(Last Updated 10 June 2019)
BACKFLIP’S PRIVACY COMMITMENT
- Note to Parents
- The Types of Information We Collect From Children
- How We Use Children’s Information
- Other Sections Applicable To Children’s Information
- The Types Of Information We Collect
- How We Use Your Information
- Who We Share Your Information With
- Our Legal Basis For Processing Your Information (for EEA visitors)
- How We Keep Your Information Secure
- International Data Transfers
- How Long We Keep Your Information
- Your Choices and Rights To Your Information
- Your California Privacy Rights
- How To Contact Us
Some of our Apps involve strategic gameplay and are directed toward experienced gamers, and some are intended for general audiences. We recognize that children may enjoy playing some of our general audience Apps and include age gates in those experiences. When a user indicates that the user is under 13 years old through an in-App age gate, we do not request that the user provide personal information to us or otherwise collect personal information from the user through that App, except as described below in this “Children’s Privacy” section.
We make efforts to avoid collecting personal information from children, except in those instances under the Children’s Online Privacy Protection Act (COPPA) and COPPA Rule or other applicable laws where personal information may be collected without parental consent.
- Information Children Provide. We collect information that children provide to us in-App for feedback or to contact us (for support, 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 We Automatically Collect From Children’s Devices. When children use one of our Apps, we automatically collect certain information to enable the App to operate, including the following:
- The Device ID (or “DID“) associated with the device used to access the App. We may store the DID or another unique ID that we generate for an App installation with a child’s contact information when the child contacts us for support.
- IP address
- MAC address
- Open Device Identification Number (or ODIN)
- The general location of the device the child is using (country and state level) from the device’s network
We also collect some general information from a child’s device such as device type, operating system, 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.
Some of this information may be collected using cookies and similar tracking technology, and by third parties as explained further under the “Information We Collect About Children From Third Parties” heading below in this “Children’s Privacy” section.
- Information We Collect About Children From Third Parties. We work with a number of companies that provide analytics services regarding use of our Apps. We may share children’s DIDs or other information with those companies, or enable them to collect children’s DIDs or other information to analyze the use of our Apps for us. When a user indicates that the user is under 13 years old through an in-App age gate, we make efforts to limit the analytics information collected to information associated with when the App is opened.
- 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 under 13.
- 4. Who We Share Your Information With
- 5. Our Legal Basis For Processing Your Information (for EEA visitors)
- 6. How We Keep Your Information Secure
- 7. International Data Transfers
- 8. How Long We Keep Your Information
- 9. Your Choices and Rights To Your Information
- 10. Your California Privacy Rights
- 12. How To Contact Us
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, or responding to a survey. This information may include:
- Your name
- Your email address
- Country of origin
- Your survey responses
- Your feedback
We may also collect your age in some of our Apps to determine whether you are old enough for certain App features. If you indicate that you are under 13, the App features that we make available to you are slightly different and governed by the Children’s Privacy section above.
Information We Automatically Collect
When you use one of our Apps we 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, and is used to build a picture about the person associated with the DID. We may store your DID or another unique ID that we generate for an App installation with your contact information when you contact us for support.
- Your IP address
- Your Advertising ID (or “ADID“). This is a unique ID that your device’s operating system provides that we and our advertising service providers use to show you relevant ads in some of our Apps.
- Your Game Store ID. This is the ID associated with your account with the platform provider of the app store accessible via your device.
- Your Device’s MAC address
- 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 and advertising service providers
- See “Information We Collect From Third Parties” section below.
- IDs associated with your accounts by Social Networking Services
- See “Information We Collect From Third Parties” section below.
- Your general location (country and state level) from your device’s network.
We also collect some general information from your device such as device type, operating system, 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.
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
- The name of the App you were visiting
- Confirmation from the app store of completion of purchase
Some of this information may be collected using cookies and similar tracking technology, and by third parties as explained further under the heading “Information We Collect From Third Parties” below.
Our Apps may also periodically examine the contents of your device to determine the presence of other Backflip Apps on the device. The Apps transmit the results of that examination to Backflip and our advertising service providers 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. When you start or stop an App, it may display an ad, and during gameplay a rotating banner ad may be displayed.
We may also automatically collect information related to the overall effectiveness of our advertising campaigns via our advertisements delivered on third party websites, apps and services (“Our Ads”). For example, we may collect information related to the number of people who click on Our Ads, and the number of people who download one of our Apps or other products via Our Ads. We may combine the information we collect via Our Ads with other information we collect via our Apps.
We work with a number of third parties who collect information via our Apps, including:
- Analytics. We may share your DID or other information with companies that provide analytics services regarding use of our Apps (or enable such companies to collect your DID or other information) to analyze use of the Apps for us, and for advertising about Backflip and other companies. These companies may combine information we provide to them or allow them to collect from or about you with information they collect in connection with other websites or applications.
Third Party Advertising
We use the personal information and other information collected through our Apps for the following purposes:
- to operate and improve our Apps, products, and services;
- to understand you and your preferences, to enhance your 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, to send relevant ads to you, to save your scores and gameplay levels, 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; and
- to link or combine it with other personal information we get from third parties, to help understand your needs and provide you with better service.
We may disclose your personal information to the following categories of recipients:
- to any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
- to any other person or entity, with your consent (or your parent or guardian’s consent, if you are a child) to the disclosure.
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 and not overridden by your rights, 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.
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.
Our servers are located in the United States, and our group companies and service providers and partners 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.
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. Backflip will also retain your information as reasonably necessary to comply with our legal 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.
If you are a resident of the EEA, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- 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 about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
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.
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
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.