Crayola® Scribble Scrubbie Pets

PRIVACY POLICY

Updated: 07/12/2024

App Privacy Policy

Effective Date: July 12, 2024

Children's Privacy Notice

Introduction

Hello,
We are Crayola LLC and we are the makers of the Crayola Create and Play and Crayola Scribble Scrubbie Pets (Crayola Washimals in the UK and EU) and Crayola Color Camera apps. Keeping your information private is very important to us and we would like to tell you how we do this.

What Information do we collect and why?

To play our apps we do not collect any personal data from you. Personal data is information about you and can include things like your full name, address, email or phone number.

We do collect some information to help us run the app such as the country you live in, how much time you spend in our game and the mobile devices you use and similar. But this information does not identify you, this means that we do not know who you are.

Who do we work with?

Crayola LLC needs a little help from other companies to run our app but they do not share any of this information with anyone else. You can find out more information here (link to service providers below), you might need a parent or guardian to help you understand this.

Your Rights

It is important for you to know that you have certain rights over your data:

  1. Right of Access - You have the right to know what information a company has about you and how it is used

  2. Right to Rectification - This means that you can ask for your data to be updated if something is incorrect

  3. Right of Deletion - You can ask a company to delete any information they may have about you

  4. Right to request the restriction of processing concerning you - You can decide how your personal information to be used.

  5. Right to data portability - You can ask for your personal information to be sent to another service provider.

  6. Right to object to processing - You can ask a company to stop using your information at any time

For more information or if you would like to action one of these rights you or your parent can contact us at support@crayola.com

Contact Us

If you have any questions about this policy or you need help with any of our apps, you or your parent can contact us here.

Privacy Policy

Last updated - February 23, 2022

Privacy and digital safety are top priorities for Crayola. Crayola LLC is providing this privacy statement to explain how we collect, use, and disclose personal information in clear, easy-to-understand language. This privacy statement applies to the following Crayola apps: Crayola Create and Play and Crayola Scribble Scrubbie Pets (Crayola Washimals in the UK and EU) and Crayola Color Camera. This Privacy Policy may be updated at any time as new features are added or as the law changes. Review this policy often. If we make a material change to this policy we will inform you before we make the change. We also encourage you to review the terms and conditions of use.

Table of Contents

  1. Personal Information

  2. Service Providers

  3. Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification & GDPRkids™

  4. App Stores

  5. Links to Third Party Sites, Services, and Content

  6. Security

  7. A Note to California residents

  8. A Note to EU and UK Citizens

  9. Contact Us

Personal Information

Crayola’s apps do not actively collect or transmit any personal information ("PI"). This includes all user generated content ("UGC") such as drawings, photos, coloring pages, and pet designs which are only stored locally on your device and are not transmitted.

Other information we collect

Our apps may collect and transmit anonymous information regarding usage patterns of the app to help Crayola improve its apps and understand usage patterns. We collect the following anonymous technical data through our analytics provider: App Store, App Version, Device Brand, Device Category, Device Model, First Time Open, Language, New and OS Version. We also collect location information at a country level. For more information, please see the service providers section below.

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification & GDPRkids™

Crayola, LLC is a member of the PRIVO Kids Privacy Assured Program(“the Program”) for COPPA Safe Harbor Certification and GDPRkids™. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online.

COPPA Safe Harbor Certification

The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO COPPA certification Seal. The certification Seal posted on this page indicates Crayola, LLC has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at 1-800-CRAYOLA  or email us at support@crayola.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

GDPRkids™ Privacy Assured

The Program applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO GDPRkids™ Verified Shield. The PRIVO GDPRkids™ Privacy Assured Program supports child directed services known as Information Society Services under the General Data Protection Regulation (GDPR), to comply with the requirements of this legislation. It impacts any child directed service in an EU Member State and any service globally that collects and or processes the personal data of children and minors. There is no safe harbor for the GDPR to date, but to ensure this company's services meet the program requirements, we conduct regular monitoring and consulting.

Service Providers

In order to deliver the best app experience possible, Crayola uses the following service providers in our apps:.

Google Firebase is used in Scrubbie Pets to store anonymous usage data for the explicit purpose of helping Crayola improve the app experience. No personal data or PII is collected. All sharing options within Google Firebase are turned off. An example of this anonymous data is the number of times each activity has been played, which helps Crayola understand what type of content is most popular. Google Firebase also collects anonymous technical data including device type, app version, country and language settings. For more information about Firebase, please view the Google privacy policy: https://policies.google.com/privacy?hl=en-US

We work with Zendesk for customer service. Our customer service portal is available for parents/adults only. For more information on Zendesk please see the Zendesk privacy here: https://www.zendesk.com/company/customers-partners/privacy-policy/

Crayola Create and Play is operated by Red GamesCo on behalf of Crayola. The app does not actively collect personal information from children. Red Games Co collects technical data including an IP address, equipment, browsing actions, country code, user agent, App version and Operating System, as well as statistics. Red Games works with the following service providers in relation to the Create and Play app:

We use Unity IAP to implement in-app purchases. Analytics and data sharing are deactivated as soon as the app launches and no data is sent to Unity Analytics. For more information, please see the Unity privacy policy: https://unity3d.com/legal/privacy-policy

iCloud Key-Value storage is a safe and secure cloud-based service provided by Apple that allows an app to save data to a user’s private iCloud Account storage and access that data from multiple devices that may be logged into the same iCloud account. Neither Crayola nor Apple has access to this information. Players can delete their User Data stored in iCloud via the settings menu. For more information, please visit Apple’s privacy center: https://www.apple.com/ca/legal/privacy/

We use Singular to track install data. Singular does not receive any personal information about our users in order to perform this service. For more information, please review Singular’s privacy policy: https://www.singular.net/privacy-policy

Parents can contact us regarding their child’s use of the app here:

Consumer Affairs
Crayola LLC
1100 Church Lane
P.O. Box 431
Easton, PA 18044.

You may also email us here or call us at 1-800-CRAYOLA.

App Stores

When you download or purchase an App, or make an in-App purchase, you may do so through a third party application online store such as the Apple App Store or Google Play. You may be required to register with the app store and be logged on before you can download or purchase an app or make in-app purchase of another product using the app. When downloading an app, or using an app with on-line features through your platform, the app provider will typically also collect certain device and app-related information. Crayola does not control the requirements or policies of app stores; you should review the Privacy Policy and terms of use of the mobile app stores before downloading or using any app, and check your device settings for control options.

Links to Third Party Sites, Services, and Content

The parent's section of these apps may contain links to other websites, online services, and content that are operated and maintained by third parties and that are not under the control of or maintained by us. Such links do not constitute an endorsement by Crayola of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to your interactions with those third parties, even if you find a link to them on the Crayola website. We encourage you to read the Privacy Policy of the third-party website provider to see how your personal information will be treated on its site.

Security

Crayola uses generally accepted security measures and safeguards in an attempt to keep the data it collects secure and requires that the service providers it works with agree to do the same. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

A Note to California Residents

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

You have the right to request access to your Personal Information that Crayola collects, uses, sells, or discloses to third parties,

You have right to request the deletion of your Personal Information that Crayola collects about you and you have the right to opt-out of selling of your Personal Information to the third parties.

A Note to EU and UK Citizens

Crayola complies with the rights given to EU and UK Citizens 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 - 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 - 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 analyse your information for targeted content etc. (also known as profiling).

For more information on how to action these rights please contact us at: support@crayola.com

To action these rights in relation to Crayola Create and Play, please contact Red Games at: support@createandplay.zendesk.com.

If you have a concern about our handling of personal 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 data protection regulator.

App Data Collection & Use

To play our app we do not actively collect any personal data from children. Personal data is information about you and can include things like your full name, address, email or phone number.

If a parent or legal guardian uses the contact form in the app, we collect their email address in order to respond to their query. 

If a parent or legal guardian creates an account in the app, we collect their email address for their login and account access. We also collect an anonymous device identifier to allow them to manage the devices that can access their subscription. 

Certain non-personal data (as described below) is collected and used in the App to allow players to create and save their scores and game progress. This data is stored locally on a player's device and in a player’s iCloud Key Value Store for iOS users. 

iCloud Key Value Store

iCloud Key-Value Storage is a safe and secure cloud-based service provided by Apple that allows an app to save data to a user’s private iCloud Account storage and access that data from multiple devices that may be logged into the same iCloud account. Neither Crayola, Red Games Co, or Apple have access to this information. Players can delete their User Data stored in iCloud via the Settings menu.

User Data

The following game data is saved to a player’s iCloud Key Value Store unless they choose to opt out: 

Session Data

  • Current session ID

  • Is this the user’s first session 

  • Is the user subscribed

  • Time user began playing

  • Time user last played

  • Last timestamp the user played

  • Number of rewards earned this session

  • Number of times a coloring activity was played this session

  • Number of pet activities played this session

  • Number of lab activities played this session

  • Number of arcade activities played this session 

  • Number of learning activities played this session

Rewards Data

  • The number of new eggs that the player has not hatched

  • The index of the last reward that was unlocked from the Reward schedule 

  • The number of rewards that have been given from the current theme

  • The current fill value of the reward meter

  • The number of rewards that the player has already received today 

  • The Time in ticks when the player last unlocked a reward

  • The total number of rewards that this player has ever received

  • The total number of rewards that the player has received while playing this version of the app

  • The total number of locked rewards that this player has received ever

  • The List of all the items that the player has unlocked

  • The list of all the items that the player has unlocked and has not yet viewed

  • The list of all unlocked items

  • The list of all the items the player unlocked while unsubscribed

Trophy Data

  • Number of trophies

  • Trophy ID

  • Trophy color

  • Trophy mold ID

  • Trophy modifiers used

  • Trophy creation date

Plants Data

  • Plant ID

  • Plant size

  • Plant rotation

  • Plant mirroring status

  • Plant growth stage

  • Plant type

  • Flowers type(s)

  • Plant index

  • Plant creation date

  • Plant last watered date

  • Was this plant created by a user?

AR Data

  • Plant placement on AR map

  • Cached version of AR map data

Onboarding Data

  • Which onboarding steps a user has viewed

Games Data

  • Highest score in Scoop Stacks (ice cream) game

Challenges Data

  • Challenge ID

  • Event ID that is tied to the challenge

  • Challenge completion status

  • Challenge acceptance status

  • Challenge objectives

  • Challenge acceptance date

  • Badges earned from challenge

Lifetime Data

  • How many times each video was viewed

  • How many times the paywall has been viewed

  • Total time spent drawing

  • Total time spent with pets

  • Total time spent playing (overall)

  • Time spent drawing for free users

  • Time spent with pets for free

  • Total time spent playing for free users

Events Data

  • IDs of earned rewards

  • IDs of unearned, but awarded, rewards

Device Save Data

  • The date representing the last say the news schedule was checked for the latest news

  • The date representing the last time a news alert was shown

  • Number of alerts seen today

  • Number of times a survey has been seen

  • Total number of sessions

  • Was the last load unsuccessful

  • Time the last survey was seen

  • Time the last offer was seen

  • Has the user seen the notification permission dialog

  • All of the news IDs that have been seen by this player

  • Notifications that have been seen by the user

  • Validated promo codes

  • Amount of times a challenge call-to-action was viewed before accepting

  • All of the event schedules that are active (or were active) on last run

  • All of the parent portal alerts that have been seen by this player

  • Has the user seen the guest pass

  • Previous session timestamps

  • The number of times a player has seen the rate prompt

  • The last time the rate prompt was shown

  • The version of the game when the user was shown the rate prompt

Admin Data

  • Time the admin data was last changed

  • Names of fields in the admin data (no longer used) 

  • Has the user rated the app

  • Time when the user subscription will end

  • Last known subscription end time

  • Modified subscription end time

  • Is the user in the free trial period

  • Most recent app version

  • Version that the user originally installed the game on

  • Permissions the user has allowed

  • Date the user installed the game

  • Has the user ever subscribed to the game

  • Type of subscription the user has

  • Override user paywall with this tag

  • Is the user using family share

User-Generated Content

  • Drawings

  • Pets

  • Pet Selfies

  • Tracings

  • Selfies

  • Molds

Third Parties Service Providers

The App does not share data with any third-party service provider that can be used for that third party’s own purposes. Red Games Co collects technical data including an IP address, equipment, browsing actions, country code, user agent, App version and Operating System, as well as statistics. 

In order to deliver the best app experience possible, Crayola and Red Games Co. use the following service providers in the Crayola Create and Play app:

Google Firebase is used to store anonymous usage data for the purpose of helping Red Games Co. improve the app experience. All sharing options within Google Firebase are turned off. An example of this anonymous data is the number of times each activity has been played, which helps us understand what type of content is most popular. Google Firebase also collects anonymous technical data including device type, app version, country and language settings. For more information about Firebase, please view the Google privacy policy: https://policies.google.com/privacy?hl=en-US

We work with Zendesk for customer service. Our customer service portal is available for parents/adults only. For more information on Zendesk please see the Zendesk privacy policy here: https://www.zendesk.com/company/customers-partners/privacy-policy/

We use Unity IAP to implement in-app purchases. Analytics and data sharing are deactivated as soon as the app launches and no data is sent to Unity Analytics. For more information, please see the Unity privacy policy: https://unity3d.com/legal/privacy-policy

iCloud Key-Value storage is a safe and secure cloud-based service provided by Apple that allows an app to save data to a user’s personal iCloud Account storage and access that data from multiple devices that may be logged into the same iCloud account. Neither Crayola, Red Games Co, or Apple have access to this information. Players can delete their User Data stored in iCloud via the Settings menu. For more information, please visit Apple’s privacy center: https://www.apple.com/ca/legal/privacy

We use Singular to track install data. Singular does not receive any personal information about our users in order to perform this service. For more information, please review Singular’s privacy policy: https://www.singular.net/privacy-policy

Data Retention

  • User Data: Stored in the user’s iCloud and retained at the user’s discretion

  • Player Data and Real-Time Game Inputs: These are stored until deleted by the user

  • Device Data: Is saved locally on the user’s device

EU/UK Data Subject Rights

It is important for you to know that you have certain rights over your data:

  • Right to be informed - You have the right to know what personal data a company has about you and how it is used

  • Right to Access – You have the right to request a copy of the personal data a company has about you.

  • Right to Rectification - This means that you can ask for your personal data to be updated if something is incorrect

  • Right of Deletion - You can ask a company to delete any personal data they may have about you. Players can also delete their User Data stored in iCloud via the settings menu. 

  • Right to request the restriction of processing concerning you - You can decide how your personal data is to be used. 

  • Right to data portability - You can ask for your personal data to be sent to another service provider.

  • Right to object to processing - You can ask a company to stop using your personal data at any time

For more information or if you would like to action one of these rights you can contact us at support@createandplay.zendesk.com.

If you would like to make a complaint about how we handle your personal data, you can contact the relevant Data Protection Authority (DPA).

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification & GDPRkids™

Red Games Co., LLC is a member of the PRIVO Kids Privacy Assured Program (“the Program”) for COPPASafe Harbor Certification and GDPRkids™. PRIVO is an independent, third-party organization committed to supporting online services to safeguard children’s personal information collected online.

COPPA Safe Harbor Certification

The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO COPPA certification Seal. The certification Seal posted on this page indicates Red Games Co., LLC has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at 801-210-0439 or privacypolicy@redgames.co. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

GDPRkids™ Privacy Assured

The Program applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO GDPRkids™ Verified Shield. The PRIVO GDPRkids™ Privacy Assured Program supports child directed services known as Information Society Services under the General Data Protection Regulation (GDPR), to comply with the requirements of this legislation. It impacts any child directed service in an EU Member State and any service globally that collects and or processes the personal data of children and minors. There is no safe harbor for the GDPR to date, but to ensure this company's services meet the program requirements, we conduct regular monitoring and consulting.

Security

Red Games Co uses generally accepted security measures and safeguards in an attempt to keep the data it collects secure and requires that the service providers it works with agree to do the same. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

Cancellation Policy

Payment will be charged at confirmation of purchase. Subscription automatically renews unless canceled before the end of the current period. Account will be charged for renewal within 24-hours prior to the end of the current period, and identify the cost of the renewal. The current period begins after the trial period ends (if available). If you cancel within your free trial period, you will not be charged. If you cancel after the free trial period ends, you will be charged for the full amount.

Contact Info

For more information on Crayola’s Create & Play+ privacy policy or data processing practices please email John Park at privacypolicy@redgames.co. Parents can contact us regarding their child’s use of the app here:

Consumer Affairs Crayola LLC

1100 Church Lane P.O. Box 431 Easton, PA 18044

You may also email us here or call us at 1-800-CRAYOLA