(Last Updated 6 June 2019)
BACKFLIP'S PRIVACY COMMITMENT
Note to Parents
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
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.
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
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:
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:
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.
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.
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:
We work with a number of service providers and third parties who collect information via our Apps and Our Ads (as defined below), including:
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
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.
We may disclose your personal information to the following categories of recipients:
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.
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.
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.
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:
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 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:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
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.
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.
If you believe you received this message in error, please contact us for assistance.
If you believe you received this message in error, please contact us for assistance.