PRIVACY POLICY. - («-

Transcription

1 - («-»),, : ,,.,., (). - Play-Doh,, -,, Play- Doh. -, (). -.,,,.,,.?, ( ).. х х,,,,, (),. PRIVACY POLICY This website ( Website ) is maintained and operated by Limited Liability Company Hasbro Russia, a company registered in accordance with the Russian laws, having its registered office at: , Moscow region, Khimki, Panfilova street, 21 bld. 1 ( Hasbro ). Website provides its users with the content on Play-Doh activities in form of video materials, articles, master classes, lessons, text messages, and information about Play-Doh products. You can use the functionality of the Website subject to acceptance this Privacy Policy ( Policy ). While maintaining and operating this Website, Hasbro may collect and further process Your personal data and personal data of Your child. In the Policy You may learn how Hasbro, being a data controller, processes personal data. By accepting the Policy You agree with processing of Your and Your child s personal data by ways described in the Policy. WHAT DO THE SPECIFIC TERMS MEAN? Personal data means information related directly or indirectly to identified or identifiable individual (data subject). You and Your child are the data subjects. Data controller means legal entity arranging alone or jointly with others and/or carrying out processing, as well as defining the purposes of processing, operations performed on personal data and categories of processed personal data. Hasbro is the data controller. 1

2 . ч х х,..? : Data processor means any third party processing personal data under the data controller s assignment. Data processors and purposes of their processing are specified below in this Policy. FOR WHAT PURPOSES HASBRO PROCESSES PERSONAL DATA? Hasbro processes Your personal data and personal data of Your child for the purposes of: Play- Doh,, -,, ; Providing You with content on Play-Doh activities in form of video materials, articles, master classes, lessons, text messages; Play-Doh; Providing You with product catalogue with Play-Doh; - ; Providing you with the personalized content in the Website and by ; -; Ensuring You may enjoy the Website s full functionality; ; Responding Your questions and requests; -,,, ; Administrating the Website, including its technical support, testing, troubleshooting; -; ; Ensuring the Website s effective performance; Developing Hasbro s products and approaches to them; Play-Doh. Statistic and research regarding use of Play-Doh products. WHAT ARE LEGITIMATE GORUNDS FOR PROCESSING PERSONAL DATA BY HASBRO? 2

3 ? : Hasbro processes personal data where there are the following legitimate grounds to their processing: ;, ; ; ;,,. You have provided Your consent to processing of Your personal data and processing of personal data of Your child; Processing of personal data is required to perform Hasbro s obligations and carry out its functions imposed on Hasbro by virtue of applicable laws; Processing of personal data is required to enter into and to perform the contract with You; Processing of personal is required to exercise Hasbro s legitimate rights and interests; Personal data are processed for research and statistical purposes provided that Hasbro anonymizes such personal data.,, -.,,,.? : MARKETING MAILINGS Hasbro will address marketing, advertising, promotional and information materials only based on Your prior explicit opt-in consent to receipt such mailings. Hasbro ensures that each such content contains a link allowing You to unsubscribe from receipt of such mailings. WHAT PERSONAL DATA IS PROCESSED BY HASBRO? To fulfill the above mentioned purposes and to personalize the content Hasbro needs the following personal data related to You and Your child: 3

4 , Your name, and. The date of Your child s birth.,. Play-Doh., / : You shall understand that the age of Your child is the primary criteria of personalizing the content. Hasbro needs additional information in order to conduct statistics and researches regarding use of Play-Doh. If You agree to participate in Hasbro statistics and researches, You may also provide Hasbro with the following Your personal data and/or personal data of your child: :, ; Your personal data: date of birth, gender; :. Your child s personal data: name and gender., -. Э.,,.?,, -. Providing these additional personal data is not obligatory in order to use content and services provided by the Website and is upon Your discretion. While providing these additional personal data to Hasbro, You may be absolutely sure that Hasbro will treat these data as it treats other personal data without any prejudice to their confidentiality and security. HOW HASBRO COLLECTS PERSONAL DATA Hasbro collects personal data related to You and Your child when You provide these data to Hasbro in the Website., cookies, - -. cookies 4 Hasbro uses such technologies as cookies, web server logs and web beacons. You may learn more about cookies and Hasbro policy with regard to them in the Hasbro Cookie Policy via:

5 Cookies : [ ()., () :,,,,, (, ),,, (,, ),,,,.?,..? - -,.,., : [ HOW HASBRO PROCESSES PERSONAL DATA? Hasbro processes Your personal data both by automated means and without them (manually). In particular, Hasbro carries out the following actions (operations) with Your personal data: collection, recording, systematization, accumulation, storage, alteration (update, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of Your personal data. WHERE PERSONAL DATA ARE PROCESSED? Once collected, personal data are processed by Hasbro in primary databases located in the territory of the Russian Federation. Personal data however may be further transferred and backupped in Hasbro secondary databases located abroad. WHO PROCESS PERSONAL DATA WITH HASBRO? Maintaining and support of the Website is a comprehensive process that implies engagement of the third parties processing personal data under Hasbro s assignment and on Hasbro s behalf, or together with Hasbro. Such third parties may reside either in Russia or abroad. In particular, the following companies can have access to and process Your personal data:, Ш, Ш, 2800,, Э- 31, -, 5 Hasbro Holding SA Joint Stock Company, a company registered in accordance with the laws of Switzerland, having its registered office at: Switzerland, 2800, Delmont, rue Emile- Boechat 31 in order to maintain and support the Website and its content,

6 , ; considering that Hasbro is a member of global group of companies;, - : -К,. Content Partners of Hasbro, who participate in preparing content of the Website together with Hasbro: Baby Club, Center of kids development & creativity SPRR. ( ),,,,,,.?,. 30.,,,,,.? While transferring Your personal data and assigning processing personal data to the third parties (data processors), Hasbro ensures that such third parties undertake confidentiality obligation with regard to processed personal data, purposes of processing personal data are limited to the ones determined by Hasbro, and that they take necessary organizational, legal and technical security measures. FOR HOW LONG HASBRO PROCESS PERSONAL DATA? Hasbro processes personal data no longer than it is required to fulfill the purposes of their processing. Once purposes of personal data processing are fulfilled Hasbro ensures destruction of personal data or their anonymization within 30 days. Hasbro however may continue processing personal data where it is required to fulfil other legitimate purposes or legal obligations arising by virtue of applicable laws or where Hasbro requires these data to protect Hasbro s rights and legitimate interests. HOW HASBRO PROTECTS PERSONAL DATA?,,,, 6 Hasbro ensures security and confidentiality of processed personal data and takes legal, organizational and technical security measures, including but not limited to the following:

7 :,,,., ; Arranges a regime ensuring security of the premises where the informational system used to personal data processing is located. Such regime shall prevent any uncontrolled access to or stay in such premises of persons having no rights to access such premises; ; Ensures safety of the personal data mediums;,,,, ; Approves the document, determining the list of persons who require access to the information system where the personal data are processed due to performance of their job duties; И,, ( ),, ; Uses means for protection of the information, including the ones passed compliance evaluation procedure (certified tools) where they are required to neutralize actual threats to information system, including antivirus software; ; Perform data back-up measures;, ; Appoints a person responsible for arrangement of personal data processing (data protection officer);, ; Identifies threats to security of personal data processed in personal data information systems;, Assesses the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of a personal data information system; 7

8 ; ; Detects cases of unauthorized access to personal data and takes measures;, ; Restores personal data which has been modified or destroyed as a result of unauthorized access;, ; Monitors measures taken to ensure the security of personal data and the level of protection of personal data information systems;,,,. Establishes rules for access to personal data processed in a personal data information system and ensures registration and recording of all actions performed on personal data in a personal data information system.? WHAT ARE YOUR RIGHTS REGARDS PERSONAL DATA?, :,, ( ), ( ),,,,,,, 8 Hasbro respects Your and Your child s rights, and You may request any of the following information form Hasbro in whole or in part: confirmation of processing Your personal data or personal data of Your child, legitimate grounds to processing personal data, purposes and ways of processing personal data, Hasbro s legal details (name and address), names and address of legal entities and individuals (excluding Hasbro s employees) who have access to personal data or whom personal data may be disclosed by Hasbro, personal data and the source of their obtaining, terms of processing personal data, including terms of their retention, way of exercising Your rights with respect to processing personal data, information on immediate or intended cross-border transfer of personal data, name and address of engaged data processor.

9 ,.,,.,, : [Hasbrorussia@hasbro.co.uk]..,,,.,, (, ).,,,... You may also withdraw Your consent to processing personal data by Hasbro, as well as to require alteration, blocking and destruction of personal data. To exercise Your rights please address Your according request to Hasbro via [Hasbrorussia@hasbro.co.uk]. RESPONSIBILITES AND LIMITATIONS Hasbro shall be responsible to ensure confidentiality and security of processed personal data, and to comply with applicable data protection laws. Hasbro presumes that Your personal data and personal data of Your child provided by you are complete and accurate. You shall be responsible to inform Hasbro if Your personal data is inaccurate or incomplete, and it shall be altered (updated, modified). Hasbro presumes that You are legitimate representative of the child whose personal data You provide to Hasbro and You are authorized to provide these personal data to Hasbro. You bear full responsibility for illegal provision of child s personal data. MODIFICATION OF THIS PRIVACY POLICY Hasbro Reserves the right to modify and update this Privacy Policy., 9 Hasbro will notify You via on any modifications and updates to this Policy, so You will have an opportunity to confirm Your consent with the new version of the Privacy Policy or to opt-out. Should You opt-out the Privacy Policy

10 ., -., , -,,,., -., -, : [Hasbrorussia@hasbro.co.uk].,. 1 [01/02/2018] You may not be able to use all functionality of the Website. Hasbro shall publish all modifications and updates to this Privacy Policy as well as earlier versions of this Policy on the Website. THIRD PARTY WEBSITES Where the Website contains links to the third party website, or the third party website may be associated with the Website, Hasbro shall not be responsible for processing personal data in this third party website, policies and practices applied therein by its owner, administrator or other alike entity. Please refer to terms of use and privacy policies of the third party website prior to its use. CONTACT HASBRO If You have questions about this Privacy Policy, processing personal data by Hasbro, or You want to share Your concerns or report about any violations in this regard, You may contact Hasbro via [Hasbrorussia@hasbro.co.uk]. Privacy Policy, ver. 1 Effective since [01/02/2018] 10