Privacy Policy

Effective: October 26, 2022

This Privacy Policy (“Policy”) describes how the JAKKS Pacific, Inc. family of companies, including Disguise, Inc. and JAKKS Sales LLC(collectively, “JAKKS,” “we,” “us,” and “our”) collect, store, process, and share personal information. This Policy also explains the controls available to you regarding how JAKKS collects and processes your personal information. When we say “you” or “your,” we are referring to any person or entity who views, uses, accesses, browses, or submits any content or material to JAKKS. “Personal Information” may include information that is connected to you, such as data that you provide to us voluntarily (e.g., name, e-mail address, shipping and billing address, telephone number, username, personal images, etc.) and information that we collect automatically from you (e.g., location data and other online identifiers). This Policy is not applicable to websites, applications, or platforms owned or operated by third parties, even if this website (“Site”) redirects you to, or we communicate with you directly on, those sites. For example, a post made on Facebook or Twitter is governed by the policies of those websites alone.

Policy Changes
JAKKS reserves the right to modify this Policy at any time. If changes are material, JAKKS will provide notice to you and, where required by applicable law, obtain your consent. Notice may be sent by email to the last email address you provided to us, by posting notice of those changes to this Policy on our Site, or by other means we deem appropriate. Please check back periodically for up-to-date information about our privacy practices.

Data Collected
JAKKS may collect Personal Information in one of two forms. First, JAKKS may collect information that you submit to us, such as by placing an order, registering a product, creating an account, subscribing to a mailing list, completing an online form, or by emailing us directly. Additionally, JAKKS, directly or through a third-party, may collect anonymous data from your computer, phone, or other device. This data is collected automatically and it cannot be linked to an identifiable person unless and until you submit your information to us.

Data Collected Automatically

• Automatically collected data generally includes:
• Identifiers, including IP address;
• Site activity (e.g., history of visiting and interacting with our services, browser type, browser language, etc.

Geolocation data;

• The URL of the website you visited before navigating to our Site; and
• Information about your product preferences or interests

Data Submitted to JAKKS
We may collect information you submit to us such as:

Other Tracking Technologies

We may use cookies (data that a website or application transfers to a user’s device for record-keeping purposes), or similar technologies like pixels and web beacons, to collect this anonymous information to support our digital operations. A “web beacon” is a one-pixel image (that may be visible or transparent), which may be embedded on a web page or e-mail message, and which may also provide us with information about usage of that page or e-mail message. As a user moves from one page or one screen to another, a cookie is used to tell us that it is the same device. We also may use a cookie to keep track of your selections. You may set your device to accept or not accept cookies and you may delete any cookies that you have received. However, should you decide to disable any cookies we place on your device, you may not be able to use certain services or features on our Site.

Additionally, we may use adverts to offset the costs of running this Site. To ensure that we provide you with the most relevant adverts where possible, adverts may anonymously track your interests and present items or information that may be of interest to you. We may also use social media (e.g., Twitter, Facebook, Instagram, and YouTube) buttons and/or plugins on this Site so that you may connect with your social network. These social media sites will set cookies through our Site, which may be used as outlined in their respective privacy notices. Some browsers have a ‘do not track’ feature, which tells websites not to track your online activities. These features are not yet uniform, and our Site is not currently designed to respond to those signals.

Why Does JAKKS Collect and Process Information?

Automatically collected Personal information is used to support our digital operations, such as:

• To adapt content to the browsers used by our visitors;
• To diagnose and fix technology problems;
• To identify popular products and activities;
• To learn how visitors navigate to our Site (i.e., the pages visitors entered our Sites and the pages viewed);
• To monitor Site traffic and total number of Site visitors; and
• To learn the general geographic region of our visitors

We also collect information about you so that we may complete your order efficiently, provide you with order updates, communicate offers that may interest you, or meet our business objectives (e.g., to improve our products, enhance customer service, and conduct internal marketing and demographic studies). JAKKS may also use this information to investigate or prevent activities that may violate our policies or the law, or to defend our legal rights.

With Whom Does JAKKS Share My Information?
We may share Personal Information and non-Personal Information with our subsidiaries, business partners, company affiliates, and third-party service providers, but only as necessary to further our business interests. We do not disclose your Personal Information, except as noted in this Policy, as required by law, or in connection with a merger, asset sale, or similar business transaction. , or to protect our legal rights

JAKKS may share your Personal Information in the following circumstances:

• Information collected from third parties. We may use information, such as demographic data (e.g., household size) and purchase preference information, to supplement or update our records, improve our communications to you, or to prevent or detect fraud.
• Disclosure to Affiliates. JAKKS may share certain Personal Information with its affiliates to further our legitimate business interests.
• Service providers. JAKKS participates in, has certified its compliance with, and is responsible for processing Personal Information it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on JAKKS’ behalf.

  We also may share your Personal Information with third party service providers that perform services for us (e.g., to operate this Site, fulfill orders, gather user analytics, provide online services, deliver packages, send postal mail and e-mails, provide marketing assistance, process credit card payments, investigate fraudulent activity, conduct customer surveys, provide customer service, etc.). These third party service providers are contractually obligated to protect the security and integrity of any information we share with them. JAKKS remains liable under Privacy Shield principles if its agent processes such Personal Information in a manner inconsistent with those principles, unless JAKKS proves that it is not responsible for the event giving rise to the damage.

• Social Networks, Widgets, and Plug-ins. This Site may use third party social media widgets (such as buttons or similar mechanisms from Facebook, Twitter, Instagram, and YouTube) that collect information about you and place cookies on your device. These social media widgets are either hosted by a third party or by our Site. Your interactions with those features are governed by the privacy policies of the third party social media networks that provide them. Where JAKKS reposts information that you shared through those third-party social media sites, JAKKS may also retain that information consistent with this Policy.
• The public. JAKKS may share the Personal Information that you submit through one of our interactive services, like Ratings & Reviews, with the general public or our affiliates. You may voluntarily disclose your own Personal Information when you leave product reviews. Review your content before submitting a review.
• Other instances. JAKKS may share your Personal Information in order to comply with requests by law enforcement; protect the legal rights of our company, our employees, our agents, and our affiliates; to protect the safety and security of our visitors; to detect and protect against fraud; and to comply with law or legal process.
• Business transition. We may disclose your Personal Information and other information to a potential or actual buyer or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us is among the assets transferred. In such event, our transfer or license (whether by contract, merger or operation of law) of rights to your Personal Information, in whole or in part, and other information may be disclosed with or without further notice to you and without your further consent.

JAKKS may also share non-identifiable information in the following circumstances:

• Aggregate information. We may share your non-identifiable aggregated, de-identified, or anonymized information with advertisers and marketing partners.
• Interest-based advertising. Third-parties may use technology (i.e., cookies) to collect information about your use of our Site and other websites so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on our or other websites. If you opt-out of interest-based ads, you may still see ads on websites you visit, but those ads will not be based on your browsing behavior.

Collection and Use of Children’s Personal Information
Children’s privacy is important to us. JAKKS complies with the Children’s Online Privacy Protection Act of 1998 (“COPPA”) and follows guidelines provided by the Children’s Advertising Review Unit of the Advertising Self-Regulatory Council. Children under the age of 13 (“Child” or “Children”) may view this Site, but should not make a purchase, register, or submit Personal Information to us without prior parental consent.

JAKKS will obtain parental consent before asking for personal information on our Children’s Platforms, unless the request for information falls within an exception that would be permitted under COPPA. We will not condition a child’s participation in any activity or service on the disclosure of more personal information than is reasonably necessary to participate in an activity.

Please refer to the sections entitled “Why does JAKKS collect Personal Information” and “Who Does JAKKS Share My Information With?” for further details on the information we collect and the tools we use to collect it.

Parental Rights
Parents may contact us (at privacy@jakks.com) to review, update or delete any of their children’s personal information that we may have collected and to elect for us not to collect any additional personal information from their children.

If JAKKS discovers that it has unintentionally collected Personal Information from a Child that does not meet COPPA requirements, we will either delete the information or ask the parent or guardian for consent for us to retain the information.

How Does JAKKS Protect Your Information?
We have implemented various security practices regarding the collection, storage and processing of Personal Information. We also limit access to the data as reasonably necessary, and we adhere to strict confidentiality policies with our employees and contractors. While we strive to ensure the integrity and security of our network and systems, no security measure is ever perfect, and JAKKS cannot guarantee that our security measures will prevent third party hackers from illegally obtaining this information.

International Transfer, Storage, and Processing of Personal Information
Because JAKKS is an international company, we may transfer your Personal Information to individual subsidiaries of JAKKS or to third parties in locations around the world, as set forth in this Policy. Some of these countries may not offer the same level of data protection as the laws in your country of residence. JAKKS will take reasonable steps to protect your Personal Information by remaining compliant with the European Union’s Global Data Processing Regulation (“GDPR”) and JAKKS’ Privacy Shield certification prior to transfer.

You may choose whether your Personal Information is (1) disclosed to a third party or (2) used for a purpose that is materially different from the purpose(s) for which your Personal Information was originally collected or authorized by you. To exercise any right granted herein, contact us at the methods listed in the “Contact Us” section below.

JAKKS complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, transfer, and retention of Personal Information from Site visitors and residents of the United Kingdom and European Union member countries. JAKKS has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Privacy Principles (“Principles”) of notice, choice, onward transfer accountability, security, data integrity and access limits, access, recourse, enforcement, and liability, with respect to such information. If there is any conflict between the policies in this Policy and the Principles, the Principles shall govern. JAKKS will cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship. Additionally, JAKKS remains subject to the investigatory and enforcement powers of the Federal Trade Commission.

This Policy, its assurances, and JAKKS’ Privacy Shield certification apply to all JAKKS’ subsidiaries. To learn more about the Privacy Shield program, and to view our certification page, please click here. The list of organizations which are on the Privacy Shield List is here. The U.S. Federal Trade Commission (FTC) has jurisdiction over JAKKS’ Privacy Shield compliance.

How Long Does JAKKS Retain Your Information?
JAKKS may keep your Personal Information for the longer of as long as it is needed to provide you with access and enjoyment of this Site, for our legitimate business interests, or to comply with legal and regulatory obligations. Where we no longer need your information for any of the above reasons, or are not required to retain it, we endeavor to delete it. If you want to cancel your account, or want JAKKS to delete your Personal Information, JAKKS will do so and will only keep information that we are required to maintain for legal reasons. Contact privacy@jakks.com with any such request.

Automated Decision-Making
JAKKS does not currently use automated decision-making as it relates to your Personal Information. However, if JAKKS begins to use automated decision-making, you have the right to object to processing of your information in such a manner, where the decision-making process does not involve a human, only when that decision-making affects you legally or significantly (i.e., a decision that affects your civil rights, employment or rights under a contract).

United States Privacy Rights
You have the following choices with how your information is used:

Do Not Sell My Personal Information

Additional Disclosures for CALIFORNIA RESIDENTS ONLY

The California Consumer Privacy Act (“CCPA”) provides additional rights to California residents only.

Data Collection : In the past 12 months, we or our service providers may have collected certain categories of Personal Information (as defined above) about you. For more information, including the sources of the information we collect, see the sections titled “Data Collected” and “Why Does JAKKS Collect and Process Information?”

Right to Opt-Out : California residents have the right to opt out of the sale of Personal Information to third parties. JAKKS does not “sell” information as we currently understand that term to be defined by the CCPA and its related regulations. To the extent that “sell” is interpreted to include any of the activities described in the “Who Does JAKKS Share This Information With?” section, JAKKS will comply with applicable law. (See the “Contact Us” section below.)

Right to Know and Delete : California residents have the right to request that we delete Personal Information collected about them and to know certain information about our data practices in the prior 12 months. Specifically, Californians have the right to request the:

· Categories of Personal Information we have collected about you;

· Categories of sources from which the Personal Information was collected;

· Categories of Personal Information disclosed for a business purpose or sold;

· Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose;

· Purpose for collecting or selling the Personal Information; and

· Specific pieces of Personal Information we have collected about you.

• Authorized Agent : You can designate an authorized agent to submit requests on your behalf. However, we may require written proof of the agent’s permission to do so and verify your identity directly.
• Right to Nondiscrimination : You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
• Shine the Light : California residents may request certain information regarding our disclosure of Personal Information to our affiliates and third parties for their own direct marketing purposes.
• Contact : To exercise any of these rights, please see the “Contact Us” section and specify which right you seek to exercise and the scope of the request. We may require additional information from you to help us verify your identity and process your request. If we do not have adequate information to permit us to verify your identity, we may deny your request to know or delete.
• CalOPPA : This Policy also adheres to the California Online Privacy Protection Act (CalOPPA). If you are a California resident under 18 years old, and a registered user of the Site, you may request that we remove content or information that you have posted to our Site or other online services. We cannot ensure complete or comprehensive removal (e.g., where the content or information has been reposted by another user).

ADDITIONAL PRIVACY RIGHTS FOR UNITED KINGDOM AND EUROPEAN SITE VISITORS ONLY

If you are a user or a citizen of the United Kingdom or a European Economic Area only, you have the following rights, in addition to those detailed in this Policy:

• Right to access or correct —the Personal Information that JAKKS holds about you
• Right to refusal –of the processing of your Personal Information
• Right to be informed –about how your Personal Information will be used
• Right to restrict processing –of your Personal Information where it is objected to or inaccurate
• Right to be forgotten – the right to request deletion of your Personal Information

Even if you opt out of receiving marketing communications from us, we may still contact you for transactional purposes.

Your Right to an Independent Recourse Mechanism

In compliance with Privacy Shield Principles, JAKKS commits to resolve complaints about our collection or use of your Personal Information by first contacting JAKKS at privacy@jakks.com.

If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit http://go.adr.org/privacyshield.html for more information or email casefiling@adr.org to file a complaint. The services of ICDR-AAA are provided at no cost to you. Under certain conditions, more fully described on the Privacy Shield website , you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

To Opt Out of JAKKS Communications

• Email. All bulk emails that may be sent by JAKKS will have a link that will allow you to remove your contact information from our mailing lists. If you would like to stop receiving promotions, you may also email us at privacy@jakks.com .
• Text messages. JAKKS may distribute mobile coupons and other text messages to devices of guests who request this information via an opt-in request. To opt out of text messages, reply “STOP” to text messages.

Contact Us

For questions or concerns about this Policy or to exercise any right granted, contact us at any of the below:

JAKKS Pacific, Inc.

Consumer Relations

2951 28th Street

Santa Monica, CA 90405

877-875-2557 (toll-free, North America only) or 1-909-594-7771 Monday – Friday, 7:30 AM – 5:00 PM Pacific Time (GMT – 8), excluding holidays
privacy@jakks.com