Hasbro Pulse - Privacy Notice

(Last Updated: December, 2022)

WELCOME!

This privacy notice ("Privacy Notice") explains how Hasbro, Inc. and its subsidiaries and affiliated companies that operate within Asia a (collectively, "Hasbro", "we", "our", or "us") collect, use and disclose your information when you:

1. visit the ecommerce site for Hasbro fans at the following websites:
   • hk.hasbropulse.com
   • sg.hasbropulse.com
   • my.hasbropulse.com
   • tw.hasbropulse.com
   (collectively, "Pulse Asia");
2. view or interact with content or functionality on Pulse Asia to find out more about or order Hasbro products; or
3. interact with us through our Customer Service phone line, mailing address, or the Hasbro Consumer Care portal.

This Privacy Policy refers to the content and functionality of, and related online products and services on Pulse Asia collectively as the “Services”.

We ask that you take the time to read this Privacy Notice carefully. If you do not agree with this Privacy Notice, please do not use the Services

TABLE OF CONTENTS

1. Background
2. Changes to this Privacy Notice
3. What information is processed about me?
4. How does Hasbro use my information?
5. With whom does Hasbro share my information?
6. Cookies
7. What are my information choices?
8. International transfers of Personal Data
9. How we safeguard your Personal Data
10. How long we keep your Personal Data
11. Your rights
12. Accuracy of Personal Data
13. Contact Us
14. Supplemental Terms - Jurisdiction-Specific

1. BACKGROUND

We respect your privacy and we are committed to keeping all your Personal Data (as defined below) 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 national, implementing or supplementing data protection legislation.

Your provision of personal data is voluntary. However, if you do not provide your personal data we may not be able to provide the products, services or information requested by you.

We use the following definitions in this Privacy Notice:

User(s) or You	Means the users of Pulse Asia and / or anyone whose Personal Data we collect and use in relation to the Services.
Personal Data	Means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including Sensitive Personal Data. Personal Data also includes any materially similar or analogous concept or definition under applicable data protection law.
Sensitive Personal Data	Means data relating to: password; bank account, credit or debit card details, or any other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; biometric information. Sensitive Personal Data also includes any materially similar or analogous concept or definition under applicable data protection law.

2. CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

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 Pulse Asia. Your continued use of our services constitutes your acknowledgement and acceptance of such changes. If required by applicable laws, we will obtain your consent to the amended Privacy Notice.

3. WHAT INFORMATION IS PROCESSED ABOUT ME?

Many of the products and/or services offered by Hasbro on Pulse Asia 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 Pulse Asia 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, or as permitted under applicable data privacy laws:

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 Pulse Asia 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;
• sign up for our newsletter or other email alerts;
• share a website with a friend; or
• otherwise communicate with us through the Services.

Depending on the nature of your activity on Pulse Asia, the types of Personal Data that you provide and we collect may include:

• your first and/or last name (including any usernames containing your first and/or last name);
• gender;
• email address;
• date of birth;
• physical address and country or region of residence;
• Sensitive Personal Data (such as credit card/debit card and other payment instrument details) and
• other information that you choose to provide and/or share on Pulse Asia 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, or will obtain your express consent if required under applicable laws.

INFORMATION THAT WE COLLECT OR GENERATE ABOUT YOU

This includes:

• Any information regarding the products and/or services purchased and/or used on Pulse Asia 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; and
• any information, content and/or feedback that you choose to share on Pulse Asia which may be considered Personal Data.

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 Pulse Asia 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 authorisation 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 Pulse Asia, 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 provide warranty, technical support or after-sales services;
• 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 personalise your experience with the Services, including through Site features such as product search results and product recommendations;
• with your express consent, to the extent required under applicable laws, 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 Pulse Asia, and inform design development for future updates;
• with your express consent, 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, with your written consent, to the extent required under applicable laws, our select partners;
• with your express consent, 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 where:

• 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 and to the extent required under applicable laws, it is difficult to obtain your consent;
• the use of your Personal Data as described is necessary for our legitimate business interests to the extent such use is allowed under applicable laws, such as:
  • allowing us to effectively and efficiently manage and administer the operation of Pulse Asia and our business;
  • maintaining compliance with internal policies and procedures;
  • 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 Pulse Asia 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 reorganisation, 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 applicable direct marketing laws.

You may opt-out of receiving email 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. 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 email 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 your jurisdiction, we will not transfer or permit any of your Personal Data to be transferred outside of your jurisdiction unless the transfer is in compliance with applicable laws. This may be done in one of the following ways:

• the recipient might have signed up to a contract that imposes a comparable standard of protection to that under applicable data protection laws, and which specifies the countries and territories to which the personal data may be transferred under the contract;
• 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 of your jurisdiction.

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 unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. 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

The length of time for which we will hold your Personal Data will vary pursuant to applicable laws and may 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 Personal Data 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

To the extent permitted by applicable laws, 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 a duplicate of or 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 or cease our processing or use 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

You can exercise your rights by contacting us using the details listed in section “Contact Us” below.

You have the right to lodge a complaint with a supervisory authority 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. ACCURACY OF PERSONAL DATA

We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer (DPO) via email at the contact details provided below.

13. 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:

For Singapore

Address	Hasbro Singapore Pte limited 101 Thomson Rd, #31-03/04 United Square, 307591 Singapore
Representative Numbers	+65 6736 2822 +65 6736 2477

For Hong Kong

Address	Hasbro Hong Kong Limited 18-20/F, Hang Seng Tower 33 Wai Yip Street Kowloon Bay, Hong Kong
Representative Number	+852 2736 8373

For Malaysia

Address	Hasbro Toy (Malaysia) Sdn Bhd 12th Floor Menara Symphony, No. 5 Jalan Prof. Khoo Kay Kim Seksyen 13 Petaling Jaya, Selangor Darul Ehsan Malaysia
Contact Person Phone Number	+603 807 51177

For Taiwan

Address	Hasbro Taiwan Limited Room A, 4F, No.2 Sec.1, Fu Hsing S Road Taipei, Taiwan
Representative Number	+886 2 7281 1158

For privacy-related requests, please contact us at DPO@hasbro.com or dataprivacy@hasbro.com. For product-related questions and requests, please contact Customer Service. For additional information about the Services, please review the Terms of Use.

14. SUPPLEMENTAL TERMS - JURISDICTION-SPECIFIC

In the event of a conflict between the provisions of the Jurisdiction-Specific Supplemental Terms that are relevant to your jurisdiction from which you access or use the services and the rest of this Privacy Notice, the relevant jurisdictions' Supplemental Terms - Jurisdiction Specific will take precedence.

Hong Kong

The provisions below replace the corresponding provisions for persons based in Hong Kong.

14.1 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 to use your name and contact information to:

• send you information about Hasbro products and services;
• 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; and
• show you advertising or promotional materials for Hasbro products and services on social media platforms, such as Facebook and Instagram.

You may withdraw your consent and opt-out of receiving email 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. 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 email 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.

PROCEDURE AND METHOD FOR DESTROYING (DELETING) PERSONAL DATA

We will promptly destroy your Personal Data in our possession when we no longer need your Personal Data, due to expiration of the retention period or achievement of the purpose of collection and use of your Personal Data. The process and means of destroying your personal data are as follows.

1. Procedure

   We will select your Personal Data that will be subject to destruction (deletion) and we will destroy or delete such Personal Data with the approval of our data protection officer.

2. Method

   Personal data recorded or stored in electronic form will be deleted by a method that will not permit data recovery. Personal data that has been printed on paper will be shredded through the use of document shredder or incinerated.

PERSONAL DATA INFRINGEMENT HOTLINE INFORMATION

• Supreme Prosecutor's Office, Scientific Investigation Division, Cyber Investigation Bureau (https://www.spo.go.kr, Telephone No. 02-3480-3570)
• National Police Agency, Cyber Bureau (https://www.cyber.go.kr, Telephone No. 182 (without area code)).

Last updated: August 2022.

THIS DOCUMENT IS AN INTEGRAL PART OF THE STORE'S TERMS OF SALE AND DOES NOT CONSTITUTE AN INDEPENDENT AGREEMENT. THE TERMS DEFINED IN THE TERMS OF SALE HAVE THE SAME MEANING IN THIS PRIVACY POLICY DOCUMENT.

1. Preamble

This Privacy Policy applies to the website "

• hk.hasbropulse.com
• my.hasbropulse.com
• sg.hasbropulse.com
• tw.hasbropulse.com

(the "Website"). Scalefast Inc. is the data controller for all data collected via the Website, which is operated by Scalefast Singapore PTE. LTD. (collectively, referred to herein as "we", "us" or "our").

We respect the privacy of our customers, partners and suppliers of products or services and clients. The purpose of this Privacy Policy is to provide you with information concerning how we collect Personal Information (as hereinafter defined) when you access and/or use the Website, and how we collect other information regarding your interaction with the Website without identifying you as an individual; how we use, handle and disclose collected information; and choices you may have about the ways we collect and use that information. Our goal in handling Personal Information provided to us is also to comply with applicable data protection and privacy laws.

"Personal Information" means information or data, whether true or not, about an individual who can be identified: (a) from that information or data; or (b) from that information or data and other information to which we have or is likely to have access.

Third Party Privacy Policies or Statements. If you access a website through which we offer products or services for sale, you will often see our web pages co-branded with the name and branding of the organization whose product you are purchasing. If the privacy policy or statement of one of our partners also appears on the Website, this Privacy Policy will apply to our use of any Personal Information collected by us, and the privacy policy or statement of our partner will apply to any Personal Information provided to that partner as contemplated by this Privacy Policy.

By interacting with us, submitting information to us, or purchasing any products or services offered by us on the Website, you hereby agree and consent to us collecting, using and disclosing your Personal Information, and sharing your Personal Information with relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Information, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Information.

We reserve the right to update or modify this Privacy Policy from time to time, and you should regularly check this Privacy Policy. You may also contact us in the manner disclosed in this Privacy Policy to learn about our handling or processing of your Personal Information.

2. Which Personal Information do we collect?

The Personal Information we collect may include, but is not limited to, your full name, email address, IP address, billing and/or shipping address, phone number, payment account information, and other information about you submit to us to verify who you are or to prevent fraud.

3. How do we collect your Personal Information?

We collect Personal Information you provide when you access and use the Website. Generally, we collect Personal Information in the following ways:

1. when you use our electronic services, or interact with us on the Website or use any services, functions or features on the Website (e.g. when creating an Account on the Website);
2. when you provide information to us or when you submit any application, documentation or form on the Website;
3. when you interact with our staff and representatives (e.g. members of our support team or customer service team), for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and/or email;
4. when you request information about a product or service available through the Website;
5. when you purchase a product or service through the Website;
6. when you are enter into or participate in a contest or a promotion on the Website;
7. when you order a newsletter on the Website;
8. when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
9. when you share comments, feedback, suggestions or recommendations with us (such as by leaving a review);
10. when you respond to our request for additional Personal Information;
11. when you are downloading and/or registering products and/or signing up for additional services on the Website; and
12. when you submit Personal Information to us for any other reason.

If you provide us with any Personal Information relating to a third party (e.g. information on your spouse, children and/or parents), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Information, and for the collection, use and disclosure of their Personal Information for all purposes set out in our herein and by or for the benefit of the persons referenced herein.

You should ensure that all Personal Information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with any products and/or services you have purchase and/or requested.

We furthermore collect information that is sent to us automatically by your web browser, which may include, without limitation, information that does not identify you personally (such as the date and time of your visit). The information we receive in this manner depends on the settings on your web browser. If you have created a user identity on one of your visits to the Website, we may link the information provided by your browser to information that identifies you personally and use it for the purposes described below. Please review the settings of your web browser if you want to learn what information your browser sends or how to change your browser settings.

Most browsers by default will accept cookies, but you can choose to systematically accept or reject all cookies or only cookies from certain issuers. You may also configure your browser to accept or reject cookies on a case by case basis prior to their installation. You may also regularly delete cookies from your device terminal via your browser's settings.

Remember to adjust the browser settings on each of your devices (tablets, smartphones, computers). Each browser has its own way of managing cookies and cookies settings. Go to the "Help" menu of each browser to be informed of how to change cookie settings.

For example:

1. for Internet Explorer™: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
2. for Safari™: https://support.apple.com/safari;
3. for Chrome™: https://support.google.com/chrome/answer/95647?hl=en-GB&hlrm=en;
4. for Firefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
5. for Opera™: https://help.opera.com/en/latest/web-preferences/#cookies.

Please note that setting your browser to disable cookies may restrict and prevent you from accessing and using certain features, pages, functions or areas of the Website and we shall not be held responsible and do not accept any liability for any consequences related to the browser settings that you have chosen.

4. Our use of cookies and technologies

We collect information that is typically not personally identifiable through the use of web technologies, including, without limitation, "session cookies," "persistent cookies," "JavaScript tags" and "web beacons" (also referred to as "tracking pixels"). As the Internet evolves, we may implement and use different types of technologies on the Website.

Cookies. When you visit the Website, your computer may receive one or more "cookies" in order to help personalize and support your use of the Website, our services, and/or the services of our partners. A "cookie" is a small text file that is transferred to your computer's web browser by a web server, and can be read by a web server in the same domain at a later time. If you do not wish to receive cookies or wish to manage when you accept cookies in general, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. We provide more information on this in the "What are my choices?" section, below. Although you are not required to accept our cookies, if you set your browser to reject cookies, please note that you may not be able to access and use all of the features and functionalities of this Website.

Cookies allow a website to customize information that is presented to you through your use of the Website (such as to display personalized content and targeted advertising to you on your future visits to the Website), and to save time by storing information so you do not need to re-enter it during a later use of our Website. We may place cookies on this site directly, or on behalf of a partner whose advertisement appears on this Website or its service providers. In general, cookies do not identify you personally. However if you have created a user identity on one of your visits to the Website, we may link the cookies to information that identifies you personally. We may use a combination of "session cookies" and "persistent cookies" on this Website, as further described below.

Session Cookies. A "session cookie" is a temporary cookie that expires when you close your browser. A session cookie assigns a randomly-generated, unique identification number to your computer when you access this Website. Assigning your computer a number facilitates the proper functioning of the features of the Website by permitting us to maintain a persistent "state" for your session, such as maintaining the contents of your shopping cart during checkout. We also use session cookies to collect anonymous and aggregated information (i.e. information that does not identify you personally) about the ways in which visitors use this Website (e.g. web traffic information, which pages they visit, which links they use, and how long they stay on each page). We analyze this information (known as "click-stream information") to better understand our visitors' interests and needs in order to improve the content and functionality of this Website.

Persistent Cookies.Unlike a session cookie, a "persistent cookie" does not expire when you close your browser. It stays on your computer until the expiration date set in the cookie (e.g. at the end of a calendar month) or until you delete it. Persistent cookies can be used to "tag" your computer so that the next time you visit (or someone using your computer visits), our server will recognize you, not by name, but by the "tag" on your computer. This will enable us to provide you with a personalized experience even if we do not know who you are. It will also allow us to collect more accurate information about the ways in which visitors use this Website, for example, how people use the Website on their first visit and how often they return. Using persistent cookies allows us to provide you with a more personalized shopping experience and, in some cases, may save you the trouble of re-entering information already in our database.

Web Beacons. you visit this Website, your computer may receive one or more "web beacons" in order to assist us with delivering cookies on the Website, to collect anonymous information about the use of this Website by our visitors, and to deliver customized or targeted content to you on this Website and through our partners. Web beacons are graphic images, usually no larger than a 1x1 pixel, placed at various locations on the Website. They also help us identify browser types, search terms that bring visitors to our website, and the domain names of websites that refer traffic to us. We may place web beacons on this site directly, and may place web beacons on behalf of the partner whose branding appears on the Website or its service providers. They also help us identify your IP address. The information collected by web beacons does not identify you personally. However, if you have created a user identity on one of your visits to the Website, for example, by making a purchase, we may link the information we collect using web beacons to the information that identifies you personally and use it in the same ways as we use the information we collect using cookies. We also use web beacons to provide us with more information on any emails we send out. In particular, a web beacon in an email communication will send us information to let us know that you have received, opened, or acted upon an email you have chosen to receive from us.

List of Cookies

The cookies placed by our website are detailed in the table below:

N°	TYPE	NAME	PURPOSE	DURATION
1.	Application cookie	GEOBLOCK_*	Used for geo restriction	1 day
2.	Session cookie	pep-territory	Used to save geo ip detection	Session
3.	Application cookie	pep-sstorage	Used to save personal information (access token and API result)	6 months
4.	Application cookie	pep-lastconn	Used to save the last connection time, to detect when to renew the access token	6 months
5.	Application cookie	pep-esrb-data	Used to save the birth date for age gating (ESRB / PEGI checks)	1 hour
6.	Permanent cookie	cashrun* CS_FPC	Used for anti-fraud checks (Cashshield): fingerprint , fraud assessment	1 year
7.	Application cookie	_air360_e	Hold the last event done	30 minutes
8.	Application cookie	_air360_ev	Used for the event visualizer feature	30 minutes
9.	Permanent cookie	_air360_u	Used to hold the User ID	6 months
10.	Session cookie	_air360_s	Used to hold the current session ID	Session
11.	Permanent cookie	_air360_i	Used to hold the unique fingerprint / browser ID	6 months
12.	Application cookie	air360_app	Used to save the Air360 app ID	6 months
13.	Session cookie	laravel_session	Used to identify the session with a user	2 hours

Third-party cookies

We also use services offered by third parties.

Analytics cookies

Google Analytics helps us measure the number of visitors and see how they use the website, which helps us improving the website.

The data used in connection with these cookies include:

1. How you interact with the site, such as the pages you visited; and/or
2. What your IP address is in order to locate where you log in from. This data is immediately anonymized and is not disclosed to Google.

The cookies used are detailed in the table below:

N°	TYPE	NAME	COMPANY	PURPOSE	DURATION
1.	Application cookie	_ga,, , ,	GOOGLE	Needed for Google Analytics / GTM	6 months
2.	Application cookie	_gid	GOOGLE	Needed for Google Analytics / GTM	1 day
3.	Application cookie	_gat_*	GOOGLE	Needed for Google Analytics / GTM	1 min
4.	Application cookie	_gat	GOOGLE	Needed for Google Analytics / GTM	1 min

We also use cookies that make the website more user-friendly and include interactive functions and features such as:

1. Share buttons (Facebook , Twitter, Google+);
2. Video broadcasting on the website (YouTube);
3. Social connectors (Facebook, Twitter, Google, Instagram, Twitch, YouTube).

These features rely on third-party cookies that are directly placed by the service providers.

Facebook

The Website may use social plugins ("plugins") of the social network facebook.com which is operated by Meta Platforms, Inc., 1601 Willow Road Menlo Park, CA 94025 United States.

These plugins can be recognised by one of the Facebook logos (white "f" on a blue tile or a "thumbs-up" sign) or are marked as "Facebook Social Plugin". A list of Facebook social plugins with illustrations is available on:https://developers.facebook.com/docs/plugins/page-plugin.

As soon as a web page is being accessed which contains such a plugin, your browser will establish a direct connection with the servers of Facebook. The content of the plugin will be communicated directly from Facebook to your browser and embedded in the web page. We therefore have no influence on the amount of data Facebook obtains through these plugins and thus inform you according to our current state of knowledge: http://www.facebook.com/help/help/?faq=17512 .

Facebook obtains information that you have accessed a corresponding page of the Website through the embedding of the plugin. If you are at that time logged into Facebook, Facebook will be able to allocate your visit to our page to your Facebook account. If you interact with the plugins, (e.g. use the "Like" button or leave a comment) then this information will be transmitted by your browser directly to Facebook and stored there. If you are not on Facebook, Facebook may still be able to find out your IP address and store it.

The plugins of Facebook can be embedded by website providers on their own website or platform. By clicking on the plugin registered, Facebook users can automatically leave a note in their Facebook profile that they approve the linked contents of the respective website provider. The embedded Facebook plugin communicates continuously with Facebook and sends data immediately upon visiting the embedding web page to Facebook — whether or not the user clicks on it.

The so-called iFrame (or source text) embedding causes the browser to load apart from the actually accessed website another "page in the page" which contains the respective plugin. In the case of Facebook plugins, this iFrame or source text is entirely created by Facebook and can in principle not be controlled or edited by us. If the user is not logged in or not registered with Facebook, a cookie is still installed which carries identifying information, such as, for instance, B7dcTqgWq3fuDgllFw47QPIO, and is valid for two years.

If the browser later re-connects with the server of Facebook, this cookie will be transmitted to the user account and can be used to create a profile. The information stored in the cookie may also still be retrieved retrospectively if the user registers later on Facebook. If the user is logged into Facebook during the current browser session, both the accessed web page and the cookie will be transmitted to Facebook - in this case the session ID will allow for this information to be clearly allocatable to the respective user account. We are not acquainted with the purpose and extent of the data collection as well as any further processing and use of the data by Facebook. For further information on your rights in this respect and on the browser settings options available to protect your privacy, please contact Facebook or refer to Facebook's data protection information:http://www.facebook.com/policy.php.

It is possible to block Facebook social plugins with add-ons for your browser.

Twitter

Our websites may use social plugins from the social network twitter.com operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA.

These plugins are identifiable by their Twitter logo (white bird on blue square). In particular, they allow you to share the content of our website with your Twitter contacts.

Instagram

Our websites may use plugins from the Instagram social network operated by Instagram LLC, 1601 Willow Rd Menlo Park CA 94025 USA.

These plugins are identifiable by their Instagram logo (minimalist camera). In particular, they allow you to share the content of our website with your Instagram contacts.

Youtube

Our websites may use YouTube social network plugins operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

These plugins are identifiable by their YouTube logo (white triangle in a red rectangle). They allow you to follow our video channel on this social network.

5. What purposes do we use your Personal Information?

We may use collect, use and/or disclosure your Personal Information for the following purposes:

1. to contact you if you have requested information or communication from us;
2. to determine the country or region in which you are located for compliance purposes (including without limitation export compliance) and for security, anti-piracy, and fraud prevention purposes;
3. to help verify that existing Personal Information about you, in our possession, is accurate and complete;
4. to provide you with product updates and upgrades, special offers, pricing information, newsletters, and other information, either on our own behalf or in some cases on behalf of a partner, client and/or service provider, where you have consented to receive it;
5. to undertake any other promotional activity in the case you have consented to receiving and participating to such promotional activity;
6. in connection with keys, access codes or other information as may be required to permit you to access the Website or make use of the services of our partners and/or service provides to receive products, updates or services;
7. to verify your compliance with applicable laws, rules and regulations;
8. if you visit the Website for the purposes of conducting a purchase transaction:
   1. to take, verify, process or deliver your order, process or obtain payment, verify your tax or tax exempt status, contest chargebacks, determine your eligibility for a line of credit, or notify you of the status of your order;
   2. for fraud and piracy prevention purposes;
   3. to provide you, to the extent permitted by law, with a personalized shopping experience;
   4. to register your purchase with the manufacturer or service provider for warranty, technical support or similar purposes;
   5. to provide notice of your purchase to the provider of an online service for which you purchase a service use right from us, for example, in order for the service provider to enable your access to the service;
   6. for you to establish an account for future purchases, if you have consented to the creation of such an account;
   7. to facilitate the renewal of your subscriptions for products or services; and
   8. to provide you with effective customer service (which may to the extent and in a manner permitted by applicable law, include contacting visitors who commence but do not complete a checkout process to follow up on the incomplete session or to see if there was a problem with their use of this website), and/or technical support.
9. to facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us or any of our affiliates or related corporations;
10. any other purpose relating to or reasonably necessary for any of the above.

We keep your Personal Information only as long as we need it for the purposes for which it was originally collected (or to which you have subsequently additionally consented) or for legal and business purposes as permitted or required by applicable law.

6. What use are you making of the anonymous information you collect?

We may use anonymous information collected by us:

1. to personalize and support your use of this website, our services, and/or the services of our partners;
2. to improve the website, the customer experience, our advertising systems, and our products and services;
3. to identify actions or transactions as originating through an affiliate marketing or referral program;
4. to deliver targeted advertisements on the Website and other websites;
5. to provide reporting to our current and prospective partners and service providers; and
6. for other historical, statistical or research and analyses purposes.

7. Disclosure of your Personal Information

Subject to applicable law, we may provide and disclose your Personal Information, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

1. our affiliates and related corporations;
2. our partners, publishers, manufacturers, operators, and their respective service providers and subcontractors - When we make products available for sale through a website, we are doing so as an independent e-commerce seller of the partner whose name and/or logo appears on the particular website. In connection with your purchase of a product or service through an online store we operate that is co-branded with our partner's branding, we will provide certain Personal Information and/or anonymous information you provide in connection with your purchase to that partner for reporting purposes, to allow our partner or its service provider to register your purchase, to enable your access to products or services provided by our partner or its suppliers, to facilitate warranty, technical support or after-sales service, to allow our partner or its subcontractor to send communications to you if you have consented to receive them, to allow our partner or its service provider to provide services in connection with the Website such as customer support or single sign-on functionality on the Website and our partner's website, or for similar purposes in order to fulfill obligations to you. We may also provide some of the Personal Information you provide in connection with your purchase to the publisher or manufacturer of a product you purchase, or operator of a service for which you purchase a service use right from us, if different than the partner whose name and/or logo appears on the Website;
3. our agents, contractors, third party service providers, and third parties who provide goods and services either independently or on our behalf - We use other companies to provide joint services or certain services to us or on our behalf and help us to operate our business. For example, to the extent permitted by applicable law we may use other companies to host or maintain this Website, to process credit card payments, to provide fraud screening and/or detection services, to perform data integrity checks, to offer you a line of credit, to provide website optimization services, to fulfill your order, for payment collection, to deliver advertisements on this Website and third party websites, to send mail or email, and/or to provide customer service. We may share your Personal Information with our service providers in connection with their provision of services to us. These companies are required by contract to use any Personal Information we share with them only to perform services to us or on our behalf and to your Personal Information. We will not share your Personal Information with our affiliates or unrelated third parties to use for their own marketing purposes without your consent;
4. banks, credit card companies and their respective service providers;
5. our professional advisers such as our board of directors, auditors and lawyers;
6. analytics, search engine providers or other third party service providers that assist us in delivering our products, services, the Website as well as improving and optimising the same;
7. relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them - To Comply With Legal Requirements, Cooperate With Law Enforcement, Prevent Fraud and Other Crimes, and Protect Legal Rights, Property, You and Others. To the extent permitted by applicable law, we may disclose the Personal Information we collect on the Website without notifying you when we, in good faith, believe disclosure is appropriate to comply with the law or a regulatory requirement; to comply with governmental, administrative or judicial process, requirement or order, such as a subpoena or court order; to cooperate with law enforcement or other governmental investigations (without necessarily requiring the law enforcement or government agency requesting the Personal Information to formally serve us with a subpoena); to prevent or investigate a possible crime, such as fraud or identity theft; to enforce a contract; to protect our legal rights, property or safety, our corporate affiliates, and their respective employees, clients and partners and agents, other users or the public in general; or to protect your vital interests if determined necessary by us. In addition, we may review our server logs for security purposes, such as detecting intrusions into our network. If we suspect criminal activity, we may share our server logs - which contain visitors' IP addresses - with the appropriate investigative authorities who may use that information to trace and identify individuals. We also reserve the right to report to appropriate law enforcement or government agencies any activities that we, in good faith, believe are or may be in violation of applicable laws, rules or regulations without providing notice to you;
8. affiliate, related corporation, external business, or third party in connection with any business asset transactions - If one of our corporate affiliates or a third party has acquired our business, specific assets or the business of one of our operating divisions through which you have provided Personal Information to us, for example, as the result of a sale, merger, reorganization, insolvency, dissolution or liquidation, your Personal Information will become owned by that company. In that event, the acquiring company's use of your Personal Information will still be subject to this Privacy Policy, any applicable Supplemental Privacy Notices, and the privacy preferences you have expressed to us; and
9. any other party to whom you authorise us to disclose your Personal Information to.

8. What are my choices?

We respect your right to make choices about the ways we collect, use and disclose Personal Information about you. We generally ask you to indicate your choices at the time and on the page where you provide your Personal Information.

When you provide Personal Information, we may offer you a choice as to whether you would like to receive further communications from us and/or from our partners, such as communications relating to updates and upgrades. We may send you marketing or promotion communications including information on special offers and pricing if you have indicated your consent to receiving such communications and information. You have the right to withdraw your consent at any time. If you decide you no longer want to receive promotional messages from us, you may let us know by clicking "unsubscribe" in any promotional messages you have received from us or via the contact form on our website www.scalefast.com ; please specify which consent you are revoking in the contact form to us. Please note, however, if you indicate your consent to adding your contact information to the Merchant's mailing list and later withdraw your permission, you will have to contact the Merchant (or use the "opt-out" provided in the emails the Merchant sends you) to have your name and mailing details removed from the Merchant's mailing lists.

If you accept a session or persistent cookie, you can delete it at any time through your web browser (e.g., as soon as you leave our website). If you do not wish to receive cookies or wish to manage when you accept cookies in general, you may set your browser settings to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept our cookies, if you set your browser settings to reject cookies, please note that you may not be able to access and use all of the features and functionalities of the Website.

We and our partners use third party service providers, which may include but are not limited to Google Analytics and Omniture, to serve advertisements on our behalf across the Internet, and sometimes on the Website. These advertisements may collect anonymous information about your visits to the website on which such advertisements are placed, your interaction with these advertisements and the products and services offered by us, our partners and our suppliers through the use of a pixel tag or other web technologies. We and our partners may use this anonymous information to provide targeted advertisements to you for goods and services. If you opt out of having your information collected through cookies, web beacons and other tools, your existing display advertising cookie(s) will be deleted and new cookie(s) will attempt to be placed that instructs service providers not to track your future activities when that cookie is detected (a "no-track" cookie). If your browsers are configured to reject cookies when you visit our opt-out page, a "no-track" cookie cannot be set on your computer. Also, if you subsequently erase "no-track" cookies, use a different computer or change web browsers, you will need to opt-out again.

In certain circumstances, where you choose not to provide Personal Information which is required to us, we will not be able to provide you with the products and services requested or purchased by you, or we may not be able to comply with a legal obligation on us. We will make it clear if and when this situation arises and the consequences of your choice not to provide your Personal Information to us.

9. How do we secure your personal information?

We are committed to keeping Personal Information secure. We have implemented physical, technical and administrative safeguards reasonably designed to protect your Personal Information from unauthorized access and disclosure. When we collect or transmit sensitive information such as a financial account number, we use industry standard methods to protect that information. It is important that you understand, however, that no website, database or system is completely secure or "hacker proof." You are also responsible for taking reasonable steps to protect your Personal Information against unauthorized disclosure or misuse, for example, by protecting your password.

Different countries and regions have different privacy laws and requirements. Please know, however, that no matter where your Personal Information is collected, used, transferred or stored, if it was collected through the Website, it will be protected by us in accordance with the terms of this Privacy Policy and applicable laws, rules and regulations.

10. What are my rights?

You have certain rights in relation to your Personal Information. Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please submit a request in writing or email to privacy@scalefast.com and provide sufficient information to allow us to understand the scope of your request. Where permitted under law, we may charge a fee to process your request.

1. Access: you are entitled to request that we provide Personal Information about you that is in our possession or under our control, and information about the ways in which your Personal Information has been or may have been used or disclosed by us in the past year.
2. Correction: you are entitled to request that any incomplete or inaccurate Personal Information we hold about you is corrected.
3. Portability: you may request the transfer of your personal data to another third party.
4. Consent withdrawal: you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on your consent before withdrawal.
5. Supervisory Authority: you also have a right to lodge a complaint with a competent supervisory authority (e.g. the Singapore Personal Data Protection Commission).

11. What is your policy regarding children's privacy?

The Website is not directed at nor targeted to children (i.e. individuals below the age of 13. If you have not reached the age of 13, you may not use the Website unless supervised by a parent or legal guardian who is required to provide consent (on your behalf) to the collection, use and/or disclosure of your Personal Information as set out in this Privacy Policy. Our goal is to comply with applicable laws and regulations relating to collection and use of Personal Information from children. If you believe that we have received Personal Information from a child under the age of 13, please notify us immediately by email by clicking privacy@scalefast.com, and we will take reasonable steps to remove that Personal Information from our databases.

12. Transfers of Personal Information outside of Singapore

Your Personal Information may be transferred to our affiliates and to third parties (e.g. authorised service providers that provide us with products or services) - such as the partner whose name and/or logo appears on this Website, and the entities and parties identified at paragraph 7 above - which may be located outside Singapore.

When your Personal Information is transferred to a party located outside of Singapore, we will do so in accordance with the requirements under the PDPA - i.e. to ensure that the receiving party provides a standard of protection to the transferred Personal Information that is comparable to the protection under the PDPA.

13. Additional information

If you have any questions, comments, or concerns regarding this Privacy Policy or our privacy practices, or have privacy-related questions not answered online, you may contact us by any of the following means:

1. Via our contact form on our website www.scalefast.com.
2. You may also write to our Data Protection Officer as the following: click

We may from time to time update this Privacy Policy to reflect, among other things, changes in applicable laws, rules or regulations, changes to our data collection practices, and/or changes to our business or services. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of this Privacy Policy as may be updated from time to time on the Website www.scalefast.com and/or as you may be notified. Hence, please check back regularly for updated information on our handling or processing of your Personal Information. If revisions to the Privacy Policy materially affect how we may use Personal Information collected from you prior to the date of the revised statement, then we may request that you opt-in to the revised Privacy Policy. We will post an updated version of this Privacy Policy on the Website with a revised effective date, to let you know that we have updated the Privacy Policy.