PAW Patrol: The Game App – Privacy Policy

About Our Privacy Policy

Hello! Welcome to the Originator Inc. Privacy Policy.

Originator Inc. ("Originator"), a subsidiary of Spin Master Ltd., develops and publishes the most entertaining and educational mobile apps for kids and families. As we create truly meaningful digital experiences beloved and respected by kids, parents, and educators, we are also committed to protecting your privacy. We take privacy seriously at Originator, and this Privacy Policy explains how we collect, use, and process data collected from our users. This notice describes Originator's privacy policy for the PAW Patrol: The Game™ app ("PP: TG"), which is developed and distributed by Originator. We may revise this privacy policy at any time, and the date of last revision will be available at the top of this page. By using PP: TG, you understand and accept this Privacy Policy. Your continued use of PP: TG after changes have been posted to the Privacy Policy will constitute your acceptance of such changes.

This Privacy Policy is also part of the Terms of Service that explain your and Originator's rights and responsibilities as part of your use of PP: TG.

If you don't agree with this Privacy Policy or the Terms of Use, you should not use PP: TG.

If you would like specific information about how our privacy policy impacts children, please see our children's privacy section.

Information We Collect

For this Privacy Policy, personal data means information that relates to an identified or identifiable natural person.

In the sections and tables below, we indicate:

• What personal data we collect
• What we use your personal data for
• Our legal justifications (each called a "legal basis") under the General Data Protection Regulation for each purpose
• The categories of personal data we use for each purpose.

Here is a general explanation of each legal basis to help you understand:

Contract with the data subject: Where it is necessary for PP: TG (or a third party) to process your personal data to:

• Fulfill obligations under a contract with you. This includes Originator's obligations under the Terms of Service to provide the PP: TG app to you.
• Verify information before the start of a new contract with you.

Legitimate Interest: Where Originator or its Affiliates or a third party 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 PP: TG users. For example, we may use your usage data to improve the PP: TG app for all users. Contact us if you want to understand a specific legitimate interest.

Consent: When Originator asks you to actively consent to use your personal data for a specific purpose.

Legal obligation: When Originator needs to process your personal data to comply with legal requirements.

We collect the following information when you install and/or use the PAW Patrol: The Game app:

Analytics

What we use your personal data for

In order to understand how you use our app, so that we can answer questions relating to the performance of our app and our business. These include:

• User experience
• User engagement with different parts of the app
• Purchasing behavior
• Improvement of functionality
• App technical performance
• Business performance
• Number of active users
• A/B test results

Legal basis allowing the processing

Our Legitimate Interest

Categories of personal data used for the processing

• Unique Identifiers such as:
  • MixPanel ID
  • Device Language
• Technical data such as:
  • Time spent in the app
  • Game progress
  • Device type and operating system
  • Mobile Phone Carrier
  • Purchases

Crash Reports and Analytics

What we use your personal data for

To understand what went wrong.

Legal basis allowing the processing

Our Legitimate Interest

Categories of personal data used for the processing

• Information tied to the following IDs:
  • System Environment Variables
  • Event Information (for example, where in the game the crash occurred)

When you make a purchase

Legal basis allowing the processing

Contract

Categories of personal data used for the processing

• Subscription Purchased
• Amount paid
• In-game items

We Collect the Following Information when you Contact our Customer Support

What we use your personal data for

• To provide you with support
• To gain insights into how we can improve our products and services
• To act according to applicable law in responding to consumer complaints
• To fulfill the agreement we have made with you regarding your purchase from us

Legal basis allowing the processing

Our Contractual Obligation

Categories of personal data used for the processing

• Your Name
• Email Address
• User ID
• Subscription / Purchase data
• Technical data and information about technical issues
• Product questions/complaints
• General questions
• Other information or content regarding the reason for your contact

Information We Collect for Performance Marketing

What we use your personal data for

User attribution and market analytics

Legal basis allowing the processing

Legitimate Interest

Categories of personal data used for the processing

• Technical identifiers such as IP address

We Collect the Following Information When You Sign Up for Digital Marketing Communications (e.g., email, cross-promotion, or similar direct marketing)

What we use your personal data for

• Subscribe to one of our digital marketing communications
• When we cross-promote our own Services within our apps

Legal basis allowing the processing

Your Consent and Our Legitimate Interest

Categories of personal data used for the processing

• Your email address
• Your first name
• Your last name
• Information on what other Services you have with us

We Collect the Following Information when you Interact with Third-Party Social Networking Features

What we use your personal data for

When you interact with one of Originator's social networking features (such as like buttons, comments, etc.).

Please note that the social media platforms may use personal information collected from the Originator's social network account on their platform for their own purposes, as described in their own privacy policies.

Legal basis allowing the processing

Our Legitimate Interest

Categories of personal data used for the processing

• Information you have made available, which may include:
  • Demographic information about you and where you live
  • Your comments, reactions, sharing of our social media account posts
  • Other user-generated content
  • Analytical performance data for social media posts and digital ads

We Collect the Following Information when you Participate in Research Surveys, Focus Groups, Other Research Activities, or Provide Feedback on our Apps

What we use your personal data for

• To improve our existing products and services
• To develop and improve new products

Legal basis allowing the processing

The performance of a contract, or our Legitimate Interest if you voluntarily have provided us with your information.

Categories of personal data used for the processing

• Your email address
• Your first name
• Your last name
• Photos or videos (if the research is conducted in such a manner that this is shared/collected)
• Other personal information you provide us with

How We Collect, Process, and Share Your Information

We collect and process personal data directly from you when you:

• Play the app
• Request technical support
• Sign up for a newsletter
• Participate in a Research Activity
• Contact our Customer Support

We are using service providers to help us collect and process some of your personal data. Although we are using the services of these providers, these providers are acting as our processors, only processing your personal data as we instruct them to, unless you have given your direct consent for us to share the information with them.

The purposes of collecting this information can be for functions such as technical support, ad attribution, transactional or marketing emails, and payment processing.

For these purposes, we are engaging the services of the following service providers:

• Zendesk
• MixPanel
• Unity
• AppsFlyer
• Google Firebase
• Microsoft Azure

We use the Appsflyer attribution platform to record installs of our apps in relation to the mixed audience experience, as well as to track in-app events.

We may share users' information, including Personal Data, with our third-party agents, contractors, or service providers who are hired to perform services on our behalf. We may also share your information with your affiliates. We disclose necessary information to data protection authorities and other authorities if we are required to do so by law, or under some circumstances if you have requested us to do so.

We work very closely with our affiliates from the Spin Master Ltd. corporate group. This means that we may transfer personal data to the following legal entities, such as Sago Sago Toys Inc., Toca Boca, and Spin Master.

If you have questions about third-party use of data, please contact us at info@originatorkids.com.

How we Collect and Process Children's Information in our apps

A "Child" is a person under the age of digital consent as designated in each jurisdiction.

We believe it is important to provide added protection for children online. We encourage parents and guardians to spend time online with their children to observe, participate in and/or monitor and guide their online activity. We do not share or otherwise disclose children's personal data, except for the following purposes:

• as may be necessary to protect the safety of a Child, including by disclosing their personal data, where appropriate, to law enforcement agencies or for an investigation related to public safety;
• to enable us to take precautions against liability;
• to protect the safety and security of the app; or
• where required to do so by law or legal process.

We collect personal data from the following third-party analytics providers. These providers do not share user data with any third parties; they are used to support the operation of our app (and their respective privacy policies are noted below):

• MixPanel (https://mixpanel.com/legal/privacy-policy) is used to assess how users are playing and progressing through the game
• Unity (unity3d.com/legal/privacy-policy) - is used as our game development platform and subscription purchasing handling
• AppsFlyer is used for marketing attribution
• Microsoft Azure is used to host our services
• Google Firebase (https://firebase.google.com/support/privacy) - is used to create your account, monitor crash analytics, and A/B testing

A parent or legal guardian may, at any time, review their child's personal data maintained by us. A parent or legal guardian may also require us to correct, prevent further collection or use, or delete any such personal data. If you, as a parent or legal guardian, want to exercise any of your rights, please contact us using the email address provided in the section How To Contact Us below. To protect parents and legal guardians' privacy and security and the privacy and security of Children, we may require a parent or legal guardian to take certain steps or provide additional information, which we will keep strictly confidential, to verify their identity before we provide any information about the Child or make any corrections.

Originator will notify and obtain consent from a parent before collecting or using a child's personal information for significantly new purposes not previously consented to by the parent.

How We Use Your Information

We work with companies that follow our agreements with them, in which they agree not to use your information for any other purposes.

We use the information we collect to:

• Manage your account
• Provide technical support
• Understand your use of our app
• Help us operate, analyze, and improve our services
• Contact you about new services and features

How We Store Your Information

Originator uses generally accepted security measures and safeguards to keep the data it collects secure. We require that the third parties we work with do the same.

These measures and safeguards include:

• Limiting access to data to those persons who need it to complete their work for Originator
• Using a firewall-protected environment
• Storing personal information in secure operating environments

Where We Store Your Information

The information we maintain may be stored both within and outside of the European Union (EU). As part of the services and products we offer and the third-party services we use, the information you provide to us may be transferred to countries outside these areas.

If we transfer your information outside of the EU, we will take appropriate steps to ensure that any personal data relating to you will continue to be adequately protected by using the case-by-case applicable transfer mechanism in accordance with privacy legislation.

How Long Do We Keep Your Data?

We will retain your personal information for as long as necessary to provide our services to you or as required by law or for as long as we see the need for us to have them for the practices described in this Privacy Policy. We will also keep information as otherwise required by law.

After that period of time has passed, your personal data will be deleted or anonymized so that we can no longer connect the data with any individual.

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 data. We strive to take appropriate technical and organizational measures to ensure the protection of your personal data.

Third Country Transfers

In some cases, Originator might transfer personal data outside the EU, so-called third countries (countries outside of the European Economic Area). Such transfers can be made if any of the following conditions apply;

• The European Commission has decided that there is an adequate level of protection in the country in question, or
• Binding Corporate Rules (BCR) are in place (for inter-company transfers); or
• Standard Contractual Clauses (EU model-clauses) are used; or
• 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
• transfer impact assessments

Your Rights

Under the GDPR and the UK GDPR (United Kingdom General Data Protection Regulation), you have certain rights concerning the processing of personal data by us. The following rights may be applicable to you.

If you would like to access, correct, erase, or limit the use or disclosure of any personal data about you that has been processed by Originator or exercise any other right under applicable data protection legislation, please notify us at info@originatorkids.com so that we may consider and respond to your request in accordance with applicable law.

You can also erase your personal data and all account information from your PAW Patrol: The Game account yourself by accessing the Delete Account feature from the Account tab in the Parents' Section.

If you want to contact our Data Protection Officer directly, you can do so at dpo@spinmaster.com.

• Right of information: You have the right to be provided with information regarding the processing of your personal data by us.
• 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, access to the 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, you have the right to obtain the erasure of personal data concerning you.
• Right to restriction: Under certain circumstances, you have the right to obtain the restriction of processing.
• Right to data portability: Under certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit this data to another controller.
• Right to object: Under certain circumstances, you have the right to object to the processing of personal data concerning you. This includes but is not limited to the right to object in cases in which we process your personal data based on legitimate interest.
• Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority if you consider that Originator's processing of personal data relating to you infringes the GDPR.
• Right to withdraw consent: If the processing of your personal data is based on your consent as set out, you have the right to withdraw your consent at any time.
• Right to not be subject to a decision based solely on automated processing, including profiling: 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.

Notice to California Residents

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Originator to third parties for the third parties' direct marketing purposes. With respect to these entities, this Privacy Policy applies only to their activities within the State of California.

California Consumer Privacy Act of 2018 (CCPA) provides consumers who are California residents with specific rights regarding their Personal Information.

• 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 personal information about you 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 personal information that we collect from you, subject to applicable legal exceptions.
• Right to Opt Out of Sale of Personal Information: As the term is defined by the CCPA, Originator does not sell any personal information.

To make a request regarding your rights as described above, please send an email to us at info@originatorkids.com. Or write to us, using the addresses stated in this Privacy Policy below.

Legal Disclosure

As we have disclosed, we collect the minimum possible personal data from you that we need in order to provide our services and products to you. In addition, we may disclose your personal or non-personal information to additional parties if we believe we are required to by law, by a judicial proceeding, to protect Originator's rights and properties, or to investigate fraud, intellectual property infringement, and any other conduct that might be illegal or expose Originator or a user of its services to legal liability.

In addition, Originator may disclose your information in the event of a change or proposed change in the ownership of the company; for example, a sale, a merger, or a bankruptcy.

Changes to our Privacy Policy

Originator may change or update this Privacy Policy at any time as we add new or different features, or as the law changes. Unless another date is given, the changes are effective upon posting. If we make a material change to this policy, users will be notified before collecting or using a child's personal information for significantly new purposes. You should review the Privacy Policy frequently.

How to Contact Us

If you have questions, please contact us at info@originatorkids.com or call us at 1-800-622-8339.

You can also write to us at:

Originator Inc.
809 Laurel Street #12
San Carlos, CA 94070
USA

You can contact our Data Protection Officer at:

Attn: Data Protection Officer
Spin Master Ltd
225 King Street West, Toronto,
ON M5V 3M2, Canada
Or by email at DPO@spinmaster.com

Copyright © 2025 Originator Inc. All rights reserved.