Children’s Privacy Policy

TOPPS CHILDREN’S PRIVACY POLICY
Last Updated: December 28, 2018

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 Children’s Sites (as defined below), please read the following Privacy Policy carefully to understand how your personally identifiable information will be treated as you make full use of our offerings.

This Privacy Policy, applies only to information collected on these Topps’ web sites and mobile apps directed to children where this Privacy Policy appears (the “Children’s Sites”).

Topps and its affiliated entities are collectively referred to in this Privacy Policy as “Topps,” “we” or “us.” This Privacy Policy describes what information the Children’s Sites collect from users, including children, when they visit the Sites; 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.

Our Children’s Sites are based in the U.S. All data is collected and stored in the U.S. and we reserve the right to restrict access to our Children’s Sites from visitors outside the U.S. By accessing any of the Children’s Sites, you are consenting to this Privacy Policy or any Privacy Policy in effect at the time you access any of the Children’s Sites. This document is the sole statement of the Children’s Sites’ Privacy Policy and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, without limitation, machine-generated, is valid.  In interpreting this document, the English version governs the interpretation and meaning of the obligation set forth herein. To the extent there is an ambiguity or conflict with the Privacy Policy in other languages, the Privacy Policy in English governs.  If you do not consent to the terms of this Privacy Policy, please do not use the Children’s Sites because your use of the Children’s Sites represents your consent. If you have already provided personal information, please contact us about how you would like us to handle such information.

I. INFORMATION COLLECTION AND USE.
We may request or collect certain information when you visit the Children’s Sites. However, visitors are required to share only the information that is reasonably necessary to participate in the particular activity.

A. Registration Information:The information required to register varies by Children’s Site, but may include: (i) birth date; (ii) user name and password; and (iii) 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 Sites.

    B. Contests and Sweepstakes:The Children’s Sites 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 Sites, 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 Sites, 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.

    C. Computer Information Collected by Us and Third Parties:When visitors come to a Children’s Site, we may automatically collect certain information from their computers, such as the type of computer operating system (e.g., Windows XP or Mac OS); the visitor’s IP address, as permitted for the internal functioning of the Children’s Sites the web browser (e.g., Internet Explorer, Safari, Chrome and Firefox); information collected through the use of unique identifiers such as cookies (see below), information regarding the Internet service provider; and other standard server log information (collectively referred to as “Computer Information”). We only use Tracking Technologies (defined below) at Children’s Sites 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 Sites. Cookies (which may be html files, Flash 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 advertising data, such as counting page views, promotion views, or advertising responses. The Children’s Sites and/or third parties may use Tracking Technologies to collect Computer Information automatically to support internal operations, such as providing web analytics.

    We may use Tracking Technologies to help tailor our content, allow users to move between certain Children’s Sites without logging into each Children’s Site, enable the internal functioning of the Children’s Sites, understand Children’s Site and internet usage, improve or customize the content or offerings on the Children’s Sites, personalize your experience on the Children’s Sites (for example, to recognize you by username when you return to a Children’s Site), save your password, and/or maintain and administer the Children’s Sites. These Tracking Technologies collect click stream data and additional other information regarding your visits to the Children’s Sites (such as your visits to specific webpages or use of features), may collect such other information across multiple sessions on the Children’s Sites, and may also collect your IP address or some other identifier unique to the device you use to access the Children’s Sites (“Identifier”). An Identifier may be automatically assigned to any device you use to access the Children’s Sites to enable internal functioning of the Children’s Sites.

    You may be able to have the device you use to access the Children’s Sites warn you each time a cookie (other than Flash cookies) 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.  Deleting, rejecting, disabling or turning off Tracking Technologies through the above options will not remove Flash cookies. Please be aware that certain areas and features of Children’s Sites can only be accessed in conjunction with Tracking Technologies, and that disabling Tracking Technologies might prevent you from accessing such content.

On bazookajoe.com, the following third-party operators collect persistent identifiers on our website solely for the purposes described above:  Google Analytics.

On candymania.com and the Candymania mobile app, the following third-party operators collect persistent identifiers on our website solely for the purposes described above:  Google Analytics.

    D. Social Media Links:Some of the Children’s Sites display social media links in the Parents Corner, such as the Facebook “Like” or Twitter “Follow”. When link to social networking platforms, you share your information with them and their privacy policy applies to their collection, use, and disclosure of such information. In addition, they may be able to collect information about you, including your activity on the Children’s Sites, and they may notify your connections on the social networking platform about your use of the Children’s Sites. Such services may also employ unique identifiers which allow your activity to be monitored across multiple websites for purposes of delivering more targeted advertising to you. The privacy policies of such services may be different from our own and we encourage you to read them.

    E. 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 Sites and understand and improve our service offerings; (ii) prevent potentially prohibited or illegal activities; or (iii) for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

    II. DISCLOSURE TO THIRD PARTIES.
    We may share your information with third parties for the limited purposes described below. In the U.S., 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.

    A. Law Enforcement and Safety:You acknowledge, consent, and agree to the extent legally permissible in your jurisdiction to allow us to 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 legal process; (ii) enforce the Terms of Service of the respective Children’s Sites; (iii) respond to claims that the content violates the rights of third parties; (iv) respond to your requests for customer service; or (v) protect the rights, property, or personal safety of the owners of the Children’s Sites, any user of the Children’s Sites, a third party or the general public. We also may disclose user information whenever we believe disclosure is necessary to limit our legal liability; to protect or defend our rights or property; or protect the safety, rights, or property of others.

    If you have concerns about the conduct of a particular user, please send an e-mail to privacypolicy@topps.com. This email is not to contact us about the status of your account.

    B. Agents:Information collected through the Children’s Sites may be transferred, disclosed or shared with third parties 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, 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 specifically agree to maintain the confidentiality of such information.

    C. Co-Branded Sites and Features:Some of the Children’s Sites 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.

    D. Business Transfer:In the event that assets relating to one or more of the Children’s Sites 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 Sites may be transferred to the acquiring company.

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

    III. INTERNATIONAL TRANSFER.
    The Children’s Sites are designed for and targeted to U.S. audiences and are governed by and operated in accordance with the laws of the U.S. While users from countries other than the U.S. may access certain of the Children’s Sites, we make no representation that the Children’s Sites are operated in accordance with the laws or regulations of, or governed by, other nations. By participating in activities on the Children’s Sites, you certify that you meet the age and other eligibility requirements for the Children’s Sites as set forth in the respective Terms of Service for each Children’s Site. If you do not meet the age and other eligibility requirements of the particular Children’s Site you are visiting, please discontinue using that Children’s Site immediately as your continued use of the Children’s Sites 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.

    IV. SECURITY, STORAGE AND RETENTION OF INFORMATION.
    The Children’s Sites maintain reasonable technical and organizational steps 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 agents protect the security of your personal information. However, as with most Internet sites and services, it is possible that third parties may unlawfully access such personal information through a number of means despite our efforts. Information collected at the Children’s Sites will not be stored for longer than is necessary for the purposes described in this Privacy Policy, or to otherwise meet legal requirements.

    V. ACCESSING AND CORRECTING INFORMATION.
    You have the right to access, update and correct factual inaccuracies in your or your child’s personally identifiable information that we collect online at the Children’s Sites, subject to certain exceptions. To do so, you should log into your or your account or you may e-mail us at privacypolicy@topps.com. To help protect your privacy and the security of your personally identifiable information, we will take reasonable steps to verify your identity before granting access. We will take steps to verify the identity of anyone requesting personally identifiable 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 who is a registered user of a Children’s Site, you may submit a request to remove content or information you posted at such Children’s Site 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.

    VI. LINKS TO THIRD PARTIES.
    The websites that comprise the Children’s Sites may contain links to other sites. These other websites are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage visitors to other websites to review the privacy policies and information collection practices of those websites.

    VII. YOUR CALIFORNIA PRIVACY RIGHTS.
    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. 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

VIII. 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

IX. POLICY MODIFICATIONS
From time to time, we may update this Privacy Policy and will post the revised 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. By accessing any of the Children’s Sites, you are consenting to this Privacy Policy or any Privacy Policy in effect at the time you access the Children’s Sites.