Effective Date: April 13, 2020

Table of Contents: Spin Master Career Site Privacy Policy
1. Overview
2. Information We Collect
3. How We Use the Information We Collect
4. Sensitive Candidate Information
5. Information We Share
6. International Data Transfers
7. Update Your Account Information
8. Notice to California Residents
9. Notice to EU residents
10. Cookies and Third-party Analytics
11. Links to Other Websites
12. How We Protect Candidate Information
13. Changes to this Policy
14. How to Contact Us

1. Overview

This Privacy Policy (“Policy”) describes how Spin Master and its subsidiaries and related companies (collectively, “Spin Master”) handle and protect information collected, used and processed in connection with the recruiting process. We have drafted this Policy to provide you notice of our information and security practices and policies as you use this Career Site.

By making available your Candidate Information, as defined below, you confirm that you have reviewed this Policy and agree that Spin Master may collect, use, disclose and process your Candidate Information in accordance with this Policy.

Your consent to this Policy is required in order to submit or make available Candidate Information.  If you decline to submit or make available your Candidate Information, it may affect your ability to apply for or receive an offer of employment.

Spin Master will process Candidate Information in accordance with this Policy, unless in conflict with requirements of applicable law, in which case applicable law will prevail.
This Policy does not form part of any contract of employment offered to candidates hired by Spin Master.

This Policy describes the Candidate Information we collect, how we use the information, with whom we share it, and the choices you can make about our collection, use and disclosure of your Candidate Information. The term “Candidate Information” refers to information that may be used to personally identify you that you make available to Spin Master either directly or indirectly in connection with the recruiting process, or by sharing your work experience or interests. We also describe the measures we take to help protect the security of your Candidate Information and how you can contact us about our privacy practices.

Please review this Policy periodically as we may update it from time to time. We reserve the right to modify this Policy by posting changes to relevant Spin Master websites.

2. Information We Collect

We may obtain Candidate Information directly from a job candidate, such as information that you upload to our Career Site, or from third parties, for example, from recruiters or in connection with a background or employment check or employment reference, subject to your consent where required by law.
The types of information we may obtain include:

  • Your Candidate Information, if you choose to provide it or if we obtain it from a third party in the manner described above. Candidate Information includes your name, address, telephone number, email address, candidate status, work history, education, compensation, employer feedback, questionnaire results, contact information, additional information provided by the candidate (e.g., a cover letter), expertise or project work publicly shared,  references, and criminal history where permitted by law.  We collect this information either through the registration process, from your resume or in the manner described above.
  • You do not have to give us any Candidate Information in order to perform job searches or to read the content portions of the Career Site.
  • Your name and email address when you ask us to email you a job posting or sign up for job alerts.
  • Username and password for the account you may establish on the Career Site.
  • Job search behaviour and preferences, and a record of the searches that you make on the Career Site. We do this in order to present you with job recommendations based on your interests as expressed previously through your searches.
  • Other details that you may submit to us or that may be included in the information provided to us by third parties.

We may collect information stored in your social media profile that you authorize us to access when you use your social media profile to enact features on the Career Site, such as the ability to pre-populate our registration form or a job application.

In addition, when you visit the Career Site, we may collect certain information by automated means, such as cookies, as described in more detail in the section Cookies and Third Party Analytics. The information we may collect by automated means includes:

  • Information about the devices our visitors use to access the Career Site such as the IP address and the device, browser and operating system type.
  • Pages and URLs that refer visitors to the Career Site, also pages and URLs that visitors exit to once they leave the Career Site.
  • Dates and times of visits to the Career Site.
  • Information on actions taken on the Career Site such as page views, site navigation patterns and job view or application activity.
  • A general geographic location (such as country and city) from which a visitor accesses the Career Site.
  • Search terms that visitors use to reach the Career Site.

3. How We Use the Information We Collect

Spin Master uses Candidate Information for legitimate human resources and business management purposes. These include identifying and evaluating candidates for positions, record-keeping related to hiring processes, analyzing the hiring process and outcomes, and conducting background checks, where permitted by law.
In addition, we may use the information we obtain about you to:
  • Register, manage and maintain your account on the Career Site.
  • Provide products or services you request.
  • Maintain a record of the jobs you view or apply to on the Career Site.
  • Inform you of relevant job postings that may be of interest to you.
  • Provide administrative notices or communications applicable to your use of the Career Site.
  • Respond to your questions and comments and provide customer support.
  • Contact you and deliver marketing and promotional communications to you by email, text message or other means that, in some cases, is targeted to your interests (such as relevant services, educational or other career development opportunities) and to solicit your feedback and input. These communications will contain links for preference management and, where appropriate, unsubscribe links should you decide you do not want to receive further communications. Please note that if you unsubscribe from receiving marketing and promotional communications, you may continue to receive transactional and operational emails from us.
  • Operate, evaluate and improve our business and the products and services we offer.
  • Analyze and enhance our marketing communications and strategies including by identifying when emails we have sent to you have been received and read.
  • Analyze trends and statistics regarding visitors’ use of the Career Site, mobile applications and social media assets, and the jobs viewed or applied to on the Career Site.
  • Enforce the Career Site's Terms of Use.
  • Comply with Spin Master’s legal, regulatory and corporate governance requirements.

If a candidate is hired, Candidate Information may be used in connection with their employment consistent with Spin Master’s employment policies.
In addition to using Candidate Information for the position for which you have applied, Spin Master may retain and use your Candidate Information to consider you for other positions.  If you do not want to be considered for other positions or would like to have your Candidate Information removed, you may contact us as specified under How to Contact Us below.

Unless required for tax or other legal purposes or in connection with employment as specified above, Candidate Information will be retained for a maximum of three years, unless otherwise required by law.

We also use certain technical information about your computer and your access of the Career Site (including your IP address) in order to operate, maintain and improve the Career Site. We collect this information by automated means, such as cookies, as described in more detail in the section Cookies and Third Party Analytics below.

4. Sensitive Candidate Information

Spin Master may perform background and criminal checks where permitted by law, and may process other sensitive Candidate Information, such as citizenship or nationality information or health information, when relevant for a position and permitted by law.  If Spin Master intends to collect sensitive Candidate Information from third parties, you will be provided notice and the opportunity to consent.  If you have a disability and would like Spin Master to consider an accommodation, you may provide that information during the recruiting process.   To the extent you make sensitive Candidate Information available to us, you consent to Spin Master processing such information in accordance with this Policy.

5. Information We Share

We may share Candidate Information with our third-party service providers who help us in providing the Career Site, such as hosting our site, sending communications to you, serving advertisements on our sites and managing and analyzing data. These service providers are only authorized to use or disclose the information as necessary to perform services on our behalf or as otherwise required by law.
Spin Master may be required to disclose certain Candidate Information to other third parties (1) as required by law; (2) to protect Spin Master’s legal rights to the extent authorized or permitted by law; or (3) in an emergency where the health or safety of a candidate or other individual may be endangered.  In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of Spin Master’s business, Spin Master may transfer Candidate Information to successor entities or parties.

6. International Data Transfers

Information we maintain may be stored both within and outside of the United States. Where possible, we try to keep the information you supply to us locally. However, as part of the services offered through our Career Site, the information you provide to us may be transferred to countries outside the European Economic Area (EEA). This may happen where any of our servers are hosted by one of our Spin Master offices outside of the EEA, or one of our service providers is located in a country outside of the EEA.  We may also share information between our group companies which are located in countries worldwide. These countries may not have similar data protection laws to the EEA.  If we transfer your information outside of the EEA in this way, we will take appropriate steps to ensure that any personal data relating to you will continue to be adequately protected.

7. Update Your Account Information

You may access, update and amend some of the Candidate Information in our custody and control at any time by logging into your account and making the necessary changes or by contacting us at the contact information set forth at the end of this Policy.

8. Notice to California Residents

If you are a California resident, we are required to provide additional information to you about how we use and disclose your personal information and set out your rights in connection with how we use your information.

Use and Disclosure of your Information

Consistent with the sections Information We Collect and How We Use the Information We Collect of this Policy, we collect certain categories and specific pieces of information about individuals that are considered "personal information" in California. As detailed above, we may collect this personal information from you and other third parties. We collect, share and disclose personal information for the purposes described in this Policy.
As a consumer, under California law, you have the following rights:

Right of Access

You have the right to request access to your personal information which we may have collected. We will provide:
  • Categories of personal information collected by us;
  • Categories of sources of the personal information collected;
  • Business reason for collecting your personal information;
  • Any third parties whom we share the personal information;
  • Specific data fields/pieces of personal information we have collected.
We do not sell your personal information to third parties.

Right to Deletion

You have the right to request the deletion of personal information which we hold. However, this right is subject to some exceptions and does not apply in the following situations:
  • We require the information to continue to provide goods or services to you;
  • Information is required to resolve security or functionary related issues;
  • Information is required to comply with the law;
  • Information is safeguarded to the right to free speech;
  • Information is supporting researching in the public interest;
  • Information is required for internal purposes which you as the consumer reasonably expect.

Right to Non-Discrimination

California consumers have the right not to be discriminated against for having exercised your rights under California law. Specifically, we will not:
  • Deny you any goods or services;
  • Charge you different prices for goods or services, whether through denying benefits or imposing penalties, due to your request; or
  • Provide you with a different level or quality of products or services due to your request.
As an individual, you are enabled to make requests twice in a 12-month period. As a business, we will need to collect information from the requesting party to verify your identity prior to taking any action. We will respond within 45 days of receiving a personal information request.

Exercising Your Rights

To exercise your rights, you may send a request by contacting us at the contact information set forth at the end of this Policy. To make a request, please ensure the request includes:
  • Sufficient information to allow us to reasonably verify you are the person about whom the information is collected; and
  • Describe your request which allows us to understand and action on your request.

Please note that only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

The information we provide to you will only cover the 12-month period preceding receipt of a consumer’s verifiable request. We will aim to provide a response within 45 days of receipt. If we require additional time to respond, we will provide an update to you and include the reason and extension period. In case we are unable to comply with your request, we will provide an update with explanation of the reasons we cannot comply.
We do not charge a fee to process or respond to your requests unless such request is excessive, repetitive, or unfounded. If we determine the request warrants a fee, we will provide a written response with the fee estimate prior to completing or responding to your request.

9. Notice to EU Residents

Spin Master complies with the rights given to EU citizens and residents under the General Data Protection Regulation (GDPR). These rights are as follows:
  • Correcting your Information – the right to have your personal information updated to ensure it is up-to-date and accurate.
  • Withdrawing Consent – the right to withdraw your consent to any processing that is currently being done under your consent, e.g. marketing.
  • Obtaining a Copy of your Information – the right to receive a copy of the personal information we hold about you.
  • Deleting your Information – the right to request that we delete personal information in certain circumstances.
  • Data Portability – the right to have us transfer to another controller the personal information that you have provided us with.
  • Restricting Processing – the right to request a restriction on the processing of your data in some limited circumstances.
  • Right to Object to Processing – the right to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyze your information for targeted content (also known as profiling).
For more information on how to action these rights, please contact us at the contact information set forth at the end of this Policy.

10. Cookies and Third Party Analytics

This Career Site may request cookies to be set on your device. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We do not link the information we store in cookies to personally identifiable information you submit while on this Career Site. We use cookies to let us know when you visit this Career Site and how you interact with us, to enrich your user experience, and to personalize your experience with this Career Site. You can change your cookie preferences by selecting to turn certain cookies off. Please note that blocking some types of cookies may impact your experience on this career site and the services we are able to offer.
Spin Master uses cookies and other similar technologies in order to operate, maintain and improve the Career Site, ensure the proper functioning and efficiency of the Career Site and evaluate and improve our business and the products and services we offer. Cookies enable us to serve secure pages to our users without asking them to sign in repeatedly. Spin Master also stores information about you such as past jobs viewed and job searches conducted by you. We do this in order to present you with job recommendations based on your interests as expressed previously through your searches.
Spin Master permits third party cookies on its Career Site. For example, third party tools located on the Career Site may use cookies to remember user preference settings. Spin Master also uses web analytics services provided by third parties, which use cookies to collect information about details of our users’ visits to the Career Site (including IP addresses) and the resources they access on the Career Site. These third-party web analytics services provide us with reports based on this information in order to help us understand how visitors engage with the Career Site.
To learn more about our use of cookies and how to disable them, and thereby limiting the automatic collection of information by such cookies, please visit our Career Site Cookie Settings page.

11. Links to Other Websites

The Career Site may contain links to other sites for your convenience and information. These sites may be operated by companies not owned by Spin Master. These other sites or linked third-party sites may have their own privacy notices, which you should review if you visit those sites. We are not responsible for the content of any sites not owned by Spin Master, any use of those sites, or those sites’ privacy practices.

12. How We Protect Candidate Information

Spin Master employs technical and organizational measures designed to protect the integrity, confidentiality, security and availability of Candidate Information, and to comply with applicable legal requirements for information security. Spin Master limits access to internal systems that hold Candidate Information to individuals who need access for a legitimate business purpose.
Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard Candidate Information will never be defeated or fail, or that those measures will always be sufficient or effective. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your Candidate Information will always remain private. As a user of the Career Site, you understand and agree that you assume all responsibility and risk for your use of the Career Site and the documents you post or access, and for your conduct on the Career Site.
You should safeguard your account username and password and not share that information with anyone. You should also sign off your account and close your browser window when you have finished your visit to the Career Site. Please note that we will never ask for your account username or password via email. You agree to notify Spin Master immediately of any unauthorized use of your account or password.

13. Changes to this Policy

Spin Master reserves the right to modify this Policy by posting changes to relevant Spin Master websites.  If you submit additional Candidate Information or request to be considered for a Spin Master position following the effective date of a modified Policy, your Candidate Information will be handled in accordance with the Policy in effect at that time.

14. How to Contact Us

You may direct questions regarding this Policy, or the manner in which we treat your Candidate Information, by sending a request in writing to:
Human Resources Data Protection Administrator.
Spin Master Ltd., 225 King Street West, Suite 200, Toronto, Ontario, M5V 3M2, Canada; or by email at TAinquiries@spinmaster.com
If you have a concern about our handling of your Candidate Information, please get in contact with us first so we can try to resolve your query. If, however, you feel we have not dealt with your concern and that we are failing to meet our legal obligations, you can report this to your local privacy or data protection regulator.