Privacy Policy Effective Date November 2012 (last updated July 2021) Spin Master® Privacy Policy Table of Contents This Privacy Policy applies to our sites and apps. Our privacy practices and children. We collect information from and about you and children under 13. We collect information in different ways. We use information as disclosed and described here. We may share information with third parties. You have certain choices about sharing and marketing practices. We use standard security measures. We store information both in and outside of the United States. We may link to other sites or have third party services on our site we don't control. Notice to California residents Notice to EU residents Feel free to contact us if you have more questions. Spin Master Mobile Apps Policy We may update this Policy This Privacy Policy applies to our sites and apps. This Policy describes how we collect, share and use personal information on our websites. It also applies to our mobile sites and apps. By interacting with us, you consent to these practices. Our privacy practices and children. Under the Children’s Online Privacy Protection Act, you can review your child’s information by contacting us at customercare@spinmaster.com. You may also request that we no longer collect information from your child or have your child’s information deleted. To do so, contact us at the email address or phone number below. We collect information from and about you and children under 13. Children's Information. We collect what is reasonably necessary for kids to participate on our site. This might include gender and age. This might alsoinclude an email address. We may also collect usernames or chat logs. Parent and Other Adults’ Information. We collect parents’ email addresses. We may collect this from the child or the parent. We also collect order information from parents or other customers for purchases on our sites or when placing an item in a shopping cart, including products ordered, payment information/credit card numbers, personal contact information (such as full name, email address, home address, telephone number) and other information necessary to fulfill a transaction. We will also collect login information when customers register for an account on our site. When registered customers return to our site to place subsequent orders, they can identify themselves with their login information. Information you submit or post. We collect information posted in a public space on our site. We also collect information if you or your child contacts us. Other information. If you or your child uses our websites or apps, we may collect information about the browser or network used, device information or user’s IP address. We might look at what site you or your child came from, or visit next. We may collect passive information about what activity you or the child did or how long the child played. We collect information in different ways. We collect information directly. For example, if you or your child create an account with us. We also collect information if you or your child contacts us. We collect information passively. We use tracking tools like browser cookies and web beacons to collect information from you. We use information as disclosed and described here. How we use children’s information. Unless permitted by law, we use children’s information after getting parental consent. In some circumstances we may not request parental consent. For example, if we are only going to use the information one time to respond to a direct request. Or if we are using information obtained from a child to get parental consent. We also use children’s information as described in any request for parental consent. How we use parent and guardian information. We use email addresses to notify parents or guardians that their children have registered on our site. We may also use your email address to communicate about your child’s account. We may contact you about this Policy or our website Terms. We use children and parent’s information to improve our products and services. We may use information to make our website and products better. We might use information to customize you or your child’s experience with us. For example, we might use information to store your child’s password if he or she registers for our site. We use information for security purposes. We may use information to protect our company, our customers, and our websites. We keep the data that we collect about you for as long as necessary for the purposes set out in this Privacy Policy. We use adult’s information for marketing purposes. For example, we might send adults information about new site features. We might send adults information about third party offers or products we think you might find interesting. We use information as otherwise disclosed or permitted by law. For example, we will use information about children as we describe in parental consent requests. We may share information with third parties. We may share children’s information. We will share children’s information if we’re required to by law. We will share it if Spin Master transfers ownership. We will also share children’s information with vendors who help us run our site. We do not currently have any platforms that are designed to let children make their personal information publicly available. We will share information with third parties who perform services on our behalf. For example, we share information with vendors who help us send emails and operate our sites. We also share information with vendors to complete payments or administer a promotion. We may share adult’s information with our business partners. For example, we might share information with third parties who co-sponsor a promotion. These partners may send adults information about events and products by mail or email. We will share information if we think we have to in order to comply with the law or to protect ourselves. For example, we will share information to respond to a court order or subpoena. We may share it if a government agency or investigatory body requests. We might share information when we are investigating potential fraud. We may share information with any successor to all or part of our business. For example, if part of our business was sold we may give our user information as part of that transaction. We will share information with other Spin Master entities. We may share information for other reasons we may describe to you. You have certain choices about sharing and marketing practices. You can opt out of receiving our marketing emails. To stop receiving our promotional emails, follow the instructions in any promotional message you get from us. Don’t worry! Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions, information about your children, or information about your account or your orders. You can control if we share information with third parties for their marketing purposes. To opt out of having us share your information with third parties for their promotional purposes, email us at customercare@spinmaster.com or call us at 1-800-622-8339. You can control cookies and tracking tools. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings. If you block cookies or enable your browser’s “do not track” settings, certain features on our sites may not work. We use standard security measures. The Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords. We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law. Parents, you can take steps to protect your kids too. To learn more about how to protect your child online, read the helpful information provided by the FTC. Please also read this bulletin. We store information both in and outside of the United States. Information we maintain may be stored both within and outside of the United States. Where possible, we try to keep the information you supply to us locally. However, as part of the services offered through our site, the information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any of our servers are hosted by one of our Spin Master offices outside of the EEA, or one of our service providers is located in a country outside of the EEA. We may also share information between our group companies which are located in countries worldwide. If you require contact details of our other group companies, please contact us. This site is subject to U.S. laws, which may not afford the same level of protection as those in your country. These countries may not have similar data protection laws to the EEA. If we transfer your information outside of the EEA in this way, we will take appropriate steps to ensure that any personal data relating to you will continue to be adequately protected. We may link to other sites or have third party services on our site we don't control. If you click on a link to a third party site, you will be taken to websites we do not control. This includes social media sites. This policy does not apply to the privacy practices of these websites. Read the privacy policy of other websites and insurance carriers carefully. We are not responsible for these third party practices. Notice to California residents If you are a California resident, we are required to provide additional information to you about how we use and disclose your personal information and set out your rights in connection with how we use your information. Use and Disclosure of your Information Consistent with the sections “We collect information from and about you and children under 13” and “We use information as disclosed and described here” of this Privacy Policy, we collect certain categories and specific pieces of information about individuals that are considered "personal information" in California. As detailed above, we may collect this personal information from you and other third parties. We collect, share and disclose personal information for the purposes described in this Privacy Policy. As a consumer, under California law, you have the following rights: Right of Access You have the right to request access to your personal information which we may have collected. We will provide: Categories of personal information collected by us; Categories of sources of the personal information collected; Business reason for collecting your personal information; Any third parties whom we share the personal information; Specific data fields/pieces of personal information we have collected. We do not sell your personal information to third parties. Right to Deletion You have the right to request the deletion of personal information which we hold. However, this right is subject to some exceptions and does not apply in the following situations: We require the information to continue to provide goods or services to you; Information is required to resolve security or functionary related issues; Information is required to comply with the law; Information is safeguarded to the right to free speech; Information is supporting researching in the public interest; Information is required for internal purposes which you as the consumer reasonably expect. Right to Non-Discrimination California consumers have the right not to be discriminated against for having exercised your rights under California law. Specifically, we will not: Deny you any goods or services; Charge you different prices for goods or services, whether through denying benefits or imposing penalties, due to your request; or Provide you with a different level or quality of products or services due to your request. As an individual, you are enabled to make requests twice in a 12-month period. As a business, we will need to collect information from the requesting party to verify your identity prior to taking any action. We will respond within 45 days of receiving a personal information request. Exercising Your Rights To exercise your rights, please email us at customercare@spinmaster.com or call us at 1-800-622-8339. To make a request for yourself or your minor child, please ensure the request includes: Sufficient information to allow us to reasonably verify you are the person about whom the information is collected; and Describe your request which allows us to understand and action on your request. Please note that only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. The information we provide to you will only cover the 12-month period preceding receipt of a consumer’s verifiable request. We will aim to provide a response within 45 days of receipt. If we require additional time to respond, we will provide an update to you and include the reason and extension period. In case we are unable to comply with your request, we will provide an update with explanation of the reasons we cannot comply. We do not charge a fee to process or respond to your requests unless such request is excessive, repetitive, or unfounded. If we determine the request warrants a fee, we will provide a written response with the fee estimate prior to completing or responding to your request. California Shine the Light Under California Civil Code Section 1798.83, California residents using this Site are entitled to request, once a year, information regarding the disclosure of their personal information by Spin Master to third parties for their direct marketing purposes, including what personal information we have shared with such third parties and the parties with which we have shared such information. You also have the right to opt out of such disclosure. To make such a request, please email us at customercare@spinmaster.com or call us at 1-800-622-8339. Notice to EU residents Spin Master complies with the rights given to EU citizens and residents under the General Data Protection Regulation (GDPR). These rights are as follows: Correcting your Information – the right to have your personal information updated to ensure it is up-to-date and accurate. Withdrawing Consent – the right to withdraw your consent to any processing that is currently being done under your consent, e.g. marketing. Obtaining a Copy of your Information – the right to receive a copy of the personal information we hold about you. Deleting your Information – the right to request that we delete personal information in certain circumstances. Data Portability – the right to have us transfer to another controller the personal information that you have provided us with. Restricting Processing – the right to request a restriction on the processing of your data in some limited circumstances. Right to Object to Processing – the right to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyze your information for targeted content (also known as profiling). For more information on how to action these rights please contact us at: dpo@spinmaster.com Feel free to contact us if you have more questions. If you have any questions about this Policy or our processing of data about you, please contact us at dpo@spinmaster.com. Or via mail at: Data Protection Officer 225 King Street West Toronto, ON M5V 3M2 If you have a concern about our handling of your personal information, please get in contact with us first so we can try to resolve your query. If however you feel we have not dealt with your concern and that we are failing to meet our legal obligations, you can report this to your local data protection regulator. Spin Master Mobile Apps Policy The following Privacy Policy applies to Spin Master’s suite of mobile applications and describes how we Spin Master treats personal information in our mobile apps: https://www.spinmaster.com/en-US/legal/mobile-apps-policy We may update this Policy. From time to time we may change our privacy policies. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our website. Please check our site periodically for updates. © 2021 Spin Master Ltd. All rights reserved. Our Brands Toys & Games Entertainment Digital Games All Brands About Us Careers Overview Investors Media Corporate Social Responsibility Customer Support Contact Us Legal Suppliers Terms & Conditions Regulatory Matters Patents UK Modern Slavery Act Transparency Statement Accessibility Statement Social EN-US EN-GB ©2021 Spin Master. All Rights Reserved. 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