| Scenario/ processing purpose | Categories of data | Legal basis and special condition for processing | Third parties and others with whom we share this data | Retention |
| --- | --- | --- | --- | --- |
| **User account registration and management of Regular Accounts for users over 18 years of age - In order to allow you to create and use an account.** Arduino will process your data in order to allow you to create and use an account on the Website, whether or not you make a purchase in the Store. In particular, the creation of a Regular Account allows you to use different functionalities of the Website and of the Apps. | **Customer Records:** Your username, email address and other profile information such as your interests.
If we deactivate your account, we retain your username within the Forum and Project Hub if you have posted/commented within them. | The legal basis for this processing is the performance of a contractual/pre-contractual request by you. That contract is for the provision of the Arduino services, in accordance with the applicable terms and conditions.
The legal basis for additional storage after deactivation of your account is Arduino's legitimate interest in ensuring and maintaining the integrity of the Forum and Project Hub. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The retention period of your data, in addition to the period necessary to process your order or to perform another service available on the Website, will be equal to the period of activity of your account. If you do not access your account for 24 months, we will deactivate it. When creating an account, if you do not confirm within 1 month via the link sent to you, your Arduino account will be deleted. Without your details we cannot give you access to the Arduino services described above.
If you cancel your account or we terminate it, we delete your account but retain information relating to your account as explained in this Privacy Policy. |
| **User communication - In order to send essential information concerning your account, your use of Arduino products and services.** We use your email to send you important information regarding the status of your account (for instance, if some of the services you have signed up for are about to expire or if your account is about to be closed according to the terms and conditions of the service you accepted, within the limits described), the security of Arduino products and services or changes to this Privacy Policy. | **Customer Records:** Your username, email address, (for Restricted Account and Junior Account users). | The legal basis of this processing is performance of the Terms of Service. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The retention period of data in connection with this processing is equal to the period necessary to carry out the communications described under purposes of processing. |
| **Product and service provision - In order to provide you with Arduino services and products.** Through our Website, to give you information and assistance for the activation of your account and on Arduino services, or support for services on third party platforms that you may access through your Arduino account. The processing of your data is necessary in order to give you access to the Website and its functionalities, to respond to your requests and to assist you when you use our products and services. | **Customer Records:** Your Tax Code (if applicable), your residence address and your invoicing data. | The legal basis for this processing is the performance of a contractual/pre-contractual request by you. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The retention period of your data is equal to the period of activity of your account for the use of Arduino services according to the terms and conditions of use you have accepted, within the limits described. |
| **Online community participation - In order to allow you to request information and to interact with other users (for users with Regular Accounts only).** Through the Forum and the "community" functionalities of Arduino, which you may access upon specific request, you may participate in discussions, request information and leave comments or other information relating to your experiences. This information may be viewed by other users. | **Customer Records:** Your username, your Account and, if you decide to make such data visible to other Arduino users, we use information relating to your job title and other profile information that you wish to share with Arduino community and, upon your request, with the public. To allow you to be published on Arduino Website as a "Certified User", we may use your username. | The legal basis of this processing is the performance of the terms and conditions of use for Arduino services.
In the event of deletion of your Arduino account, we will retain your username in the Forum and Project Hub. The legal basis for this further retention and processing is Arduino's legitimate interest in ensuring and maintaining the integrity of the Forum and Project Hub. | If you use the Forum or Project Hub, Arduino Cloud, Arduino Day, Arduino Blog and the Social Media Pages of Arduino accessible through our Website, you may interact with other users, and we will share your data with other users, to whom your comments, your position and the other information you would like to share will be visible.
Service providers outside of the Qualcomm Group operating as data processors. | The retention period of your data is equal to the period of activity of your account for the use of Arduino services according to the terms and conditions of use that you accepted and within the limits described.
After your account is cancelled or terminated we delete your account and de-identify your username within the Forum and Project Hub (if you have posted/commented within them). Posts remain in Forum and Project Hub for 5 years, without prejudice to your right to object at any time and/or to request the deletion of posts as well.
If your Arduino account is deactivated, after 24 months without activity, your username will be retained within the Forum and Project Hub if you have posted/commented within them, for 5 years, without prejudice to the right to object at any time and/or to request the deletion of usernames as well. After this period, the username will be deleted and the post de-identified in the Forum or in Project Hub. |
| **Certification - In order to enable you to obtain an Arduino Certification.** We will process your information when you submit a purchase order for the Arduino Certification Program and to enable you to obtain the Arduino Certification. | **Customer Records:** Your Tax Code (if applicable), your residence address and your invoicing data. | The legal basis for this processing is the performance of the agreement to which you became a party from the moment when you accept the terms and conditions of the Arduino Certification Program.
We retain your Certification for 5 years after issuance. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The period of retention of your data, for this purpose, is equal to the period necessary to process your order, carry out the certification process and issue your Certification. We will retain your data until the expiration of your Certification (however, if you also have an account, the period of retention of your data will be equal to the period of activity of your account, according to the terms and conditions of use that you have accepted, within the limits described therein). Without your data we will not be able to process your order and provide you with the requested service. |
| **In order to enable the use of Arduino Education products and Arduino Cloud.** When you purchase an Arduino Education product, we process your data in order to process your purchase order, as well as to enable the use of these services on your terminal and on the terminal of the users you wish to involve in the educational program. | **Customer Records:** Your first name and last name, email address, residence or work address, as well as invoicing data. Personal data of users under the age of 14 will be processed as described in **Section 3, "Minors' Data**. | The legal basis of this processing is the need to fulfil the agreement you entered into with us when you ordered an Arduino Education product. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The retention period in connection with this purpose is equal to the period during which you or your team uses the educational package. Without your data, we cannot process your purchase order and provide you with the educational services of Arduino Education. |
| **In order to allow Arduino to release the software to which you are a contributor.** Arduino allows you to make available to the developers' community the result of your development work within the Contributor License Agreement program. | **Identifiers:** Your GitHub username, the data of your account, your first name and last name, the email and the personal data you filled into the header of the source code and in the documents of the license. | The legal basis of this processing is the need to fulfil the contractual obligations in accordance with the terms and conditions that you have accepted.
If your work is part of other works released by third parties and the terms of the license provide for the publication of your data as author/co-author, the legal basis of the processing is the legitimate interest of Arduino in pursuing its corporate organizational purposes to promote the open source community, which considers, and is compatible with, your rights and interests as developer of open source programs and as a community member. | Service providers outside of the Qualcomm Group operating as data processors. | The retention period in connection with this purpose is equal to the period during which your software is available on the Arduino sharing platform. Without your data we cannot release your work within the Contributor License Agreement program. If your work is part of other works released by third parties and the terms of the license provide for the publication of your data as author/co-author, the retention period is equal to the period during which the software, in which your work is embedded, is available on the Arduino sharing platform. If you want to erase your data from the published licenses, you shall exercise your moral rights as author of the software, compatible with the terms of the license you and the next contributors used. |
| **In order to prevent or assess unlawful conduct or to protect and enforce our rights.** For instance, we may use your data to prevent or prosecute infringements, including of our-and third parties'-intellectual/industrial property rights, or to prevent or prosecute cybercrimes or crimes committed through the internet. | All categories as described in this table. | The legal basis of this processing is the legitimate interest of Arduino to protect its rights and to prevent criminal offences. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group.
Where we believe we have to do so in order to comply with an order from the judge or from an authority, or to comply with statutory obligations or in order to protect us or third parties in court, we may disclose your data. | The retention period of your data is equal to the time reasonably necessary to enforce our rights from the moment we become aware of the offence or of its potential commission. |
| **In order to allow you to participate in our surveys.** We will process your personal data to allow you to participate in a survey aimed at improving our products and services, through the completion of an online form. | **Identifiers:** Your first name and last name and contact details (e-mail). | The legal basis of this processing is consent, when we ask for your consent and you consent by responding to our survey.
In other cases, the legal basis of this processing is the legitimate interest of Arduino to improve its products and services by obtaining user feedback. | Service providers operating outside of the Qualcomm Group as data processors. | The data retention period is equal to the duration of the survey, after which response data will be de-identified, unless your consent is requested for further storage and publication of the survey results on our Store. |
| **To enable you to subscribe to the newsletter.** Subject to your consent, you may be contacted by Arduino by e-mail or other electronic communication tools in order to send you the newsletter, as well as following your subscription to the same by entering your e-mail address or following your subscription to a waiting list for the launch of a new product. | **Identifiers:** Your email address and your first name and last name.
**Internet and Other Electronic Network Activity Information:** Browsing data and Website behavioral information to personalize the newsletter, provided that you have previously authorized processing of browser and Website behavioral information. | The legal basis for this processing is your consent, which in the case of newsletter subscription consists of entering your e-mail address. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The data retention period is 24 months after your last interaction with us by accessing our Website, by your consent to the use of cookies, or by interaction with our newsletter. |
| **To send you personalized education and professional newsletters and subscribe you to a waiting list**. | **Identifiers:** Your email address and your first name and last name. When you subscribe to a waiting list, we may ask you, on an optional basis, for some of your additional personal data (such as your first name and last name or your country) for Arduino's internal statistical purposes.
**Internet and Other Electronic Network Activity Information:** Browsing data and Website behavioral information to understand better which products and services you prefer, provided that you have previously authorized such processing. | The legal basis is always your consent, which you can express by choosing to subscribe to such newsletters and by ticking the corresponding checkbox.
When we subscribe you to a waiting list, the legal basis for the processing of such personal data is our legitimate interest in ensuring you are notified when a product is available so that you may consider buying it. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The data retention period is 24 months after your last interaction with us by accessing our Website, by your consent to the use of cookies, or by interaction with our newsletter.
When we subscribe you to a waiting list, the retention period is as set out above. |
| **Training.** We may offer training or other services to the employees, workers and agents of our business customers. | **Identifiers:** Your email address and your first name and last name, position, employer, time zone, country and purchased products. | The legal basis for this processing is our legitimate interest in using your personal data in order to perform the relevant contract with our business customer(s) and thereby abide by our contractual obligations. | We may need to disclose personal information relating to the use of our training and other services to the relevant business customer.
Service providers outside of the Qualcomm Group operating as data processors. | The data retention period is 5 years. |
| **For Arduino's profiling purposes.** We may carry out profiling in order to better understand users of Arduino services, organise (segment) users into groups that share similar interests and characteristics, and use those groups and the personal data of group members to build audiences for our campaigns and to deliver tailored marketing communications to you (where you have consented to receive such communications) as well as more relevant online advertising or other content (in accordance with your consent to cookies) | **Customer Records:** Your username, email address and other profile information, including your place of residence and interests.
Internet and Other Electronic Network Activity Information: Browsing data and Website behavioral information to understand better which products and services you prefer, provided that you have previously authorized such processing. | The legal basis for this processing is:
- either your consent (where we ask for your consent), or
- our legitimate interest to better understand users of Arduino services and organize groups that share similar interests or characteristics to perform targeted campaigns, to the extent consent is not legally required and after having assessed that your rights and interests are not overridden by such processing.
| Service providers outside of the Qualcomm Group operating as data processors. | The retention period of your data is 24 months after your last interaction with us by accessing our Website or using your account, by your consent to the use of cookies, or by interaction with marketing communication. |
| **For sending Arduino marketing communication.** After having obtained your consent, or where otherwise permitted by law (such as if you are a customer and we have informed you of your right to opt-out of marketing) you may be contacted by Arduino via email with information or promotional content regarding Arduino's services or selected third party products or services. | **Identifiers:** Your email address, telephone number and your first name and last name. | The legal basis for this processing is:
- either your consent (where we ask for your consent) or
- article 130, paragraph 4, of the Italian Legislative Decree 196/2003 when marketing communications are sent via email for promoting our products and services that are the same or similar to products or services that you have already purchased, unless you have opted out to the delivery of such communications.
If Italian law does not apply, the legal basis is our legitimate interest in promoting our products and services in order to grow our business. | Service providers outside of the Qualcomm Group operating as data processors. | The retention period of your data is 24 months after your last interaction with us by accessing our Website, by your consent to the use of cookies, or by interaction with marketing communication. |
| **In order to provide you with the products and services you purchased and to send you communications in connection with your purchase order or with your payments.** We will process your data to process your purchase orders. We may send you emails regarding your account or your purchase of Arduino products and services, or the payments made through our Website. | **Customer Records:** Your email address, your Tax Code (if applicable), your residence address and your invoicing data. | The legal basis of this processing is the performance of the agreement to which you became party from the moment when you accept the Store's general terms and conditions of sale and the fulfilment of pre-contractual measures that you may have requested. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The retention period of your data is equal to the period required to process the purchase order (however, if you also have an account, the retention period of your data is equal to the period of activity of your account for the use of Arduino services, according to the terms and conditions of use that you have accepted, within the limits described). Without your data we cannot process your purchase order and provide you with the products and services requested. |
| **To provide you with necessary after-sales support, such as to handle returns and in compliance with applicable product warranty laws.** Arduino will use your information to provide you with assistance, to manage the return and/or repair of products you purchased from the Store in accordance with applicable laws and the Store's general terms and conditions of sale. | **Customer Records:** Your username and email address. | The legal basis for this processing is to comply with legal obligations. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The retention period is the time required to fulfill the obligations required by applicable law (in particular consumer protection law). |
| **In order to let you interact with customer care operators.** We will assist you in case you need help using Arduino products and services.
We might also collect feedback provided through surveys submitted to the customer regarding customer assistance. | **Customer Records:** Your username, email address or telephone number, as well as your first name and last name and/or postal address. | The legal basis of this processing is the performance of the agreement which you entered into with Arduino when you accepted the terms and conditions of use of Arduino services and compliance with legal obligations relating to statutory due warranties and consumer assistance.
If we collect feedback, the legal basis for this processing is your consent. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The data retention period is equal to the activity period of your account, according to the terms and conditions of use that you accepted, within the limits described. |
| **To update you on your shopping cart.** When you create an account, Arduino may remind you that your shopping cart on the Store contains products. | **Customer Records:** Your email address and the content in the shopping cart associated with your account. | The legal basis for such processing is Arduino's legitimate interest in keeping you updated about your shopping cart. | Service providers outside of the Qualcomm Group operating as data processors. | The retention period of your data for this purpose is 24 hours from when you left the shopping cart without completing your purchase. |
| **To update you on the availability of a product.** Following your explicit request, Arduino will process your personal data in order to update you on the availability in the Store of the product you requested which is 'Out of Stock'. | **Customer Records:** Username and email address. | The legal basis for this processing is the performance of a contractual/pre-contractual request by you. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The storage period of your data is equal to the period necessary to process the request. |
| **To ask you to review products you have purchased.** After 10 days from the shipment of the product, we may send you an email asking you to review the product(s) you have purchased. | **Customer Records:** Your first name and last name, email address and order information. | The legal basis for such processing is our legitimate interest in improving our products and services. | Service providers outside of the Qualcomm Group operating as data processors. | The retention period of your e-mail address for this purpose is equal to the period necessary to send you the review request. |
| **To publish your review on our Website.** Our policy is to avoid publishing any reviews that contain street addresses or images depicting identifiable natural persons. | **Customer Records:** Your comments, if any, your first name (and the first letter of the surname you have provided us with) and any image you share with us. | The legal basis for this processing is your express consent, which you can give by clicking on the 'Done' button at the end of the review. | Service providers outside of the Qualcomm Group operating as data processors. | The data retention period is 5 years from when you provide your consent. |
| **To obtain information about your use of our Website and Apps (except Junior Account users).** Arduino uses this information solely in order to allow navigation on its Website and to process the operations normally relating to the use of the Website. We may also analyze how often you use the App and where you downloaded it from. We use third party tools to mask your IP address and analyze use of our Website at the country (and not individual) level. | **Internet and Other Electronic Network Activity Information:** We may collect data about the type of device you are using, or the version of the operating system of your computer or browser.
**Internet and Other Electronic Network Activity Information:** For unregistered users, we collect data related to how the Website is used in a de-identified form that does not in any way allow, even in combination with the Unique Device Identifier (UDID), the MAC address, the IMEI or IMSI codes or other customer codes, to trace directly or indirectly back to your identity. If you give us your explicit consent to use your data at the moment of registration, we connect your browsing data collected in a de-identified form in the previous 30 days to your identity. This category of data includes IP addresses or domain names of the devices used by users connecting to the App, the Uniform Resource Identifier (URI) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code given by the server indicating the status of the response (e.g., successful, error), the sections of the Website visited, the type of device used, the country which you connect from and other parameters relating to the operating system and the computer environment of the user. | The legal basis of this processing is the legitimate interest of Arduino to communicate with the public through electronic networks, such as for data processing subject to Italian or other data protection law for which consent is not required in relation to the data processing performed by means of necessary cookies.
The legal basis is consent if you consent to allow us to link your data and, in relation to data processing subject to Italian data protection law for the data processing occurring through profiling cookies. | We use third-party tools for these purposes and those third parties will receive your data: please consult the document available
here for indications of such third parties or see our
cookie policy.
Service providers outside of the Qualcomm Group operating as data processors. | The retention period of the information that could potentially allow the identification is 30 days from access to the Website. |
| **To obtain information about your use of our Website (except Junior Account users).** Arduino uses this information solely in order to allow navigation on our Website and to process the operations normally relating to the use of the Website. We may analyze where you navigated from to reach our Website. We use third party tools to mask your IP address and analyze use of our Website at the country (and not individual) level. | **Geolocation Data:** We collect geographical location data. | The legal basis is consent if you consent to allow us to collect your data. | We use third-party tools for these purposes and those third parties will receive your data: please consult the document available
here for indications of such third parties or see our
cookie policy.
Service providers outside of the Qualcomm Group operating as data processors. | The retention period of the information that could potentially allow identification is 30 days from access to the Website. |
| **In order to allow you to report a problem and/or violations of applicable law or to make a report and subsequent handling.** We will process your personal data when you report a violation of the terms and conditions of the Website as well as violations of applicable law, such as copyright violations. We will process your data if a third party reports to us that a violation has been committed by you, in order to assess it. | **Identifiers:** Your first name and last name, e-mail address and the information you provide us in the report. | The legal basis for this processing is Arduino's legitimate interest in protecting its rights and preventing unlawful acts, as well as in some cases (such as copyright infringement or reporting certain content), to comply with legal obligations. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group.
Where we believe we have to do so in order to comply with an order from the judge or from an authority, or to comply with statutory obligations or in order to protect us or third parties in court, we may disclose your data. | The retention period is equal to the relevant statute of limitations period, it being understood that the reports and the related management process may be retained according to the ordinary statute of limitations. |
| **Legal and financial obligations.** To comply with obligations under applicable law, such as product safety and compliance; in legal proceedings, responding to legal authorities, or if we believe it is necessary to protect the rights, property, or safety of Arduino or the Qualcomm Group, our users, the public, or others; as necessary to obtain advice or otherwise protect and manage our business interests. | **Commercial Information**, such as your business contact information, the business you represent, products purchased or supplies provided, financial information, course of conduct with you or your employer; other categories set forth in this table as relevant. | Legal Obligation of the relevant European jurisdiction(s); otherwise, our Legitimate Interests in complying with applicable legal obligations in order to protect our business and our reputation | Where we believe we have to do so in order to comply with an order from a judge or an authority, to comply with statutory obligations or in order to protect us or third parties in court, we may disclose your data. | The retention period is equal to the relevant statutes of limitations period. |
| **Security Protection.** To detect, investigate and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Qualcomm and others.
**Safety:** to protect safety of our stakeholders and visitors | **Identifiers:** such as visitor registration information, your images that might be captured by our cameras installed around our facilities and your network activities when you connect your devices to Qualcomm-managed IT systems.
**Sensitive Personal Information:** health data in the event of a medical emergency.
| The legal basis for this processing is Arduino's (or a Qualcomm Group entity's) legitimate interest in protecting our rights and assets, interests of stakeholders and our reputation
Where health data is processed, that is special category information and the legal basis and special condition for this processing are your vital interests. | Qualcomm Group entities, any relevant governmental agency or a judicial authority. | The retention period is equal to the ordinary statute of limitations applicable to the relevant document (such as a security report or safety report). |
| **In order to manage your administrative position properly.** We process your data (including account information) for accounting, administrative and tax purposes, directly related to the business of Arduino as required by the applicable legislation. | All categories as described in this table. | The legal basis of this processing is compliance with statutory obligations. | Service providers outside of the Qualcomm Group operating as data processors.
With other companies belonging to the Qualcomm Group. | The retention period is equal to that required by law (in particular, by tax, anti-money laundering, banking and public security law). |
| **In support of corporate transactions and other operations.** To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financing and related to the administration of our general business, accounting, auditing, compliance, recordkeeping and legal functions. | All categories as described in this table. | The legal basis for this processing is Arduino's legitimate interest in expanding and reorganizing its business and that of the Qualcomm Group, and to efficiently manage business in compliance with the law, in order to foster continued growth. | Contract parties, any relevant governmental agency or a judicial authority. | The retention period is equal to the ordinary statute of limitations applicable to the relevant contract, or the mandatory retention period under law such as for accounting and similar records. |
| **Category of Personal Information** | **Business or Commercial Purpose for Sale or Sharing** | **Category of Third-Party Data Recipient** |
| --- | --- | --- |
| **Identifiers**, such as unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers. | This category of personal information may be sold or shared for analytics, marketing, advertising and cross-context behavioral advertising. | We may have shared or sold such personal information with third parties engaged in the provision of advertising and marketing services and third parties that operate the cookies that run on our Website. |
| **Internet and Other Electronic Network Activity Information**, such as network usage, browsing history, search history, and information regarding a consumer's interaction with a website, application, or advertisement. | This category of personal information may be sold or shared for analytics, marketing, advertising and cross-context behavioral advertising. | We may have shared or sold such personal information with third parties engaged in the provision of advertising and marketing services and third parties that operate the cookies that run on our Website. |
| **Geolocation data**, such as city-level location (e.g., which city the user may be located in). | This category of personal information may be sold or shared for analytics, marketing, advertising and cross-context behavioral advertising. | We may have shared or sold such personal information with third parties engaged in the provision of advertising and marketing services and third parties that operate the cookies that run on our Website. |
| **Inferences** drawn from any of the information identified above in this table, such as preferences derived from marketing interactions. | This category of personal information may be sold or shared for analytics, marketing, advertising and cross-context behavioral advertising. | We may have shared or sold such personal information with third parties engaged in the provision of advertising and marketing services and third parties that operate the cookies that run on our Website. |
### Use of Sensitive Personal Information under Certain United States Privacy Laws
Where required by law, we will limit our use of sensitive personal information (including sensitive data, as defined under applicable laws) to certain purposes, including performing the services or providing the goods reasonably expected by an average consumer who requests those goods or services; prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information; resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions; ensure the physical safety of natural persons; verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Arduino; and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Arduino. We generally do not collect sensitive personal information for the purpose of inferring characteristics about you.
## 3. Minors' Data
Please read the following information regarding the processing of personal data of minors under 18 years of age (a "**minor**" or "**minors**").
Arduino requires different types of registration (i.e., account creation) on our Website, depending on the age group, in order to better protect browsing and use of services through our Website by users under 18. Minors (including students) under the age of 18 may create an account by selecting unique access credentials and getting parental or legal guardian consent.
When account holders under the age of 14 use Arduino services, their browsing data will not be visible to Arduino. More details are below. Once a minor reaches the age of 14, his or her account will be upgraded to a Restricted Account with the functions and features associated with that type of account.
The Operator collecting information about minors is Arduino S.r.l, with contact information as disclosed at the beginning of this Policy.
- **Junior Accounts (for minors under the age of 14)**
**_Information Collection_**
The table below identifies the purposes for which we process personal data of minors under 14 (including students) and their parents/legal guardians, the corresponding categories of personal data processed for each purpose, our legal basis (and special condition) for processing and how long we retain the personal data. The personal data collected within the Junior Account may be considered personal information (or similar term) in certain jurisdictions, including the United States under the Children's Online Privacy Protection Act ("**COPPA**"):
| **Scenario/ Processing purpose** | **Categories of data** | **Legal basis and special condition for processing** | **Others with whom we share this data** | **Retention** |
| --- | --- | --- | --- | --- |
| To create a Junior Account on our Website, including to obtain consent from the minor's parent or legal guardian, and to provide our services to minors and their parents and legal guardians (as applicable). | **Customer Records**, including the minor's date of birth, a randomly generated username and avatar, the Junior Account password and the email address of the parent or legal guardian; a unique identifier assigned by the Arduino platform ("**Unique ID**") and other personal data stored with the Unique ID; any personal data that the user uploads to their projects, including, if the minor is a student, to the Arduino classroom environment.
**Internet and Other Electronic Network Activity Information**, IP address. | Performance of a contractual/pre-contractual request by the minor with the parent's or legal guardian's consent. That contract is for the provision of the Arduino services, in accordance with the applicable terms and conditions. | Service providers outside of the Qualcomm Group operating as data processors (only to the extent their functionalities and services are made available to the user).
With other companies belonging to the Qualcomm Group.
If the minor is a student, with other students in the Arduino classroom environment, and the teacher. | The retention period of personal data will be equal to the period of activity on the Junior Account. If the Junior Account is not accessed for 24 months, we will deactivate it.
Without the details of the minor and their parents and legal guardians (as applicable), we cannot give access to the Arduino services described above. |
**_Information Use and Disclosure_**
Information related to minors under the age of 14 will be processed in order to create a Junior Account and to allow access to a limited set of services and features on the Arduino Website.
In addition, Arduino may also use minors' information for legal compliance and corporate transaction related purposes, as those purposes are described under **Section 1, "Collection of Personal Data."**
**_Service Providers and Operators used in Relation to Minors_**
We use service providers to assist us in providing services that are open to users under the age of 14, including, for example, providers that host our platform. On areas of the services available to users under the age of 14, we use a subset of our service providers, and we do not permit service providers to use minors' data for behavioral advertising. We do not disclose minors' personal data to other third-party operators.
In Arduino's application Science Kit Physics Lab, we embed videos from YouTube and the App is tagged for child-directed treatment with Google so that according to Google/YouTube's system design, no personal data is sent to YouTube. For more information on the tag please follow this link: 
| Arduino leverages the cloud-based DevOps platform from Foundries.io to reinvent the way embedded Linux solutions are built, tested, deployed and maintained.