BACKFLIP STUDIOS MOBILE APPLICATION PRIVACY POLICY


(Last Updated 24 May 2018)

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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 under 13 years old (“children”).

Backflip’s Apps covered by this Privacy Policy include any mobile applications displaying or linking to this Privacy Policy.

What’s in this Privacy Policy:

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

 

  • 1. CHILDREN’S PRIVACY
  • Note to Parents

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.

The Types of Information We Collect From Children

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.

 

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 under 13.

 

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:

 

  • 2. THE TYPES OF INFORMATION WE COLLECT

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
  • IDs associated with your accounts by Social Networking Services
  • 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.

  • Information We Collect From Third Parties

We work with a number of third parties who collect information via our Apps, including:

  • Social Networking Sites. If you use one of our Apps in connection with a social networking site (such as Facebook, Twitter, or Google+) (each, a “Social Networking Site”), we may receive information about you from such Social Networking Site, in accordance with such Social Networking Site’s terms of use and privacy policy (“SNS Terms”) and your privacy settings with them. For instance, if you associate an App with your Facebook account, Facebook provides the App with information which may include your name, profile picture, gender, networks, user ID, list of friends, email address, location, birthday and publishing stream, and other information you store on Facebook. We may add this information to the information we have already collected from you via the App. If you elect to share information you have provided to us or that we have collected from you with these Social Networking Sites, we share information with them in accordance with your election in the App. The SNS Terms apply to the information we disclose to them.

 

  • 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 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, the third party(ies) providing the Activity may automatically collect certain information about you and your participation in the Activity. 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, or the information collected by such third parties.

 

Third Party Advertising

We may also use third parties to serve ads on the Apps. Certain third parties may automatically collect information about your visits to our Apps and other applications, your IP address, your ISP, or your DID, ADID, or another unique ID. They do this using cookies, clear gifs, or other similar technologies. Information collected 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 policy does not apply to, and we are not responsible for, cookies or clear gifs 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 not having this information used by these companies, click here: http://www.networkadvertising.org.

  • 3. HOW WE USE YOUR INFORMATION

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.

 

  • 4. WHO WE SHARE YOUR INFORMATION WITH

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

  • to our group companies, third party service providers (such as data analytics providers and hosting providers) and partners (such as our advertising partners, in the case of personal information of users who are not children) who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Apps), 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 (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 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, 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 to Social Networking Sites, as described in the section under the heading “Information We Collect From Third Parties” above. You acknowledge and agree that you are solely responsible for your use of those websites 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 Site. We are not and will not be responsible or liable for: (i) the availability or accuracy of such Social Networking Sites; (ii) the content, products or services on or availability of such Social Networking Sites; or (iii) your use of any such Social Networking Sites.

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

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.

  • 6. HOW WE KEEP YOUR INFORMATION SECURE

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

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. 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. Other than the disclosures referred to in this Privacy Policy, we will not disclose your personal information without your permission.

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.

  • 8. HOW LONG WE KEEP YOUR INFORMATION

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.

  • 9. YOUR CHOICES AND RIGHTS TO YOUR INFORMATION

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.

  • 10. YOUR CALIFORNIA PRIVACY RIGHTS

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

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

  • 12. HOW TO CONTACT US

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.

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