This policy was last updated November 7, 2023.
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 policy is designed to share the information we collect and how we use it. This notice describes Originator’s privacy policy for the Cubric app (“Cubric”) 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 Cubric, you understand and accept this Privacy Policy. Your continued use of Cubric 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 Cubric.
If you don’t agree with this Privacy Policy or the Terms of Use, you should not use Cubric.
For the purpose of this Privacy Policy personal data means information that relates to an identified or identifiable natural person.
In the sections and tables below we indicate:
Here is a general explanation of each legal basis to help you understand the table:
Account creation is optional on Cubric. We do however want to inform you that when playing as a guest we assign a unique internal identifier to your device (Cubric User ID). This is done in order to make sure that we can connect your previous progress and designs within the app to your account should you decide to create one. If you decide to create a Cubric account this information will be transferred to your Cubric account.
When you create a Cubric account, we will ask you to choose a unique username and password in addition to providing an email. We require this information so that you can log into your account and participate in various game features (multiplayer, parent control emails, voice chat, cross-device access, and purchasing).
You must not create a username that includes your real name or other personal information. It is also important to create a password that is not easy to guess. You may share your password with your parent(s) or legal guardian, but never share it with anyone else, not even your friends.
The primary purpose for the collection of the email address is to provide account security, since this is the only way for Cubric to check the authenticity of an account owner. In this circumstance, children (under the age of 16) are required to provide a parent email address. Email addresses are also used to inform the parent or guardian about their child's activity, provide consent for the collection of the child's personal information, and enable other features that require email. Users may change the email address associated with their account at any time; however, a notification will be sent to the previously provided email address upon making that change.
To protect our users that are children we ask for your year of birth to understand how old you are so that we can provide you, parents and legal guardians with different safety measures. We do not store this information.
When you create a Cubric account in the Cubric app, the same login credentials can be used across multiple devices so that you can continue your player journey on your preferred device at the moment without losing any progress or achievements.
We collect the following data from you, for the following purposes when setting up a Cubric account:
|
What we use your personal data for |
Legal basis allowing the purpose |
Categories of personal data used for the purpose |
|
To create an account for the Cubric App |
Our legitimate interest |
|
|
To send out emails for parental consent |
Legal Requirement |
|
We collect the following information when you install and/or use the Cubric app:
|
What we use your personal data for |
Legal basis allowing the purpose |
Categories of personal data used for the purpose |
|
To provide you with the service |
Contract |
Unique Identifiers such as:
Technical data such as
|
|
To understand how you play the app
Cubric - Analytics
Process players' in-app activity in order to answer questions relating to the performance of our app and our business. These include
|
Our Legitimate Interest |
Unique Identifiers such as:
Technical data such as
|
|
To understand what went wrong - Crash Reports and Analytics |
Our Legitimate Interest |
Information tied to following IDs:
|
|
When you make a purchase |
Contract |
|
|
Account Linking - You are able to log on to your account across different devices so that any purchase and in-game progress will be transferable cross devices. |
Contract |
Unique Identifiers such as:
Technical data such as
|
|
Multiplayer and Voice Chat |
Legitimate interest |
Unique Identifiers such as:
|
|
What we use your personal data for |
Legal basis allowing the purpose |
Categories of personal data used for the purpose |
|
When you reach out to our customer support |
Contract |
|
|
What we use your personal data for |
Legal basis allowing the purpose |
Categories of personal data used for the purpose |
|
User attribution and market analytics |
Consent |
Only for users above 16 that have consented to the processing Technical Identifiers such as:
|
We collect and process personal data directly from you when you:
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, parental control emails, multiplayer game experience, and payment processing.
For these purposes we are engaging the services of the following service providers:
Zendesk (https://www.zendesk.com/company/agreements-and-terms/privacy-notice/)
We use the following third-party analytics providers and advertising partners in relation to users that are over 16 years only:
We use the Appsflyer (appsflyer.com/privacy-policy) attribution platform to record installs of our apps in relation to the over 16 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.
If you have questions about third party use of data, please contact us at info@originatorkids.com.
You can contact our Data Protection Officer at:
Attn: Data Protection Officer
Spin Master Ltd
225 King Street West Toronto,
ON M5V 3M2, Canada
Friend Multiplayer Mode:
We offer the ability for users to play with their friends in the Friend Multiplayer mode in the app. This mode is a strict friend experience that does not allow for users to play with other people they do not know. Cubric allows players to communicate with their friends using voice chat while playing the app in this mode. While playing in friend multiplayer mode, if you use the voice chat functions in Cubric, any personal information said aloud will be available to others playing in your world at that moment. We are not responsible for how other individuals use the information they receive in this manner. Cubric strives to be a safe space for all its users, so we strongly recommend that you do not share any personal information about yourself (including your real name, where you live, or your email address) with anyone while using Cubric.
This voice chat feature is enabled using a third-party provider, Photon. Voice conversations are not stored locally or on servers, and we have no control over what is said or heard during these conversations. The voice chat feature is only available to users who create a Cubric account with the help of a parent and can be turned off at any time. To make sure that we provide you and our younger players with a safe experience we have the following safeguarding measure in place:
Anonymous Multiplayer Mode:
We also offer the ability for users to build small virtual plots on their own and with their friends and then share them in an Anonymous Multiplayer mode. In this mode, users can play with other players who are not their friends, with each player sharing their virtual plot with each other in a common world. There is no voice chat in this mode, and communication is done through safe, premade text chat and emoticons.
To make sure that we provide you and our younger players with a safe experience, we have the following safeguarding measures in place:
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. The personal data we collect from or about children is used to give them access to certain features of the app and communicate with a parent or legal guardian about the child’s registration, including for the purpose of verifying their information in connection with the registration. 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.
Children may register an account with us using a registration process similar to the one users over 16 go through; however, in compliance with COPPA (the Children’s Online Privacy Protection Rule) and GDPR (the General Data Protection Regulation), children will first be subject to a parental notice and consent process prior to activation of their account. To initiate the registration and consent process for a Child, we collect a parent or legal guardian’s email address.
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):
Cubric allows children to build their own 3D world using blocks and other digital items (e.g. virtual furniture). We have no control over what children create. This content is saved locally on the device and on a server (to save the state of the world and to allow play across multiple devices).
A parent or legal guardian may, anytime when convenient for them, review their Child’s personal data maintained by us. A parent or legal guardian may also require us to correct or delete any such personal data, request that we delete their Child’s account, and/or refuse to permit us from further collecting or using their Child’s 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.
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:
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:
The information we maintain may be stored both within and outside of the European Union. 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 European Union, 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 no longer can connect the data with any individual.
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;
We also identify and use additional protections as needed for each data transfer. For example, we use:
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 for you.
If you would like to access, correct, erase or limit the use or disclosure of any personal data about you that has been collected and stored by Toca Boca 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.
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 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 Toca Boca’s processing of personal data relating to you infringes the GDPR.
Right to withdraw consent: If a 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: 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 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 contact our DPO at DPO@spinmaster.com. Or write to us, using the addresses stated in this Privacy Policy below.
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.
This policy was last updated March 03, 2023.
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 and we have your email address, we may contact you to notify you before making the changes. You should review the Privacy Policy frequently.
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 © 2023 Originator Inc. All rights reserved.