(Last Updated August 1,2019)
BACKFLIP'S PRIVACY COMMITMENT
- Children’s Privacy
- Note to Parents
- The Types of Information We Collect From Children
- How We Use Children’s Information
- Other Sections Applicable To Children’s Information
- THE TYPES OF INFORMATION COLLECTED THROUGH OUR APPS AND OUR ADS
- How We Use Your Information
- Who We Share Your Information With
- Our Legal Basis For Processing Your Information (for EEA visitors)
- How We Keep Your Information Secure
- International Data Transfers
- How Long We Keep Your Information
- Your Choices and Rights To Your Information
- Your California Privacy Rights
- How To Contact Us
- CHILDREN’S PRIVACY
Note to Parents
Some of our Apps involve strategic or competitive gameplay and are targeted toward experienced gamers, and some are intended for a broader audience. We recognize that children may enjoy playing some of our Apps and include age gates in those experiences. When a user indicates that the user is a child through an in-App age gate, we make efforts to avoid collecting information from that user, except in those instances under the Children’s Online Privacy Protection Act (COPPA) and COPPA Rule or other applicable laws where information may be collected from children (as “child” or “children” is defined under such laws) without parental consent.
Information Collected From Children
- Information Children Provide. We collect information that children provide to us in-App for feedback or to contact us (for support requests, for example). If children provide any personal information in queries or support requests, we use that information solely to assist them in response to the applicable query or support request.
- Information Automatically Collected From Devices. When children use one of our Apps, we and some of our service providers automatically collect certain information from the device the App is installed on to maintain and analyze the functioning of the App, and for other purposes to support the internal operations of the App. This information includes the following:
- The Device ID (or "DID") associated with the device used to access the App. We may store or associate the DID or other unique IDs generated by us or our analytics service providers for an App installation with a child’s contact information when the child contacts us for support for purposes of addressing and responding to that support request.
- IP address
- Game Store ID. This is the ID associated with a device by the platform provider of the app store accessible via that device.
- Media Access Control (or MAC) address. This is an assigned ID that makes the device uniquely identifiable on a network.
- Open Device Identification Number (or ODIN). This is a unique ID related to the device’s MAC address.
- The general location of the device (country and state level) based on IP address from the device's network.
We also collect some general information from a device such as device type, operating system, device language, application software, and other metadata (such as timestamps) about use of the App and may connect it with the DID or other information described above.
- Information about Gameplay. We and some of our service providers gather analytics and statistical information about use of an App and gameplay data, such as session start, end, and length (when and for how long the App was played), what levels were reached in the App, and what (if any) in-App items were purchased by a user, or sent from one user to another. We use this information to administer our Apps, to analyze trends in user interactions with App features, to debug our Apps in case of problems, and to gather information about our user base as a whole (for example, number of users in a particular country or region), so that we can improve our Apps.
Some of the information described above in the “Information Automatically Collected From Devices” and "Information about Gameplay” sections may be collected by us or our service providers using cookies and other tracking technologies.
How We Use Children’s Information
- We use children’s information collected through our Apps as described above, and to otherwise support the internal operation of our Apps. For example, we use this information to track available in-App currency, to save gameplay levels, and to permit access to gameplay across different devices. Our Apps do not display advertising to users who have indicated they are children.
4. Who We Share Your Information With
5. Our Legal Basis For Processing Your Information (for EEA visitors)
6. How We Keep Your Information Secure
7. International Data Transfers
8. How Long We Keep Your Information
9. Your Choices and Rights To Your Information
10. Your California Privacy Rights
12. How To Contact Us
- THE TYPES OF INFORMATION COLLECTED THROUGH OUR APPS AND OUR ADS
Information You Provide
We collect any information that you provide directly to us through use of one or more of our Apps, whether you provide that information through gameplay or other in-App interactions, such as contacting us for support, providing feedback about App features or functionality, responding to a survey, or engaging with other users of our Apps in-game. This information may include:
- Your name
- Your email address
- Account IDs and other information associated with your accounts with Social Networking Services that you use in connection with our Apps (described in more detail below)
- Your survey responses
- Your feedback
- Information you provide through text boxes or fields in our Apps, or through other features of our Apps (for example, when you name App features, or when you send in-App items to or otherwise interact with your friends or teammates in an App)
We may also ask for your birthdate and collect your age in some of our Apps to determine which App features to make available to you. We do not keep the birthdate you enter, but we do use general age information in certain of our Apps in an effort to provide you and other users with appropriate in-App experiences.
Automatically Collected Information
When you use one of our Apps, we and some of our service providers and partners automatically collect certain information, including the following:
- Your Device ID (or "DID"). This is a unique identifier for the device you use to access our Apps. We may store or associate your DID or other unique IDs generated by us or our service providers for an App installation with your contact information when you contact us for support. We or our service providers or advertising networks and vendors may also store or associate your DID with other unique IDs generated or used in connection with analytics and advertising services.
- Your IP address
- Your Advertising ID (or "Ad ID"). This is a unique ID that your device’s operating system provides that we and advertising networks and vendors use to show you relevant ads in some of our Apps and in apps and online services operated by others, and to link an App installation on your device to a particular ad campaign.
- Your Game Store ID. This is the ID associated with your account by the platform provider of the app store accessible via your device.
- Your Device’s Media Access Control (or MAC) address. This is an assigned ID that makes your device uniquely identifiable on a network.
- Your Device’s Open Device Identification Number (or ODIN). This is a unique ID related to your device’s MAC address.
- Unique IDs assigned to you by our analytics service providers and advertising networks and vendors
- IDs associated with your accounts with Social Networking Services
- Your general location (country and state level) based on your IP address.
We also collect some general information from your device such as device type, operating system, device language, application software version, and other metadata (such as timestamps) about your use of our Apps and may connect that information with your DID or the other information described above.
Our Apps may periodically examine apps on your device to determine if you have installed other Backflip Apps. The Apps transmit the results of that examination to Backflip and our advertising partners to be used in targeting advertisements to your device. For example, if you have PaperToss and NinJump installed on your device, when you play PaperToss, we will not send you ads for NinJump and will instead send you other, more relevant ads.
- Information About Gameplay
We and some of our service providers gather analytics and statistical information about use of an App and gameplay data, such as session start, end, and length (when and for how long the App was played), what levels were reached in the App, and what (if any) in-App items were purchased by a user, or sent from one user to another. We use this information to administer our Apps, to analyze trends in user interactions with App features, to debug our Apps in case of problems, to gather information about groups of our users, as well as our user base as a whole (for example, number of users in a particular country or region), and to show relevant ads and in-App features and items to you and users like you, so that we can improve our Apps and user experiences with them.
- Information about In-App Purchases
If you make any in-App purchases for yourself or your child, we also automatically collect or receive information related to those purchases from the platform provider (e.g., Apple or Google). This may include:
- Your name, Game Store ID, or other ID associated with your account with the platform provider
- The item purchased, and its cost
- The name of the App you were visiting
- Confirmation from the app store of completion of purchase
- Information Collected By and From Service Providers and Third Parties
We work with a number of service providers and third parties who collect information via our Apps and Our Ads (as defined below), including:
- Advertising Networks and Vendors. We may receive information from advertising networks and vendors that create and place advertisements for us on third party websites, apps, and other online services (“Our Ads”), and from service providers and vendors we work with for ad attribution purposes. This could include information about the overall effectiveness of Backflip’s advertising campaigns, such as general information on the number of people who have clicked on one of Our Ads and who have downloaded one of our Apps via Our Ads, as well as information about how you have interacted with one of Our Ads, and when you have clicked on one of Our Ads, installed one of our Apps, and launched the App after viewing or clicking on one of Our Ads. We and our ad networks and vendors may collect this information via cookies and other tracking technologies embedded in our Ads, and we may combine the information collected via Our Ads with other information we collect via our Apps.
- Analytics Service Providers. We may also receive information about gameplay and your other interactions with our Apps from companies that provide analytics services regarding use of our Apps, as described above in the “Information about Gameplay” section.
If you would like more information about this practice and to know your choices about use of your information for behavioral advertising by certain ad networks and other members of the Network Advertising Initiative and the Digital Advertising Alliance, you can visit http://www.networkadvertising.org/choices and http://www.aboutads.info/appchoices. Backflip is not responsible for the effectiveness of, or compliance with, any third parties' opt-out options or programs or the accuracy of their statements regarding their opt-out options or programs.
- HOW WE USE YOUR INFORMATION
- to operate and improve our Apps, products, and services;
- to understand you and your preferences, to enhance your and other users’ experiences with and enjoyment of our Apps and related products and services;
- to send you push notifications;
- to respond to your comments and questions and provide customer service;
- to track (via your DID or other unique ID that we or our service providers generate or assign) your in-App currency and other virtual items, to save your scores and gameplay levels, to match you with opponents at similar levels of gameplay in Apps with competitive player vs. player or player vs. environment experiences, to permit you to access gameplay across different devices, and to provide the services you request;
- to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- to communicate with you about new promotions, rewards, upcoming events, and other news about products and services offered by Backflip and our selected partners;
- to facilitate our ad networks’ display of Our Ads to you and others in third party apps and online services, and relevant ads for third party apps to you in our Apps;
- to associate your installation of an App with one of Our Ads from a particular ad campaign (if applicable), for purposes of ad attribution; and
- to link or combine it with other information we get from third parties, to help us understand the needs and preferences of you and other users, and to provide you and other users with better service.
- WHO WE SHARE YOUR INFORMATION WITH
We may disclose your personal information to the following categories of recipients:
- to our group companies, for internal business purposes.
- to any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary or appropriate to (i) comply with applicable law or regulation or legal process or to respond to lawful requests of competent legal authorities, (ii) exercise, establish, defend, or protect our legal rights, including to enforce our agreements, policies and the Terms of Service for the applicable App and protect against fraudulent, abusive, inappropriate, or unlawful use of an App, or (iii) protect your vital interests or those of any other person or to protect the safety of Backflip and our group companies, our or their users, or any third party.
- to any other person or entity, with your consent (or your parent or guardian’s consent, if you are a child) to the disclosure.
- OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION (FOR EEA VISITORS)
If you are a user from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above depends on the personal information concerned and the specific context in which we collect it. However, we normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as our Terms of Service), (ii) where the processing is in our legitimate interests, or (iii) where we have your consent (or your parent or guardian’s consent, if you are a child) to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Apps, or communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
- HOW WE KEEP YOUR INFORMATION SECURE
We use and periodically review our technical and organisational security measures in an effort to protect the personal information that we collect and process about you. For example, Backflip strives to provide only those employees performing a legitimate business function with access to users’ personal information.
Despite our efforts, please be aware that no security measure is ever perfect or impenetrable. To that end, Backflip will notify users of a data breach when Backflip determines that is reasonably necessary in accordance with applicable law.
- INTERNATIONAL DATA TRANSFERS
- HOW LONG WE KEEP YOUR INFORMATION
We retain personal information we collect from you for legitimate business purposes, and/or as long as is reasonably necessary to provide you with access to our Apps or our other products or services. How long we retain your personal information will vary and will be determined by the following criteria:
- The purpose for which we are using it—Backflip will need to keep your personal information for as long as it is necessary for that purpose.
- Legal and regulatory obligations—Laws and regulations may set a minimum period for which Backflip will need to keep your personal information, and we will retain your information as reasonably necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- YOUR CHOICES AND RIGHTS TO YOUR INFORMATION
If you are a resident of the EEA, you have the data protection rights described below. If you want to exercise these rights, you can do so by contacting us using the contact details provided under the “How to contact us” heading below:
- You can access, correct, update, or request deletion of your personal information. Please note that there may be circumstances where you ask us to delete your personal information but we are legally entitled to retain it.
- In addition, you can object to processing of your personal information, or ask us to restrict processing of your personal information. Please note that there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
- In some circumstances, you can also request to receive some of your personal information in a structured, commonly used and machine-readable format and/or request that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to us.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority if you think that any of your rights have been infringed by us.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
You can opt-out of marketing communications we send you at any time by clicking on the “unsubscribe” or “opt-out” link in any marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing, if applicable), please contact us using the contact details provided under the “How to contact us” heading below.
- YOUR CALIFORNIA PRIVACY RIGHTS
Since 2005, California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident and would like this information, please contact us using the details set out under the "How to contact us" section below.
- HOW TO CONTACT US
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
Backflip Studios, LLC
Attn: Legal Department 1690 38th St.
Boulder, CO 80301
The data controller of your personal information is Backflip Studios, LLC.
For DPO requests, please contact us at DPO@hasbro.com.