(Last updated:25 May 2018)
We are committed to protecting the privacy of your personal data in accordance with applicable privacy and data protection laws. The term “we”, “us” or “our” in this Privacy Notice refers to Boulder Media and any of its affiliate companies). This Policy applies to information we collect when you use our websites and other online products and services where this Policy is posted (collectively, the “Website” or “Websites”).
If you have any questions or concerns about our use of your personal data, then please contact us using the contact details provided at the bottom of this Privacy Notice.
We may update this Privacy Notice from time to time in response to changing legal, technical, or business developments. When we update our Privacy Notice, 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 Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
Table of Contents
1. What personal information do we collect and why?
2. With whom do we share your personal information.
3. Legal Basis for processing personal information.
4. How do we keep your personal information secure?
5. International data transfers.
6. Third party sites.
7. Your data protection rights.
8. How to contact us.
1. What personal information do we collect and why?
The personal information that we collect about you falls into the following categories:
- Cookies and similar tracking technology
- Information that you provide voluntarily
Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
- Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. Please note that we use aggregated (i.e. non-personal) information for these analytics purposes.
- Information that we obtain from third party sources
- Third Party Advertising
We may disclose your personal information to the following categories of recipients:
- to our group companies, third party services providers and partners 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 Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
- to any competent law enforcement body, regulatory, 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 disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
3. Legal Basis for Processing Personal Information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent 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).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we 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.
4. How Do We Keep Your Personal Information Secure?
Hasbro has established policies in an effort to protect your personal information against loss, misuse and unauthorized access, disclosure, alteration and/or destruction. For example, Hasbro strives to provide only those employees performing a legitimate business function with access to users’ personal information. Hasbro also reviews its security procedures periodically to implement appropriate technical and organisational measures to help safeguard your privacy.
Hasbro retains your information for legitimate business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. Hasbro will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time. 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 archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
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 that is reasonably necessary in accordance with applicable law.
5. International data transfers
Where possible, we try to keep the information you supply to us via this Website locally in the European Economic Area. However, as part of the services offered through our Website, the information you provide to us may be transferred to countries outside the EEA. By way of example, this may happen where any of our servers are hosted by one of our Hasbro Group companies in a country outside the EEA or one of our service providers is located in a country outside the EEA.
We may also share information between our group companies, which are located in countries worldwide. If you require contact details of our other group companies, please contact us. These countries may not have similar data protection laws to the EEA. If we transfer your information outside the EEA in this way, we will take appropriate steps to ensure that any personal data relating to you will continue to be adequately protected.
Other than the disclosures referred to in this Privacy Notice, we will not disclose any personal information without your permission.
6. Third party sites
We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Website and we recommend that you check the policy of each Website you visit.
In addition, if you have linked to our Website from a third party Website or other online service, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party Website or online service and recommend that you check the policy of that third party Website or online service and contact its owner or operator if you have any concerns or questions.
7. Your data protection rights
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 following rights in relation to your personal information: (i) to access, correct, update or request deletion of it; (ii) to object to processing of your personal information; (iii) to ask us to restrict processing of it; (iv) to request portability of it; and (v) to opt-out of marketing communications. You can exercise these rights by contacting us using the contact details provided below. 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 will respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
8. How to contact us
The data controller of your personal information is Hasbro, Inc.
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
Free phone: +343 1 6779775
Or write to us at:
2-4 Claremont Road
For DPO requests, please contact us at DPO@hasbro.com.