BACKFLIP STUDIOS MOBILE APPLICATION PRIVACY POLICY


( Last Updated August 1, 2019)

Privacy Policy also available at http://www.backflipstudios.com/backflip-studios-privacy-policy/.

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BACKFLIP’S PRIVACY COMMITMENT

Backflip Studios, LLC (“Backflip”, “we“, “us“, or “our”) has prepared this Privacy Policy to describe how we collect, use, and share information from users of Backflip’s downloadable applications (each, an “App”), including users of some of our general audience Apps who identify themselves as children (“children”).

Apps covered by this Privacy Policy include any mobile applications published by Backflip that display or link to this Privacy Policy.

What’s in this Privacy Policy:

  1. 1. Children’s Privacy
  • Note to Parents
  • The Types of Information We Collect From Children
  • How We Use Children’s Information
  • Other Sections Applicable To Children’s Information
  1. 2. THE TYPES OF INFORMATION COLLECTED THROUGH OUR APPS AND OUR ADS
  2. 3. How We Use Your Information
  3. 4. Who We Share Your Information With
  4. 5. Our Legal Basis For Processing Your Information (for EEA visitors)
  5. 6. How We Keep Your Information Secure
  6. 7. International Data Transfers
  7. 8. How Long We Keep Your Information
  8. 9. Your Choices and Rights To Your Information
  9. 10. Your California Privacy Rights
  10. 11. Changes To This Privacy Policy
  11. 12. How To Contact Us

 

    1. 1.CHILDREN’S PRIVACY

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    1. Note to Parents

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Some of our Apps involve strategic or competitive gameplay and are targeted toward experienced gamers, and some are intended for a broader audience. We recognize that children may enjoy playing some of our Apps and include age gates in those experiences. When a user indicates that the user is a child through an in-App age gate, we make efforts to avoid collecting information from that user, except in those instances under the Children’s Online Privacy Protection Act (COPPA) and COPPA Rule or other applicable laws where information may be collected from children (as “child” or “children” is defined under such laws) without parental consent.

Information Collected From Children

  • Information Children Provide. We collect information that children provide to us in-App for feedback or to contact us (for support requests, for example). If children provide any personal information in queries or support requests, we use that information solely to assist them in response to the applicable query or support request.

 

  • Information Automatically Collected From Devices. When children use one of our Apps, we and some of our service providers automatically collect certain information from the device the App is installed on to maintain and analyze the functioning of the App, and for other purposes to support the internal operations of the App. This information includes the following:

 

  • The Device ID (or “DID”) associated with the device used to access the App. We may store or associate the DID or other unique IDs generated by us or our analytics service providers for an App installation with a child’s contact information when the child contacts us for support for purposes of addressing and responding to that support request.
  • IP address
  • Game Store ID. This is the ID associated with a device by the platform provider of the app store accessible via that device.
  • Media Access Control (or MAC) address. This is an assigned ID that makes the device uniquely identifiable on a network.
  • Open Device Identification Number (or ODIN). This is a unique ID related to the device’s MAC address.
  • The general location of the device (country and state level) based on IP address from the device’s network.

 

We also collect some general information from a device such as device type, operating system, device language, application software, and other metadata (such as timestamps) about use of the App and may connect it with the DID or other information described above.

  • Information about Gameplay. We and some of our service providers gather analytics and statistical information about use of an App and gameplay data, such as session start, end, and length (when and for how long the App was played), what levels were reached in the App, and what (if any) in-App items were purchased by a user, or sent from one user to another. We use this information to administer our Apps, to analyze trends in user interactions with App features, to debug our Apps in case of problems, and to gather information about our user base as a whole (for example, number of users in a particular country or region), so that we can improve our Apps.

 

Some of the information described above in the “Information Automatically Collected From Devices” and “Information about Gameplay” sections may be collected by us or our service providers using cookies and other tracking technologies.

How We Use Children’s Information

  • We use children’s information collected through our Apps as described above, and to otherwise support the internal operation of our Apps. For example, we use this information to track available in-App currency, to save gameplay levels, and to permit access to gameplay across different devices. Our Apps do not display advertising to users who have indicated they are children.

 

Other Sections Applicable To Children’s Information. The following sections of this Privacy Policy also apply to children who use our Apps, and the information that we collect from them:

  1. 4. Who We Share Your Information With
  2. 5. Our Legal Basis For Processing Your Information (for EEA visitors)
  3. 6. How We Keep Your Information Secure
  4. 7. International Data Transfers
  5. 8. How Long We Keep Your Information
  6. 9. Your Choices and Rights To Your Information
  7. 10. Your California Privacy Rights
  8. 11. Changes To This Privacy Policy
  9. 12. How To Contact Us

 

  1. 2. THE TYPES OF INFORMATION COLLECTED THROUGH OUR APPS AND OUR ADS

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Information You Provide

We collect any information that you provide directly to us through use of one or more of our Apps, whether you provide that information through gameplay or other in-App interactions, such as contacting us for support, providing feedback about App features or functionality, responding to a survey, or engaging with other users of our Apps in-game. This information may include:

  • Your name
  • Your email address
  • Account IDs and other information associated with your accounts with Social Networking Services that you use in connection with our Apps (described in more detail below)
  • Your survey responses
  • Your feedback
  • Information you provide through text boxes or fields in our Apps, or through other features of our Apps (for example, when you name App features, or when you send in-App items to or otherwise interact with your friends or teammates in an App)

We may also ask for your birthdate and collect your age in some of our Apps to determine which App features to make available to you. We do not keep the birthdate you enter, but we do use general age information in certain of our Apps in an effort to provide you and other users with appropriate in-App experiences.

Automatically Collected Information

When you use one of our Apps, we and some of our service providers and partners automatically collect certain information, including the following:

      • Your Device ID (or “DID“). This is a unique identifier for the device you use to access our Apps. We may store or associate your DID or other unique IDs generated by us or our service providers for an App installation with your contact information when you contact us for support. We or our service providers or advertising networks and vendors may also store or associate your DID with other unique IDs generated or used in connection with analytics and advertising services.
      • Your IP address
      • Your Advertising ID (or “Ad ID”). This is a unique ID that your device’s operating system provides that we and advertising networks and vendors use to show you relevant ads in some of our Apps and in apps and online services operated by others, and to link an App installation on your device to a particular ad campaign.
      • Your Game Store ID. This is the ID associated with your account by the platform provider of the app store accessible via your device.
      • Your Device’s Media Access Control (or MAC) address. This is an assigned ID that makes your device uniquely identifiable on a network.
      • Your Device’s Open Device Identification Number (or ODIN). This is a unique ID related to your device’s MAC address.
      • Unique IDs assigned to you by our analytics service providers and advertising networks and vendors
      • IDs associated with your accounts with Social Networking Services
      • Your general location (country and state level) based on your IP address.

 

We also collect some general information from your device such as device type, operating system, device language, application software version, and other metadata (such as timestamps) about your use of our Apps and may connect that information with your DID or the other information described above.

Our Apps may periodically examine apps on your device to determine if you have installed other Backflip Apps. The Apps transmit the results of that examination to Backflip and our advertising partners to be used in targeting advertisements to your device. For example, if you have PaperToss and NinJump installed on your device, when you play PaperToss, we will not send you ads for NinJump and will instead send you other, more relevant ads.

      1. Information About Gameplay

We and some of our service providers gather analytics and statistical information about use of an App and gameplay data, such as session start, end, and length (when and for how long the App was played), what levels were reached in the App, and what (if any) in-App items were purchased by a user, or sent from one user to another. We use this information to administer our Apps, to analyze trends in user interactions with App features, to debug our Apps in case of problems, to gather information about groups of our users, as well as our user base as a whole (for example, number of users in a particular country or region), and to show relevant ads and in-App features and items to you and users like you, so that we can improve our Apps and user experiences with them.

      1. Information about In-App Purchases

If you make any in-App purchases for yourself or your child, we also automatically collect or receive information related to those purchases from the platform provider (e.g., Apple or Google). This may include:

      • Your name, Game Store ID, or other ID associated with your account with the platform provider
      • The item purchased, and its cost
      • The name of the App you were visiting
      • Confirmation from the app store of completion of purchase
      1. Information Collected By and From Service Providers and Third Parties

We work with a number of service providers and third parties who collect information via our Apps and Our Ads (as defined below), including:

      • Social Networking Services. If you use one of our Apps in connection with a social networking site or service (such as Facebook or Twitter) (each, a “Social Networking Service”), we may receive information about you from such Social Networking Service, in accordance with such Social Networking Service’s terms of use and privacy policy (together, the “SNS Terms”) and your privacy settings with them. For instance, if you associate an App with your Facebook account, Facebook provides the App (and us) with information which may include your name, profile picture, gender, networks, Facebook user ID, list of friends, email address, location, birthday and publishing stream, and other information you store on Facebook. We may make certain of this information visible to you and other users of the App (for example, your profile name or Facebook user ID and picture), and may add this information to the information we have already collected from you via the App. If you elect to share information about your in-App activities by posting on Social Networking Services you use in connection with the App, we share information with them in accordance with your election in the App.

 

      • Advertising Networks and Vendors. We may receive information from advertising networks and vendors that create and place advertisements for us on third party websites, apps, and other online services (“Our Ads”), and from service providers and vendors we work with for ad attribution purposes. This could include information about the overall effectiveness of Backflip’s advertising campaigns, such as general information on the number of people who have clicked on one of Our Ads and who have downloaded one of our Apps via Our Ads, as well as information about how you have interacted with one of Our Ads, and when you have clicked on one of Our Ads, installed one of our Apps, and launched the App after viewing or clicking on one of Our Ads. We and our ad networks and vendors may collect this information via cookies and other tracking technologies embedded in our Ads, and we may combine the information collected via Our Ads with other information we collect via our Apps.

 

      • Analytics Service Providers. We may also receive information about gameplay and your other interactions with our Apps from companies that provide analytics services regarding use of our Apps, as described above in the “Information about Gameplay” section.

 

      • Third Party Offers or Activities. Our Apps may provide you access to third party services that offer in-App rewards in exchange for your participation in the third party’s offer or activity (each an “Activity”). If you click on or otherwise participate in any Activity outside of one of our Apps, the third party(ies) providing the Activity may collect certain information about you and your participation in the Activity, and may provide some of that information to us. We may combine that information with other information collected through our Apps and Our Ads, as described in the “How We Use Your Information” section below. We recommend that you review the privacy policy(ies) of the third party(ies) providing the Activity and contact the applicable third party(ies) if you have any concerns or questions. Backflip is not responsible for any third party providing any Activity, the information collected by such third parties, or the third parties’ use of such information.

 

Some of the information described in this section on information collected through our Apps and Our Ads may be collected by us, our service providers, or third parties using cookies and other tracking technologies.

Third Party Advertising

In addition to our work with ad networks and vendors in connection with Our Ads as described in the section above on “Advertising Networks and Vendors,” we may also work with third parties to serve ads on the Apps, and may make your Ad ID available to such third parties in connection with in-App advertising. If you click on ads from third party publishers in our Apps, those third parties and the ad networks they work with may automatically collect information about your visits to our Apps and other applications, your IP address, your ISP, or your DID, Ad ID, or another unique ID. They do this using cookies, clear gifs, or other similar tracking technologies. Information collected by these third parties may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Apps and the other applications and online services tracked by these third parties. This Privacy Policy does not apply to, and we are not responsible for, cookies, clear gifs, or other tracking technologies in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology.

If you would like more information about this practice and to know your choices about use of your information for behavioral advertising by certain ad networks and other members of the Network Advertising Initiative and the Digital Advertising Alliance, you can visit http://www.networkadvertising.org/choices and http://www.aboutads.info/appchoices. Backflip is not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their opt-out options or programs.

3. HOW WE USE YOUR INFORMATION

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We use the personal information and other information collected through our Apps and Our Ads for the following purposes, in addition to those purposes described elsewhere in this Privacy Policy:

      • to operate and improve our Apps, products, and services;
      • to understand you and your preferences, to enhance your and other users’ experiences with and enjoyment of our Apps and related products and services;
      • to send you push notifications;
      • to respond to your comments and questions and provide customer service;
      • to track (via your DID or other unique ID that we or our service providers generate or assign) your in-App currency and other virtual items, to save your scores and gameplay levels, to match you with opponents at similar levels of gameplay in Apps with competitive player vs. player or player vs. environment experiences, to permit you to access gameplay across different devices, and to provide the services you request;
      • to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
      • to communicate with you about new promotions, rewards, upcoming events, and other news about products and services offered by Backflip and our selected partners;
      • to facilitate our ad networks’ display of Our Ads to you and others in third party apps and online services, and relevant ads for third party apps to you in our Apps;
      • to associate your installation of an App with one of Our Ads from a particular ad campaign (if applicable), for purposes of ad attribution; and
      • to link or combine it with other information we get from third parties, to help us understand the needs and preferences of you and other users, and to provide you and other users with better service.

 

4. WHO WE SHARE YOUR INFORMATION WITH

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We may disclose your personal information to the following categories of recipients:

      • to our group companies, for internal business purposes.
      • to our service providers (such as analytics providers, hosting providers, and other companies we engage in connection with the operation and support of our Apps), partners, and vendors (such as our advertising partners, in the case of personal information of users who are not children) who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Policy or that you (and your parent or guardian, if you are a child) are notified of when we collect your personal information.
      • to any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary or appropriate to (i) comply with applicable law or regulation or legal process or to respond to lawful requests of competent legal authorities, (ii) exercise, establish, defend, or protect our legal rights, including to enforce our agreements, policies and the Terms of Service for the applicable App and protect against fraudulent, abusive, inappropriate, or unlawful use of an App, or (iii) protect your vital interests or those of any other person or to protect the safety of Backflip and our group companies, our or their users, or any third party.
      • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business or sale of company assets, provided that we inform the buyer it must use your personal information only for the purposes described in this Privacy Policy.
      • to any other person or entity, with your consent (or your parent or guardian’s consent, if you are a child) to the disclosure.

Our Apps may also enable users who are not children to post content from our Apps or related to use of our Apps to Social Networking Services, as described in the section under the heading “Information Collected By and From Service Providers and Third Parties” above. You acknowledge and agree that you are solely responsible for your use of those Social Networking Services, and that it is your responsibility to review the terms of use and privacy policy of the third party provider of each such Social Networking Service. We are not and will not be responsible or liable for: (i) the availability or accuracy of such Social Networking Services; (ii) the content, products or services on such Social Networking Services; or (iii) your use of any such Social Networking Services.

5. OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION (FOR EEA VISITORS)

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If you are a user from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above depends on the personal information concerned and the specific context in which we collect it.

However, we normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as our Terms of Service), (ii) where the processing is in our legitimate interests, or (iii) where we have your consent (or your parent or guardian’s consent, if you are a child) to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Apps, or communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

6. HOW WE KEEP YOUR INFORMATION SECURE

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We use and periodically review our technical and organisational security measures in an effort to protect the personal information that we collect and process about you. For example, Backflip strives to provide only those employees performing a legitimate business function with access to users’ personal information.

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

7. INTERNATIONAL DATA TRANSFERS

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Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. Our servers are located in the United States, and our group companies, service providers, partners, and vendors operate in the United States, Europe, and in countries outside of the EEA. This means that when we collect your personal information, we or others may process it in any of these countries. These countries may have data protection laws that are different than the laws of your country. If you are a user from the EEA and we transfer your information outside of the EEA in this way, we will take appropriate steps to ensure that any personal information relating to you will continue to be adequately protected.

You can obtain more details of the protection given to your personal information when it is transferred outside the EEA by contacting us using the details set out under the “How to contact us” section below.

Other than the disclosures referred to in this Privacy Policy, we will not disclose your personal information without your permission.

8. HOW LONG WE KEEP YOUR INFORMATION

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We retain personal information we collect from you for legitimate business purposes, and/or as long as is reasonably necessary to provide you with access to our Apps or our other products or services. How long we retain your personal information will vary and will be determined by the following criteria:

      • The purpose for which we are using it—Backflip will need to keep your personal information for as long as it is necessary for that purpose.

 

      • Legal and regulatory obligations—Laws and regulations may set a minimum period for which Backflip will need to keep your personal information, and we will retain your information as reasonably necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. YOUR CHOICES AND RIGHTS TO YOUR INFORMATION

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If you are a resident of the EEA, you have the data protection rights described below. If you want to exercise these rights, you can do so by contacting us using the contact details provided under the “How to contact us” heading below:

      • You can access, correct, update, or request deletion of your personal information. Please note that there may be circumstances where you ask us to delete your personal information but we are legally entitled to retain it.

 

      • In addition, you can object to processing of your personal information, or ask us to restrict processing of your personal information. Please note that there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.

 

      • In some circumstances, you can also request to receive some of your personal information in a structured, commonly used and machine-readable format and/or request that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to us.

 

      • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. 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 information conducted in reliance on lawful processing grounds other than consent.

 

      • You have the right to complain to a data protection authority if you think that any of your rights have been infringed by us.

 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

      1. Marketing Communications

You can opt-out of marketing communications we send you at any time by clicking on the “unsubscribe” or “opt-out” link in any marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing, if applicable), please contact us using the contact details provided under the “How to contact us” heading below.

10. YOUR CALIFORNIA PRIVACY RIGHTS

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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 are a California resident and would like this information, please contact us using the details set out under the “How to contact us” section below.

11. CHANGES TO THIS PRIVACY POLICY

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We may update this Privacy Policy from time to time, such as in response to changing legal, technical or business developments, and will indicate when changes have been made by revising the date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will provide you with additional notice of such changes by prominently posting notice of the changes or otherwise taking appropriate measures to inform you of the changes, consistent with the significance of the changes we make. Your use of our Apps following the posting of such changes will constitute your consent to such changes. If you do not agree with the changes we make to this Privacy Policy, please stop using our Apps.

12. HOW TO CONTACT US

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If you have any questions or concerns about our use of your personal information, please contact us using the following details:

privacy@backflipstudios.com .
Backflip Studios, LLC

Attn: Legal Department

1690 38th St.

Boulder, CO 80301

The data controller of your personal information is Backflip Studios, LLC.

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