HASBRO PULSE PRIVACY POLICY
(Last Updated: [6 November 2024])
WELCOME!
Hasbro, Inc. is an international toy company, headquartered in the United States but with affiliates and subsidiaries globally (collectively referred to in this notice as "Hasbro", "we", "our", or "us").
This privacy policy (“Privacy Policy”) covers the Hasbro Pulse website, the Hasbro Pulse mobile app (available to US customers) and Hasbro Pulse Premium (these products and services, together with their content and functionality, and related online products and services, are referred to collectively as the “Services”). It explains how Hasbro collects, uses, and discloses your personal information when you:
- visit the ecommerce site for Hasbro fans known as Hasbro Pulse (the "Site");
- view or interact with content or functionality on the Site;
- download and use the Hasbro Pulse mobile app (currently only available and thus whose terms are only applicable for our United States customers);
- contact us to find out more about or to order Hasbro Pulse products;
- participate in backing a product through our HasLab crowdfunding platform by making a commitment to order to product if the minimum number of backings is met; and
- interact with us through our Hasbro Pulse Customer Services phone line, mailing address or the Hasbro Consumer Care online portal; and
This Privacy Policy also governs how we collect, use and disclose your personal information when you interact with us offline regarding the Services, including at offline events such as fan conventions.
Hasbro, Inc. is the controller of any personal information collected and processed from your use of the Services.
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Our EU representative is: |
Hasbro European Trading BV |
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Our UK representative is: |
Hasbro UK, Ltd. |
You may contact us for DPO related matters at DPO@hasbro.com.
We ask that you take the time to read this Privacy Policy carefully.
If we collect and/or share Personal Data in a manner that differs from what is described in this Privacy Policy, we will notify you of the purposes for which such Personal Data will be collected and/or with whom such Personal Data will be shared (if applicable), whether via just-in-time notification at the point of collection or via an alternate notice.
If you are a California, Colorado, Connecticut, Utah or Virginia resident, please also see the “Additional State-Specific Disclosures” section below.
If you are in the EEA or United Kingdom, please also see the “EEA/UK Annex” below.
The Services are not directed to or otherwise intended for use by individuals under 16 years of age in the United States and Canada or by use by individuals under 18 years of age in the EEA and UK. To learn more about our privacy practices for our other general audience websites and mobile applications (some of which are child-directed), please review the applicable posted Hasbro Privacy Policy.
If you believe we have collected information from an individual under 16 (in the US/Canada) or 18 (in the EEA/UK) in relation to the Services, you may directly request the deletion of such information here, contact us at DPO@Hasbro.com or contact us via any of the methods or addresses listed in the Contact Us Section below.
The Entertainment Software Rating Board’s Privacy Certified privacy compliance and certification program (“ESRB Privacy Certified”) is approved by the United States Federal Trade Commission (“FTC”) to serve as a Safe Harbor under the Children’s Online Privacy Protection Act (“COPPA”). It permits participating members to display their seals to demonstrate compliance with established online information, collection, use and disclosure practices under COPPA and other U.S. data privacy laws. This Privacy Policy and the ESRB certification seals shown on the Site confirm Hasbro is a valid licensee and participating member of ESRB Privacy Certified. To protect your privacy, we have voluntarily undertaken this privacy initiative and have had the Services 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 Services and other online products and services operated by us, and other enforcement and accountability mechanisms administered independently by the ESRB.
TABLE OF CONTENTS
- Background
- Changes to this Privacy Policy
- What Information is Collected About Me
- With Whom Does Hasbro Share My Information
- International Transfers of Personal Data
- How We Safeguard Your Personal Data
- How Long Do We Keep Your Personal Data
- What are My Information Choices?
- State Specific Disclosures and Rights
- EEA/UK Annex
- Contact Us
BACKGROUND
We respect the privacy of our customers, and we are committed to keeping all your Personal Data secure.
We collect and use certain Personal Data and we are responsible for ensuring that we use that Personal Data in compliance with applicable data protection laws.
We use the following definitions in this Privacy Policy:
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User(s) or You: |
means the users of the Site, the Hasbro Pulse mobile app (US only), and/or anyone whose Personal Data we collect and use in relation to the Services |
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Personal Data: |
means any information relating to an identified or identifiable living individual (an identifiable living individual is an individual who can be identified directly or indirectly in particular by reference to an identifier such as name, an identification number, location data, on online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person) |
This Privacy 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 mobile apps (other than the Hasbro Pulse mobile app available in the United States); 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 or use before submitting Personal Data or other information or using that mobile app, website or online service.
CHANGES TO THIS PRIVACY POLICY
We encourage you to review this Privacy Policy whenever you access and/or use the Services to make sure that you understand our Personal Data collection, use and disclosure practices. We may make minor changes to the provisions of this Privacy Policy at any time and will indicate when changes have been made by revising the data at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will provide you with additional notice of such changes by sending you and email at the last email address that you provided us, or by prominently posting notice of the changes on the Site.
WHAT INFORMATION IS COLLECTED ABOUT ME
Information That You Provide
Many of the products and/or services offered by Hasbro on the Site require us to obtain Personal Data about you in order to provide and/or perform the Services, such as when you:
- Create an account or subscribe to the Services;
- Make a purchase or request purchase of a product;
- Rate, review, or ask a question about a product;
- Back (i.e. make a commitment to order) a crowd-funded product on the HasLab platform;
- Participate in contests, events or promotions;
- Send questions or comments to us, or contact Hasbro Pulse Customer Service;
- Fill out online surveys;
- Sign up for our newsletter or other email alerts, including marketing;
- Share a website with a friend; or
- Otherwise communicate with us through the Services
Users may be unable to access the Services, or applicable parts of the Services, if such Personal Data is not provided.
In relation to the Services and depending on how you choose to interact with our Services, we or our service providers collects and processes the following kinds of Personal Data about you:
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• Identity Data: |
includes first name, last name, username or other identifier, date of birth |
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• Contact Data: |
includes billing address, delivery address, email address and telephone number |
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• Financial Data: |
includes bank account details, payment card details or other payment information |
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• Transaction Data: |
includes details about payments by you, order details, details of products that you have purchased from us |
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• Basket Data: |
includes details of the items placed in your basked and whether or not they were purchased |
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• Technical Data: |
includes IP address, login data, browser type, time zone setting and location, browser plug-in types, operating system and platform, device ID |
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• Usage Data: |
includes information about how you use and interact with our site and our Services, product searches, browsing activity |
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• Marketing and Communication Data: |
includes your preferences in receiving marketing from us and our third-party partners, your communication preferences, what marketing and communications have been sent to you, and how you interacted with such marketing and communications |
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• Profile Data: |
includes information about your interests, preferences, participation in prize draws and competitions, survey responses and feedback, your username and password, purchases or orders made by you, product preferences |
In some cases, we also collect information about you where this is provided to us directly by other Pulse customers, such as when one of our customers refers you to the Services (including promotions) or when they purchase and ship products to you. We will use this information to fulfill our customer's request and will not send communications to you unrelated to that request unless you separately consent to receive communications from us.
Information that We Collect or Generate About Your Use of Services
When you visit the Site or use our Services, we collect or generate information about you that relates to your usage and interactions with the Services. This includes:
Information regarding the products and/or services purchased and/or used on the Site
We may collect or generate Transaction, Usage and Profile Data to keep a record of the products and/or services you have purchased from us and to help us understand how you interact with the Site and the Services so that we can provide you with a better and more personalized user experience.
Information about your contact history and our interactions with you
We may collect or generate Contact, Usage or Profile Data to be able to offer you safe and efficient support, and so that we may ensure that you are satisfied with the products and/or services which we have provided to you and with the Site.
Activity data relating to you publishing content on the Site
We may collect or generate Usage and Profile Data about content you publish on the Site. You may also choose to upload images or photographs and other information that may be considered Personal Data when you publish content on the Site.
Information Collected Automatically From You
When you use the Services, we may also automatically collect information about your visit (collectively, “Online User Activity”). When you visit our websites, the personal information we collect is your computer's Internet Protocol (“IP”) address, which we use for the support of our internal operations. Other information we and our service providers may collect includes your operating system, access times, browser type, and the URL of the website you visited before navigating to our Services. If you access our Services via a mobile device, we may also collect your device make and model, mobile carrier, operating system version, language your device is set to, mobile web browser type and version, and non-personal analytics and statistical data regarding use of the websites (e.g., downloads, number of users, sessions, frequency of use, and retention).
To collect “Online User Activity” we use various technologies, including the following:
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Cookies: |
Cookies are small data files stored on your computer or mobile device by a website. Among other things, cookies help us and our service providers to improve the Services, remember your settings and preferences, support security features, see which areas and features of the Services are popular, count visits, measure users’ responses to offers for our Services, and better understand how ou use the Services so we can provide you with personalized content and advertising. For more information about cookies and how to disable them, please see the “What are my information choices?" section below. You can read more about our Cookie policy in our separate Cookie Notice. |
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Clear GIFs: |
Clear GIFs, sometimes called "web bugs" or "web beacons," are small electronic images that are placed on a web page or in an email message or advertisement. Clear GIFs may permit us to drop or read cookies and are often used in combination with cookies to track activity by a particular browser to a particular device. We use clear GIFs to, among other things, collect information, count visits, understand usage and campaign effectiveness, provide and personalize content and advertising, and tell if a recipient has opened and acted upon an email. |
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Log Files: |
Log files record website activity on the Services and enable us to gather statistics about our users' browsing habits. These entries help Hasbro determine, among other things, how many and how often users have accessed or used the Services, which pages of the Services they've visited, and other similar data. |
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Service Use Analytics and Telemetry: |
We may use one or more types of data analytics applications or providers to understand how consumers interact with our Services in a pseudonymized fashion (i.e., to collect analytics on trends in the aggregate, or to distinguish large, broad groups of different user types). We may also use analytics to provide improvements to our app and website, to assist with bug fixing, and to understand our users’ preferences so we improve products and services in the future. |
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Marketing Retargeting: |
If you opt-in to our email notifications, and/or newsletter services, we may use such notifications to deliver marketing promotional messages to you about products and services you have demonstrated an interest in. |
We may also associate the information we collect from these technologies with other information that you provide for the purposes described in this Privacy Policy
Information Collected from Other Sources
We may also obtain Personal Data from other sources and combine it with information we collect through the Services. For example, if we enable a feature on the Site that permits you to interact with a social media site or platform, or if we partner with a social media site, such as Facebook, or platform for advertising purposes, we may have access to certain Personal Data from that social media site or platform, such as your name, account information, and friends, and engagement with our content or our brands on the social media site or platform, in accordance with your settings for how the social media site or platform may share your information and the authorization procedures determined by such social media site or platform. In addition to social media sites and platforms, the other sources from which we have collected information about you include:
- Publicly available sources, including data in the public domain; and
- Third-party service providers engaged for services such as e-commerce, payment, technical and delivery of products
WITH WHOM DOES HASBRO SHARE MY INFORMATION
We may share your Personal Data with the following categories of recipients:
Our Hasbro group companies, who provide data processing services for us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site and Services, or who otherwise process personal information for the purposes that are described in this Privacy Policy.
Third party agents, consultants and other services providers who are working on our behalf and need access to your Personal Data to provide services to us. We work with the following types of third-party service providers:
Payments service providers, who process Identity Data, Contact Data, and Financial Data to assist us with payment processing.
Data analytics service providers, who process Identity Data, Transaction Data, Technical Data and Usage Data to help us analyze use of our Site and our Services and how we can improve them.
Marketing, and advertising service providers agents and consultants who process Identity Data, Technical Data and Usage Data to help us to better market and advertise the Site and our Services.
Technical service providers, who process Technical Data and Usage Data to provide technical support to Us and You in connection with the Services.
We contractually prohibit these entities from retaining, using, or disclosing Personal Data about you for any purpose other than performing services for us and as described in this Privacy Policy. We also require these entities to comply with appropriate data protection obligations and maintain the confidentiality, security, and integrity of the Personal Data they obtain from us or through the Site and the Services.
Partners, for business or commercial purposes as well as paid advertising, who in certain contexts, independently decide how to process information. We work with the following types of partners:
Delivery partners who process Identity Data and Contact Data to deliver products you have purchased or otherwise requested.
Third-party services or platforms where it is necessary to share personal data in order to facilitate your requests, such as when you choose to share Identity Data or Contact Data with a social media site or platform about your activities on the Services.
Any competent law enforcement body, regulatory, government agency, court or other third party where 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 parties, including to enforce our agreements, policies and terms of use as provided on the Services, and protect against fraudulent, abusive, inappropriate, or unlawful use of the Services; and (iii) protect the safety of Hasbro, our users or any person or entity.
An actual or potential buyer (and its agents and advisers) in connection with, or during negotiations of, any actual or proposed purchase, 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 your personal information only for the purposes disclosed in this Privacy Notice.
Any other person with your consent to the disclosure, including if we notify you that the Personal Data you provide will be shared in a particular manner and you provide such Personal Data and consent to it being shared.
Social Sharing Features
The Services (including content, functionality or features of the Services provided by our service providers) may offer social sharing features and other integrated tools (such as Facebook and Twitter widgets), which let you share actions you take through the Services with other media, and vice versa. The use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the party that provides these features. For more information about the purpose and scope of Personal Data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these features.
Linking to External Sites, Applications and Other Online Services
INTERNATIONAL TRANSFERS OF PERSONAL DATA
Hasbro is a global business whose headquarters is in the United States. Our customers and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country. These countries may have data protection laws that are different to the laws of your country.
Specifically, our website servers are located in the United States and our group companies and third-party service providers and partners operate in the United States, as well as elsewhere. This means that when we collect your Personal Data it will be processed in the United States, in addition to other locations. We will ensure that it is protected and transferred in a manner consistent with legal requirements. For EEA and UK customers, see more information on the safeguards we implement when transferring your Personal Data outside the EEA/UK in theEEA/UK Annex below.
You may obtain more information regarding our appropriate safeguards by contacting us using the details below.
HOW WE SAFEGUARD YOUR PERSONAL DATA
We have established controls and policies to maintain the security of our information and information systems and to protect your Personal Data against loss, misuse and unauthorized access, disclosure, alteration and/or destruction. Specific measures we use include data encryption according to industry standards and providing access to Personal Data only to employees performing a legitimate business function.
When you contact a Hasbro employee about your use of the Services, transactions or Personal Data, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your Personal Data.
Where you have created an account and unique password to enable you to access our Services it is your responsibility to keep this password secure and confidential.
We also review our security procedures periodically to consider appropriate new technology and updated methods for keeping Personal Data secure.
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 it is reasonably necessary in accordance with applicable law.
HOW LONG DO WE KEEP YOUR PERSONAL DATA
How long we will hold your Personal Data for will vary and will be determined by different criteria.
We retain your Personal Data where we have an ongoing legitimate business need to do so. This may be to provide you with products and services you have requested, or to comply with applicable legal, tax or accounting requirements (laws or regulations may set a minimum period for which we have to keep your Personal Data), or otherwise administer our business.
In certain circumstance, we will need to keep your information for legal reasons after your account has been deleted. The specific retention periods depend on the nature of the information, why it is collected and processed, and the nature of the legal requirement. For example: We keep your information when we have a legal obligation to do so (such as, if a court order is received about your account, for ongoing local tax obligations, or to keep adequate records of winner information for any sweepstakes or contests we may offer from time to time, we would retained your data for longer than the usual retention period when an account is deleted); to deal with and resolve requests and complaints (for example, if there was an ongoing complaint with respect to a purchased item arriving broken but you had deleted your account), to protect individuals' rights and property (for example, we will retain information about a data subject access request for one year after the request in case there is a subsequent complaint and the information is needed to demonstrate how the request was handled), and for litigation or regulatory matters (for example, we would retained your information if there was an ongoing legal claim and the information was relevant to the claim.) All required information would be retained until the applicable matter had been concluded.
When we have no ongoing legitimate business need or legal reason to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
ANALYTICS AND ADVERTISING
We use the following analytics and advertising tools and services and specific information relating to the analytics and advertising tools we use in your geographic location can be found in your localized Cookie Policy. For more information about your choices and rights associated with analytics, interest-based advertising and matched adds, please visit our Cookie policy, set your preferences in our cookie management tool and/or review the next section of this Privacy Policy, “What are my information choices.”
Website and Mobile Analytics
We use analytics and services, such as Google Analytics and Google advertising tags to help us understand how our users access and use our Services. These tools and services use cookies, web beacons, and other devices or technologies on the Services to enable them to track traffic data. The data collected typically includes information such as your IP address, your Internet Service Provider, your web browser, the time spent on web pages, the links clicked, and the advertisements viewed on those pages. We use this information to improve the Services and your experience, to see which areas and features of the Services are popular, and for which visitors, and to count visits.
Interest-Based Advertising
We work with agencies, ad networks, technology services, and other parties to place ads for our products and services on other websites and online services. These other parties use cookies, web beacons, and other devices or technologies to collect information about your visits to websites and mobile applications, including to the Services. The data is collected through first party cookies and third-party cookies and typically includes information such as your IP address, your web browser, web pages viewed, time spent on pages, links clicked, and whether you purchased an advertised product. These other parties use this information to track your activities across time and services for purposes of associating the different devices you use and delivering advertising and/or content targeted to your interests.
Matched Ads
Websites and applications owned or operated by other parties may display ads from Hasbro that are targeted to reach people (or people similar to people) on those websites or applications who have visited our Services or are also identified on one of more of Hasbro's databases. This is done by us uploading a customer list to the other party or incorporating a pixel from the other party on our Services, and the other party matching common factors between our data and the data of the other party. For instance, we incorporate the Facebook pixel on our Site and may share your email address with Facebook as part of Facebook Custom Audiences. We may also work with partners to deliver matched ads based on data about you and others in those partners' own databases.
WHAT ARE MY INFORMATION CHOICES
Regarding Accounts
If you have created an account with the Services, you may at any time review and/or update the contact details and address information we have for you by signing into your account or by contacting your applicable Hasbro Consumer Care Pulse representative with any questions or updates to your account information.
If you wish to fully remove your account information from our database and delete your information, please click on this link to our online Form to do so.
If you choose to send us an email through Consumer Care, please be sure to include the following in your message: the name of the Hasbro website with which you have an account, and the email address you used to sign up for that account so that we can verify your request. If you have requested that we save information for you in connection with placing an order through the Services, please email your request to the Hasbro Pulse Consumer Care representative. See the Contact Us section below for specific details. We will respond to requests as soon as possible.
Please note, however, that we may retain your information following such requests as described in the section on How Long Do We Keep Your Personal Data.
Regarding Ratings, Reviews and Questions You Post
If you have posted product-related questions, ratings, or review content that you want us to remove from the Site, please email your request using the applicable contact info below. Please note, however, that we may need to keep your previously posted information set out in the section on How Long Do We Keep Your Personal Data above.
Regarding Promotional Communications
We may send you promotional communications if you sign up and agree to receive them through the Services. If you have signed up to receive promotional communications from Hasbro via another Hasbro ecommerce site, you will receive them through Hasbro Pulse rather than directly from the ecommerce site.
You may opt-out of receiving promotions emails or mails from Hasbro at any time by declining to receive such communications when you sign up for an account, place an order or otherwise provide your contact information to us. You may also opt-out of receiving promotions emails at any time either by following the instructions to “unsubscribe” in those emails or by contacting your Hasbro Pulse Consumer Care representative.
If you opt-out or unsubscribe, we may still send you transactional or relationship messages, such as emails about your account, an order you placed, a crowdfunded product you have backed, or our other ongoing business relations.
Regarding Cookies
You may choose to set your cookie settings and preferences at any time by clicking and using the Cookies Settings link. Please note that if you choose to remove or reject certain cookies, the functionality and availability of some or all of the content and features available via the Services may be affected. Please refer to the Cookie Notice for more information.
Additional Choices Regarding Analytics and Interest Based Advertising
Google provides tools to manage the collection and use of certain information by Google Analytics at tools.google.com/dlpage/gaoptout.
Some of the companies we work with to provide you with targeted advertising participate in the Digital Advertising Alliance ("DAA") or the Network Advertising Initiative ("NAI"). For more information about the targeted advertising provided by these companies, and how to opt out of having your information used in this way by these companies, please visit: www.aboutads.info/choices for opt out for DAA participating companies or https://www.networkadvertising.org/choices for opt out for NAI participating companies. Opting out only means that the selected participants should no longer deliver certain targeted ads to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).
To opt out of us using your data for matched ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of matched ads. We will request that the applicable party not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable party to opt-out.
You may also limit our use of information collected from or about your mobile device for purposes of serving online behavioral advertising to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Ads Personalization” (for Android devices).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. Hasbro is not responsible for the effectiveness of, or compliance with, any third-party opt out options or programs, or the accuracy of any third-party statements regarding opt out options or programs.
Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. In addition, some browsers or plug-ins use a Global Privacy Control (GPC), which allows you to opt-out of certain data processing. (You can learn more about the GPC at https://globalprivacycontrol.org) Currently, our system does not support and cannot act on DNT signal headers that we may receive. If our Site detects a GPC signal from your device, however, we will interpret it as either a “Do Not Sell” request to limit the sale or sharing of Personal Data for targeted advertising depending on the law applicable to your jurisdiction.
U.S. STATE-SPECIFIC DISCLOSURES AND RIGHTS
This section provides additional disclosures for individuals who reside in California, Colorado, Connecticut, Utah, or Virginia. 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 Apps:
- Identifiers, including name, address, email address, IP address – and an ID number assigned to your account;
- Customer records, phone number, billing address, credit or debit card information;
- Commercial Information, including purchases and engagement with the Services
- Internet activity, including history or visiting and interacting with our Services, browser type, browser language and other information collected automatically;
- Geolocation data;and
- Inferences including information about your interests, preferences and favorite brands and products
For more information on information we collect, including the sources we receive information from, review the “What information is collected about me” Section of this Privacy Policy.
Residents in certain states, however, may have the right to opt-out of some of our advertising technology activities under the State Privacy Laws. Accordingly, please review the “Right to Opt-Out” section below, which provides you with information on how to opt-out. When you opt-out, Hasbro will stop sharing your information with its advertising partners for the delivery of relevant advertising.
Right to Opt-Out
Under applicable State Privacy Law, you may have the right to opt out of the sale of your Personal Data by us to third parties at any time. You may submit a request to opt out of advertising technologies we use on the Services by accessing our online Form.
Right to Access or Delete Your Information
You have the right to request access to, and a copy of, the:
- categories of personal information we have collected about you;
- categories of sources from which the personal information was collected;
- categories of personal information about you we disclosed for a business purpose or sold;
- categories of third parties to whom the personal information was sold or disclosed for a business purpose;
- business or commercial purpose for collecting or selling the personal information;and
- specific pieces of personal information we have collected about you.
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, by accessing our online Form 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.
Otherwise, you may submit opt-out requests by calling our toll-free number at (800) 255-5516 or emailing us at DPO@Hasbro.com.
We do not knowingly sell or share Personal Data of minors under 16 (sixteen) years of age.
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.
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.
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. 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
EEA/UK ANNEX
This annex provides additional disclosures for individuals who reside in the United Kingdom and in the European Union.
Your Rights
You have the following rights in relation to your Personal Data. To exercise any of them please submit a request to us by accessing our online Form or contact us using the contact details provided under the “Contact Us” heading:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent with effect for the future to the processing of your Personal Data at any time. Please note, however, that 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 data conducted in reliance on a lawful basis other than consent. For example, we may need to retain Personal Data to comply with a legal obligation;
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Hasbro;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data (including removing your account information) in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it;
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request. If we process your Person Data for direct marketing purposes, you have the right to object at any time to processing of your Personal Data for such marketing as explained above at “What are my Information Choices”;
- the right to opt out of marketing communications we send you at any time; and
- the right to lodge a complaint with a data protection regulator.
What is Hasbro’s Legal Basis for Processing Personal Data?
When we use your Personal Data, we make sure that we have a valid "legal basis" for each of our processing purposes/activities. Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. We have set out a description of the ways we will use your Personal Data and which of the legal bases we rely on to do so, in the table below.
In certain situations, we require your data to pursue our legitimate interests in a way which is reasonable for you to expect as part of the running our business and which does not materially affect your rights and freedoms. We have identified below what our legitimate interests are.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To provide you with access to the Site, its content and functionalities, including registering you as a new customer and providing you with access to your account |
(a) Identity (b) Contact |
(a) Performance of a contract with you (b) Otherwise (where we do not have a relevant contract with you), it is necessary for our legitimate interests (in providing access to the Site and related functionality to Site visitors) |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Send you order confirmations and invoices
|
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Basket (f) Marketing and Communications
|
(a) Performance of a contract with you |
|
To collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Necessary for our legitimate interests (to recover debts due to us)
|
|
To enable you to back a crowdfunded product |
(a) Identity (b) Contact (c) Financial |
(a) Performance of a contract with you |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Sending you technical notices, updates, security alerts, and support and administrative messages
(c) Responding to your comments, questions, and requests and providing customer service |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Normally our legal basis will be in order to perform our contract with you (b) On occasion, our legal basis might be that it is necessary to comply with a legal obligation such as obligations under UK GDPR to notify you about security incidents in certain circumstances |
|
To study how customers use our products/services, understand feedback on products/ services (including where you opt to take part in a survey) |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Transaction (g) Basket |
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|
|
To enable you to partake in a prize draw, competition |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Transaction
(g) Basket |
(a) Performance of a contract with you
|
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, technical security and hosting of data) |
(a) Identity (b) Contact (c) Technical (d) Transaction
(e) Basket |
(a) Generally our legal basis is that this is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) In some circumstances our legal basis may be that it is necessary to comply with a legal obligation (e.g. anti-fraud legislation and our obligations under UK GDPR to maintain appropriate technical and organisational security measures) |
|
To operate and improve the Services, including by linking or combining your Personal Data with other information we get from our service providers or other parties, or information related to your interactions with other Hasbro sites or online services
|
(a) Identity (b) Contact (c) Profile (d) Usage (e) Technical
(f) Transaction
(g) Basket |
[(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to ensure our Site and our Services operate effectively) // Based on your consent. |
|
To personalize your experience with the Services, including through Site features such as product search results and product recommendations |
(a) Identity
(b) Profile
(c) Usage
(d) Technical
(f) Transaction
(g) Basket
|
(a) Consent: Where Personal Data is collected via Cookies, we will process your Personal Data on the basis of your consent
(b) Necessary for our legitimate interests (to give you a more tailored experience, develop our products/services and grow our business). |
|
To deliver relevant advertisements to you and measure or understand your interests and the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Transaction
(h) Basket |
(a) Consent (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
|
To monitor performance of the Site and overall usage of the Site and user retention rates, track how users are engaging with the Site and the Services, identify how and how frequently Site features are utilized, identify problem areas within the Site, and inform design development for future updates |
(a) Technical (b) Usage (c) Basket |
(a) Consent (b) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
For internal business purposes, including tracking and measuring product sales information, management and administration of our business, and administration and maintenance of databases storing Personal Data |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
(g) Transaction
(h) Basket
|
(a) Necessary for our legitimate interests (for running our business)
|
|
To share information with law enforcement and others, in circumstances where someone’s vital interests require protection, such as in the case of emergencies. These vital interests include protection of your (or in exceptional circumstances someone else’s) life, physical or mental health or integrity or that of others.
|
(a) Identity (b) Profile (c) Contact (d) Communications (e) Usage (f) Technical (g) Transaction
|
(a) Necessary to protect vital interest (to combat harmful conduct and promote safety, integrity and security). For example, we investigate reports of harmful conduct at our in-person events or conventions and take appropriate action, such as sharing information with relevant authorities, where there is a risk of imminent harmful conduct such as an attack or where a person’s safety is at risk.
|
|
To share information with law enforcement and public authorities where necessary to protect against fraudulent, abusive, inappropriate, or unlawful use of the Services; and to protect the safety of Hasbro, our users or any person or entity |
(a) Identity (b) Profile (c) Contact (d)Communications (e) Usage (f) Technical (g) Transaction
(h) Basket
|
(a) In some circumstances this is necessary to comply with a legal obligation such as to comply with anti-fraud laws;
(b) In some circumstances it may be necessary to share data with these entities for our legitimate interests (in combatting harmful conduct and promote safety, integrity and security). For example, to protect individuals from severe fraud threats.
|
|
To make suggestions and recommendations to you about aspects of the Services and products that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Transaction
(h) Basket |
(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (where consent is not required by marketing laws) |
|
To send you advertising or promotional materials, including information about new products, contests, features and enhancements, special offers and other events of interest from Hasbro and our select partners |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Transaction (f) Basket |
(a) If required by marketing laws, we seek consent before sending marketing materials to individuals and in such cases, consent is our lawful basis for sending marketing to you.
When we process your information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before it is withdrawn. To exercise your rights, see the 'Your data protection rights' section of this Privacy Policy.
(b) Where consent is not required, we carry out this processing as it is necessary for our legitimate interests (in marketing the Services and developing our business) |
|
For collecting information through the device-based settings which you have enabled |
(a) User Content (if provided by a user), including photos and media that you choose to share by enabling such sharing on your device-based settings |
(a) Consent When we process your information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before it is withdrawn. To exercise your rights, see your device-based settings, and 'Your data protection rights' section of this Privacy Policy. |
|
To comply with applicable laws, rules and regulations, and internal policies and procedures |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Financial (h) Transaction
|
(a) Necessary to comply with a legal obligation
|
Where our lawful basis is performance of a contract with you, your provision of the Personal Data is a contractual requirement (unless we tell you otherwise) – if you do not provide this Personal Data, then we may not be able to provide the Services to you.
International data transfers: Where we transfer your Personal Data outside the UK or the EEA, we rely on the following safeguards to keep your data protected:
- Where we transfer your Personal Data to countries or organizations outside the EEA and the UK, which have been formally recognized as providing an adequate level of protection for personal data, we rely on the relevant "adequacy decisions" from the European Commission and "adequacy regulations" from the Secretary of State in the UK;or
- Where the transfer is not subject to an adequacy decision or regulation, we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Privacy Policy and applicable laws. The safeguards we use to transfer Personal Data are controller-to- processor and controller-to-controller modules of the Standard Contractual Clauses approved by the European Commission and the UK Secretary of State, as appropriate.
You can obtain more details of the protection given to your Personal Data when it is transferred outside the country of your residence (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in section “Contact us” below.
CONTACT US
If you have a privacy-related inquiry, including questions or concerns regarding this Privacy Policy, questions or concerns regarding the processing of your Personal Data by Hasbro, questions relating to consent, or in order to exercise all your rights as mentioned above, or if you have a disability and would like to exercise this Privacy Policy in an alternative format, please contact us using the following contact information:
For Residents in the United States and Canada
Address:
Hasbro, Inc.
Attention: Hasbro Pulse Services Administrator
1027 Newport Avenue, Mailstop A906
Pawtucket, RI 02861
Email Address: DPO@hasbro.com
Telephone: (800) 255-5516
For product-related questions and requests, please contact Hasbro Consumer Care. Please note that any personal information provided by you via our consumer care 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 consumer care website.
For any other issues, please contact Customer Service by submitting a question or support request via the Site, calling us at 1-866-278-4264 Monday through Friday: 8AM to 7PM EST, Saturday: 8:30AM to 5:00PM EST, or emailing us at CustomerService@HasbroPulse.com. We will be happy to take your request.
For additional information about the Services, please review the Terms of Use provided on the Services.
For Residents in the United Kingdom
Address:
Hasbro Consumer Affairs Department
PO Box 43
Newport
Gwent NP19 4YH
United Kingdom
Email Address: customerservice_uk@hasbropulse.com
To get in touch with our Data Protection Officer, please contact us at DPO@hasbro.com
For product related questions and requests, please contact Customer Service.
For additional information about the Services, please review the Terms of Use provided on the Services
For Residents in the EEA
Address:
Hasbro Promotions International B.V.
De Entrée 240
1011 EE Amsterdam
The Netherlands
Email Address: dataprivacy@hasbro.com
To get in touch with our Data Protection Officer, please contact us at DPO@hasbro.com
For product-related questions and requests, please contact Customer Service.
For additional information about the Services, please review the Terms of Use provided on the Services
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 the ESRB at https://www.esrb.org/privacy/contact/.
ESRB