Deadpool’s Head: Mobile Application Privacy Notice & Policy

(Last Updated: 29 June 2020)

Hasbro Cares About Your Privacy

                                                                                                   

Hasbro, Inc. is an international toy company, headquartered in the United States but with affiliates globally. Hasbro, Inc. is the controller of any personal information processed for the mobile applications listed below and any other mobile applications where this Mobile Privacy Policy (“MPP”) is posted (collectively, the “Mobile App(s)” or “App(s)”).

Our EU Representative is Hasbro UK, Ltd.

This MPP explains how Hasbro, Inc. and its affiliated companies (collectively, “Hasbro”, “we”, “our”, or “us”) collect, use, and disclose information when the Mobile Apps are used.

NOTE: the Deadpool’s Head App and the related product, the Marvel Legends Deadpool’s Head Premium Interactive Head, are solely intended for an adult audience of at least the age of 17.

Who is ESRB and what do they do for Hasbro?

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 https://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 that display an ESRB Privacy Certified seal 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 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.

 

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.        If You’re in California

10.    How to Ask Us a Question

11.    When Can this Change and How?

 

1.   The App

This MPP is effective as of the Last Updated date posted above and applies only to information collected by Hasbro from users of the Deadpool’s Head mobile application and any other mobile app published by Hasbro which links to the MPP.

Deadpool’s Head

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 third-party mobile app, website, or online service is subject to such third-party’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.

 

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. We also get some info about 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 you use our App, like how long you play a game, what country you are playing in and what kind of smart device you are playing on.

 

Device Info

We get some info from the smart device you use our App on 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.”

 

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.  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 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 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.

 

Our App use Device Info, like the device’s country and city, to make sure you get the right App in the right language.  Our App also uses Device Info to help you use the App and tell you things you might want to know about the App or toy.  And, if there is a problem with the App, like a bug, your Device Info helps us fix it.

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.

 

Game Info

We use some info sent from the App to help us figure out how players 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.”  It may include things to help us keep track of your progress, like when you complete a level or reach a new milestone in the App.  And it includes info on how long and how often you play with the App, so that we know if we are doing a good job or need to do better.  We get Game Info whenever you use your App and if you have a connection to the Internet.

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. Moreover, our service providers (see below) can only view aggregated data.

 

Do we need to use this Info?

We only collect and use the information that we've told you about in this document and only for the reasons we’ve explained.  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.

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.

 

App Features

The App can access wi-fi for updates and periodically may send Device Info and Game Info to us via the Internet.  If you do not have the companion product, the Marvel Legend’s Deadpool’s Head Premium Interactive Head (the “Product”), the App also includes additional Product information, including where to buy it.

The App also makes a secure connection to the Product and the App may be used in several modes to play interactively with the Product. This requires an active Bluetooth connection between the Product and your mobile device. Hasbro has made this a secure connection.

You may save videos and recorded moves of the Product locally to your device.  The App does not share these or otherwise transmit them to any other device (except your individually paired Product) or over the Internet, etc. in any manner from your device. The videos are stored locally on your device camera roll and the digital instructions for the Product are stored in App memory locally.

 

3.   Who Can See Info from the App?

We use a third-party service provider, Localytics, to assist us in gathering analytics and statistical data in connection with the App (the Device Info).

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

With our group companies, third-party 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 App and protect against fraudulent, abusive, inappropriate, or unlawful use of the Mobile App 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 Privacy Policy.

With your consent, to any other person.

 

4.   Where Is Info from the App Kept?

We strive not to collect any personal information, as described above.

We keep the Game Info from all Apps in the United States, and 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.

 

5.   How Long 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 real name and address. But in case you want to know, we generally get rid of all Game Info and Device Info after we no longer have a need for it.

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. Once we take an app down from the app stores, we destroy all raw data within six months.

 

6.   Note to Parents

This App and the companion Product are intended for an adult audience, at least over 17 years of age.

 

7.   You Have Rights About Your Info & Can Complain

We explained that we try not to collect any personal info about you like your real name or 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, you may ask us about the following:

·      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.

Reviewing, Updating, or Deleting Your 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 personal information, you may contact us using the details below How to Ask Us a Question.” 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 (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.

 

8.   Keeping Your Personal Info Safe

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.

 

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:

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 this App 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

 

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 email us here at: consumer_affairs@hasbro.co.uk; you may send us a letter using the information below:

Contact Us:

If you have questions or concerns regarding this MPP, e.g. if you believe that our App may have unintentionally collected your 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 https://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 privacy@esrb.org

 

11.   When Can this Change and How?

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 Privacy Policy changes if and where this is required by applicable data protection laws.

 

Thanks for playing!