PRIVACY POLICY FOR THE HASBRO PULSE! MOBILE APPLICATION
(Last Updated: 2/9/2018)
Our Privacy Commitment
This mobile privacy policy ("HASBRO PULSE! Privacy Policy") explains how Hasbro, Inc. and its respective subsidiaries and affiliated companies that operate within the United States (collectively, “we”, “our”, or “us”) collect, use and disclose your information when you use the HASBRO PULSE! mobile application (the "HASBRO PULSE! App").
This HASBRO PULSE! Privacy Policy and the ESRB certification seals shown on the HASBRO PULSE! App confirm that Hasbro is a valid licensee, and participating member, of the Entertainment Software Rating Board's Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, we have voluntarily undertaken this privacy initiative and have had the HASBRO PULSE! App reviewed and certified by ESRB Privacy Certified to meet established online information collection, use, and disclosure practices. As a licensee of this privacy program, we are subject to frequent audits of the HASBRO PULSE! App and other enforcement and accountability mechanisms administered independently by the ESRB.
We ask that you take the time to read this HASBRO PULSE! Privacy Policy carefully. By using the HASBRO PULSE! App, you agree to this HASBRO PULSE! Privacy Policy. If you do not agree with this HASBRO PULSE! Privacy Policy, please do not use the HASBRO PULSE! App.
Table of Contents
- NOTE TO USERS
- Changes to this HASBRO PULSE! Privacy Policy
- What information is collected from me?
- How do we use your information?
- With whom do we share your personal information?
- Security
- Your California Privacy Rights
- Contact Us
1. NOTE TO USERS
The HASBRO PULSE! App is an app intended for an 18+ audience only and is not intended for children. We do not knowingly solicit or collect personal information from users under the age of 18 in connection with the HASBRO PULSE! App. If you believe that we may have unintentionally collected personal information from your child, you may contact us at:
Hasbro, Inc.
Attn: HASBRO PULSE! App Administrator
1027 Newport Avenue, Mailstop A906
Pawtucket, RI 02861
(800) 255-5516
hasbroregistration@hasbro.com
For any other issue, please contact Hasbro Consumer Care. We will be happy to take 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.
2. Changes to this HASBRO PULSE! Privacy Policy
We encourage you to review this HASBRO PULSE! Privacy Policy whenever you access the HASBRO PULSE! App to make sure that you understand our information collection, use and disclosure practices. We may change the provisions of this HASBRO PULSE! Privacy Policy at any time and will indicate when changes have been made by revising the date at the top of this HASBRO PULSE! Privacy Policy. Your use of the HASBRO PULSE! App, or any portion thereof, following the posting of such changes shall constitute your consent to such changes. If we make material changes to this HASBRO PULSE! Privacy Policy, we will provide you with additional notice of such changes by updating our website containing information about the HASBRO PULSE! App and/or by updating the description of the HASBRO PULSE! App in the applicable app store. If you do not agree with the changes we make to this HASBRO PULSE! Privacy Policy, please stop using and uninstall the HASBRO PULSE! App.
3. What information is collected from me?
Information We Collect
We may collect information that you provide when you use the HASBRO PULSE! App, such as:
- Your device ID, 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 HASBRO PULSE! App (e.g., session length, cards played, etc.);
- Your first and last name, profile photo (manual entry of via Facebook Connect) and email address that is used to assist us in creating an account through the HASBRO PULSE! app and website using the same credentials and to send you newsletters from time to time; and
- Non-Personal Information (See “Non-Personal Information” below)
We retain this information for as long as reasonably necessary to fulfill the purposes outlined in this HASBRO PULSE! Privacy Policy 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 collect certain non-personal information from you in connection with your use of the HASBRO PULSE! App.
For example, if the HASBRO PULSE! App includes advertisements for Hasbro products, we may collect information about whether or not the advertisement is clicked.
Further, the HASBRO PULSE! App may send local notifications to a user’s device; however, local notifications operate differently from “push” notifications. Specifically, local notifications are messages delivered directly through the HASBRO PULSE! App and do not require collection or use of your personal information (though it may require the use of device ID, if necessary, solely for the purpose of sending the local notification). Please note that you may opt-out of receiving local notifications by changing your device settings.
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 the HASBRO PULSE! App and to gather demographic information about our user base as a whole.
We use a third-party service provider, Localytics, to assist us in gathering analytics and statistical data in connection with the HASBRO PULSE! App.
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
4. How do we use your information?
Use of Information
We use personal information collected through the HASBRO PULSE! App for the purposes described in this HASBRO PULSE! Privacy Policy or as otherwise disclosed to you on or in connection with the HASBRO PULSE! App. For example, we may use your information to:
- Send you advertising or promotional materials, including information about new products, contests, features and enhancements, special offers and other events of interest from us;
- Monitor performance of the HASBRO PULSE! App, overall usage of the HASBRO PULSE! App and user retention rates, track how users are engaging with the HASBRO PULSE! App, and inform design development for future updates;
- Operate and improve the HASBRO PULSE! App, including by linking or combining your information with other information we get from third parties;
- Send you technical notices, updates, security alerts and support and administrative messages; and
- Carry out any other purpose conveyed to you at the time the information was collected.
5. With whom do we share your personal information?
Sharing of Information
We share information about you with third parties as follows or as otherwise described in this HASBRO PULSE! Privacy Policy or through the HASBRO PULSE! App, including:
- With your consent, including if we notify you through the HASBRO PULSE! App 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. We require these entities to maintain the confidentiality, security and integrity of the personal information they obtain from us;
- With our affiliates for internal business purposes;
- 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 HASBRO PULSE! App and protect against fraudulent, abusive, inappropriate, or unlawful use of the HASBRO PULSE! App 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.
We may also share aggregated information or information that we have collected from you through the HASBRO PULSE! App where we have taken reasonable measures to de-identify such information.
Linking to Third Party Sites
To provide relevant information not found on the HASBRO PULSE! App, to facilitate online shopping, and to allow you to interact with other websites and/or applications in which you may have accounts (such as Facebook and other social media sites), we may provide links or embed third-party applications that allow login from the HASBRO PULSE! App to third party websites. Your use of these third party websites and/or applications is subject to the third parties' 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 the websites and/or applications.
6. Security
We have established policies in an effort to protect your personal information against loss, misuse and unauthorized access, disclosure, alteration and/or destruction. For example, we strive to provide only those employees performing a legitimate business function with access to users’ personal information. We also review our security procedures periodically to consider appropriate new technology and updated methods.
We retain your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. We 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, we will notify users of a data breach when we determine that is reasonably necessary in accordance with applicable law.
7. Your California Privacy Rights
Since 2005, California Civil Code Section 1798.83 permits customers of the HASBRO PULSE! App who are California residents to request certain information regarding our disclosure of personal information as defined by the statute to our affiliates and third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please call or write us at:
Hasbro, Inc.
Attention: HASBRO PULSE! App Administrator
1027 Newport Avenue, Mailstop A906
Pawtucket, RI 02861
(800) 255-5516
8. Contact Us
If you have questions or concerns regarding this HASBRO PULSE! Privacy Policy, please contact us using the following contact information:
Hasbro, Inc.
Attention: HASBRO PULSE! App Administrator
1027 Newport Avenue, Mailstop A906
Pawtucket, RI 02861
(800) 255-5516
For any other issues, please contact Hasbro Consumer Care. For additional information about the HASBRO PULSE! App, please review the terms and conditions of use.
As aforementioned, 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 2240
New York, NY 10170
