Entertainment One UK Limited, registered in England and Wales with company number 02989602, and located at 45 Warren Street, London, W1T 6AG, UK.
Notice for residents of the EU/EEA, UK, Switzerland and other jurisdictions with similar data privacy and protection laws: We operate as a “data controller” under such laws with respect to personal information we collect and process about you/your children. We are registered as a data controller with the UK Information Commissioner’s Office (reg. no. Z9919769).
The Apps are designed partly for use by children, and we are therefore extra cautious when processing personal information. Our Apps generally contain a children’s section (the “Children’s Area”) and a separate parents/guardians section (the “Grown-Up Area”). In the Children’s Area, children participate by playing games, reading e-books and/or watching videos. The Children’s Area does not generally enable a child to enter personal information. Typically, the only part of the Apps where anyone can enter personal information directly is the Grown-Up Area. Accordingly, we do not generally expect to collect personal information directly from any children, except at the direction of a parent/guardian.
For added assurance, our Apps are enrolled in the kidSAFE Seal Program dependently reviewed, certified and/or listed by kidSAFE as meeting their standards of online safety and privacy.
3.Types of personal information we collect
We may collect the following personal information from you:
- Profile and contact information, including name, email address, postal address, country, date of birth, username and password (or other such authentication information), gender and marketing preferences;
- Limited children’s information if you permit, including name(s), date(s) of birth and gender, as well as any information you (or your child) submit as part of a promotion or competition;
- Transactional information such as for paid subscription to the Apps (such as subscription type, current status, and subscription and expiration dates);
- Survey information in response to any customer satisfaction surveys or market research (unless these are provided anonymously);
- Communications between you and us, such as via email, web form, mail, phone, or other channels;
- Online User Activity as described below in Section 10.
If you provide us with personal information regarding a minor, you represent that you either have authority (as parent/guardian) or consent of an individual with such authority to permit us to use the information in accordance with this policy. If you provide us with personal information regarding anyone else, you represent that you have that person’s consent to give us their information and permit us to use it in accordance with this policy.
4.How and when we collect your/your children’s personal information
We may collect personal information from you when you/your children:
- Participate in, access or sign up to any of the Apps’ activities, paid subscriptions, online content, newsletters, or competitions;
- Create an online account or fill in any other forms on the Apps;
- Contact our customer service teams or request information from us in any other way;
- Respond to communications from us;
- Participate in our customer satisfaction surveys or other market research; or
- Communicate or engage with us via social networking websites, third party apps or similar technologies.
When you browse or otherwise use the Apps, we will also collect certain information about your device and your use of the Apps using cookies and similar technologies as further described below.
We will indicate where any personal information we have requested is mandatory or optional. Please note that if you decide not to provide certain information which we have indicated is mandatory, in some circumstances this may mean we are unable to provide you with a certain service or product.
We may also collect personal information about you from third party sources, such as from our subcontractors.
5.How we may use your/your children’s personal information
We (or third party data processors acting on our behalf) may collect, store and use your/your children’s personal information for the following purposes, to the extent permitted by applicable laws:
- To provide our Apps, activities or online content and to provide information about our Apps, including to authenticate users and offer access, activities or online content which may be personalized or tailored to you/your children;
- To identify and contact you/your child as the winner of a particular competition;
- To send out newsletters and other communications that you/your children have subscribed to;
- For system administration purposes and for internal operations (including troubleshooting, data analysis, and testing) to ensure the Apps operate properly;
- To analyse use of the Apps to improve the user experience and to ensure that content is presented in the most effective manner for our users;
- To notify you of any changes to the Apps or provide other administrative notices;
- To provide customer support and ensure we provide a good level of customer service;
- Where you have given us your consent or we are otherwise permitted by law, to contact you/your children (including by e-mail) with products and services which we think may interest you/your children – you can unsubscribe from our marketing communications at any time;
- Where you have given your consent, to pass your personal information to selected third parties for marketing purposes;
- For geo-based redirection (so that if you see the correct version of the Apps depending on the country from which you are accessing the Apps);
- For security and fraud prevention, to ensure that our Apps are safe and secure, to comply with applicable laws and regulations, and to adhere to our policies and contractual rights.
We may also collect information about visitors to and users of the Apps for the purposes of de-identified and aggregate statistics or reporting purposes.
6.Legal basis for processing your personal information
Certain jurisdictions, such as the EU/EEA/UK/Switzerland, require that a business satisfy one or more legal bases to process personal information. We will therefore only process your/your child’s personal information where we have a legal basis to do so, and the legal basis will depend on the purposes for which we have collected and use the personal information. The legal basis is generally one or more of the following:
- Consent: For example, where you have provided your consent to receive certain marketing from us or permit collection and processing of your/your children’s personal information. You can withdraw your consent at any time by notifying us as provided below. You can also click on the “unsubscribe” link at the bottom of any marketing email.
- Our legitimate business interests: Where it is necessary for us to provide the Apps for your use, understand our customers, promote our services and operate effectively as a provider of children’s content and related services, provided in each case that this is done in a legitimate way which does not unduly affect your or your child’s privacy and other rights.
- Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
7.Where we store your personal information
Our Services are primarily provided from the US, so you should understand that when using our Apps you are directly sending your information to US-based Services. In addition, any other personal information that we collect may be transferred to, and stored at, locations outside the country you reside in, including locations that may not have data protection laws as stringent as those in your country (such as the strict laws in the EU/EEA).
Whenever we transfer your/your child’s personal information as described above, we will implement reasonable safeguards designed to protect such personal information and handle it securely, in accordance with this policy. Where applicable, we rely on technical controls, contractual commitments and approved data transfer mechanisms (such as the EU “Standard Contractual Clauses”) to maintain adequate safeguards in the recipient country.
8.How we store and secure your personal information
We take steps to ensure that the personal information we collect is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised.
Where we have collected personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will reasonably endeavor to delete or anonymize your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
We endeavor to only keep personal information while we have an active relationship with you (e.g., ongoing services) and thereafter when needed for business or legal purposes. We may keep anonymised and statistical data indefinitely but take care to ensure that it can no longer identify or be connected to any individual.
9.Do we share personal information with any third parties?
We may share your/your children’s personal information with our vendors (data processors) who may use it strictly as necessary to develop, host and provide the Apps to you, and provide associated services and marketing activities on our behalf.
10.Online user activity
When you use the Apps, the information that we may collect by automated means includes, for example:
- Usage Details about your interaction with our Apps (such as the date, time, and length of visits, and specific content accessed during the visits, frequency of the visits, and other user activity events);
- Device Information including the IP address and other details of a device that you use to connect with our Apps (such as device type and unique device identifier, operating system, mobile network information); and
- Regional information where you or your device provide us with information about your device’s general region.
To provide enhanced privacy protections for our users, Online User Activity is typically anonymized or pseudonymized when used for general analytics or other purposes so it is not associated with you/your child except as necessary to provide the Apps (e.g., account and subscription status for access to paid content).
11.Third party advertisements and sites
Our Apps may display contextual advertisements served by SuperAwesome Trading Limited (“SuperAwesome”) through its platform known as ‘AwesomeAds’, which is designed specifically for younger audiences, including those aged under the age of digital consent. SuperAwesome wants us to share the following additional details with you:
- SuperAwesome temporarily receives limited information from your device to create a “Marker” that is a temporary, unique, one-way hashed value that cannot be reverse engineered to identify an individual. The Marker is used to deliver Ads without SuperAwesome or any third party storing other personal data of users, and to ensure a user does not receive the exact same contextual ad again and again. SuperAwesome may also retain a truncated and anonymized portion of the IP address to identify the general region of users without identifying any actual location.
- AwesomeAds is:
- certified as COPPA-compliant by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. To learn more about the kidSAFE Seal Program, please go to www.kidsafeseal.com for more information;
- a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program. To learn more about this program, please go to https://www.esrb.org/privacy-certified-seals;
- a participant of the CARU® COPPA Safe Harbor Program. To learn more about this program, please go to https://bbbprograms.org/programs/all-programs/children's-advertising-review-unit.
- SuperAwesome acts as a service provider, as defined by the CCPA, and does not use data collected from children under the age of 16 for any purpose other than to provide contextual advertising for our Apps.
We take appropriate technical and organisational measures designed to safeguard our users’ personal information and regularly review our security measures in view of evolving risks and safeguards. Please note that no transmission over the internet can ever be guaranteed secure and we consequently cannot guarantee the security of any personal information that we receive over the Internet.
You must keep your password and any other authentication information for the Apps confidential. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us via the contact information below.
We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.
- Marketing Emails: If you have opted-in to marketing communications, we may contact you periodically via email or through other channels for the purpose of providing announcements, promotional information and/or other general communication. In order to improve our Apps, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we may continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our terms of service.
- Device settings: You device may enable you to disable certain permissions or functionality in our Apps (e.g., location); however, when necessary permissions or functionality are disabled, some features or functionality of our Apps may not function correctly.
- Other rights regarding your information: You have the right in certain jurisdictions (including the EU/EEA, UK, Switzerland, Brazil, California) or under some app stores’ terms to submit a privacy request in regard to your/your children’s personal information. These rights include: the right to withdraw consent or object to the processing of that information for certain purposes; the right to access, receive a copy, or correct that information; and the ability to erase that information. These rights can include: the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing or selling/sharing personal information we have collected about you. In addition, you have the right to ask us not to process your personal information (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us. Please note that we retain information as necessary to fulfil the purposes for which it was collected and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
We will respond to any such request to exercise your rights in accordance with applicable laws and app store rules, and any relevant legal exemptions. If you wish to exercise any of these rights, please contact us via the contact information below. To protect your privacy, we will require verification of your identity before fulfilling any request you make with respect to your personal information. You have a right to not be discriminated against for exercising your rights under applicable privacy laws, and we never discriminate in any way against users who exercise any of these rights. We may offer promotions or contests, and invite you to review such promotion or contest notices for details about the benefits, terms and conditions for such offers. We do not generally assign monetary value to users’ personal information in connection with such activities we engage in.
If you have any issues concerning our compliance with your privacy rights, you may contact our Data Protection Officer at DPO@hasbro.com. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction (such as the UK Information Commissioner’s Office) if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.
- by e-mail to: email@example.com;
- by phone to: +44 (0)20 3691 8600
- or in writing to:
Entertainment One UK Limited
Part Ground and First Floor
2-20 Capper Street,
London WC1E 6JA
Please note that the above email is for privacy-related queries only. For other queries please use the following email addresses:
- for any technical issues and general inquiries: firstname.lastname@example.org