Data” means data from which all identifying information has been removed and which cannot reasonably be re-identified.

“Controller” (or “Data Controller”) means the entity that determines the purposes and means of processing personal data. For purposes of this Privacy Policy, Owlet Baby Care, Inc. is the controller.

“De-identified Data” means data that has been processed to remove or obscure direct identifiers such that the data cannot reasonably identify an individual without additional information.

“Personal Information” (also referred to as “Personal Data”) means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to an identified or identifiable individual.

“Processing” means any operation or set of operations performed on personal data, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, transmission, or deletion.

“Processor” (or “Service Provider”) means a natural or legal person that processes personal data on behalf of and under the instructions of the Controller.

“Sensitive Personal Information” (or “Special Category Data”) means categories of personal information that are afforded heightened protection under applicable law, including health and biometric data, precise geolocation, racial or ethnic origin, religious beliefs, and financial account information, among others.

“Services” means the websites, mobile applications, connected devices, customer support services, and other products and services offered by Owlet, as further described in Section 1 of this Privacy Policy.

17. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services or legal requirements. If we make material changes to how we handle your personal information, we will notify you by posting a notice on our Website, sending an email, or alerting you through the Owlet app. We encourage you to check the "Last Revised" date at the top of this page periodically to stay informed. By continuing to use our services after an update, you acknowledge the terms of the revised policy; if you do not agree with the changes, you may close your account at any time.