Privacy Notice

Hasbro Pulse – Privacy Notice

(Last Updated: 13 October 2022)

WELCOME!

This privacy notice ("Privacy Notice") explains how Hasbro Promotions International B.V., with its registered office at De Entrée 240, 1101 EE Amsterdam, the Netherlands, and its subsidiaries and affiliated companies (collectively, "Hasbro", "we", "our", or "us") collects, uses, processes and discloses your Personal Data when you visit the e-commerce site for Hasbro fans at https://eu.hasbropulse.com (the “Site”), view or interact with content or functionality on the Site to find out more about or order Hasbro products and services, including Hasbro Pulse Premium and backing the crowdfunded products (the Site, such content and functionality, and related online products and services collectively, the “Services”), or interact with us offline regarding the Services.

We ask that you take the time to read this Privacy Notice carefully.

TABLE OF CONTENTS

Background
Changes to this Privacy Notice
What information is processed about me?
How does Hasbro use my information?
With whom does Hasbro share my information?
Cookies
What are my information choices?
International transfers of Personal Data
How we safeguard your Personal Data
How long we keep your Personal Data
Your rights
Contact Us

1. BACKGROUND

We respect your privacy, and we are committed to keeping all your Personal Data secure.

We collect, process and use certain Personal Data and we are responsible for ensuring that we process that Personal Data in compliance with data protection laws, including the EU General Data Protection Regulation (“GDPR”), and any other national, implementing or supplementing data protection legislation.

We use the following definitions in this Privacy Notice:

User(s) or You	means the users of the Site and/or anyone whose Personal Data we collect and use in relation to the Services.
Personal Data	means any data or information which relates to a living individual who can be identified, directly or indirectly, from that data or from that data and other information, which is in the possession of, or is likely to come into the possession of, Hasbro (or its representatives, or service providers).

2. CHANGES TO THIS PRIVACY NOTICE

We encourage you to review this Privacy Notice whenever you access and/or use the Services to make sure that you understand our Personal Data collection, use, processing, and disclosure practices. We may make minor changes to the provisions of this Privacy Notice at any time and will indicate when changes have been made by revising the date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we will provide you with additional notice of such changes by sending you an email at the last email address that you provided us, or by prominently posting notice of the changes on the Site.

3. WHAT INFORMATION IS PROCESSED ABOUT ME?

Many of the products and/or services offered by Hasbro on the Site require us to obtain Personal Data about you in order to provide and/or perform the Services. Users may be unable to access certain services or sections of the Site if such Personal Data are not provided. In relation to the Services, we may collect and process the following Personal Data about you subject to us having a legal basis as set out in section 4 of this Privacy Notice:

INFORMATION THAT YOU PROVIDE TO HASBRO

We collect Personal Data that you provide when you access and use the Services, such as when you:

create an account on the Site or subscribe to the Services;

make a purchase or request to purchase a product;

rate, review, or ask a question about a product;

back a crowdfunded product;

participate in contests, events, or promotions;

send questions or comments to us, or contact Customer Service;

fill out online surveys;

share a website with a friend; or

otherwise communicate with us through the Services.

Depending on the nature of your activity on the Site, the types of Personal Data that you provide, and we collect will include:

your first and/or last name (including any usernames containing your first and/or last name);

email address;

telephone number;

address (including billing address and/or delivery address);

credit or debit card details or other payment information;

your unique digital identifiers (e.g., IP address); and

other information that you choose to provide and/or share on the Site which may be considered Personal Data.

Other Personal Data you may also provide through your use of the Services includes your product preferences, searches, and browsing activity.

In some cases, we also collect Personal Data you provide about others, such as when you refer someone to the Services (including promotions) or when you purchase and ship products to someone.

Please note that this Privacy Notice applies to any Personal Data that we collect (or that our service providers process on our behalf) through your access and/or use of the Services or offline (for example, at fan conventions). If we collect and/or share Personal Data in a manner that differs from what is described in this Privacy Notice, we will notify you of the purposes for which such Personal Data will be collected and/or with whom such Personal Data will be shared (if applicable), whether via a just-in-time notification at the point of collection or via an alternate notice.

INFORMATION THAT WE COLLECT OR GENERATE ABOUT YOU

This includes:

any information regarding the products and/or services purchased and/or used on the Site and our interactions with you;

a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the products and/or services which we have provided to you;

activity data relating to you publishing content on the Site;

any information, content and/or feedback that you choose to share on the Site which may be considered Personal Data; and

any information we save in connection with placing an order on the Site (where you have asked us to save the information).

INFORMATION COLLECTED AUTOMATICALLY FROM YOU

When you access and/or use the Services, we may also automatically collect information about your visit. The types of information we and our service providers automatically collect include your computer's Internet Protocol ("IP") address, other unique identifiers (e.g. ad tags or IDs), information about your hardware, operating system version, browser type and language, screen resolution, geographic location (country, state, and city level), the URL of the website you visited before navigating to the Services, and other analytics and statistical data regarding your access to and/or use of the Services (e.g., downloads, number of users, access times, sessions, page views, frequency of use, retention, clicks, etc.).

INFORMATION OBTAINED FROM OTHER SOURCES

We may also obtain Personal Data from other sources and combine it with information we collect through the Services. For example, if we enable a feature on the Site that permits you to interact with a social media site or platform, or if we partner with a social media site or platform for advertising purposes, we may have access to certain Personal Data from that social media site or platform, such as your name, account information, and friends, and engagement with our content or our brands on the social media site or platform, in accordance with your settings for how the social media site or platform may share your information and the authorization procedures determined by such social media site or platform. In addition to social media sites and platforms, the other sources from which we have collected information about you include:

partners that offer co-branded services or engage in marketing and advertising activities on our behalf;

publicly available sources, including data in the public domain; and

third-party service providers, agencies, or other publicly available sources where applicable.

INFORMATION PROCESSED ABOUT YOU BY SOCIAL MEDIA PARTNERS

Where we partner with social media platforms such as Facebook, they may process personal data about existing Pulse customers and potential customers, in order to (i) identify individuals who use their platforms and may be interested in Pulse products; and (ii) show advertising for Pulse products to such individuals. We do not receive any personal data about such individuals from these social media platforms in the context of these activities. We instruct social media platforms such as Facebook, to display advertising of Pulse products to individuals within certain demographics, who have interacted with relevant brand pages and who have made public certain interests and hobbies. We may also instruct social media platforms such as Facebook, to identify members whose demographics and behaviour looks like those of our customers and Site visitors, in order to send these individuals advertising for Pulse products.

ANONYMISED DATA

In addition to the categories of Personal Data described above, we will also use anonymised information (i.e. data that does not identify a specific individual).

4. HOW DOES HASBRO USE MY INFORMATION?

We use your Personal Data for the business and commercial purposes described in this Privacy Notice or as otherwise disclosed to you in connection with the Services. The following are ways and purposes for which we may use your Personal Data:

to provide and deliver the products and/or services you request, process your orders, and to send you related information, including confirmations and invoices;

to provide you with access to the Site, its content, and functionalities, including setting up and providing you with access to your account;

to enable you to back a crowdfunded product;

to send you technical notices, updates, security alerts and support and administrative messages;

to respond to your comments, questions, and requests and provide customer service;

to understand feedback on products and services and to help quickly and easily provide more information on the use of those products and services;

to operate and improve the Services, including by linking or combining your Personal Data with other information we get from our service providers or other parties, or information related to your interactions with other Hasbro sites or online services;

to personalize your experience with the Services, including through Site features such as product search results and product recommendations;

for direct marketing communications to help us offer you information about our products and services;

to understand your interests and the effectiveness of marketing communications we send to you;

to monitor performance of the Services and overall usage of the Services and user retention rates, track how users are engaging with the Services, identify how and how frequently Site features are utilized, identify problem areas within the Site, and inform design development for future updates;

with your consent, or where we can rely on our legitimate interest, to send you advertising or promotional materials, including information about new products, contests, features and enhancements, special offers and other events of interest from Hasbro and our select partners;

with your consent or where we can rely on our legitimate interest, to show you advertising or promotional materials for Pulse products and services on social media platforms, such as Facebook and Instagram;

for internal business purposes, including tracking sales and measuring product sales information, management and administration of our business, and administration and maintenance of databases storing Personal Data;

in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or

to carry out any other legitimate business or commercial purpose, at your direction or with notice to you or with your consent.

When we use Personal Data, we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

we need to do so in order to perform our contractual obligations with our customers and third-party providers;

we have obtained your consent;

we have legal and regulatory obligations that we have to discharge;

we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

the use of your Personal Data as described is necessary for our legitimate business interests, such as:

allowing us to effectively and efficiently manage and administer the operation of the Site and our business;

maintaining compliance with internal policies and procedures;

direct marketing and advertising;

monitoring the use of our copyrighted materials; and

enabling quick and easy access to information on the products and/or services.

5. WITH WHOM DOES HASBRO SHARE MY INFORMATION?

SHARING OF INFORMATION

We may share your Personal Data within the Hasbro group of companies for the purposes described above.

We may also share your Personal Data outside of the Hasbro group for the following purposes:

with your consent, including if we notify you that the Personal Data you provide will be shared in a particular manner and you provide such Personal Data and consent to it being shared;

with third party agents, consultants and other service providers who are working on our behalf and need access to your Personal Data to provide services to us. For example, service providers assist us with payment processing, data analytics, marketing, website hosting, advertising, email marketing and technical support. We contractually prohibit these entities from retaining, using, or disclosing Personal Data about you for any purpose other than performing services for us and as described in this Privacy Notice. We also require these entities to comply with appropriate data protection obligations and maintain the confidentiality, security, and integrity of the Personal Data they obtain from us or through the Site and the Services;

with vendors, agencies, social media, social networks, ad networks, and analytics and advertising technology companies for business or commercial purposes as well as paid advertising. Vendors and other parties may act as a service provider, or in certain contexts, independently decide how to process information.;

to facilitate your requests, including at your direction, such as when you choose to share information with a social media site or platform about your activities on the Services;

when we believe it is necessary or appropriate to: (i) comply with applicable law or legal process or to respond to lawful requests or legal authorities; (ii) protect the rights and property of Hasbro and our employees, agents, users and other parties, including to enforce our agreements, policies and terms of use as provided on the Services, and protect against fraudulent, abusive, inappropriate, or unlawful use of the Services; and (iii) protect the safety of Hasbro, our users or any person or entity; and

in connection with, or during negotiations of, any merger, sale of company assets, bankruptcy or reorganization, financing or acquisition of all or a portion of our business to another company, in which case: (i) we may need to disclose your Personal Data to the prospective buyer for due diligence purposes, and/or (ii) we will disclose the Personal Data held by us about you to the third party buyer to the extent we have a valid legal basis for such disclosure.

We may also share with the persons identified above aggregated information or information that we have collected from or about you through the Services, including on co-branded pages where we have taken reasonable measures to anonymise such information.

SOCIAL SHARING FEATURES

The Services (including content, functionality or features of the Services provided by our service providers) may offer social sharing features and other integrated tools (such as Facebook and Twitter links), which let you share actions you take through the Services with other media, and vice versa. The use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the party that provides these features. For more information about the purpose and scope of Personal Data collection and processing in connection with social sharing features, please visit the privacy policies of the parties that provide these features.

LINKING TO EXTERNAL SITES, APPLICATIONS, AND OTHER ONLINE SERVICES

To provide relevant information not found on the Services and to allow you to interact with other websites, applications, and/or other online services with which you may have accounts (such as Facebook and other social media sites) or which may be of interest to you, we may provide links or embed applications on the Services that allow you to login to or otherwise engage with online services not operated or controlled by us. Your use of these online services is subject to the other parties' privacy policies and terms of use, and we encourage you to read the other parties' privacy policies and terms of use before submitting Personal Data or other information or using their online services.

6. COOKIES

We may collect Personal Data with the help of cookies and other similar technologies. Any such data will be collected and used in accordance with this Privacy Notice.

For more information about the cookies and other technologies used by Hasbro please see our Cookie Policy.

7. WHAT ARE MY INFORMATION CHOICES?

REGARDING ACCOUNTS

If you have created an account with the Services, you may at any time review and/or update the contact details and address information we have for you by signing into your account.

MARKETING COMMUNICATIONS

We may send you email marketing communications from time to time based on your specific consent pursuant to the GDPR and the applicable direct marketing laws.

You may opt-out of receiving marketing communications at any time by clicking the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, or by contacting Customer Service here. Please note that the right to unsubscribe or opt-out does not affect the lawfulness of the data processing based on your consent prior to your withdrawal.

If you opt-out of marketing communications, we will still send you service messages, such as emails about your account, an order you have placed, a crowdfunded product you have backed, or our other ongoing business relations.

8. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Hasbro is a global business. Our customers and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your jurisdiction.

Where we transfer your Personal Data to another jurisdiction outside of the European Economic Area (“EEA”), we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:

the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;

the recipient might have signed up to a contract based on “standard contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;

the recipient may have adhered to binding corporate rules (only for intragroup transfers); or

in other circumstances the law may permit us to otherwise transfer your Personal Data outside EEA.

You can obtain more details of the protection given to your Personal Data when it is transferred outside of the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in section “Contact us” below.

9. HOW WE SAFEGUARD YOUR PERSONAL DATA

We have established controls and policies to maintain the security of our information and information systems and to protect your Personal Data against loss, misuse and unauthorized access, disclosure, alteration and/or destruction. When you contact a Hasbro employee about your use of the Services, transactions, or Personal Data, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your Personal Data.

We will take steps to ensure that the personal data is accessed only by authorized employees, representatives and service providers of Hasbro who have a need to access your personal data for the purposes described in this Privacy Notice and that, in any case, are subject to confidentiality obligations.

We also review our security procedures periodically to consider appropriate new technology and updated methods.

10. HOW LONG WE KEEP YOUR PERSONAL DATA

How long we will hold your Personal Data for will vary and will be determined by the following criteria:

we retain your Personal Data for 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 or otherwise administer our business;

we will also retain your information as reasonably necessary to comply with our legal obligations (laws or regulations may set a minimum period for which we have to keep your Personal Data), resolve disputes and enforce our agreements; and

we may also retain cached or archived copies of your Personal Data for a reasonable period of time as long as necessary for the intended purposes and to the extent required by applicable laws.

11. YOUR RIGHTS

You may have the following rights in relation to your Personal Data:

the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

where the data processing is based on your consent, the right to withdraw your consent to the processing of your Personal Data at any time with effect for the future. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;

in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Hasbro;

the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

the right to request that we erase your Personal Data (including removing your account information) in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it;

the right to request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request;

the right to provide instructions regarding the processing of their data after a data subject’s death subject to the formal designation of a trusted third party or by default a legitimate heir, along with compliance with the applicable legal requirements; and

the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

Right to object

You have the right to object with effect for the future, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, in accordance with Article 21 of the GDPR. We will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. If we process personal your data for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing. You can also object to phone marketing in certain jurisdictions such as France.

You can exercise your rights by contacting us using the following link: Privacy Web Form (onetrust.com)

You have the right to lodge a complaint with a supervisory authority (see contact details here) without prejudice to your other rights of administrative or legal recourse.

You can find out more information about your rights by contacting the data protection authority in your jurisdiction.

12. CONTACT US

If you have questions or concerns regarding the processing of your Personal Data by Hasbro, this Privacy Notice, questions relating to consent, or in order to exercise the rights mentioned above, or if you have a disability and would like to access this Privacy Notice in an alternative format, please contact us using the following contact information:

Address: Hasbro Promotions International B.V.
De Entrée 240
1101 EE Amsterdam
the Netherlands
dataprivacy@hasbro.com

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

For product-related questions and requests, please contact Customer Service here.

For additional information about the Services, please review the Terms of Use.