(Last Updated: 08/07/2023)
This Policy and the ESRB certification seals shown on our Services confirm that Hasbro is a valid licensee, and participating member, of the Entertainment Software Rating Board's Privacy Certified Program(“ESRB Privacy Certified”). To protect your privacy, we have voluntarily undertaken this privacy initiative and have had all of our Services where this Policy is posted reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, we are subject to frequent audits of our Services and other enforcement and accountability mechanisms administered independently by the ESRB. If you are a California resident, please see the “Additional disclosures for California residents” section below.
Please note that this Policy applies to any information we collect when you use our Services online or offline.
We ask that you take the time to read this Policy carefully. By using our Services, you agree to this Policy and our Terms and Conditions of Use (“Terms”). If you do not agree with this Policy or the Terms, please do not use the Services.
Table of Contents
1.Changes to this Policy
2.What information is collected from me?
3.How does Hasbro use my information?
4.How does Hasbro handle children’s information?
5.With whom does Hasbro share my personal information?
6.What are my information choices?
7.Security and Retention
8.State-Specific Privacy Disclosures and Rights
1. Changes to this Policy
We encourage you to review this Policy whenever you access the Services to make sure that you understand our information collection, use and disclosure practices. We may change the provisions of this Policy at any time and will indicate when changes have been made by revising the date at the top of this Policy. Your use of the Services, or any portion thereof, following the posting of such changes shall constitute your consent to such changes. If we make material changes to this Policy, we will endeavor to provide you with additional notice of such changes by sending you an email at the last email address that you provided us, or by prominently posting notice of the changes on the Services.If you do not agree with any changes we make, please stop using the Services.
2. What information is collected from me?
Information That You Provide
Hasbro may collect information that you provide when you use the Services, such as when you:
(1) send questions or comments via email or live chat to Hasbro customer support;
(2) fill out online surveys;
(3) sign up for our newsletter or other email alerts;
(4) share a website with a friend;
(5) share a news release through our investor website;
(6) provide information necessary to obtain parental consent; or
(7) otherwise communicate with us through the Services.
Depending on the activity, the types of personal information that we or our service providers collect, including in the last 12 months, may include:
(1) your first and/or last name;
(2) email address
(3) telephone number;
(4) address (including billing address and/or shipping address); and
(5) other contact or identifying information that you choose to provide.
In some cases, we may also collect information you provide about others, such as when you refer someone to our Services (including promotions). We will use this information to fulfill your requests and will not send communications to your contacts unrelated to your requests, unless they separately consent to receive communications from us. If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this policy.
Information We Collect Automatically From You.
When you access or use our Services, we may also automatically collect information about your visit (collectively, “Online User Activity”). When you visit our websites, the personal information we collect is your computer's Internet Protocol (“IP”) address, which we use for the support of our internal operations. Other information we and our service providers may collect includes your operating system, access times, browser type and language, country, and the URL of the website you visited before navigating to our Services. If you access our Services via a mobile device, we may also collect your device make and model, mobile carrier, operating system version, language your device is set to, mobile web browser type and version, the country in which you are using your device, and non-personal analytics and statistical data regarding use of the websites (e.g., downloads, number of users, sessions, frequency of use, retention, territories, and in-game events).
To collect this Online User Activity, we use various technologies, including the following:
We may associate the information we collect from these technologies with other personal information that you provide for the purposes described in this Policy.
Information We Collect from Other Sources
We may also obtain information from other sources and combine that with information we collect through our Services. For example, if you connect with us on a social media service or log into a Hasbro account using a third-party “social sign on”, we may have access to certain information from that party, such as your name, account information and friends, in accordance with the authorization procedures determined by such third-party social networking site.
Third-Party Website Technology and Analytics
3. How does Hasbro use my information?
Use of Information
We use personal information collected through our Services for the purposes described in this Policy or as otherwise disclosed to you on or in connection with our Services. For example, we may use your information to:
We may also use or share information in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing, and improvement of our Services.
4. How does Hasbro handle children’s information?
NOTE TO PARENTS
Hasbro has developed its Services to be an enjoyable experience for users of all ages, including those under 13 (“Child(ren)”). Please discuss this Policy with your Children so that they will better understand how to use the Services and the information they may be asked to provide when using the Services. Hasbro believes that providing its visitors with accurate and adequate notice about the Services will inform choices and decisions about how to use the Services and will better protect its users' privacy. If you have any questions or comments about this Policy, please contact us using the contact information provided at the end of this section.
Hasbro is committed to compliance with the Children’s Online Privacy Protection Act (“COPPA”), a federal law designed to protect Children online. We take Children's privacy seriously and encourage parents to take an active role in protecting their Children's privacy and online experience at all times. As shown on our website, we are Privacy Certified by ESRB for Kids, which indicates that our Services were subject to a third party review to ensure they restrict the collection and use of personal information in compliance with COPPA.
Collection and Use of Children's Personal Information
Hasbro may collect and store certain persistent identifiers (e.g., cookies, IP addresses, etc.) from Children without parental consent for the purpose of supporting the internal operations of the Services or as otherwise permitted under COPPA.
Hasbro may collect and store other personal information about Children if this information is submitted by a Child with prior parental consent or by the parent or guardian of the Child. If a Service is directed to children under COPPA, we may ask users to verify their dates of birth before collecting any personal information from them. Those users that indicate they are Children are either blocked from the activity or taken through a parental consent process.
Hasbro may collect and store the following types of personal information about a Child when submitted by a Child with prior parental consent or by the parent or guardian of the Child: first and/or last name, email address, parent's or guardian's name, and parent's or guardian's email address. Hasbro may also collect the Child's mailing address and/or telephone number when necessary to respond to an inquiry or fulfill a transaction, such as sending the winner of a contest or sweepstakes the awarded prize. Hasbro may also collect demographic information about a Child such as the Child's date of birth, gender, toy and game ownership and other preferences, and combine such information with the Child's personal information. Please refer to the sections entitled "What information is collected from me?" and “How does Hasbro use my information?” for further details on the information we collect and the tools we use to collect it.
When registering an account to play online games, we may collect a username and password from registrants for the purpose of saving that user’s gaming activities (e.g., pets collected in Littlest Pet Shop). Once collected, we may also use the game play information for our internal marketing and demographic studies so that we can improve the products and services we provide our visitors in order to better meet their needs, or as otherwise described in this Policy. Please note that we use aggregated (i.e., non-personal) information for analytics purposes.
Additionally, we are prohibited by COPPA from conditioning a Child's participation in an activity - like contests - on the Child's disclosure of more personal information than is reasonably necessary to participate in the activity. This means that if we don't need a specific piece of information (like the Child's phone number) to allow the Child to participate in a contest, we simply won't ask for it, even with parental consent. To read about the steps Hasbro takes to protect the confidentiality, security, and integrity of all users’ personal information, please see our section on "Security".
Disclosure of Children's Personal Information
We follow our standard policy ("With whom does Hasbro share my personal information?") for the disclosure of personal information collected from and about Children.
A parent who has already given Hasbro permission to collect and use his or her Child's personal information can, at any time, do the following: (1) review, correct, or delete the Child's personal information; and/or (2) discontinue further collection or use of the Child's personal information. To do so, please refer to the confirmation email provided to you when you gave consent or contact Hasbro Consumer Care. Please be sure to include your Child's name and email address, your name and email address, and the name of the site on which your Child is registered. Alternatively, you may contact us at:
Attention: Website Administrator
1027 Newport Avenue, Mailstop A906
Pawtucket, RI 02861
For any other issue, please contact Hasbro Consumer Care. We will be happy to take your request.
5. With whom does Hasbro share my personal information?
Sharing of Information
We do not share your personal information with third parties other than as described in this Policy or in connection with the Services, including:
We may also share aggregated information or information that we have collected from you through the Services, including on co-branded pages and where we have taken reasonable measures to de-identify such information.
Social Sharing Features
The Services may offer third party social sharing features and other integrated tools (such as the Facebook widget), which let you share actions you take on our Services with other media, and vice versa. The use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides these features. The third party provider may also collect other information in connection with your use of their features, including your IP address, which page you are visiting on our Services, and may set a cookie to enable the features to function properly. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these features.
Linking to Third Party Sites
6. What are my information choices?
Regarding Personal Information
If you have registered with our Services, you may at any time review and/or update the contact information we have for you or inform us that you want us to remove your information from our database by either visiting the online profile section of one of our Services or contacting Hasbro Consumer Care. If you choose to send us an email, please be sure to include in your message, the name of the website at which you registered and the email address you used to register so that we can verify your request. We will respond to all access requests as soon as possible.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Regarding Promotional Communications
You may opt out of receiving promotional emails, text messages or mail from Hasbro by declining to receive such communications at the time of registration or at the time you otherwise provide the information to us. You may also opt-out of receiving promotional emails or text messages by following the instructions in those emails or text messages or by sending an email to Hasbro Consumer Care. If you opt out, we may still send you transactional or relationship messages, such as emails about your account or our ongoing business relations.
7. Security and Retention
Hasbro has established a security program with administrative, technical and physical safeguards designed to protect your personal information against loss, misuse and unauthorized access, disclosure, alteration and/or destruction. For example, Hasbro strives to provide only those employees performing a legitimate business function with access to users’ personal information. Hasbro also reviews its security procedures periodically to consider appropriate new technology and updated methods.
Hasbro retains your information based on a number of factors, including (i) for business purposes such as for as long as your account is active, as long as is reasonably necessary to provide you with our products and services, and for the other purposes we use your information as described above, and (ii) as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time.
Despite our efforts, please be aware that no security measure is ever perfect or impenetrable. To that end, Hasbro will notify users of a data breach when Hasbro determines that is reasonably necessary in accordance with applicable law, and you agree to receive such notice via email where possible.
8. State-Specific Privacy Disclosures and Rights
Residents of California, Virginia, Colorado and Connecticut
These additional disclosures currently apply to personal information concerning individuals who reside in California or Virginia, and starting July 1, 2023, also include individuals who reside in Colorado or Connecticut. We anticipate expanding these disclosures and rights to residents of additional states in the future.
The California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), and Connecticut Public Act No. 22-15 (collectively, “State Privacy Laws”) direct businesses (1) provide additional disclosures about privacy practices and (2) offer consumers the right to access, correct or delete their personal information (subject to certain exceptions), as well as the right to opt out of the selling/sharing of personal information, third party targeted advertising, or certain other activities as described further below.
NOTICE OF COLLECTION
In at least the past 12 months, we or our service providers have collected the categories of personal information described above in this Policy in connection with the Services, and as enumerated in one or more State Privacy Laws that includes:
For more information on information we collect, including the sources we receive information from, review the "What information is collected from me?" section. We collect and use these categories of personal information for the business purposes described in the “3. How does Hasbro use my information?” section, including to provide, manage and improve our Services. Hasbro does not generally sell information as the term “sell” is traditionally understood. However, to the extent any of the activities described in the "With whom does Hasbro share my personal information?" section constitute selling or sharing information with third parties, we will comply with State Privacy Laws as to such activity. Specifically, we may share email addresses with third parties for targeted advertising purposes, and may share Online User Activity with third parties who provide cookies and other tools described in the “Information We Collect Automatically From You.” section above for enhanced website functionality, analytics and targeted advertising purposes.
RIGHT TO ACCESS, CORRECT OR DELETE YOUR INFORMATION
You have the right to request access to, and a copy of, the:
You also have a right to request that we delete your personal information (subject to certain exceptions), and request that we correct your personal information if it is inaccurate.
To exercise any of these rights, please submit a request to us by calling our toll-free number at (800) 255-5516, or by completing the request form found here. In the request, please specify which right you are seeking to exercise and the scope of the request. We will endeavor confirm receipt of your request within 10 business days. We may require specific information from you to verify your identity before processing your request, and we may send you a confirmation email that you must respond to before we process the request. Due to our privacy-protective practices, in some instances Hasbro may not have sufficient personal information (e.g., name, email) that would enable us to verify an individual’s identity and complete a request to know or delete information. We aim to complete requests within 45 days, and if needed we may extend the response by another 45 days.
RIGHT TO OPT OUT
You have the right at any time to opt out of (i) selling or sharing of your personal information to third parties, and (ii) third party targeted advertising activities. You may contact us by calling our toll-free number at (800) 255-5516, or emailing us at DPO@hasbro.com, if you have any questions or concerns.
State Privacy Laws may offer other opt-out rights which are inapplicable. In particular, Hasbro does not engage in impactful profiling activities with respect to consumers, and Hasbro does not collect, use or disclose Sensitive Personal Information (such as government identification number, precise geolocation, financial account credentials, etc.) except for the specific purpose(s) that you provide it.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly with you.
If we deny a privacy request, you may appeal the decision to us at DPO@hasbro.com. To the extent possible, please describe the basis for your appeal and if there is any specific personal information that concern you. We will endeavor to provide a prompt response. If we deny your appeal, you can raise concerns with your state’s Office of the Attorney General.
We do not to our knowledge sell or share the personal information of individuals under 16 years of age to third parties, although as described above we may use third parties in connection with Online User Activity in compliance with COPPA.
RIGHT TO NON-DISCRIMINATION
You have the right not to receive discriminatory treatment by us for the exercise of any your rights, and we do not discriminate against anyone for exercising such rights.
NO FINANCIAL INCENTIVES (GENERALLY)
We do not generally provide a loyalty program or other financial incentive in return for the collection or use of personal information under this Policy. On some occasions we may engage in a limited-time marketing event or promotional offer that includes a registration or other collection of personal information, and we will disclose the benefits and terms of that promotion at the time of collection.
SHINE THE LIGHT
California Civil Code Section 1798.83 permits customers of this website who are California residents to request certain information regarding our disclosure of personal information as defined by the statute to our affiliates and third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please call (800) 255-5516 or write us at: Hasbro, Inc., Attention: Website Administrator, 1027 Newport Avenue, Mailstop A906, Pawtucket, RI 02861.
RIGHTS REQUESTS FOR NON-CUSTOMERS
California privacy rights apply to all individuals (not just general customers), including job applicants, current and former employees, contractors and business partners. Due to the nature of these relationships, the collection and use of personal information can vary, but in general terms and in addition to all the disclosures above:
All such individuals who are California residents can request additional information about our privacy practices with respect to their information, as well as submit access, deletion, correction or opt-out requests as described above by contacting us at DPO@hasbro.com. Please provide sufficient information that we can identify you and be aware that we may employ a more extensive authentication process to verify your identity before responding to your request.
For Nevada residents, please note that we do not sell personal information as defined by Nevada law (Ch. 603A, Sec. 1.6). You can submit a request to us regarding the sale of such information via the contact information provided below.
Virginia provides additional rights to Virginia residents through the Virginia Consumer Data Protection Act (“VCDPA”). This section addresses those rights and applies only to Virginia residents. You have the following rights under the VCDPA:
To exercise any of these rights, please contact us through this Form.
Effective July 1, 2023, the Colorado Privacy Act (“CPA”) provides specific rights to Colorado residents. This section addresses those rights and applies only to Colorado residents.
If you are a Colorado resident, you have a right under the CPA to access all of the personal information we have collected from you and that we maintain about you, to obtain a portable copy of that information, and a right to request deletion or correction of that information.
Under the CPA, we must obtain your clear, affirmative consent for:
You may additionally opt out of any sales or processing of any data for which we formerly obtained your consent.
Data Minimization: We must also limit the data we store by reviewing no less than annually whether storage of your information serves a legitimate business purpose and removing that data if no legitimate business purpose is identified.
Re-Obtaining Consent: We may re-seek consent from you if you have previously opted out from processing activities. If you have not interacted with us for at least one year, we are required by the CPA to re-obtain your affirmative consent to process any of your information.
For clarification on any of these rights and requirements or to submit a request for us to access, correct, or delete your information, please contact us through this Form.
Effective July 1, 2023, the Connecticut Data Privacy Act (“CTDPA”) provides specific rights to Connecticut residents. This section addresses those rights and applies only to Connecticut residents.
Under the CTDPA, you have a right to access, correction, and deletion of your personal information. You further have the right to obtain from us a portable copy of your personal data to the extent it is technically feasible for us to provide such a copy.
You may also opt out of processing for:
Consent: We must obtain your direct, clear consent for processing of any sensitive personal information, and must provide an effective method to you for revocation of consent. If we receive a revocation request, we must cease processing your data within 15 days.
Children in Connecticut: We may not process children’s personal data for targeted advertising or sell children’s personal data. We must obtain consent to use personal data for targeted advertising or sell personal data from a person aged 13 to 15 when we have actual knowledge that that person is between 13 and 15.
For clarification on any of these rights and requirements or to submit a request for us to access, correct, or delete your information, please contact us through this Form.
9. Contact Us
If you have questions or concerns regarding this Policy, please contact us using the following contact information:
Attention: Website Administrator
1027 Newport Avenue, Mailstop A906
Pawtucket, RI 02861
As mentioned above, Hasbro is a participant in the ESRB’s Privacy Certified Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB at https://www.esrb.org/privacy/contact.aspx or firstname.lastname@example.org.