HASBRO MOBILE APPLICATION PRIVACY NOTICE

(Last Updated: 20 December 2019)

Hasbro Cares About Your Privacy

 

We're Hasbro, Inc., in the US. We make toys and games that you can find all over the world.

Here, we tell you how we use info and keep it safe whenever you use one of our Apps that we mention below. Please make sure you read everything here carefully and ask a grown up to explain anything you don't understand.

Parents and adults: the sections labeled “FOR GROWN-UPS” provide additional detail and information.

FOR GROWN-UPS: Hasbro, Inc. is an international toy company, headquartered in the United States but with affiliates globally, and Hasbro, Inc. is the controller of any personal information processed for the Mobile Apps.

Our EU Representative is Hasbro UK, Ltd.

This Mobile Privacy Policy (“MPP”) explains how Hasbro, Inc. and its affiliated companies (collectively, “Hasbro”, “we”, “our”, or “us”) collect, use, and disclose information when the mobile applications listed below are used, or any other mobile applications where this MPP is posted or interact with us offline (for instance by contacting Customer Care) regarding the Apps (collectively, the “Mobile Apps” or “Apps”).

If you are a California resident, please see the “Additional Disclosures for California Residents” section below.

 

Who is ESRB and what do they do for Hasbro?

We've asked someone else called the ESRB to check how our Apps use info and keep it safe, and make sure that it's all OK. The ESRB will keep checking our Apps.

FOR GROWN-UPS: This MPP and the “ESRB privacy certified” certification seal shown in the MPP confirms that Hasbro is a valid licensee, and participating member, of the Entertainment Software Rating Board's Privacy Certified Program (“ESRB”). Please see http://www.esrb.org/privacy/index.aspx for more information. To protect your privacy, we have voluntarily undertaken this privacy initiative and have had the Mobile Apps reviewed and certified by ESRB Privacy Certified to meet established online information collection and use practices. As a licensee of this privacy program, we are subject to frequent audits of our Mobile Apps and other enforcement and accountability mechanisms administered independently by the ESRB.

We ask that you take the time to read this MPP carefully.

 

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TABLE OF CONTENTS

  1.    The Apps
  2.    Your Info
  3.    Who Can See Info from the App?
  4.    Where Is Info from the App Kept?
  5.    How Long is Info from the App Kept?
  6.    Note to Parents
  7.    You Have Rights About Your Info and can Complain
  8.    Keeping Your Personal Info Safe
  9.    Additional Disclosures for California Residents
  10.    How to Ask Us Questions
  11.    When Can this Change and How?

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1. The Apps

What we say on this page is only about the Apps named below. And any other Apps of ours where you see all this.

FOR GROWN-UPS: This MPP is effective as of the Last Updated date posted above and applies only to information collected by Hasbro from users of the following Mobile Apps and any other mobile app published by Hasbro which links to the MPP.

 

Beyblade Burst
Dance Code
Equestria Girls
Force Link
Furby Connect World
FurReal Makers: Proto Max
FurReal Friends: Get Up & Go Go
Hanazuki: Full of Treasures
HeroVision: Iron Man
Littlest Pet Shop Your World
Love2Learn Elmo
My Little Pony: Friendship Celebration
NERF Energy Rush
NERF LaserOps Pro
Play-Doh Touch
Smart R2-D2
Star Wars Lightsaber Academy
Star Wars Studio FX
Star Wars Ultimate D-O
Transformers Bee Vision
Transformers: Robots in Disguise
Transformers TCG Companion App

If your App is not named above, we'll tell you about it somewhere else, or it might be someone else's app, not ours, so you should check out what they say about their app and how they use your info.

FOR GROWN-UPS: This MPP does not apply to any other information collected by Hasbro through any other means. For clarity, this MPP does not apply to any of Hasbro’s websites; Hasbro’s other mobile apps that do not link here; Hasbro’s other online services (e.g., social media channels); or any apps, websites, or online services maintained by other companies or organizations to which we may link.

Your use of any mobile app, website, or online service created or maintained by another company is subject to such other company’s applicable privacy policies and terms of use, and we encourage you to read the third-parties’ privacy policies and terms of use before submitting personal or other information or using that mobile app, website, or online service.

 

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2. Your Info

We get some info about the smart device you use to play our Apps (we call this Device Info – more on this below) and how you like to play with the App (we call this Game Info). We get this in a way that means we can't tell who you are in real life. This is because we try hard not to get any personal info about you (like your name or your address), and we try to use your personal info in a way that keeps your info safe.

What we do like to know is how our App is being used, like how long a game is being played for, what country you are playing in and what kind of smart device (maybe your mom's or dad's mobile phone or iPad) you are playing on.

Device Info

We get some info from the smart device you use our App on (maybe your mom's or dad's mobile phone or iPad) to avoid repeat information and make it easy to play with our Apps, but we try to do this in a way that keeps this info safe. We call this “Device Info.

FOR GROWN-UPS: When an App is used for the first time, we create a special identifier (a random alphanumeric code “scrambled ID”, which we term a "Localytics Device ID") which will relate to that App. To do this, we generate the Localytics Device ID from some other random identifiers that are on your mobile device, specifically a temporary random alphanumeric code called an "install ID" and a so-called advertising ID. These elements (which we use to create the new special identifier, the Localytics Device ID) come from your particular mobile device and operating system, but the elements themselves are not collected or transmitted to us or anyone else — only the newly-created Localytics Device ID is collected and used in connection with Device Info and Game Info.

In addition, due to the way in which the Localytics Device ID is generated, it is not possible to work out (i.e. "reverse engineer") your original device advertising ID from your Localytics Device ID. This means that once the Localytics Device ID has been generated, we are no longer able to identify a specific individual in the real world from that identifier. Neither Hasbro nor the user can access the Localytics Device ID on their device. The creation of the Localytics Device ID only occurs the first time the App is opened and is capable of connecting to the Internet and not again unless the App is uninstalled and subsequently reinstalled.

The Localytics Device ID is unique to your particular advertising ID. If you delete our Apps from your device and then install or reinstall one of our Apps again for the same device, the Localytics Device ID will be likely be the same, unless you have also changed your advertising ID in your device settings. If you get the same App for different devices, the Localytics Device ID on each device will be different, even if the same person uses the same App on different devices. The Localytics Device ID in one App does not share with, or “know” about, a Localytics Device ID on another device or platform. However, if you download multiple Apps on one device (i.e. you already have one App on that device and you download a different App on the same device), they may share the same Localytics Device ID.

We do not generally use analytics to compare Localytics Device IDs between Apps; however we do use it to: (i) distinguish one user from another (for counting purposes); (ii) to understand what parts of our Apps are being used; and (iii) to ensure that our Apps are appropriately secure and protected. We do not use Localytics Device IDs in order to treat users any differently, to segment our audiences, to target advertisements or push notifications, and we do not routinely collect anything that could be used in connection with the Localytics Device ID in order to identify the user in the real world.

 

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Our App uses Device Info (like guessing its country and city) to make sure you get the right App in the right language, and to help you use the App and tell you things you might want to know about your App or toy and to help us fix problems with the App like bugs, should they arise.

FOR GROWN-UPS: Hasbro will collect the device type, the device's operating system (like iOS or Android) and language setting, the network carrier that your device uses (e.g., Vodafone, EE, Orange), the Localytics Device ID (so long as the device connects to the Internet) and will guess the country and city (from the network info used by the device).. Hasbro uses this information to work out which version of the App to install on the device, and in which language (e.g., if the device language is set to French, then the French version would be delivered), to provide the user with a suitable App, for performance of our contract or for our legitimate business interests in delivering and maintaining our Apps.

 

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Game Info

We use some info sent from the App to help us figure out how kids or grownups use our App, so we can make it better, easier and more fun to use, and to connect your play experience with other players. We call this info “Game Info.” Game Info may include things you can see and choose in the App, like a Blader ID or a Blaster ID. It also includes various play events and milestones you may come across while playing, to keep track of your progress. We get Game Info whenever you use your App if you have the Internet on. We try hard not to get any personal info about you, like your address. We only want to know how our App is being used, like how long a game is being played for. We often combine Game Info with Device Info to help us find this stuff out – but don't worry, we still won't know who you are in the real world if we do this.

FOR GROWN-UPS: The Localytics Device ID is used to assist us in gathering non-personal analytics and statistical information regarding the use of our Apps and game play data (both Game Info and Device Info), e.g., session length (how long the App was played for), what game levels were reached in the App, whether the app connected to a Hasbro toy, etc. It may also be used to deliver in-App messages about gameplay (see below).

We use this Game Info, which does not identify individual users, in our own legitimate business interests, to analyze trends, to administer our Apps, debug them in case of problems and to gather demographic information about our user base as a whole (e.g., number of users in a particular country or region), so that we can improve our Apps and toys.

Although Game Info is associated with Device Info, including the Localytics Device ID, we do not link this data to users’ personal information. Even knowing a Localytics Device ID, device type, operating system, device language, gameplay statistics, network carrier and estimated city and country together would not be enough to identify the individual who used the App. Nevertheless, Hasbro limits which employees are permitted to see the Localytics Device ID associated with particular data. Our service providers (see below) can only view aggregated data.

Country and language info is used by some Apps to check if Hasbro shows ads in that country (see below) and if so, show contextual ads in the correct language, or suppress them altogether.

 

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Do we need to use this Info?

We only collect and use the info that we've told you about in this MPP and only for the reasons we have told you in this MPP. We only collect the info that we need. Sometimes, if you still don't want us to use this info, you may need to stop using or uninstall the App.

FOR GROWN-UPS: In this MPP we describe the types of personal info we collect and why we need it. In some circumstances, you may still decide that you do not want us to collect and use this info in the way that we have described. If we can provide you with the App functionality without this info, we will let you know and give you the option to choose not to provide us with this information. However, sometimes we cannot provide the App without this personal info and if you decide that you still don't want us to collect and use it, you will have to uninstall and not use the App.

 

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Find What Your App Does

In the line for your App in the chart below, a  (check mark) means we use that type of info. Like, for Beyblade Burst we use the "Multiplayer ID", we know if a Hasbro Ad has been clicked in your App, and so on – all this is explained more just below the chart. We always use Game Info and Device Info for every App on the list.

Mobile AppInformation Used
Multiplayer IDHasbro Ad ClickedIn-app Purchase MadeToy Scanning ActivityToy Connection ActivityIn-app MessagingOther Stuff
RestoreGPSCameraBTLEMedia
Beyblade Burst
 
 
    
Dance Code    
      
Equestria Girls  
       
Force Link 
         
Furby Connect 
      
FurReal Friends: Get Up & Go Go 
         
FurReal Makers: Proto Max 
  
      
Hanazuki   
      
HeroVision: Iron Man 
 
    
  
Littlest Pet Shop: Your World 
       
Love2Learn Elmo 
  
     
My Little Pony: Friendship Celebration   
      
NERF Energy Rush    
    
 
NERF LaserOps Pro
   
  
 
Play-Doh Touch 
       
Smart R2-D2 
  
      
Star Wars Lightsaber Academy 
  
    
 
Star Wars Studio FX 
 
     
Star Wars Ultimate D-O 
  
    
 
Transformers: Bee Vision 
 
    
  
Transformers: Robots in Disguise   
       
Transformers TCG           

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What Does the Chart Mean?

Multiplayer ID

For some Apps like Beyblade Burst or NERF LaserOps Pro, you can choose a game name from a pre-set list and play head-to-head online with other kids over the Internet, set up lists of your friends and track who are the best players. As a part of the Game Info we collect, we keep records of wins and losses for these games, but we don't know who you are from your game name.

FOR GROWN-UPS: Apps like Beyblade Burst and NERF LaserOps Pro allow users to play games with each other online via a third-party game platform (Exit Games's Photon Cloud). This requires use of an additional identifier (the “Blader ID” or for NERF LaserOps Pro, a "Blaster ID" that works in an identical fashion (collectively, "Multiplayer IDs")). A player chooses two fanciful names, one from each of two separate, fixed lists created by Hasbro. The app automatically appends a random number (to distinguish between players who choose the same two-part name). Therefore, the player cannot choose a name with free text that might somehow identify him or herself. A Multiplayer ID is unique to the App but cannot be linked back to the user (other than to play a match through the game interface). The Multiplayer ID is sent with device platform (iOS or Android), a token for authentication with the game server, and the App version number to the game platform. Here, this very limited data set is used to match two players making a request for gameplay in a "game lobby.” No personal information (other than the A Multiplayer ID) is exchanged, and players cannot communicate with each other (there is no “chat” functionality), Hasbro or the game platform.

A Multiplayer ID is stored briefly on our Photon Cloud platform; however, it is not stored on the Photon Cloud platform beyond the session. The session is the length of time for the individual match to play out and finish a single match (see How Long Is Info from the App Kept? below). However, game statistics such as wins-and-losses are retained by Hasbro (with Multiplayer ID) after the session.

Players can create their own leader boards and play leagues on the game platform for players' known friends and for tournaments, which include the Multiplayer ID, listing match rankings. They can edit/delete their personal leader boards, add/remove friends by their Multiplayer ID, etc. Players can also join regional leaderboards when they play tournaments and matches.

 

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Hasbro Ad Clicked

When you use our App, we might show you adverts about other apps or toys that we make. Sometimes, if you watch an ad, you can get more stuff for your App for free.

Our App tells us if someone using your App clicked on an ad shown in the App, but not your name or who you are. We also don’t send ads to you based on how you act in the App.

FOR GROWN-UPS: Our Apps only show ads for Hasbro products and services, and related events such as Beyblade contests, but not any third-party's ads.

This metric means that someone using an App has clicked on a Hasbro ad. We only get sent information on whether someone has clicked on a particular ad in an App, along with the App's Localytics Device ID. Again, no advertising ID or other info is sent with the Localytics Device ID, apart from Device Info. We don't know who clicked on an ad. We do not target ads to you or send you ads based on user behavior.

 

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In-app Purchase Made

Do we sell you anything in the App?

Sometimes you can buy stuff to use in our Apps. Make sure you get your mom or dad to say it's OK for you to buy more stuff first! Our App tells us if someone using the App bought anything from it, but not your name or who you are.

If you buy stuff for one of our Apps, you’re buying it through the App stores, not us. You should check what they say about your information. If you go to an app store or another website from our App, we'll tell you that it's not ours.

If you buy stuff in one of our Apps, we don't get info about how it's paid or who bought it. We just get told which App to send the stuff to.

FOR GROWN-UPS: This means a purchase of virtual products for use in the relevant App, or other Apps. This ability is offered by some of our Apps (with ✓ (checkmark) against "In-app Purchase Made" in the chart above). We only sell Hasbro in-app virtual items related to the App in question, we don't sell or market any third-party products.

If making such a purchase, your credit card or other payment information will be collected and processed by the third-party service provider (e.g. Google Play, Apple App Store, Amazon, PayPal), but is never passed on to us.

We will notify you when you are leaving the App or otherwise indicate that you will be going to another company's site or app.

 

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Toy Scanning Activity

With some Apps, you can use the camera on your device to view a special design or “code” on your toy to get more stuff for your game. That's a Toy/Code Scan.

We use the scan only to give you that stuff in the App and it does not save a picture anywhere. The App doesn't send a photo to us or anyone else and we don't use the scan for anything else. We do get told that your App did a Toy/Code Scan and the stuff that it unlocked, but that's it.

FOR GROWN-UPS: Some of the Apps may also access the device’s camera to scan a code from one of our branded toys and/or from other promotional materials, which is noted in the “Toy Scanning Activity” column of the chart above.

For clarity, this code scan information may be used by Hasbro to, for example: unlock an in-game character, or unlock an in-game item (e.g., an in-game character accessory or improvement/enhancement to show game progression).

The fact that a code was scanned is sent to us with the Localytics Device ID and the name of the virtual item unlocked.

 

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Toy Connection Activity

In some Apps like Furby Connect, you can get your App to send stuff to your toy, like a new song. Or in other cases, you may use the App to control your toy or to change what it does. Or by playing with your toy with the app open, as with Hanazuki, it opens and uses in-App items and abilities.

We get told if this happened and what stuff was sent to the toy.

FOR GROWN-UPS: This means that the App has connected to a Hasbro toy over Bluetooth, for example to deliver content like a new song to the toy. We get sent this info with the Localytics Device ID. Some of our toys may use RFID or audio watermarking instead of Bluetooth to achieve the same general purpose of providing an interaction between the toy and the App. Neither of these technologies share any data with us or transmit any sensitive data and are merely a communication protocol between the App and the toy designed to work with the App.

Our Apps can be used to send new content etc., to our toys. Some Apps can "remote control" a toy over Bluetooth, but nothing from any toy other than Game Info is sent back to any App. Some of our Apps can also send firmware updates to the toy, but only if you deliberately do so. Our firmware updates are primarily intended to allow the App to continue to be used with the toy should the device operating system be upgraded or if the App is updated with new game features.

We do not use the device's Bluetooth or other communications functions for anything other than the game play the App and connected toy are expected to do as described on the instructions, packaging or other promotional material.

 

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In-app Messaging

Your App can tell you things like there's a video you haven't watched yet or if there’s something new you can do or try in the App.

FOR GROWN-UPS: Some of the Mobile Apps may send local notifications to a user’s device. Local notifications operate differently from “push” notifications. Specifically, local notifications are messages delivered directly through the Mobile App and do not require collection or use of user personal information (other than the use of Localytics Device ID, solely for the purpose of noting that the message was triggered and sent). For example, a local notification may let users know that they have an unwatched video or that, based on a timer automatically run within the App, that Furblings are ready to hatch.

 

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OTHER STUFF

Restore Code

If you have Beyblade Burst you can write down a code that the App displays on your user profile page. If you ever delete your App, you can use this code to restore all of your progress in the App.

FOR GROWN-UPS: The “Restore Code” is associated with the Game Info Hasbro stores on its private AWS game hosting data base. It allows players to return their App to its last current state. The Restore Code is automatically generated by the App on first running. It is provided as a convenience for players to have a way of restoring their game if a player deletes the App from his or her device. A player may not restore someone else’s game or lookup Restore Codes. Hasbro only knows about in-game progress from the restore code.

 

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If you have NERF LaserOps, when you get together with your friends to play a game with your blasters, there is a “radar” power-up feature that uses your smart phone GPS info. We do not see this info, share it, or send it or your real-world location to anyone, including the other players. You can turn off the GPS functionality at any time. Ask your parents to help. If you do turn off GPS, the app won’t be able to use the radar power up.

FOR GROWN-UPS: Each player’s app will check to see where it is, but it only uses this information locally, within the device itself. Each app will compare how far away it is from where the match began, without reference to real-world GPS coordinates. Each app does use GPS to know how far it has moved from the game origin, but it does it in a way that does not share real-world GPS coordinates with the other players, with Hasbro or with any third parties. This feature is only used for multiplayer game play fun, and for no other reason. You may switch the GPS setting for this app on or off at any time by finding the app in your device settings and switching it on or off there.

 

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If you have NERF LaserOps, you can use the camera on your device to view your surroundings and shoot down enemy drones from your device. We cannot see what is shown on your camera and we can't see any of your pictures.

FOR GROWN-UPS: The NERF LaserOps App also lets the user interact with augmented reality play in single-player mode. This works by the player choosing to allow the App to access to the device's camera. The player can then use the App to “see” computer-generated enemy drones, overlaid on the device screen camera view, which the player can shoot down in the App. For the best user functionality, players will normally mount their devices onto the cradle on the blaster toy; however, players can use this function of the App without a blaster toy. Neither Hasbro nor anyone else has access to, or use of, the camera and/or any photos or videos created with the camera or stored on the mobile device. We do not collect information via the user's camera and we will not have access to their photos or photo roll.

 

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If you have NERF LaserOps, you can save info about your game play on your blaster.

FOR GROWN-UPS: The NERF LaserOps App uses Bluetooth Low Energy (BTLE) in order to send information between the App and the blaster toy. For example, with NERF Laser Ops the App will use BTLE to send Game Info about blaster virtual status, shots, hits and so on. This information is then stored on the blaster - we do not collect or have access to this information.

 

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If you have My Little Pony: Friendship Celebration or Love2Learn Elmo, you can take photos and save them on your device. But our App doesn't send the photos to us or anyone else.

FOR GROWN-UPS: Love2Learn Elmo (aka Fun2Learn Elmo) and My Little Pony: Friendship Celebration Apps give users the ability to take pictures and save them to an in-app photo album or to the user’s mobile device and these pictures are not saved with additional "metadata" (when the photo was taken, where etc.) and are not collected or shared by us. Nor do we encourage you to share these with others. Note that these are saved to your device’s photo application for your own private use and as such, will consume memory in proportion to the size of the image file(s).

 

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If you have Hasbro Star Wars Studio FX App, you can take videos and save them on your device. But our App doesn't send the video to us or anyone else.

FOR GROWN-UPS: Hasbro Star Wars Studio FX App gives users the ability to take video clip recordings with audio and visual effects and save them locally to the app or to the user’s mobile device; however, these video clips are not shared with users through the app and are not collected or shared by us. Nor do we encourage you to share these with others.

 

We don't get or use photos, recordings or videos on your device.

FOR GROWN-UPS: We do not get sent, or have access to, the images in the device’s image library or audio or video recordings in the device's audio or video libraries.

We do not use the camera on the device for anything else and we do not use any other features or functions of the device unless necessary in using the App (e.g., Love2Learn Elmo photos above).

Our Mobile Apps do not take screen shots of activity on the device or perform similar activities.

All Apps can access wi-fi for updates and periodically may send Device Info and Game Info to us.

 

3. Who Can See Info from the App?

We let other people and companies see Device Info and Game Info, to help us keep the App going and make it more fun.

We might have to use info from our App for other good reasons. For example, to protect you, us or someone else, or if the law or police make us use it for something. We can’t imagine that could happen with the info we use, but if it does, we’ll tell you about it if we can.

FOR GROWN-UPS: We use a service provider, Localytics, to assist us in gathering analytics and statistical data in connection with the Mobile Apps (the Device Info) and to help us to display ads in some Apps.

We use Microsoft Power BI (Microsoft, Inc.) to provide a dashboard for Hasbro employees to generate reports from the aggregated Device Info and Game Info.

We use Amazon Web Services (Amazon.com, Inc.) to store content like videos and ads to display in our Apps and Game Info in Hasbro’s own private area of storage within AWS.

For some Apps we use YouTube to store and send Hasbro-curated videos for display in the App from Hasbro's YouTube channel, but we have made efforts to design this so that Google does not receive any information from the App other than the information needed to send the video, as we only use the YouTube API to provide the raw video feed that we control on our own YouTube channel (i.e., we are able to disable hyperlinks to other videos or webpages, or even indicating that the videos are coming from our YouTube channel, prevent the display of advertising, whether pre- or post-roll or around the video frame, and prevent the setting of web browser cookies or beacons on your App or device from YouTube using this method).

For multiplayer games like Beyblade Burst, or Nerf LaserOps we use Exit Games's Photon Cloud online multiplayer gaming platform. Match stats associated with your Multiplayer ID are sent to our Amazon Web Services storage for purposes of keeping the results of matches for you and other players in your App and displaying progress in leaderboards to you and other players.

United States users only: Please note that the analytics and statistical data collected via our NERF Energy App is shared with UnitedHealthCare; however, this data is used for monitoring the internal operations of the NERF Energy App only and is not linked to an individual’s health records or other personal information.

We do not share your personal information with third-parties other than as described in this MPP, or in connection with the Mobile Apps, including:

With our group companies, vendors, consultants and other service providers or partners who are working on our behalf on the Apps and need access to your information to carry out their work for us. These entities (including those mentioned above) have agreed to maintain the confidentiality, security, and integrity of the personal information they obtain from us, and not to use your personal information for any purpose other than as described in this MPP or as required or permitted by applicable law.

When we believe it 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 the rights and property of Hasbro and our employees, agents, users and other third-parties, including to enforce our agreements, policies and the Terms and Conditions of Use for the applicable Mobile App and protect against fraudulent, abusive, inappropriate, or unlawful use of the Mobile Apps or our products; and (iii) protect your vital interests or those of any other person or to protect the safety of Hasbro, our users or any third-party; and in connection with, or during negotiations of, any actual or proposed merger, sale of company assets, bankruptcy or reorganization, financing or acquisition of all or a portion of our business to another company, provided that we inform the buyer it must use any of your personal information only for the purposes disclosed in this MPP.

With your consent, to any other person.

 

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4. Where Is Info from the App Kept?

We limit the info we get to Device Info and Game Info, we try hard not to get personal info like your address.

But if you want to know, we store Device Info and Game Info in the United States. If we decide to keep the Game Info somewhere else, we'll make sure that is allowed.

FOR GROWN-UPS: We strive not to collect any personal information, as described above.

We keep the Game Info from all Apps in the United States, and also other countries where we have other offices or where our service providers are located. These countries may have data protection laws that are different from the laws of your country. However, we have taken safeguards to require that any personal information we may collect will remain protected in accordance with this MPP. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

 

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5. How Long is Info from the App Kept?

We limit the info we get to Game Info, we try hard not to get personal info like your address. But in case you want to know, we generally get rid of all Game Info after we no longer have a need for it.

FOR GROWN-UPS: We strive not to collect any personal information, as described above.

If we do have any of your personal information relating to the App, we retain your personal information for as long as reasonably necessary to fulfill the purposes outlined in this MPP and in accordance with our retention policies, as applicable, unless a longer retention period is required by applicable laws and/or regulations.

For Beyblade Burst, once the short player matching session is over, data sent to the Photon Cloud is destroyed (except if there was a connection error, then the data is kept for problem solving purposes for 14 days). After a match, game stats including win/loss etc. and Multiplayer ID are sent to Hasbro.

 

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6. Note to Parents

If you're not 16 years old yet, please ask your mom or dad to look at this bit.

FOR GROWN-UPS: Hasbro has developed the Mobile Apps to be an enjoyable experience for users, including those under 16. Please discuss this MPP with your children who are under 16 so that they will better understand how to use the Mobile Apps and what information they may be asked to provide when using the Mobile Apps. Hasbro believes that providing its visitors with accurate and adequate notice about the Mobile Apps will inform choices and decisions about how to use the Mobile Apps and will better protect its users' privacy. If you have any questions or comments about this MPP, please contact us using the contact information provided below.

Hasbro takes the protection of children's privacy very seriously and is committed to compliance with the Children’s Online Privacy Protection Act (“COPPA”), a US law designed to protect kids online. We also encourage parents to take an active role in protecting their children's privacy and online experience at all times. Except as otherwise outlined in this MPP, we do not collect personal information from our users.

 

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7. You Have Rights About Your Info & Can Complain

We explained that we try not to collect any personal info about you like your address. In fact, we make sure that we can't identify you in the real world from any of the personal info we collect about you. Because of this, we are not able to retrieve or delete Game Info or Device Info about you, because we are not able to link your Game Info or Device Info to any information we hold about you (so, we can't find it!). However, if you are worried about how we use your personal info, or if you have any questions, we will do everything we can to help you. If you think we have your personal info, get your mom or dad to ask us about the next bit (your "rights"):

  • If you're in Europe, you have "rights" about your info. This means you can make us do some things with your personal info or stop us doing some other things with your info, and you can complain if you don't like what we're doing with your info.
  • We have tried very hard to make sure that we don't get any of your personal info, we try to limit it to Device Info and Game Info.
  • But if we have any of your personal info and you're in a country that has these rights, you can make us:
    • Tell you what info we have about you and what we do with it
    • Fix your personal info if it's wrong
    • Stop us doing some things with some of your personal info
    • Not use your personal info while some other things are being sorted out
    • Take your personal info away from us and send it to someone else
    • Not show you some marketing ads.

If you want to ask us about any of these things, just see below on how to reach us.

If you want to understand more it might be good to ask your mom and dad to help you and explain all this.

FOR GROWN-UPS: Reviewing, Updating, or Deleting Your (or Your Child’s) Information: As previously mentioned, except as otherwise noted in this MPP we do not collect the personal information of our individual users. However, if you believe that our App may have unintentionally collected your and/or your child’s personal information, you may contact us using the details below. We will be happy to honor your request.

If you are a resident of the European Economic Area, and if we do have any of your personal information or your child's (together, personal information), then the following data protection rights apply:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to Ask Us a Question” heading below.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to Ask Us a Question” heading below.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to Ask Us a Question” heading below.
  • 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 following rights in relation to your personal information: (i) to access, correct, update or request deletion of it; (ii) to object to processing of your personal information; (iii) to ask us to restrict processing of it; (iv) to request portability of it; and (v) to opt-out of marketing communications. You can exercise these rights by contacting us using the contact details provided below. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We will respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

 

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8. Keeping Your Personal Info Safe

We try not to get any of your personal info. But we do things meant to keep safe any personal info and Device Info that we might get.

FOR GROWN-UPS: We strive not to collect any personal information, as described above. However, Hasbro has established policies in an effort to protect any personal information it may have 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 personal information. Hasbro also reviews its security procedures periodically to consider appropriate new technology and updated methods.

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 affecting any of their personal information that Hasbro may have, as necessary in accordance with applicable law.

 

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9. Additional Disclosures for California Residents

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

CALIFORNIA NOTICE OF COLLECTION

In the past 12 months, we or our service providers have collected the following categories of personal information enumerated in the CCPA in connection with the Apps:

  • Identifiers, including an ID number associated with your Device Info and your Game Info.

For more information on information we collect, Device Info and Game Info, including the sources we receive information from, review the “Your Info” section above. We collect and use these categories of personal information for the business purposes described in the “Your Info” section, including to provide, manage and improve our Apps.

RIGHT TO KNOW AND DELETE

If you are a California resident, you have the right to delete personal information we have collected about you and you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the:

  • categories of personal information we have collected about you;
  • categories of sources from which the personal information was collected;
  • categories of personal information about you we disclosed for a business purpose or sold;
  • categories of third parties to whom the personal information was sold or disclosed for a business purpose;
  • business or commercial purpose for collecting or selling the personal information; and
  • specific pieces of personal information we have collected about you

To exercise any of these rights, please submit a request to us by calling our toll-free number at (800) 255-5516 or emailing us at DPO@hasbro.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

RIGHT TO OPT OUT

Under the California Consumer Privacy Act, you have the right to opt out of the sale of your personal information to third parties at any time.

Hasbro does not and will not sell (as that term is defined in the CCPA) personal information in connection with the use of our Apps covered by this MPP.

AUTHORIZED AGENT

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.

RIGHT TO NON-DISCRIMINATION

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

SHINE THE LIGHT

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. We do not knowingly share personal information collected by Hasbro via the Mobile Apps with third-parties for their direct marketing purposes. If you have any questions regarding our disclosure policy, however, please contact us at:

Hasbro, Inc.
Attn: App Administrator
1027 Newport Avenue, Mailstop A906
Pawtucket, RI 02861
(800) 255-5516

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10. How to Ask Us a Question

We hope we have helped you to understand how we use your information. If you want to know more, you can click here to ask us anything, or get your mom or dad to call us, send us an email or send us a letter using the info below:

FOR GROWN-UPS: Contact Us:

If you have questions or concerns regarding this MPP, e.g. if you believe that our App may have unintentionally collected your and/or your child’s personal information, please contact us at:

For parents and consumers who are located outside of the United States:

Email: consumer_affairs@hasbro.co.uk

Free phone: 00800 2242 72 76

Or write to us at:

Hasbro Consumer Affairs Department
PO Box 43
Newport
Gwent NP19 4YH

For DPO requests, please contact us at DPO@hasbro.com

For parents and consumers who are located within the United States:

Hasbro, Inc.
Attn: App Administrator
1027 Newport Avenue, Mailstop A906
Pawtucket, RI 02861
(800) 255-5516

For any other issues, please contact http://corporate.hasbro.com/en-us/consumer-care.

As mentioned above, Hasbro is a licensee of 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:

ESRB
privacy@esrb.org

 

If you have a disability and would like to access this MPP in an alternative format, please contact us at (800) 255-5516 or email consumercare@hasbro.com.

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11. When Can this Change and How?

We might change what we say here. The date at the top shows the last date we did this.

FOR GROWN-UPS: We may change the provisions of this MPP at any time (such as in response to changing legal, technical or business developments) and will indicate when changes have been made by revising the date at the top of this MPP. When we update this MPP, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material MPP changes if and where this is required by applicable data protection laws.

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