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HASBRO MOBILE APPLICATION PRIVACY POLICY

(Last Updated 10/27/2015)

 

Our Privacy Commitment

This Mobile Privacy Policy (“Mobile Privacy Policy” or “MPP”) explains how Hasbro, Inc. and its subsidiaries and affiliated companies that operate within the United States (collectively, “Hasbro”, “we”, “our”, or “us”) collect, use, and disclose your information. This Mobile Privacy Policy applies to information we collect when you use the mobile applications listed in Section 3 below, or any other mobile applications where this MPP is posted (collectively, the “Mobile Apps” or “Apps”).

This MPP and the ESRB 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”). 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. By using this Mobile App, you agree to this MPP. If you do not agree with this MPP, please exit and stop using the Mobile App.

Table of Contents

  1. Changes to this Mobile Privacy Policy
  2. What this Mobile Privacy Policy Covers
  3. Information Collected, Used, and Disclosed
  4. Safeguarding Your Personal Information
  5. Your California Privacy Rights
  6. Contact Us

1. Changes to this Mobile Privacy Policy

We encourage you to review this MPP whenever you access the Mobile Apps to make sure that you understand our information collection, use and disclosure practices. We may change the provisions of this MPP at any time and will indicate when changes have been made by revising the date at the top of this MPP. Your use of the Mobile Apps, or any portion thereof, following the posting of such changes shall constitute your consent to such changes. If we make material changes to this MPP, we will provide you with additional notice of such changes by updating our website containing information about the Mobile App and/or by updating the description of the Mobile App in the applicable app store. If you do not agree with the changes we make to this MPP, please stop using and uninstall the Mobile App(s).

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2. What this Mobile Privacy Policy Covers

This MPP is effective as of the date first posted above and applies only to information collected by Hasbro from users of the following Mobile Apps:

  • FurReal Friends: StarLily, My Magical Unicorn;
  • Furbacca;
  • Littlest Pet Shop Your World;
  • My Little Pony: Equestria Girls;
  • My Little Pony: Friendship Celebration;
  • Transformers: Robots in Disguise; and
  • Any other mobile application where this MPP is posted.

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, or any apps or websites maintained by other companies or organizations to which we may link. Your use of any third party app and/or website 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 app and/or website.

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3. Information Collected, Used, and Disclosed

The chart below outlines the information collected from users in connection with the Mobile Apps:

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Personal Information

We may collect your personal information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives. With the exception of your device ID and IP address, we do not collect personal information from our users through the Mobile Apps. We do collect your device ID and IP address, which we use to create a randomized identifier (i.e., a “scrambled ID”) that is used to assist us in gathering non-personal analytics and statistical data regarding use of the Mobile Apps (e.g., session length, toy scans, etc.). 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.

Please note that any personal information provided by you to us via our customer support website is subject to the privacy policy and terms of use of that website. Please read those documents before providing any personal information to us via our customer support website.

Non-personal Information

We may also collect non-personal information from you in connection with your use of the Mobile Apps.

For example, for those of the Mobile Apps that include advertisements for Hasbro products, we may collect information about whether or not a particular advertisement is clicked. Please see the “Hasbro Ad Clicked” column in the chart above for further detail.

Some of the Mobile Apps may also access your 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 Scan Activity” column of the chart above. For clarity, this code scan information may be used by Hasbro to, for example: (1) unlock an in-game character, (2) unlock an in-game “power module” (i.e., an in-game power up that can be used during missions), or (3) unlock in-game currency. We do not use the images in your device’s image library, take screen shots of activity on your device, or perform similar activities without your permission.

Also, our My Little Pony: Friendship Celebration App gives users the ability to take pictures and save them to an in-app photo album or to the user’s mobile device; however, these pictures are stripped of personal information regardless of the user’s mobile device settings and are not collected or shared by us.

Children Under 13

NOTE TO PARENTS

Hasbro has developed the Mobile Apps to be an enjoyable experience for users, including those under 13 (“Children” or “Child”). Please discuss this MPP with your Children 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 is committed to compliance with the Children’s Online Privacy Protection Act (“COPPA”), a federal law designed to protect kids online. We take children's privacy seriously, and encourage parents to take an active role in protecting their children's privacy and online experience at all times. Except as otherwise outlined in this MPP, we do not collect personal information from our users.

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 we may have unintentionally collected your and/or your child’s personal information, you may contact us at:

Hasbro, Inc.

Attn: App Administrator

1027 Newport Avenue, Mailstop A906

Pawtucket, RI 02861

(800) 255-5516

hasbroregistration@hasbro.com

For any other issue, please contact Hasbro Customer Service. We will be happy to honor your request. Please note that any personal information provided by you to us via our customer support website is subject to the privacy policy and terms of use of that website. Please read those documents before providing any personal information to us via our customer support website.

Third-Party Service Providers

We use third party service providers to assist us in gathering certain data, including game play information, device type, number of unique users, and country of access. We use this information, which does not identify individual users, to analyze trends, to administer our Mobile Apps, and to gather demographic information about our user base as a whole. We do not link this data to users’ personal information.

We use a third-party service provider, Localytics, to assist us in gathering analytics and statistical data in connection with the Mobile Apps.

If you have any questions or concerns with regards to Localytics’ privacy practices, you may review their privacy policy at http://www.localytics.com/privacy-policy/, or contact them at:

Localytics

101 Arch St Fl 8
Boston, MA 02110 USA

privacy@localytics.com

Some of the Mobile Apps offer the ability to make in-app purchases. 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, Amazon, PayPal). We will notify you when you are leaving the Mobile App or otherwise indicate that you will be going to the third-party's site. Your use of the third party website is subject to their privacy policies and terms of use, and we encourage you to read such privacy policies and terms of use before submitting personal or other information or using the websites.

Disclosures to Help Protect the Security and Safety of Our Apps

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 your consent, including if we notify you through the Mobile Apps that the information you provide will be shared in a particular manner and you provide such information;
  • With third party vendors, consultants and other service providers who are working on our behalf and need access to your information to carry out their work for us. These entities have agreed to maintain the confidentiality, security, and integrity of the personal information they obtain from us, and, unless we notify you otherwise and provide you with an opportunity to opt-out, will not use your personal information for any purpose other than as described in this MPP.
  • When we believe it is necessary or appropriate to (i) comply with applicable law or legal process or to respond to lawful requests or legal authorities; (ii) 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 the safety of Hasbro our users or any third party; and
  • In connection with, or during negotiations of, any merger, sale of company assets, bankruptcy or reorganization, financing or acquisition of all or a portion of our business to another company.

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4. Safeguarding Your Personal Information

Hasbro has established policies in an effort to protect your personal information against loss, misuse and unauthorized access, disclosure, alteration and/or destruction. For example, Hasbro strives to provide only those employees performing a legitimate business function with access to users’ personal information. Hasbro also reviews its security procedures periodically to consider appropriate new technology and updated methods.

Hasbro retains your information for business purposes, for as long as your account is active (if applicable), and/or as long as is reasonably necessary to provide you with access to the Mobile Apps and/or our other products and services. Hasbro will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time.

Despite our efforts, please be aware that no security measure is ever perfect or impenetrable. To that end, Hasbro will notify users of a data breach when Hasbro determines that is reasonably necessary in accordance with applicable law.

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5. Your California Privacy Rights

Since 2005, California Civil Code Section 1798.83 permits users of 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

hasbroregistration@hasbro.com

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6. Contact Us

If you have questions or concerns regarding this MPP, please contact us at:

Hasbro, Inc.

Attn: App Administrator

1027 Newport Avenue, Mailstop A906

Pawtucket, RI 02861

(800) 255-5516

hasbroregistration@hasbro.com

For any other issues, please contact Hasbro Customer Service.

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

Attn: Privacy Certified Program
420 Lexington Avenue, Suite 2024
New York, NY 10170
privacy@esrb.org

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