PRIVACY POLICY FOR BEN AND HOLLY® ONLINE SERVICES

Last modified and effective as of 25 November, 2016

Welcome to the Ben and Holly’s Little Kingdom® website (the “Ben and Holly Site”), which is operated by Entertainment One UK Limited (“eOne,” “we” or “us”). We are committed to protecting your privacy.  This privacy policy explains our practices regarding collection, use, and disclosure of personally identifying information of yours and/or personally identifying information of your children (collectively, “your PII”) that you may provide to us through the Ben and Holly Site and/or Ben and Holly mobile applications (collectively, “Ben and Holly Online Service”).  It also provides you with details about your rights to control your PII.

Our legal status is that of a "data controller" and in this capacity we will securely store and process your/your children’s personal information which you/your children have provided to us.  Data controller is a legal term used in EU legislation to signify the person who controls what to do with any given personal information.  We are registered as a data controller with the Information Commissioner’s Office (registration number Z9919769).

Who is eOne?
eOne is a company registered in England and Wales (registration number 02989602), whose registered office is at 45 Warren Street, London, W1T 6AG.

We respect your right to privacy and will only process PII that you provide to us in accordance with the applicable privacy laws, including the U.S. Children’s Online Privacy Protection Act (COPPA).  To learn more about COPPA, you may consult this simple one-page information guide from the kidSAFE Seal Program: www.kidsafeseal.com/knowaboutcoppa.html.

Where is PII collected on the Ben and Holly Online Service?

The Ben and Holly Online Service may contain websites and mobile apps directed to children, including young children between the ages of 2 and 5.  It contains a children’s section (the “Children’s Area”) and a parents’ section (the “Grown-Up Area”).  In the Children’s Area, children mainly participate only by playing games, reading e-books and watching videos. We generally do not offer any place in the Children’s Area where a child can sign up or enter PII. Typically, the only part of the Ben and Holly Online Service where anyone can enter information is the Grown-Up Area.

Accordingly, in most cases, we do not anticipate that we will be collecting PII directly from any children.  We anticipate and assume that we will be collecting PII only from parents. If we do learn that a child under the age of 18 has provided PII on the Ben and Holly Online Service, we will not process any PII of that child without the prior consent of that child’s parent or guardian in accordance with COPPA.

What PII do we collect on the Ben and Holly Online Service?

Actively, meaning, you knowingly provide it to us:

•    When you sign up for the Ben and Holly Online Service from the Grown-Up Area, we may ask you for your first and last name, e-mail address, and country, and for your child’s first name, birthday, and gender. 
•    When you sign up your child for a competition on the Ben and Holly Online Service, we may ask you to provide your child’s first name, birthday and gender, and whatever other information that particular competition requests.
• When you make a purchase or sign up for a subscription on the Ben and Holly Online Service, which may require that you provide certain credit card or financial information to us or the payment provider processing the transaction on our behalf.
•    Passively, through cookies and other tracking technology (see our Cookies policy below).
•    If you access the Ben and Holly Online Service through a computer or mobile device, we may be able to identify the country in which you are located. If you access the Ben and Holly Online Service through our mobile app icon, we may collect more specific geolocation information.  If this information is collected from a child user, we will obtain prior permission from a parent or legal guardian.
•    However you access the Ben and Holly Online Service, we may be able to identify your IP address or other persistent identifier, which uniquely identifies the computer or device that you are using to access the Ben and Holly Online Service, and we will be able to tell that someone using your computer/device has viewed particular pages of the Ben and Holly Online Service.
 
Do we collect any other kind of information through your use of the Ben and Holly Online Service?

Through cookies and other online tracking methods, we may also collect anonymised details about visitors to the Ben and Holly Online Service for the purpose of compiling, analyzing or reporting aggregate statistics. No individual person will be identifiable from the anonymized details we collect for these purposes, and such information will not be used for targeted advertising.
 
The requirements of Data Protection Laws
We regard the lawful and correct treatment of your/your children’s information by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats information lawfully and correctly. To this end we fully endorse and adhere to UK data protection legislation and in particular to the 'Data Protection Principles' set out in the Data Protection Act 1998. In particular, without your consent or first amending this Privacy Policy to reflect any change in our usage of personal information:
• we will not use your/your children’s information for any purpose that is incompatible with this Privacy Policy;
• we will only collect sufficient information for the uses set out above;
• we will endeavour to keep your/your children’s information up-to-date;
• we will not retain your/your children’s information longer than necessary unless required to do so by law;
• we will operate appropriate technical and organisational processes to protect your/your children’s information against unauthorised or unlawful access or processing and against accidental loss or destruction. The detailed measures we take are described elsewhere in this Privacy Policy; and
• we will not transfer your/your children’s information to any country unless safeguards are in place to protect your/your children’s information to the standards that apply within the EU.

How do we use cookies?
A cookie is a small data file that a website transfers to a user's hard drive when a user visits the website.  A cookie file can contain information such as a unique ID that the site uses to track the pages visited, and is a standard method of saving website user preferences.  These preferences are stored in a file on your computer's hard disk drive. 

We use “analytical” cookies to recognize and count the number of visitors to the Ben and Holly Online Service and to see how visitors move around the Ben and Holly Online Service when they’re using it.  This helps us improve the way the Ben and Holly Online Service works, for example, by making sure users find what they need easily.

The Ben and Holly Online Service may also use local shared objects, also known as flash cookies. These are pieces of data that websites which use Adobe Flash Player may store on your computer, such as game preferences or game progress.

You can set your browser to accept all cookies, to reject cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it.  Rejecting a cookie, however, may preclude you from using, or may negatively affect the display or function of, the Ben and Holly Online Service or certain areas or features of the Ben and Holly Online Service. 

To learn more about cookies, including how to enable cookies, change your browser settings and find and delete cookies on your hard drive, please refer to your web browser's help menus or visit http://ico.org.uk/for_the_public/topic_specific_guides/online/cookies.

We may also use web beacons. A web beacon is an object that is embedded in a web page or email and is usually invisible to the user but allows checking that a user has viewed the page or email.
How might we use the PII that we collect?

We, either directly or through outside data processors acting on our behalf, may use your PII for the following purposes:

•    To provide our services, activities and online content and to provide you with information about those services, activities and online content that may be tailored to your or your children’s individual tastes.
•     If you have given us consent, to send you/your children information about products and services that we think may interest you or your children. (You can unsubscribe from our marketing communications at any time.)
•    To send out newsletters to which you/your children have subscribed.
•    To contact winners of prizes in our competitions.
•    To identify you/your child as the winner of a particular competition.
•    If you have given us consent, to provide your e-mail address (if collected from a parent or other adult) to third parties to enable them to send you information about their products and services.  If you do give us such consent but later change your mind, you may contact us and we will direct any third party to whom we may have given your e-mail (with your consent) to remove your PII from their lists.
•    To complete any purchases you make through the Ben and Holly Online Service, including any subscription payments.
•    To provide you/your children with services that you request.
•    We use your IP address for session restoration, geo-based redirection (so that if you are located in the United States, you see only the United States version of the Ben and Holly Site), eCRM (electronic customer relationship management) click/open tracking (so that we can customise your visit to the Ben and Holly Online Service), and similar functions that affect your experience of the Ben and Holly Online Service.

With whom do we share your PII?

As noted above, we may share your PII (being the parent/guardian’s PII only) with our outside marketing vendor/data processor, who hosts the Ben and Holly Online Service, stores all data from the Ben and Holly Online Service for us, and sends out e-mails on our behalf, including the following entities:

• Kids Industries - http://www.kidsindustries.com/
• Cloudways - https://www.cloudways.com/en/

 
If you make a purchase on the Ben and Holly Online Service, we may share your credit-card information with an outside credit-card processor.

If you give us consent to share your PII with a third party (being the parent’s guardian’s PII only), we will disclose the PII you have authorized us to share, to that third party. We will not disclose any PII collected from any child under the age of 18 to anyone else without the consent of a parent or guardian.

If a third party acquires all or substantially all of our business and/or assets, we may disclose your PII to that third party in connection with the acquisition.

We may disclose your PII where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.

Other than as described above, we will not disclose, sell or rent your PII to any third party.
 
Can any third party track your use of the Ben and Holly Online Service?

We use Google® Analytics, for the purpose of tracking where you navigate on the Ben and Holly Online Service and in turn understanding how visitors use our service.  We do not permit anyone other than Google and its affiliates to track your use of the Ben and Holly Online Service.

We do not permit any third party to serve ads while you use the Ben and Holly Online Service.

With some browsers, it is possible for a user to activate a “Do Not Track” signal, to indicate that the user does not want to be tracked across the websites that the user visits. The Ben and Holly Site does not respond to Do Not Track signals. In other words, if you have activated a Do Not Track signal in your own browser, the Ben and Holly Site will not take any action to block tracking by Google or its affiliates of your activity on the Ben and Holly Site.
 
What rights do you have with respect to your PII?
As a parent or guardian, you also have the right to request that we review, update, correct, or delete any PII collected from your child or that we stop collecting or using any PII previously collected from your child (as applicable).

You have the right to opt out of any marketing communications that we (or any third party to whom we have disclosed your PII with your consent) may send you.

If you are a California resident, you may have the right to ask us for the names of any information brokers or any other third parties with whom we have shared your PII within the previous calendar year under California Privacy law (Cal. Bus. & Prof. Code § 22575 et seq. (“Cal-OPPA”)), and we must provide that information to you within thirty (30) days.  Please note, however, that this right may not apply if we first give you the option to opt-out from any such sharing practices.   
If you wish to exercise any of the above rights, please email us at:

familyenquiries@entonegroup.com.
 
How do we protect and maintain the integrity of your PII on the Ben and Holly Site?

We take appropriate technical and organisational measures to safeguard the personal information that we hold about you and regularly review our security measures to consider new technologies and methods, to safeguard your data.  But no Internet transmission is ever 100% secure or error-free.  In particular, e-mail sent to or from the Ben and Holly Online Service may not be secure. You are responsible for keeping any passwords for the Ben and Holly Online Service secure and for safeguarding any other passwords, ID numbers, or other special access features that you use on the Ben and Holly Online Service.

We will retain your PII for the period necessary to fulfill the purposes outlined in this privacy policy or our data retention policies unless a longer or different retention period is required by law.

The Ben and Holly Online Service may contain links or references to other websites or applications. Please be aware that we do not control such other websites/applications and that, in any case, this privacy policy does not apply to those websites/applications. We encourage you to read the privacy policy of every website or application you visit.

This website is a member in the kidSAFE Seal Program. This means that the website has been independently reviewed, certified, and/or listed by kidSAFE to meet certain standard of online safety and/or privacy, and is authorized to display the kidSAFE Seal shown. For more information visit: http://www.kidsafeseal.com/certifiedproducts/eone_peppapigholiday_app.html


Whom should I contact if I have any questions about this privacy policy?

If you have any questions regarding this privacy policy, please email us at:

familyenquiries@entonegroup.com. 

Alternatively, you can contact us in writing or by phone via the details below:

Family Enquiries
Entertainment One UK Limited
45 Warren Street
London
W1T 6AG

Phone No: +44 (0)20 3691 8600

Do we make changes to this privacy policy?
 
From time to time, we may revise this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes, so please check back regularly to keep informed of updates. We will provide notice to you if these changes are material and will seek your consent or the consent of a parent or guardian if required by applicable law.