PAW Patrol Academy™ App - Privacy Policy
This policy was last updated Sept 20, 2023.
We collect the following information when you install and/or use the PAW Academy app:
We Collect the Following Information when you Contact our Customer Support
Information We Collect for Performance Marketing
We Collect the Following Information when you Interact with Third-Party Social Networking Features
How We Collect, Process, and Share Your Information
How we Collect and Process Children’s Information in our apps
Where We Store Your Information
How Long Do We Keep Your Data?
How Do We Keep Your Information Safe?
Notice to California Residents
Hello! Welcome to the Originator Inc. Privacy Policy.
Originator Inc. (“Originator”), a subsidiary of Spin Master Ltd., develops and publishes the most entertaining and educational mobile apps for kids and families. As we create truly meaningful digital experiences beloved and respected by kids, parents, and educators we are also committed to protecting your privacy. We take privacy seriously at Originator and this Privacy Policy explains how we collect, use and process data collected from our usersThis notice describes Originator’s privacy policy for the PAW Patrol AcademyTM app (“PAW Academy”) which is developed and distributed by Originator. We may revise this privacy policy at any time, and the date of last revision will be available at the top of this page. By using PAW Academy, you understand and accept this Privacy Policy. Your continued use of PAW Academy after changes have been posted to the Privacy Policy will constitute your acceptance of such changes.
This Privacy Policy is also part of the Terms of Service that explain your and Originator’s rights and responsibilities as part of your use of PAW Academy.
If you don’t agree with this Privacy Policy or the Terms of Use, you should not use PAW Academy.
If you would like specific information about how our privacy policy impacts children please see our children's privacy section.
For the purpose of this Privacy Policy personal data means information that relates to an identified or identifiable natural person.
In the sections and tables below we indicate:
Here is a general explanation of each legal basis to help you understand the table:
What we use your personal data for | Legal basis allowing the processing | Categories of personal data used for the processing |
Analytics In order to understand how you use our app so that we can answer questions relating to the performance of our app and our business. These include:
| Our Legitimate Interest | Unique Identifiers such as:
Technical data such as
|
To understand what went wrong - Crash Reports and Analytics | Our Legitimate Interest | Information tied to following IDs:
|
When you make a purchase | Contract |
|
What we use your personal data for | Legal basis allowing the processing | Categories of personal data used for the processing |
To provide you with support To gain insights on how we can improve our products and services To act according to applicable law in responding to consumer complaints To fulfill the agreement we have made with your regarding your purchase from us | Our Contractual Obligation Our Legitimate Interest Our Legal Obligation Our Contractual Obligation |
|
What we use your personal data for | Legal basis allowing the processing | Categories of personal data used for the processing |
User attribution and market analytics | Legitimate Interest | Technical Identifiers such as:
|
What we use your personal data for | Legal basis allowing the processing | Categories of personal data used for the processing |
Subscribe to one of our digital marketing communications When we cross promote our own Services within our apps | Your Consent Our Legitimate Interest |
|
What we use your personal data for | Legal basis allowing the processing | Categories of personal data used for the processing |
When you interact with one of Originator’s social networking features (such as like buttons, comments, etc) Please note that the social media platforms may use personal information collected from the Originator’s social network account on their platform for their own purposes as described in their own privacy policies | Our Legitimate Interest | Information you have made available, which may include the following
Analytical performance data for social media posts and digital ads. |
What we use your personal data for | Legal basis allowing the processing | Categories of personal data used for the processing |
To improve our existing products and services To develop and improve new products | The Performance of a Contract, or our Legitimate Interest if you voluntarily have provided us with your information |
|
We collect and process personal data directly from you when you:
We are using service providers to help us collect and process some of your personal data. Although we are using the services of these providers, these providers are acting as our processors only processing your personal data as we instruct them to, unless you have given your direct consent for us to share the information with them.
The purposes of collecting this information can be for functions such as technical support, ad attribution, transactional or marketing emails, and payment processing.
For these purposes we are engaging the services of the following service providers:
We use the Appsflyer (appsflyer.com/privacy-policy) attribution platform to record installs of our apps in relation to the mixed audience experience, as well as to track in-app events.
We may share users' information, including Personal Data with our third-party agents, contractors, or service providers who are hired to perform services on our behalf. We may also share your information with your affiliates. We disclose necessary information to data protection authorities and other authorities if we are required to do so by law, or under some circumstances if you have requested us to do so.
We work very closely with our affiliates from the Spin Master Ltd. corporate group. This means that we may transfer personal data to the following legal entities, such as Sago Sago Toys Inc.,Toca Boca, Spin Master.
If you have questions about third party use of data, please contact us at info@originatorkids.com.
A “Child” is a person under the age of digital consent as designated in each jurisdiction.
We believe it is important to provide added protection for children online. We encourage parents and guardians to spend time online with their children to observe, participate in and/or monitor and guide their online activity. We do not share or otherwise disclose children’s personal data, except for the following purposes:
We collect personal data from the following third-party analytics providers. These providers do not share user data with any third parties; they are used to support the operation of our app (and their respective privacy policies are noted below):
A parent or legal guardian may, anytime when convenient for them, review their Child’s personal data maintained by us. A parent or legal guardian may also require us to correct, prevent further collection or use, or delete any such personal data If you as a parent or legal guardian want to exercise any of your rights please contact us using the email address provided in the section How To Contact Us below. To protect parents and legal guardians’ privacy and security and the privacy and security of Children, we may require a parent or legal guardian to take certain steps or provide additional information, which we will keep strictly confidential, to verify their identity before we provide any information about the Child or make any corrections.
Originator will notify and obtain consent from a parent before collecting or using a child’s personal information for significantly new purposes not previously consented to by the parent.
We work with companies that follow our agreements with them in which they agree not to use your information for any other purposes.
We use the information we collect to:
Originator uses generally accepted security measures and safeguards to keep the data it collects secure. We require that the third parties we work with do the same.
These measures and safeguards include:
The information we maintain may be stored both within and outside of the European Union (EU). As part of the services and products we offer and the third-party services we use, the information you provide to us may be transferred to countries outside these areas.
If we transfer your information outside of the EU, we will take appropriate steps to ensure that any personal data relating to you will continue to be adequately protected by using the case-by-case applicable transfer mechanism in accordance with privacy legislation.
We will retain your personal information for as long as necessary to provide our services to you or as required by law or for as long as we see the need for us to have them for the practices described in this Privacy Policy. We will also keep information as otherwise required by law.
After that period of time has passed, your personal data will be deleted or anonymized so that we no longer can connect the data with any individual.
We are committed to protecting our users' personal data and are among other things using pseudonymization, encryption and user based access levels to protect your data. We strive to take appropriate technical and organizational measures to ensure the protection of your personal data.
In some cases Originator might transfer personal data outside the EU, so-called third countries (countries outside of the European Economic Area). Such transfers can be made if any of the following conditions apply;
We also identify and use additional protections as needed for each data transfer. For example, we use:
Under the GDPR and the UK GDPR (United Kingdom General Data Protection Regulation) you have certain rights concerning the processing of personal data by us. The following rights may be applicable for you.
If you would like to access, correct, erase or limit the use or disclosure of any personal data about you that has been processed by Originator or exercise any other right under applicable data protection legislation, please notify us at info@originatorkids.com so that we may consider and respond to your request in accordance with applicable law.
If you want to contact our Data Protection Officer directly you can do so at dpo@spinmaster.com.
Right of information: You have the right to be provided information regarding the processing of your personal data by us.
Right of access: You have the right to obtain confirmation as to whether or not we are processing your personal data and, if this should be the case, access to the personal data.
Right to rectification: You have the right to obtain rectification of inaccurate or incomplete personal data concerning you.
Right to erasure (“right to be forgotten”): Under certain circumstances you have the right to obtain the erasure of personal data concerning you.
Right to restriction: Under certain circumstances, you have the right to obtain the restriction of processing.
Right to data portability: Under certain circumstances you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit this data to another controller.
Right to object: Under certain circumstances you have the right to object to the processing of personal data concerning you. This includes but is not limited to the right to object in cases in which we process your personal data based on legitimate interest.
Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority if you consider that Toca Boca’s processing of personal data relating to you infringes the GDPR.
Right to withdraw consent: If a processing of your personal data is based on your consent as set out you have the right to withdraw your consent at any time.
Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Originator to third parties for the third parties’ direct marketing purposes. With respect to these entities, this Privacy Policy applies only to their activities within the State of California.
California Consumer Privacy Act of 2018 (CCPA) provides consumers who are California residents with specific rights regarding their Personal Information.
Right to Access: If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use and/or disclose.
Right to Delete: If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
Right to Opt Out of Sale of Personal Information: As the term is defined by the CCPA, Originator does not sell any personal information.
To make a request regarding your rights as described above, please send an email to us at info@originatorkids.com. Or write to us, using the addresses stated in this Privacy Policy below.
As we have disclosed, we collect the minimum possible personal data from you that we need in order to provide our services and products to you. In addition, we may disclose your personal or non-personal information to additional parties if we believe we are required to by law, by a judicial proceeding, to protect Originator’s rights and properties, or to investigate fraud, intellectual property infringement, and any other conduct that might be illegal or expose Originator or a user of its services to legal liability.
In addition, Originator may disclose your information in the event of a change or proposed change in the ownership of the company; for example, a sale, a merger, or a bankruptcy.
Originator may change or update this Privacy Policy at any time as we add new or different features, or as the law changes. Unless another date is given, the changes are effective upon posting. If we make a material change to this policy users will be notified before collecting or using a child’s personal information for significantly new purposes. You should review the Privacy Policy frequently.
If you have questions, please contact us at info@originatorkids.com or call us at 1-800-622-8339.
You can also write to us at:
Originator Inc.
809 Laurel Street #12
San Carlos, CA 94070
USA
You can contact our Data Protection Officer at:
Attn: Data Protection Officer
Spin Master Ltd
225 King Street West Toronto,
ON M5V 3M2, Canada
Or by email at DPO@spinmaster.com
Copyright © 2023 Originator Inc. All rights reserved.