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HASBRO BEYBLADEX

MOBILE APPLICATION PRIVACY NOTICE

(Last Updated: 20 May 2024)

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 information and keep it safe whenever you use our BeybladeX App.   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 and subsidiaries globally. Hasbro, Inc. is the controller of any personal information processed for the Mobile App.

 Our EU Representative is:  Hasbro European Trading BV

       De entrée 240, 1101 EE Amsterdam, Netherlands

      dataprivacy@hasbro.com


Our UK Representative is:  Hasbro UK, Ltd.

      4 The Square, Stockley Park, Uxbridge

      Middlesex, UB11 1ET United Kingdom

      dataprivacy@hasbro.com

 

This BeybladeX Mobile Privacy Policy (“Policy ”) explains how Hasbro, Inc. and its affiliated companies (collectively, “ Hasbro”, “ we”, “ our”, or “ us ”) collect, use, and disclose information when the BeybladeX mobile application is used or interact with us offline (for instance by contacting Customer Care) regarding the BeybladeX mobile application (the “ Mobile App” or “ App”).

If you are a California, Virginia, Colorado, Utah or Connecticut resident, please see the “Additional State-Specific Disclosures” section below. If you are in the EEA or UK, please see the "EEA/UK Annex" below. If you are a citizen of Brazil, please see “Additional Information Regarding Brazilian Law.”

Who is ESRB and what do they do for Hasbro?

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

FOR GROWN-UPS: This Policy and the “ESRB privacy certified” certification seal shown in the Policy 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 App 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 App and other enforcement and accountability mechanisms administered independently by the ESRB.

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

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TABLE OF CONTENTS

  1. The App
  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. State-Specific Privacy Disclosures and Rights
  10. Additional Information regarding Brazilian Law
  11. How to Ask Us Questions
  12. When Can this Change and How?
  13. EEA/UK Annex: More Info if You are in the UK or the EEA

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1.      The App

What we say on this page is only about the BeybladeX app.

FOR GROWN UPS: This Policy is effective as of the Last Updated date posted above and applies only to information collected by Hasbro from users of the BeybladeX mobile app.

 

If you are not using the BeybladeX app, we'll tell you about how we use your info somewhere else. If it is someone else's app, you should check out what they say about their app and how they use your info.

FOR GROWN UPS: This Policy does not apply to any other information collected by Hasbro through any other means. For clarity, this Policy 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 App (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 directly tell who you are in real life. This is because we try hard not to get personal info that could easily identify you like your name or your address), and we try to use your personal info in a way that keeps your info safe.

If you live in the EU or the UK, you can click here to find out how we use your info. If you live somewhere else, we tell you about this below.

"Device Info " is:

  the type of device used (like an iPad or a phone);

  numbers we link to your device ("scrambled IDs" – see more information below);

  if you are using Android or IOS (i.e. operating system);

  what language your device uses (e.g. is it in English or French?);

  guessed info about where your device is (what country or time zone you are in);

  what network you are on (like EE or Vodafone).

 

When an App is used for the first time, we create a random alphanumeric code referred to as a “scrambled ID” which will relate to that App.   The scrambled ID is generated from a temporary random alphanumeric code called an "install ID" and a so-called advertising ID.   These elements 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 scrambled ID is collected and used in connection with Device Info and Game Info.

In addition, due to the way in which the scrambled ID is generated, it is not possible for us or anyone else to work out (i.e. "reverse engineer") your original device or advertising ID from the scrambled ID.  This means that once the scrambled ID has been generated, we are no longer able to directly identify a specific individual in the real world from that identifier.   The creation of the scrambled 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 scrambled ID is unique to your particular advertising ID. If you delete our App from your device and then install or reinstall one of our Apps again for the same device, the scrambled 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 scrambled ID on each device will be different, even if the same person uses the same App on different devices. The scrambled ID in one App does not share with, or “know” about, a scrambled ID on another device or platform.   However, if you download multiple App 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 scrambled ID. 

We do not generally use analytics to compare scrambled IDs between App; however we do use it to: (i) distinguish one user from another (for counting purposes); (ii) to understand what parts of our App is being used; and (iii) to ensure that our App is appropriately secure and protected.   We do not use scrambled 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 scrambled ID in order to directly identify the user in the real world.  
 

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Our App uses Device Info (like guessing its country) 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., Verizon, Vodafone, EE, Orange), the scrambled ID (so long as the device connects to the Internet) and will guess the country (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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Do we need to use this Info?

We only collect and use the info that we've told you about here and only for the reasons we have told you.   We only collect the info that we need for those reasons.   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 Policy 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.

 

Toy Scanning Activity

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:  The App 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 scrambled ID and the name of the virtual item unlocked.


 

 

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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 do not share your personal information with third-parties other than as described in this Policy . We only share your personal information with third-parties as follows:

  1.       With our group companies, vendors, consultants and other service providers or partners who are working on our behalf on the App and need access to your information to carry out their work for us.

Our group companies are:

Company Name

Address

Hasbro Inc.

1027 Newport Ave., Pawtucket RI 02861

Hasbro International, Inc.

1027 Newport Ave., Pawtucket RI 02861

Hasbro Latin America Inc.

1027 Newport Ave., Pawtucket RI 02861

Hasbro International Holdings, B.V.

De entrée 240, 1101 EE Amsterdam, Netherlands

Hasbro do Brasil Ind E Com

Av. Das Nacoes Unides 4777, 2 andar, Edificio Villa Lobos, Alto de Pinheiros, 05477-000, Sao Paulo SP, Brazil

Hasbro de Mexico S.R.L  de C.V.

Blvd. Manuel Avila Camacho No. 32, Piso 3, Torre Esmeralda III, Col. Lomas de Chapultec, Deleg. Miguel Hidalgo, 11000 Mexico D.F.

Hasbro SA

c/o Hasbro SA, Rue Emile-Boechat 31, 2800 Delemont, Switzerland

Hasbro Holding S.A.

c/o Hasbro SA, Rue Emile-Boechat 31, 2800 Delemont, Switzerland

Hasbro Canada Corporation

2350 De La Province Longuevil, Montreal, Quebec, J4G1G2 Canada

Hasbro Netherlands Holdings, B.V.

De entrée 240, 1101 EE Amsterdam, Netherlands

Hasbro France S.A.S.

139 Boulevard Haussmann, 75008 Paris, France

Hasbro Deutschland GmbH

Dreieich Plaza 2A, 63303 Dreieich, Germany

Hasbro Italy S.r.l.

Assago Strada 1, Palazzo F10, Milanofiori, Italy

Hasbro Trading Co.

 

Hasbro (Schweiz) AG

Weinberglistrasse 4, 605, Luzern, Switzerland

Hasbro U.K. Limited

4 The Square, Stockley Park, Uxbridge, Middlesex UK

Hasbro B.V.

De entrée 240, 1101 EE Amsterdam, Netherlands

Hasbro Iberia, S.L.

Ciudad Gran Turia C/Andarella l. Bloque 3., Planta 5a 46950 Xirivella Valencia, Spain

S.A. Hasbro Belgium N.V.

Avenue du Port 86C- Boite 204, 1000 Brussels, Belgium

Hasbro Oyuncak Sanayi Ve Ticaret A.S.

Burhaniye Mah. Adbullahaga Cad. No: 51 K:2, Beylerbevi, Istanbul, Turkey

Hasbro Far East LTD

1308, World Commerce Centre, Harbour City, 11 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong

Hasbro Australia Pty Ltd

Level 4, 67-75 Epping Rd, 2113 Macquarie Park NSW, Australia

Hasbro Australia Limited

Level 4, 67-75 Epping Rd, 2113 Macquarie Park NSW, Australia

Hasbro International Trading B.V.

De entrée 240, 1101 EE Amsterdam, Netherlands

Hasbro European Trading B.V.

De entrée 240, 1101 EE Amsterdam, Netherlands

Hasbro Czech S.R.O.

Hvezdova ul. 1716/2B, Prague, Czech Republic

Hasbro Emerging Markets B.V.

De entrée 240, 1101 EE Amsterdam, Netherlands

Hasbro Korea Ltd

8FL Deokmyeong Bldg., 635 Teheran-ro, Gangnam-gu Seoul, Korea

Hasbro Colombia SAS

Calle 100, N 7-33 Torre 1 Piso 15 Capital Tower, Colombia

Hasbro Thailand Ltd.

999 Gaysorn Plaza, 5 th Floor, Unit 5B-1, Ploenchit Road, Kwaeng Lumpini, Khet, Pathumwan, Bangkok, Thailand

Sobral Ltd.

Cannon’s Court, 22 Victoria Street, Hamilton HM 12 Bermuda

Allspark Animation LLC

1027 Newport Ave., Pawtucket RI 02861

My Little Pony G5 Productions LLC

333 W Empire Avenue, Burbank CA 91504

Hasbro Studios LLC

333 W Empire Avenue, Burbank CA 91504

Hasbro Managerial Services, LLC

1027 Newport Ave., Pawtucket RI 02861

Wizards of the Coast LLC

1107 Lake Washington Blvd. N. Suite 800, Renton WA 98056

 

These entities (including those mentioned below) 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 Policy or as required or permitted by applicable law.

  1.      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 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 Policy.

  1.       With your consent, to any other person.

 

Key vendors, consultants and other service providers or partners:

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

We use cloud services hosted by Amazon Web Services a/k/a “AWS” (Amazon Web Services, Inc.) to store content like videos and ads to display in our App and Game Info.

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 we use Exit Games's Photon Cloud online multiplayer gaming platform. Match stats associated with your Multiplayer ID are sent to our AWS 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.

 

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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 that shows who you are in the real world (like your address).

But if you want to know, we store Device Info and Game Info in the United States as well as other countries where we are (and where the companies that help us are). 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 that allows us to directly identify a user individually, as described above.

We keep the Device Info and 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 Policy. These include implementing the controller-to-processor and controller-to-controller modules of the European Commission’s and the UK Secretary of State's Standard Contractual Clauses for transfers of personal information between our group companies. These clauses require all group companies to protect personal information they process from the EEA and the UK in accordance with European Union and UK data protection law, respectively.

 

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5.      How Long is Info from the App Kept?

We limit the info we get to Game Info and Device Info, we try hard not to get personal info that shows who you are in the real world (like your address). But in case you want to know, we generally get rid of all your info after we no longer have a need for it.

FOR GROWN UPS: We strive not to collect any personal information that allows us to directly identify a user individually, as described above.

We retain your personal information for as long as reasonably necessary to fulfill the purposes outlined in this Policy and in accordance with our retention policies, as applicable, unless a longer retention period is required by applicable laws and/or regulations.

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 and retained for 90 days.

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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 App to be an enjoyable experience for users, including those under 16. Please discuss this Policy with your children who are under 16 so that they will better understand how to use the Mobile App and what information they may be asked to provide when using the Mobile App. Hasbro believes that providing its visitors with accurate and adequate notice about the Mobile App will inform choices and decisions about how to use the Mobile App 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 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 along with other global data protection laws that apply. 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 Policy, we do not collect personal information from our users.

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7.      You Have Rights About Your Info & Can Complain

We make every effort to prevent us from being able to directly 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"):

Some of these rights only apply in particular cases.

You also have the right to complain to an organization called a Data Protection Authority.

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 Policy we do not collect personal information that allows us to directly identify our individual users. However, if you have any questions on how we collect and use 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 United States, you can legally request access to, or deletion of, any personal information we have collected about your child under 13 and revoke any consent with respect to their information. However, as noted above, we do not typically collect or maintain any directly identifiable information about minors under 16. Certain additional state-specific rights are addressed below.

If you are a resident of the European Economic Area or the UK, and if we do have any personal information that allows us to identify you (or your child), then the following data protection rights apply:

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 in a way that means we know who you are in the real world. 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 identifiable 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.      State-Specific Privacy Disclosures and Rights

These additional disclosures currently apply only 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, as amended (“CCPA”) and privacy laws in the other states referenced above (collectively, “State Privacy Laws”) provide consumers additional rights 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 (to the extent applicable).

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 the following in connection with the App:

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 App.

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 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 endeavor to 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. If we are unable to verify your identity, we may deny your request. Due to our privacy-protective practices, as described above, in many instances we will not have sufficient personal information (e.g., name, email) that would enable us to verify your identity and complete a request to access, correct or delete any 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

State Privacy Laws provide certain opt-out rights which are inapplicable in these circumstances. Specifically, you have the right at any time to opt out of the (i) selling or sharing of your personal information to third parties, (ii) third party targeted advertising activities, (iii) impactful profiling activities with respect to consumers, or (iv) collection, use or disclosure of Sensitive Personal Information (such as children’s information, government identification number, precise geolocation, financial account credentials, etc.) other than for the specific purpose(s) that you provide it.  Hasbro does not engage in these activities with regard to our App.

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 with you.

APPEALS

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.

MINORS

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 of 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 with regard to our App. In the event we engage in a limited-time marketing event or promotional offer that includes a registration or other collection of personal information, we will disclose the benefits and terms of that promotion at the time of collection.

California Residents

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 App 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

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. Please see our general Privacy Policy for more information.

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10.  Additional Information regarding Brazilian Law

These additional disclosures apply only to processing activities which are subject to Brazilian law, namely: (i) the processing occurs in Brazil; (ii) the processing activity aims at offering or supplying goods or services – or the processing of data of individuals – located in Brazil; or (iii) the personal data object of the processing have been collected in Brazil. This section complements and supersedes any provision of the Policy which may be rendered unenforceable under Brazilian law.

PERSONAL DATA

Any processing of personal data pursuant to this section will comply with the General Data Protection Law (“LGPD” – Federal Law no. 13.709/2018), under the corresponding legal bases and general conditions set forth thereon.

The Device ID and the Game Info we collect cannot trace and directly identify a specific user. These are used only to improve our understanding of how users, in general, experience our products and to assist us in thinking about ways to improve their experience.

The LGPD provides additional rights to data subjects, which include, in addition to the other ones listed in this Policy, the exercise of the following rights:

  If you wish to access, correct, update, confirm processing or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided for Brazilian residents below.  

  In addition, you can object to processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us using the contact details provided for Brazilian residents below.

  If we have collected and process your personal information with your consent, you can further inquire about the consequences of denying consent.

  In addition to request deletion, you can also further request to anonymize or block information processed when unnecessary, in excess or non-compliant with the LGPD.

  If we do process any of your personal information, you may request specific information about those with whom your information was shared.

BRAZILIAN CONTACT

For parents and consumers who are in Brazil, please use the contact information below:

Email: 

www.hasbrosac.com.br


Free phone: 00800 2242 72 76
 

Or write to us at:
HASBRO DO BRASIL INDÚSTRIA E COMÉRCIO DE BRINQUEDOS E JOGOS LTDA.
(CNPJ 08.743.754/0001-43)
4777 - 2 andar

Av. das Nacoes Unidas

Sao Paulo SP 05477-000

Brazil
 

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

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11.  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 Policy, 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.

 

 Our EU and UK Representatives are:

Hasbro European Trading BV

De entrée 240, 1101 EE

Amsterdam, Netherlands 

 

Hasbro UK, Ltd.

4 The Square

Uxbridge, Middlesex

United Kingdom

 

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 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: ESRB at privacy@esrb.org.

 

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

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12.  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 Policy 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 Policy. When we update this Policy, 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 Policy changes if and where this is required by applicable data protection laws.

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Thanks for playing!


 

13. EEA/UK Annex: MORE INFO IF YOU ARE IN THE UK OR THE EEA

The table below shows why we use some of your info and what we use it for.

 

Why we use your info

The types of info we use

To get to know who is using our Apps and what they are doing on our Apps. This helps us to make the App more fun.

 

 

Game Info – where we say this, we mean:

  • things you see and choose in the App (like a Blader ID);
  • your progress (e.g. play events and milestones);
  • how long you use the App for;
  • whether the App is connected to a Hasbro toy;
  • your game name;
  • which game names you have played with;
  • the details of any leagues you are in.
  • number of unique users who downloaded the App
  • number of times a unique user played
  • number of times the App sessions started
  • length of each App session
  • what day of the week a user played
  • number of times each game mode (solo, team, VS) is played
  • session length of play per game mode
  • number of profiles created per device
  • number of avatar photos taken
  • percentage of profiles using a photo

 

Device Info – where we say this, we mean:

  • the type of device used (like an iPad or a phone);
  • numbers we link to your device (there is more info about these "scrambled IDs" in the Grown-Ups section on "Your Info" above);
  • if you are using Android or IOS (grown ups call this an operating system);
  • what language your device uses (e.g. is it in English or French?);
  • guessed info about where your device is (what country you are in)
  • what network you are on (like EE or Vodafone).

 

 

 

 

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

More specifically, this includes:

  • counting how many people are using our Apps;
  • understanding where users are located;
  • understanding what device they are using;
  • understanding what parts of our Apps are being used.

Lawful basis for processing:

 

It is necessary for our legitimate interest in analyzing trends and gathering 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.

 

 

To keep your info safe.

 

Device Info

Game Info

 

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

To ensure our Apps are appropriately secure and protected.

Lawful basis for processing:

 

It is necessary for our legitimate interest in managing the security of our IT infrastructure and the security of our App users and customers.

 

To make sure you get the right type of App for your device.

 

Device Info

 

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

To identify which version of the App to install on the device.

Lawful basis for processing:

 

It is necessary to perform a contract with you (the App T&Cs). Without this information, we cannot provide the App.

 

To give you the App in the right language.

 

Device Info

 

ADDITIONAL INFO FOR GROWN UPS:

 

Purpose of processing:

 

To download the App in the correct language according to your device settings.

 

Lawful basis for processing:

 

It is necessary for our legitimate interests in administering our Apps.

 

To make your App better and to fix problems.

 

Device Info

Game Info

 

ADDITIONAL INFO FOR GROWN UPS:

 

Purpose of processing:

 

This includes:

  • avoiding repeat information;
  • making the App easier and more fun to use;
  • fixing problems and bugs.

 

Lawful basis for processing:

 

It is necessary for our legitimate interests in administering, improving and de-bugging our Apps.

 

So you can play with your friends and join leaderboards.

 

Device Info

Game Info

 

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

For some Apps, players can play head-to-head online with other kids over the internet (via a third-party game platform – Exit Games's Photon Cloud) and can set up and join leaderboards of friends and other players regionally.

 

 

Lawful basis for processing:

 

It is necessary for our legitimate interests in providing a fun and engaging experience for our App players (which we balance against the best interests of the players).

 

 

  • Game name (chosen from two separate fixed lists that have been created by Hasbro)
  • Multiplayer ID (a randomly allocated number, like the Beyblade ID).
  • Device platform (iOS or Android);
  • A token for authentication with the game server;
  • App version number;
  • Records of wins / losses.

 

See "Your Info" for more detail.

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

 

Device Info

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

More specifically, some of our Apps send local notifications to the device. 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.  

Lawful basis for processing:

 

It is necessary for our legitimate interests in providing a fun and engaging experience for our App players (which we balance against the best interests of the players).

Scrambled ID (for more info see the Grown-Ups section on "Your Info" above)

To give you more fun stuff for your game – this is where you use the camera on your device to view a special "code" on your toy.

 

Device Info

 

We also get told that your App did a scan, and the stuff it unlocked, but that's it.

 

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

More specifically, 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).

Lawful basis for processing:

 

It is necessary for our legitimate interests in providing a fun and engaging experience for our App players (which we balance against the best interests of the players).

  • The fact that a code was scanned.
  • Scrambled ID (for more info see the Grown-Ups section on "Your Info" above).
  • The name of the virtual item unlocked.

 

The App does not send a photo of the scan to us or anyone else and we don't use the scan for anything else.

To check your country and either show you ads about other things we make or stop you seeing such ads.

 

Device Info

 

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

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

 

Lawful basis for processing:

 

It is necessary for our legitimate interests in advertising our products (which we balance against the best interests of the players).

  • Guessed country.
  • Language settings on your device.

When you use our App, we might show you adverts about other apps or toys we make.

 

Sometimes, if you watch an ad, you can get more stuff for your App for free. [We will tell you if this is the case.]

 

Device info

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

Our Apps only show ads for Hasbro products and services, but not any third-party's ads. We do not target ads to you or send you ads based on user behavior.

Lawful basis for processing:

 

It is necessary for our legitimate interests in advertising our products (which we balance against the best interests of the players).

  • Whether or not someone has clicked on a particular ad in an App.
  • Scrambled ID (for more info see the Grown-Ups section on "Your Info" above).

We show you a "Restore Code". If you delete the App, you can use the Restore Code to get all your game progress back later.

 

Game Info

ADDITIONAL INFO FOR GROWN UPS:

Purpose of processing:

 

The "Restore Code" allows players to return their App to its last current state.   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.  

Lawful basis for processing:

 

It is necessary for our legitimate interests in allowing gamers to take a break from the App without losing their progress.

  • Restore code (automatically generated by the App on first running).
  • Game Info.  Hasbro only knows about in-game progress from the restore code.