Privacy Policy
1. OUR PRIVACY POLICY
Last modified: Sep 17, 2024
Sago Sago Toys Inc., DUNS #203172499 , having its registered office at 171 John Street, 5th Floor, Toronto, Ontario, M5T 1X3, Canada and doing business under the name Piknik™ and Sago Mini™, (“Sago Sago”, “We”, “Our” and “Us”) is committed to protecting Your privacy as a data subject (“You” or “Your”) and the secure processing of Your personal data and We strive to limit the processing of personal data as far as possible and do not collect personal data beyond what is necessary.
While our apps are designed for young kids and parents, our websites sagomini.com and playpiknik.com (the "Site" or "Site(s)”) are intended for adult use only. We take privacy seriously at Sago Sago and this policy is designed to share the information we collect and how we use it. This Privacy Policy applies to the Sites as well as SAGO MINI WORLD, SAGO MINI SCHOOL, SAGO MINI FIRST WORDS, TOCA BOCA JR, MathTango, Endless Learning Academy, PAW Patrol Academy™ app (“PAW Academy”) and PIKNIK digital subscription programs and which are part of the services (“Services”) that Sago Sago offers.
Needless to say, all processing of personal data, including the collection, registration, storing and general handling is governed by applicable privacy legislation, including the General Data Protection Regulation (“GDPR”). Sago Mini™ strives to make sure that the processing of personal data done by Sago Mini™, is done in accordance with applicable legislation.
For our Privacy Policy for Kids, please see .
We aim to apply the GDPR to everyone but if You reside outside the European Union and use Our services, We may apply additional standards to You as required by local law. To the extent that the California Consumer Privacy Act (“CCPA”) applies to You, the definitions in this privacy policy are to be read as follows: “personal data” includes “personal information”; “data subject” includes “consumer”; “controller” includes “business”; “processor” includes “service provider”, all as defined under the CCPA. For more information about the CCPA, please see .
As a service directed towards children, We also adhere to the Children’s Online Privacy Protection Rule (“COPPA”). To the extent that the COPPA applies to You, the definitions in this privacy policy are to be read as follows: “personal data” includes “personally identifiable information”; “processor” includes “service provider”, all as defined under the COPPA.
Who are We?
Proudly Canadian, Sago Mini™ is a subsidiary of Spin Master Ltd. We cooperate with Spin Master Ltd, and the other gaming studios of the group (each a “Group Company”) to learn from one another, help each other and improve how We all make apps.
Our websites www.sagomini.com and www.playpiknik.com are just for grownups, while Our apps are designed for young children with parental supervision. We take privacy seriously at Sago Mini™ and this policy is designed to share what information We collect and how We use it. When You visit Our websites, install one of Our apps or interact with Our social media channels, Sago Mini™ processes Your personal data in accordance with this privacy policy and acts as the controller of Your personal data as defined by the GDPR.
Our contact details are:
You can also call or write to us at:
Sago Sago Toys Inc.
+1(416) 703-6459
171 John Street, 5th Floor
Toronto, ON, M5T 1X3, CANADA
The contact details to Our Data Protection Officer are:
Attn: Data Protection Officer
Spin Master Ltd
225 King Street West
Toronto, ON, M5V 3M2, CANADA
Should You have any questions related to privacy and/or Your rights, You can also contact Us at privacy@playpiknik.com or Our Data Protection Officer at DPO@spinmaster.com. Below You will also find detailed information on how We process Your personal data, on Your rights and how You can exercise them.
When does this privacy policy apply?
This privacy policy describes how We collect and use Your personal data when You are using Our services, playing Our apps or interacting with Us. It applies to all visitors of Our websites, end users (including paying and non-paying users, grownups and children) and Our social media channels.
2. YOUR RIGHTS AS A DATA SUBJECT
Under the GDPR You have certain rights concerning Our processing of Your personal data. If You would like to access, correct, erase or limit the use or disclosure of any of Your personal data that has been collected and stored by Sago Mini™ or exercise any other right under applicable data protection legislation, please notify Us at privacy@playpiknik.com so that We may consider and respond to Your request in accordance with applicable law.
Right of information: You have the right to be provided information concerning Our processing of Your personal data. This includes understanding the purposes of processing, the categories of personal data concerned, and who else might receive Your personal data.
Right of access: You have the right to obtain confirmation as to whether or not We are processing Your personal data and, if this should be the case, have access to Your personal data.
Right to rectification: You have the right to obtain rectification of inaccurate or incomplete personal data concerning You.
Right to erasure (“right to be forgotten”): Under certain circumstances, such as if the personal data is no longer necessary for the original purpose, if You withdraw Your consent, or if the personal data has been unlawfully processed, You have the right to obtain the erasure of Your personal data. However, this does not apply if Our interest in continuing to process Your personal data outweighs Your interest in having it deleted or if We are subject to a legal requirement to retain Your personal data.
Right to restriction: Under certain circumstances, such as if You contest the accuracy of Your personal data or if the processing is unlawful but You oppose erasure and request restriction instead, You have the right to obtain the restriction of processing.
Right to data portability: Under certain circumstances, such as when the processing is based on Your consent or a contract with You and the processing is carried out by automated means, You have the right to receive Your personal data in a structured, commonly used and machine-readable format and the right to transmit this information to another controller.
Right to object: Under certain circumstances You have the right to object to the processing of Your personal data. This includes but is not limited to the right to object in cases in which We process Your personal data based on legitimate interest (Article 6(1)(f) GDPR).
Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority if You consider that Sago Mini™’s processing of Your personal data infringes the GDPR or any other privacy legislation. For Canadian users you can file a complaint at the or if you live in the EU you can file a complaint at the , You can also lodge a complaint with Your own national data protection authority, please see list .
Right to withdraw consent: If a processing of Your personal data is based on Your consent as set out in this privacy policy, You have the right to withdraw Your consent at any time.
Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You.
If you would like to review or delete your or your child’s information, please contact us at privacy@playpiknik.com.
3. TYPES OF PERSONAL DATA WE COLLECT
In this Section, We describe the types of personal data that We collect or create. In We describe for what purposes and which legal ground that We rely upon when We process Your personal data. For the purposes of this privacy policy, the term personal data shall have the same definition as it has under the GDPR.
User Information: Information about Your use of Sago Mini™’s apps - such as in-app generated events based on Your interaction with the app, error and crash reports.
Device Information: Information from Your device - such as device IDs, Android ID, IDFV, App Set ID, operating system, platform, screen resolution and similar information about Your device and device settings/usage, IP address (including Your approximate location).
Unique Identifiers: Information from Your account - such as account ID, Piknik profile ID, parent’s email address and password (where email login is applicable). This also includes persistent identifiers such as App Set ID and Appsflyer ID which are used to help identify Piknik apps installed on Your device.
Purchasing Data: Information relating to Your purchase history - such as in-app properties/playset and purchasing tendencies.
Social Media: Information about You and Your interactions with Sago Mini™ fan pages on social media - such as name and/or user name, posts You like and comment.
Customer Information: Information from You provided to Us via Our customer support and/or service functions - such as first name, last name, email, age, Your issues and/or ideas.
4. WHAT PERSONAL DATA ARE USED FOR WHAT PURPOSE AND WITH WHICH LEGAL BASIS?
In the table below We indicate:
- what We use Your personal data for;
- Our legal justifications (each called a “legal basis”) under the GDPR for each purpose; and
- the categories of personal data We use for each purpose.
Here is a general explanation of each legal basis to help You understand the table:
- Contract with You: Where it is necessary for Sago Mini™ to process Your personal data to:
- fulfill obligations under a contract with You. This includes Sago Mini™’s obligations under the Terms of Service to provide the apps service to You.
- verify information before the start of a new contract with You.
- Legitimate interest: Where Sago Mini™ has an interest in using Your personal data in a particular way, which is necessary and justified after considering any risks to You and other Sago Mini™’s users. For example, We may use Your usage data to improve the Piknik service for all users. Contact Us if You want to understand a specific legitimate interest and retain information on the balancing test.
- Consent: When Sago Mini™ asks You to actively consent to Sago Mini™ use of Your personal data for a specific purpose.
In the case of a legal dispute or other legal matter between You and Us We would work together with Our owners, Spin Master Ltd, and external advisors to assess and manage the legal matter. We would however still be the controller of Your personal data. If there is a legal dispute or other legal matter We will process Your personal data relevant to the matter or dispute. In particular, this may include Your name, e-mail address, contact details and any actions, progress and purchases that You may have performed in the app.
The purpose of the processing of the data by Us would in this case be the effective and uniform handling of legal matters.
If the data processing concerns the conclusion or performance of a contract with You, the legal basis of the data processing is performance of a contract. If the data processing is based on a legitimate interest, the legal basis is Our legitimate interest in effectively and uniformly handling legal matters and disputes. In case of legally legitimate and binding obligations by authorized courts or governmental authorities the legal basis for disclosing data would be in connection with the respective laws that state the legal binding effect of the obligation.
The storage period for data processed for the purpose of handling legal matters, disputes or complying with legal obligations is governed by the relevant limitation period, so that We can sufficiently defend ourselves against claims, or by the relevant legal obligations to retain documents.
4.1 SAGO MINI WORLD, SAGO MINI FIRST WORDS, TOCA BOCA JR, TOCA BOCA JR HAIR SALON 4, ENDLESS LEARNING ACADEMY - We collect the following information from You when You install and/or use these apps on platforms such as Apple AppStore, Google Play Store, Amazon, Samsung etc.
| What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
|---|---|---|
| To provide the Sago Mini™ service in accordance with Our contract with You. For example, give You access to Our app. |
Contract with You. | ● Device information ● Unique Identifiers |
| When You register for an account for one of the Services. When You make a purchase we process the following information in order to fulfill Our contract with You. |
Our performance of a contract with You. | ● Password ● Email Address ● Single Sign On ● CRM ID ● Account ID ● Subscription Purchased ● Amount Paid ● Billing Address ● First Name ● Last Name ● Payment Details |
| Process players’ in-app activity in order to answer questions relating to the performance of Our app and Our business. To understand how many active users, user experience and user engagement. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Information ● Payment Data ● User Information ● App Interactions ● Other Installed Sago Mini™ apps |
| When We have a crash in Our apps We collect, store and analyze information about that crash. We do that to understand if something is wrong in the app, this could be a bug in the app that We need to fix so You can continue playing it. | Contract with You. | ● Device Information ● Unique Identifiers ● User Information ● App Interactions |
| For the purpose of marketing campaigns to measure ad performance by driven installs and click through rates on various media platforms. This will help Us to bring new players, create a better experience for You as a player of Our apps and provide relevant offers that You may like. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Unique Identifiers ● User Information ● Parent’s Email Address |
| Whenever an action is performed in-app that requires a server side response, We will be processing and storing pieces of personal data as part of log files. We do this to ensure technical functionality. | Contract with You. | ● Unique Identifiers ● User Information |
| If You are using Our customer support services powered by Help Scout so that We can provide service in accordance with Our contract with You. For example, give You access to Our app or answer any questions that You may have. |
Depending on the purpose of Your question We rely on either one of the legal grounds below: Contract with You. or It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Unique Identifiers ● Customer Information ● Contact Email ● Name |
4.2 SAGO MINI SCHOOL - We collect the following information from You when You install and/or use the app Sago Mini School on platforms such as Apple AppStore, Google Play Store etc.
| What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
|---|---|---|
| To provide the Sago Mini™ service in accordance with Our contract with You. For example, give You access to Our app. |
Contract with You. | ● Device information ● Unique Identifiers |
| When You register for an account for one of the Services. When You make a purchase we process the following information in order to fulfill Our contract with You. |
Our performance of a contract with You. | ● Password ● Email Address ● Single Sign On ● CRM ID ● Account ID ● Subscription Purchased ● Amount Paid ● Billing Address ● First Name ● Last Name ● Payment Details |
| You can customize the complexity level of in-app activities by selecting an age range or difficulty level appropriate to the intended user of the activities. You can set up reports on the activity and progress that occurs in Sago Mini School. |
Our legitimate interest. | ● Child’s First Name (Optional) ● Age Range that the child fits in (Optional) ● App Interactions ● Parent’s email |
| Process players’ in-app activity in order to answer questions relating to the performance of Our app and Our business. To understand how many active users, user experience and user engagement. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Information ● Payment Data ● User Information ● App Interactions ● Other Installed Sago Mini™ apps |
| When We have a crash in Our apps We collect, store and analyze information about that crash. We do that to understand if something is wrong in the app, this could be a bug in the app that We need to fix so You can continue playing it. | Contract with You. | ● Device Information ● Unique Identifiers ● User Information ● App Interactions |
| For the purpose of marketing campaigns to measure ad performance by driven installs and click through rates on various media platforms. This will help Us to bring new players, create a better experience for You as a player of Our apps and provide relevant offers that You may like. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Unique Identifiers ● User Information ● Parent’s Email Address |
| Whenever an action is performed in-app that requires a server side response, We will be processing and storing pieces of personal data as part of log files. We do this to ensure technical functionality. | Contract with You. | ● Unique Identifiers ● User Information |
| If You are using Our customer support services powered by Help Scout so that We can provide service in accordance with Our contract with You. For example, give You access to Our app or answer any questions that You may have. |
Depending on the purpose of Your question We rely on either one of the legal grounds below: Contract with You. or It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Unique Identifiers ● Customer Information ● Contact Email ● Name |
4.3 MATHTANGO - We collect the following information from You when You install and/or use the app MathTango on platforms such as Apple AppStore, Google Play Store etc.
| What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
|---|---|---|
| To provide the Sago Mini™ service in accordance with Our contract with You. For example, give You access to Our app. |
Contract with You. | ● Device information ● Unique Identifiers |
| When You register for an account for one of the Services. When You make a purchase we process the following information in order to fulfill Our contract with You. |
Our performance of a contract with You. | ● Password ● Email Address ● Single Sign On ● CRM ID ● Account ID ● Subscription Purchased ● Amount Paid ● Billing Address ● First Name ● Last Name ● Payment Details |
| You can create profiles in MathTango, which will allow You to customize the difficulty and lesson plan for that profile. Activity progression is unique to each profile. Profiles are saved locally, and are not connected to your Piknik account. |
Our legitimate interest. | ● Child’s Name ● Child's Age |
| Process players’ in-app activity in order to answer questions relating to the performance of Our app and Our business. To understand how many active users, user experience and user engagement. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Information ● Payment Data ● User Information ● App Interactions ● Other Installed Sago Mini™ apps |
| When We have a crash in Our apps We collect, store and analyze information about that crash. We do that to understand if something is wrong in the app, this could be a bug in the app that We need to fix so You can continue playing it. | Contract with You. | ● Device Information ● Unique Identifiers ● User Information ● App Interactions |
| For the purpose of marketing campaigns to measure ad performance by driven installs and click through rates on various media platforms. This will help Us to bring new players, create a better experience for You as a player of Our apps and provide relevant offers that You may like. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Unique Identifiers ● User Information ● Parent’s Email Address |
| Whenever an action is performed in-app that requires a server side response, We will be processing and storing pieces of personal data as part of log files. We do this to ensure technical functionality. | Contract with You. | ● Unique Identifiers ● User Information |
| If You are using Our customer support services powered by Help Scout so that We can provide service in accordance with Our contract with You. For example, give You access to Our app or answer any questions that You may have. |
Depending on the purpose of Your question We rely on either one of the legal grounds below: Contract with You. or It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Unique Identifiers ● Customer Information ● Contact Email ● Name |
4.4 PAW Academy - We collect the following information from You when You install and/or use the app PAW Academy on platforms such as Apple AppStore, Google Play Store etc.
| What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
|---|---|---|
| To provide the Sago Mini™ service in accordance with Our contract with You. For example, give You access to Our app. |
Contract with You. | ● Device information ● Unique Identifiers |
| When You register for an account for one of the Services. When You make a purchase we process the following information in order to fulfill Our contract with You. |
Our performance of a contract with You. | ● Password ● Email Address ● Single Sign On ● CRM ID ● Account ID ● Subscription Purchased ● Amount Paid ● Billing Address ● First Name ● Last Name ● Payment Details |
| You can create profiles in PAW Academy, which will allow You to customize the difficulty and lesson plan for that profile. Activity progression is unique to each profile. | Our legitimate interest. | ● Child’s Name ● Child's Age |
| Process players’ in-app activity in order to answer questions relating to the performance of Our app and Our business. To understand how many active users, user experience and user engagement. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Information ● Payment Data ● User Information ● App Interactions ● Other Installed Sago Mini™ apps |
| When We have a crash in Our apps We collect, store and analyze information about that crash. We do that to understand if something is wrong in the app, this could be a bug in the app that We need to fix so You can continue playing it. | Contract with You. | ● Device Information ● Unique Identifiers ● User Information ● App Interactions |
| For the purpose of marketing campaigns to measure ad performance by driven installs and click through rates on various media platforms. This will help Us to bring new players, create a better experience for You as a player of Our apps and provide relevant offers that You may like. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Unique Identifiers ● User Information ● Parent’s Email Address |
| Whenever an action is performed in-app that requires a server side response, We will be processing and storing pieces of personal data as part of log files. We do this to ensure technical functionality. | Contract with You. | ● Unique Identifiers ● User Information |
| If You are using Our customer support services powered by Help Scout so that We can provide service in accordance with Our contract with You. For example, give You access to Our app or answer any questions that You may have. |
Depending on the purpose of Your question We rely on either one of the legal grounds below: Contract with You. or It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to perform the personal data processing, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Unique Identifiers ● Customer Information ● Contact Email ● Name |
4.5 OTHER APPS - We collect the following information from You when You install and/or use the other apps on platforms such as Apple AppStore, Google Play Store, Amazon, Samsung etc.
| What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
|---|---|---|
| To provide the Sago Mini™ service in accordance with Our contract with You. For example, give You access to Our app. |
Contract with You. | ● Device information ● Unique Identifiers |
| Process players’ in-app activity in order to answer questions relating to the performance of Our app and Our business. To understand how many active users, user experience and user engagement. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Information ● Payment Data ● User Information ● App Interactions ● Other Installed Sago Mini™ apps |
| When We have a crash in Our apps We collect, store and analyze information about that crash. We do that to understand if something is wrong in the app, this could be a bug in the app that We need to fix so You can continue playing it. | Contract with You. | ● Device Information ● Unique Identifiers ● User Information ● App Interactions |
| Whenever an action is performed in-app that requires a server side response, We will be processing and storing pieces of personal data as part of log files. We do this to ensure technical functionality. | Contract with You. | ● Unique Identifiers ● User Information |
4.6 SOCIAL MEDIA - We collect the following information from You when You interact with Us on Our social media pages such as Facebook, TikTok, Instagram etc.
| What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
|---|---|---|
| We reply to comments left by fans on Our own posts, We define this as reactive engagement. We also engage (by liking, leaving emojis or commenting) with fan channels on an as needed basis, We define this as proactive engagement. These are posts that have either gained high traction among the Sago Mini™ community or have created content that We like to support. We also share social media posts internally, but these are also publicly accessible on all social media platforms. |
It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device information ● Social Media |
4.7 RESEARCH GROUPS - We collect the following information when You Participate in Research Surveys, Focus Groups, User Testing, and Other Research Activities or Provide Feedback on our Apps
| What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
|---|---|---|
| To improve our existing products and services To develop and improve new products |
The performance of a contract , or our legitimate interest if you voluntarily have provided us with your information When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Your Email Address ● Your First Name ● Your Last Name ● Child’s Date of Birth ● Child’s Gender ● Child’s Racial Background ● Child’s Medical/Physical conditions ● Child’s Physical/Psychological disabilities ● Your Precise Location / Address ● Photos or Videos (if the Research is Conducted in Such a Manner that this is Shared/Collected) ● Other Personal Information You Provide us with |
4.8 WEBSITES - We collect the following Information from You when You are visiting Our websites
| What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
|---|---|---|
| To ensure network and information security of Our websites. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device information |
| When You register for an account for one of the Services. When You make a purchase we process the following information in order to fulfill Our contract with You. |
Our performance of a contract with You. | ● Password ● Email Address ● Single Sign On ● CRM ID ● Account ID ● Subscription Purchased ● Amount Paid ● Billing Address ● First Name ● Last Name ● Payment Details |
| Subscribe to one of our digital marketing communications | Your consent | ● Your Email Address |
| Our website incorporates YouTube videos. This integration is subject to the YouTube terms of service, and may result in the collection of Your personal data by Google according to the Google privacy policy. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Social Media ● Please see |
| If You are using Our customer support services powered by Help Scout so that We can provide service in accordance with Our contract with You. For example, give You access to Our app or answer any questions that You may have. |
Depending on the purpose of Your question We rely on either one of the legal grounds below: Contract with You. or It is necessary for the purposes of Our legitimate interests. When balancing interests, Sago Mini™ has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in . |
● Device Unique Identifiers ● Customer Information ● Contact Email ● Name |
Please note that Our websites may contain links to websites of other companies. If You follow a link to any of these websites, You should be aware that they have their own privacy practices and that We do not assume any liability for their processing of Your personal data. Therefore, please make sure to read their privacy policy.
4.9 DEVICE PERMISSIONS - Some of our products will request device permissions in order to operate some of the activities
Sago Mini World: Camera access is required for the Magic Camera activity, which is only available on iOS devices with AR-Kit enabled, and optionally required for the Hat Maker activity. The data is processed ephemerally. You can disable this functionality by going to the Parent Area and deselecting the ”Access camera” permission.
Dress Up, Bug Builder, Monsters, Robot Party and Hat Maker activities also have optional snapshot functionality which allows You to save screenshots of these games. Screenshots are saved only on device, and are not collected by Sago Mini. You can disable this functionality by going to the Parent Area and deselecting the “Save snapshots” permission.
Sago Mini First Words: Parents can optionally allow microphone, camera and speech recognition permissions to improve the experience of the Sago Mini First Words app for their child. This data is only used as part of the in-game experience and is not used for content creation. This data is processed ephemerally and only saved locally to the user’s device.
Toca Boca Jr: Screenshot functionality can be found in some of the activities. Screenshots are only saved locally on the device and You can remove them at any time by deleting them from your screenshot gallery.
Toca Boca Jr Hair salon 4: Screenshots can be taken within the app using the built in screenshot functionality. Screenshots are only saved locally on the device and You can remove them at any time by deleting them from your screenshot gallery.
5. HOW LONG DO WE KEEP THE PERSONAL DATA?
We will retain Your personal data for as long as necessary to provide Our services to You or as required by law.
We will keep Your personal data that is tied to Your account and Your usage of Our apps as long as necessary unless You contact Us asking for a removal.
For analytics, instead of deleting Your personal data We may anonymise the personal data so that no direct or indirect identifiers remain and after such anonymisation We will store the information for an indefinite period.
For marketing attribution purposes, We keep Your personal data for as long as necessary to provide Our services to You or as required by law.
For the purpose of customer support and services We will keep Your personal data for as long as necessary, unless You contact Us asking for a removal.
6. COMMUNITY OR SOCIAL MEDIA FEATURES AND HOW WE KEEP THEM SECURE
Our websites and services may include community or social media features, such as forums and chat rooms. Please note that any information You post in these features may be publicly available. We encourage You to use caution when sharing personal data in these features. We take reasonable measures to keep these features secure and protect Your personal data.
7. WITH WHOM DO WE SHARE YOUR INFORMATION?
Sago Mini™ may share Your information, including Your personal data which includes but is not limited to billing information or user names, with Our agents, contractors, or service providers who are hired to perform services on Our behalf. We may also share Your information with Our affiliates. We disclose necessary information to authorities such as the Swedish Authority for Privacy Protection and other authorities if We are required to do so by law, or under some circumstances if You have requested Us to do so.
7.1 Categories of recipients with whom We share with, regardless of app
7.1.1 Suppliers and subcontractors
Description of the recipient: Suppliers and subcontractors are companies that only have the right to process the personal data they receive from Us on behalf of Sago Mini™, i.e. data processors. Examples of such suppliers and subcontractors are software and data storage providers, and business consultants.
Service Providers - Processors
- We use the following service providers that acts as processors in relation to children in all Our apps:
- We use Mixpanel, Firebase and BigQuery for analytics.
- We use Amazon Web Services for hosting assets for future downloads.
- We use SendGrid to send account management emails.
- We use Help Scout for customer service and to host Our FAQs. In the event We are contacted through Our Help Scout by a child, We will reply once before immediately deleting the child’s email address and any associated personal data.
- We also work with AppsFlyer as an attribution provider to help Us understand Your interactions with the apps and to optimize and analyze mobile ad campaigns. AppsFlyer does not collect any personally identifiable information about You.
- We use Amazon Web Services to monitor Our technical environments. This helps Us to keep Our services running and if something unexpected happens.
- We use BackTrace and Firebase Crashlytics for monitoring bug crashes and crash reports.
- We use Chargebee to process payments for users subscribing to Sago Mini™ products via our websites
7.1.2 Spin Master Group
Description of the recipient: Group Companies. These Group Companies only have the right to process the personal data they receive from Us on behalf of Sago Mini™, i.e. data processors.
List of companies that We share personal data with:
Spin Master Ltd.
225 King Street West
Toronto, ON M5V 3M2, Canada
Please see the privacy policy .
Spin Master Toys UK Limited
Winter Hill House Marlow Reach,
Station Approach, Marlow, England, SL7 1NT
Please see the privacy policy .
Toca Boca AB
Box 90293
120 31 Stockholm, Sweden
Please see the privacy policy .
Originator Inc
809 Laurel Street #12,
San Carlos, CA, 94070, USA
Please see the privacy policy .
Purpose and legal basis: This is required for Sago Mini™ to be able to provide You with its services and functionalities. We have a legitimate interest in being able to access and provide these services and functionalities (Article 6(1)(f) GDPR). We ensure that the processing this entails is necessary to pursue that interest, and that Our interest outweighs Your right not to have Your information processed for this purpose. You are entitled to object to this processing, for reasons connected to the circumstances in Your particular case. Please see for more information about Your rights.
8. THIRD COUNTRY TRANSFERS
In some cases Sago Mini™ might transfer personal data outside the EU and EEA, so-called third countries. For Our transfers to the US, Canada and UK following conditions apply:
- . This means that We transfer personal data to countries outside of the EEA which have adequate laws to protect personal data, as determined by the European Commission. For example, We transfer the personal data described in to service providers and partners based in Canada and UK.
- . These clauses require the other party to protect Your data and to provide You with EU-level rights and protections. For example, We use SCCs to transfer the personal data described in to Our service providers and partners which use servers in the US. For transfers to the US We also rely on the EU-US Data Privacy Framework.
- Exceptions in special situations apply, such as to fulfill a contract with You or Your consent to the specific transfer.
We also identify and use additional protections as needed for each data transfer. For example, We use technical protection measures, such as encryption and pseudonymization.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
We are committed to protecting Our users’ personal data and are among other things using pseudonymization, encryption and user based access levels to protect Your personal data. We strive to take appropriate technical and organizational measures to ensure the protection of Your personal data.
10. NOTICE TO CALIFORNIA RESIDENCE
Under California Civil Code sections 1798.83, “Shine the Light Act”, California residents are entitled to ask Us for a notice describing what categories of personal data We share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. Please note that We do not share Your personal data with any third parties or affiliates for their direct marketing purposes.
CCPA provides consumers who are California residents with specific rights regarding their personal data.
Right to Access: If You are a California resident, You have the right to request, up to two times each year, access to categories and specific pieces of Your personal data that We collect, use and/or disclose.
Right to Delete: If You are a California resident, You have the right to request that We delete Your personal data that We collect, subject to applicable legal exceptions.
Right to Opt Out of Sale of Personal Information: As the term is defined by the CCPA, Sago Mini™ does not sell any personal data.
To make a request regarding Your rights under CCPA as described above, please send an email to privacy@playpiknik.com or DPO@spinmaster.com or write to us, using the addresses above.
11. CHANGES TO THIS PRIVACY POLICY
This privacy notice may be changed from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to You if these changes are material and, where required by applicable law, We will obtain Your consent. The notice may be sent to You by email to the last email address You provided Us with, by posting notice of such changes on Our sites and applications, or by other means, consistent with applicable law. The date of the last modification is stated at the top of this document.
12. Children’s Privacy Policy
For the Children's privacy policy, you can see it
If you would like to review or delete your or your child’s information, request information regarding our apps, or our suppliers and service providers, please contact us at privacy@playpiknik.com.
13. KIDS PRIVACY ASSURED BY KIDSAFE: COPPA SAFE HARBOR CERTIFICATION
The Sago Mini and Toca Boca Apps listed below are COPPA certified by the kidSAFE Seal Program. The kidSAFE Seal Program is a popular safety certification service and seal-of-approval program designed exclusively for children-friendly websites, mobile apps, and connected technologies. kidSAFE is also an FTC-Approved COPPA Safe Harbor program. Click on the seal or go to for more information.
