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Children’s Privacy Policy

TOPPS CHILDREN’S PRIVACY POLICY
Last Updated: June 4, 2020

WHAT THIS POLICY COVERS
Welcome! The Topps Company, Inc. (“Topps”) respects the privacy rights of our users, particularly those under 13, and understands the importance of protecting these rights. Before you use the website or mobile app where this Privacy Policy is posted (the “Children’s Site”), please read the following Privacy Policy carefully to understand how your personal information will be treated as you make full use of our offerings.

This Privacy Policy applies only to information collected on the Children’s Site. Other Topps web sites and mobile apps might post a different privacy policy.

Topps and its affiliated entities are collectively referred to in this Privacy Policy as “Topps,” “we” or “us.” This Privacy Policy describes what information we collect from users, including children (individuals age 12 and younger), when they visit the Site; how such information is used and stored; when such information may be disclosed to third parties; how users, parents, and guardians can control the use and disclosure of collected information; and how such information is protected.
At Topps, privacy is important to us. Our children’s privacy practices are guided by the United States’ Children’s Online Privacy Protection Act of 1998, as well as data privacy laws in the United States. Younger visitors should always check with their parents or guardians before entering information on any website or mobile application, and we encourage families to discuss their household guidelines regarding the online sharing of personal information.

The Children’s Site is operated from the U.S.  All data is stored in the U.S. and we reserve the right, without assuming any obligation, to restrict access to the Children’s Site from visitors outside the U.S. By accessing the Children’s Site, you are consenting to this Privacy Policy. If you do not consent to the terms of this Privacy Policy, please do not use the Site.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

INFORMATION COLLECTION AND USE
DISCLOSURE TO THIRD PARTIES
INTERNATIONAL TRANSFER
SECURITY, STORAGE AND RETENTION OF INFORMATION
ACCESSING AND CORRECTING INFORMATION\
LINKS TO THIRD PARTIES
YOUR PRIVACY RIGHTS
LINKS TO THIRD PARTIES
CONTACT US
PRIVACY POLICY MODIFICATIONS
CARU’S COPPA SAFE HARBOR PROGRAM
INFORMATION COLLECTION AND USE.

We collect personal information and other information when you visit the Children’s Site. However, visitors are required to share only the information that is reasonably necessary to participate in the particular activity.

Registration Information: The information required to register may vary, but may include: (i) user name and password; and (ii) other information such as avatar preferences. This information allows us to personalize the child’s experience while preserving anonymity.
Registration information is used to enable visitors to take advantage of site offerings; respond to visitors’ requests for products, services, and information; manage games; serve appropriate content; and/or customize the content your child sees when visiting the Children’s Site.

 Contests and Sweepstakes: The Children’s Site may offer online contests and sweepstakes. To enter these contests and sweepstakes, you may be required to provide your first name and email address and/or additional information required for the management of the contest or sweepstakes. On the Children’s Site, we may collect a child’s e-mail address when the child enters a contest or sweepstakes and store such child’s email address for the duration of the sweepstakes, and use it solely for notification on a one-time basis if he or she is the winner. For certain contests or sweepstakes on the Children’s Site, we may ask for the email address of the child’s parent or guardian to inform the parent or guardian of his or her child’s entry and give the parent or guardian the option to have the child’s entry deleted, or to obtain a parent’s consent. If the parent or guardian’s consent is not acquired within a reasonable amount of time, the child’s information and entry will be deleted.

Information Collected Automatically by Us and Third Parties: When visitors access the Children’s Site, we automatically collect certain information from their devices, such as the type of computer operating system; the visitor’s IP address, as permitted for the internal functioning of the Children’s Site, the web browser; information regarding the Internet service provider; and other standard server log information (collectively referred to as “Technical Information”). We only use Tracking Technologies (defined below) at the Children’s Site for the purposes described below.

We may use cookies, web beacons, tokens or similar technologies (collectively referred to as “Tracking Technologies”) on the Children’s Site. Cookies (which may be html files or other technology) are text files that help store user preferences and activity. Web beacons (also known as image tags, gif or web bugs) are small pieces of code used to collect analytical data, such as counting page views, promotion views, or advertising responses. The Children’s Site and/or third parties may use Tracking Technologies to collect Technical Information automatically to support internal operations, such as providing web analytics.

We may use Tracking Technologies to help tailor our content, enable the internal functioning of the Children’s Site, understand how visitors use the Children’s Site, improve or customize the content or offerings on the Children’s Site, personalize your experience on the Children’s Site (for example, to recognize you by username when you return to the Children’s Site), save your password, and/or maintain and administer the Children’s Site. These Tracking Technologies collect click stream data and other information regarding your visits to the Children’s Site (such as your visits to specific webpages or use of features). These Tracking Technologies may collect such other information across multiple sessions on the Children’s Sites, and they may also collect your IP address or some other identifier unique to the device you use to access the Children’s Site (“Identifier”). An Identifier may be automatically assigned to any device you use to access the Children’s Site to enable internal functioning of the Children’s Site.

You may be able to have the device you use to access the Children’s Site warn you each time a cookie or most other Tracking Technologies are being set, or you can choose to turn off such warnings. This is done through your browser on the device you use to access the Children’s Sites. Additional information on warnings and removal of warnings may be available through your browser’s support feature. Please be aware that certain areas and features of Children’s Site can only be accessed in conjunction with Tracking Technologies, and that disabling Tracking Technologies might prevent you from accessing such content.

On candymania.com and the Candymania mobile app, the following service provider collects persistent identifiers on our website solely for the purposes described above:  Google Analytics.

Other Data Collection and Use: We may collect information from visitors when they contact us with questions and comments. We may use this information, along with any of the other information described above, to (i) analyze use of the Children’s Site and understand and improve our service offerings; (ii) prevent potentially prohibited or illegal activities and protect our legal rights; or (iii) for any other legitimate business purposes disclosed to you at the time we collect your information or pursuant to your consent.

DISCLOSURE TO THIRD PARTIES.
We may share your information with third parties for the limited purposes described below. Parents of children under the age of 13 have the option of consenting to the collection and use of their child’s personal information without consenting to the disclosure of that information to certain third parties.

Legal Compliance and Safety: We may access, preserve, and/or disclose the information we collect and/or content you provide to us (including information you may have posted on bulletin boards or internal site communication systems) to a law enforcement agency or other third parties if required to do so by law or with a good faith belief that such access, preservation, or disclosure is reasonably necessary to: (i) comply with laws or legal process; (ii) limit our legal liability; (iii) enforce the Terms of Service of the Children’s Site; (iv) respond to claims that the content violates the rights of third parties; (v) respond to your requests for customer service; or (vi) protect the rights, property, or personal safety of the owners of the Children’s Site, any user of the Children’s Site, a third party or the general public.

Service Providers: Information collected through the Children’s Site may be transferred, disclosed or shared with third party providers engaged by us to handle and deliver certain activities, such as sweepstakes and contests, technical and processing functions, such as sending postal mail and email, maintaining data integrity and security, programming operations, user services or technology services. We may provide these third parties information collected as needed to perform their functions, but they are prohibited from using it for other purposes and are required to maintain the confidentiality of such information.

Co-Branded Sites and Features: The Children’s Site may offer co-branded services and features, such as events and promotions that we put together with another company (“Co-Branded Partner”). Such services may be hosted on a Children’s Site and/or our Co-Branded Partner’s website. We do not share a child’s personal information with our Co-Branded Partners absent parental consent.

Business Transfer: In the event that assets relating to the Children’s Site are transferred or sold to another entity as a result of, for example, a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy, information collected at the Children’s Site may be transferred to the acquiring company.

With Your Consent: We may otherwise disclose your information pursuant to your consent.

INTERNATIONAL TRANSFER.
The Children’s Site is operated from the United States. While users from countries other than the U.S. may access the Children’s Site, we make no representation that the Children’s Site is operated in accordance with the laws or regulations of, or governed by, other nations. By participating in activities on the Children’s Site, you certify that you meet the age and other eligibility requirements for the Children’s Site as set forth in the Terms of Service. If you do not meet the age and other eligibility requirements, please discontinue using that Children’s Site immediately as your continued use of the Children’s Site indicates that you are agreeing to the collection, use, disclosure, management and storage of your information as described in this Privacy Policy.
Please be aware that by providing us with personal information, you understand and agree that: (a) your personal information may be transferred to and stored on servers located outside your resident jurisdiction; (b) to the extent you are a resident of a country other than the United States, you consent to the transfer of such data to the United States for processing by our affiliates in accordance with this Privacy Policy; and (c) the Privacy Policy and the collection of information pursuant to the Privacy Policy shall be governed by and construed in accordance with the laws of the United States, without giving effect to any principles of conflicts of law.

SECURITY, STORAGE AND RETENTION OF INFORMATION.
We maintain reasonable physical and electronic measures to help ensure that information collected is secure, including limiting the number of people who have physical access to our database servers and use of electronic security systems and password protections which guard against unauthorized access. We also take reasonable steps to help make sure our third-party service providers protect the security of your personal information. However, as with most Internet sites and services, no security measures are perfect or impenetrable, despite our efforts. Information collected at the Children’s Site will not be stored for longer than is necessary for the purposes described in this Privacy Policy, or to otherwise meet legal, regulatory, tax, accounting, or reporting requirements.

YOUR PRIVACY RIGHTS.

Accessing and Correcting Information:

You have the right to access, update and correct factual inaccuracies in your or your child’s personal information that we collect online at the Children’s Site, subject to certain exceptions. To do so, you may e-mail us at privacypolicy@topps.com. To help protect your privacy and the security of your personal information, we will take reasonable steps to verify your identity before granting access. We will take steps to verify the identity of anyone requesting personal information about a child and to ensure that the person is in fact the child’s parent or legal guardian. If you are a minor under 18, you may submit a request to remove content or information you posted at the Children’s Site, if any, at the same e-mail address.  We will use reasonable efforts to remove or update content or information in compliance with your request and the prevailing law.

California Privacy Rights:

The California Consumer Privacy Act of 2018 (CCPA) provides California residents with certain rights with respect to their personal information:

  • Right to request that we disclose, no more than twice in a 12-month period:
    • The categories and specific pieces of personal information we have collected about you.
    • The categories and sources from which personal information is collected.
    • The business or commercial purposes for collecting or selling personal information.
    • The categories of third parties with whom we share personal information.

We will provide this information upon receipt of a verifiable consumer request. How we will verify your identity depends on how you have interacted with us in the past.

  • The categories and sources of personal information we collect and the business or commercial purposes for collecting personal information are described in the Information Collection and Use section
  • Right to request that we delete any personal information about you that we have collected from you, subject to certain exceptions. If we are required to delete your personal information, then upon receipt of a verifiable request, we will delete your personal information from our records and direct any service providers to delete your personal information from their records.
  • Right to opt-out of the “sale” of your personal information to third parties. We do not sell personal information obtained from individuals known to be under 16 to third parties without consent. Some of our sharing activities at our sites directed to adults or general audiences may be considered a “sale” of personal information under California law.

California residents can exercise their CCPA rights by contacting us at https://candymaniaparentscorner.com/parents-contact/

and including “Children’s Privacy Request” in the subject line.  We will take steps to verify that you are the parent.  We will not discriminate against you for exercising your rights; provided, however, if you decline to provide parental authorization in circumstances where it is required, we cannot make those services available to your child.

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. The Children’s Site does not disclose personal information of children to third parties for their direct marketing purposes without parental consent. To make such a request, please send an email to or write us at
privacypolicy@topps.com, or you may contact us via regular mail at:

Topps California Privacy Coordinator
The Topps Company, Inc.
One Whitehall Street
New York, New York 10004

Nevada Privacy Rights:

Nevada residents have a right to submit a verified request directing a website operator to not make any “sale” of covered information collected about the consumer for monetary consideration to a person for such person to license or sell the information to additional persons, subject to certain exceptions. The Children’s Site does not engage in the “sale” of covered information, as that term is defined.

LINKS TO THIRD PARTIES.
This website may contain links to other sites. These other websites are governed by their own privacy policies or information collection practices, which may be different from ours. We encourage visitors to other websites to review the privacy policies and information collection practices of those websites.

CONTACT US.
If you have any other questions about our information handling practices, including our practices with respect to children’s personal information, please contact us at:

Topps Privacy Coordinator
c/o The Topps Company, Inc.
One Whitehall Street
New York, New York 10004
Or email us at:
privacypolicy@topps.com
Or call this number:
212-376-0300

PRIVACY POLICY MODIFICATIONS
From time to time, we may update this Privacy Policy and will at a minimum post the updated privacy policy here. We encourage you to periodically check back to this policy statement at our website to learn what information we collect, how we use it, and with whom we share it.

CARU’S COPPA SAFE HARBOR PROGRAM

The Topps Company, Inc. is a member of CARU’s COPPA Safe Harbor Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact CARU online at https://bbbprograms.org/programs/caru; by mail at CARU, Attn.: COPPA Safe Harbor Program, 112 Madison Avenue, New York, NY 10016 USA; or by email at infocaru@bbbnp.org.