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The Topps Company

TOPPS EUROPE LIMITED

PRIVACY AND COOKIE POLICY

Topps Europe Limited ("Topps," “we,” “our,” or “us”) respects the privacy rights of our users and recognizes the importance of protecting the information we collect about you. The purpose of this Privacy Policy is to help you understand what information we collect about you when you use any of our websites, apps, or other online service where this Privacy Policy is posted (collectively, the “Services”), how we use that information and what choices you have. You should review this Privacy Policy every time you access the Services. This privacy policy supplements other notices and privacy policies that we may post.

From time to time, we may update this Privacy Policy and will notify you of any changes by posting the revised policy here. We encourage you to periodically check our Privacy Policy to learn about our data processing practices.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

HOW TO CONTACT US

Topps Europe Limited is the data controller responsible for your personal information. If you wish to exercise your access, deletion, rectification or other rights please refer to the YOUR RIGHTS WITH REGARDS TO YOUR PERSONAL INFORMATION section below. If you have any other questions about this privacy policy or our privacy practices, you may contact us in the following ways:

Postal Address: Topps Europe Limited

Attn: Privacy Policy

18 Vincent Avenue

Milton Keynes

England

MK8 0AW

Telephone: 0870 120 3630

WHAT INFORMATION WE COLLECT

Topps collects personal information and other information from and about you to provide the Services.

Personal information is data that identifies an individual either directly or indirectly.

The information we collect depends on the Services involved, and includes:

•Login Information that identifies and validates you as a user. For an adult, login information typically includes a password plus personal contact information, such as an e-mail address. You may be able to access some of the Services using social sign-on information.

•Personal Contact Information that allows Topps to contact you directly, such as your first and last name, e-mail address, mailing address, telephone number, and mobile number.

•Interest and Demographic Information, such as your age, gender, interests and preferences.

•Technical Information collected when you use the Services, such as your IP address, device information, information about the network you are using to access

the Services, browser type and version, your activities while using the Services, sites

or services previously visited, and content you see or click on.

•Order Information collected when you purchase a product or service, such as products ordered, payment information, and Personal Contact Information for the sender and recipient.

•Customer Service Information collected when you contact our internal or external customer service agents.

•Location Information including information that allows you to be precisely located.

•Social Sign-On Information such as login information, profile information, and friend lists from a social network that you choose to share when accessing the Services.

•User-Generated Content that you post or upload, such as comments, videos, photos, or social media interactions.

Your Duty to Inform Us of Changes. It is important that the personal information we hold about you is accurate and current. Please keep us informed of any changes to your personal information during your relationship with us.

If You Fail to Provide Personal Information. Where we need to collect personal information by law, or under the terms of a contract we have or are seeking to enter into with you and you fail to provide such data when requested, we may not be able to perform the contract (for example, to provide you with goods).

HOW WE COLLECT INFORMATION

When you use the Services, Topps collects information from and about you in the following ways:

•Direct Interactions. We collect information voluntarily provided by you, including Login Information, Personal Contact Information, Interest and Demographic Information, Order Information, Customer Service information, and User-Generated Content when you:

•Create an account and/or register for the Services;

•Participate in one of our online games, activities or applications;

•Participate in contests, sweepstakes, or other promotions;

•Post user-generated content;

•Participate in a survey or questionnaire;

•Apply for a job online;

•Subscribe to updates, newsletters or other marketing communications;

•Place an order or engage in other transactions; or

•Contact us with a comment, question, or for further information.

•Automatically. We collect Technical Information automatically when you use the Services through the use of cookies and similar technologies, as further described in the Cookies section below.

•Third Parties. If you choose to access the Services or register using an external third-party application, such as a social network, Topps will receive information from such application. Certain Services, including eTopps, may provide the option to sell any of your eTopps cards on the special eTopps trading floor on eBay, in which case we will ask you for your eBay user name and password. That information will allow us to list your items for sale on eBay, and to track the auction for you. By providing us this information you consent to allow us to link your eBay account with your eTopps account.

•Mobile Devices. Topps or its third-party technology partners may also collect Location Information, including Location Information provided by a mobile device interacting with one of our apps or associated with your IP address or Wi-Fi network. You can generally limit or prohibit the collection of Location Information using the built-in settings on your mobile device. Check the device instructions for information on how to do so. We do not permit the collection of precise location information (actual address) in mobile apps without your consent.

HOW WE USE YOUR INFORMATION

Topps collects information from and about you to serve your needs, manage our content and advertising, operate efficiently, and improve our Services and products.

We collect information and use it, either alone or combined with other information:

•To provide you with the Services;

•To respond to inquiries and requests;

•To enable you to participate in online games, contests, sweepstakes, and other promotions;

•To enable you to communicate with other users of the Services and share information about our products and Services with others;

•To provide you with personalized content;

•To understand our visitors and improve our products and Services;

•To maintain the security, integrity, and quality of our products and Services;

•To protect our legal rights and the legal rights of others;

•To send you or other individuals you identify marketing communications on behalf of Topps and other companies within the Topps family, and on behalf of select non-affiliated companies;

•To offer interest-based advertising and measure the effectiveness of our advertising; and

•To complete and fulfill a transaction, redemption, confirm an order, track delivery and payment, and provide updates about the status of an order.

When required by applicable laws, we rely on certain legal grounds to process your personal information, depending on how you interact with the Services. Most commonly, we use your personal information in the following circumstances:

•To perform a contract we are about to enter into or have entered into with you;

•Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not overrise those interests; and

•Where we need to comply with a legal obligation.

If applicable laws require that we obtain your consent to collect information for a particular purpose, we will do so at the time we collect the information.

We may combine information we collect through your use of the Services with information that we collect from other sources (e.g., offline records or publicly available information).

Additionally, we may take personal information and de-identify it and share it in a de-identified or aggregated form with third parties, advertisers and/or business partners in

order to analyze site usage, improve our service or service offerings, and improve our user experience, or for similar purposes.

YOUR RIGHTS WITH REGARDS TO YOUR PERSONAL INFORMATION

You have the right to access, update and correct factual inaccuracies in personal information that we collect through the Services, subject to certain exceptions. Subject to applicable laws, you may also have the right to request to delete, restrict the processing of, or transfer your personal information, withdraw your consent (if we are relying on consent as a basis for processing your personal information), or object to our processing of such information. If you wish to exercise your rights in relation to how we process your Personal Data under data protection laws please visit our Privacy Request Centre which can be found here.

Any requests you submit will be reviewed and, if approved, processed by our staff. We may retain certain information as necessary to pursue legitimate business interests or resolve disputes or as required by applicable laws. To protect your privacy and the security of your personal information, we will take reasonable steps to verify your identity before granting access to your personal information or deleting your account.

If you are a citizen of an EEA member state, you also have the right to contact supervisory authorities within the EEA about any concerns you have related to Topps’ privacy practices.

You will not have to pay a fee to exercise any of the aforementioned rights, but we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it could take more than one month if your request is particularly complex or you have made a number of requests. In such case, we will notify you and keep you updated.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you are entitled by law to request, once per year, information about third parties with whom Topps has shared personal information about you for their direct marketing purposes during the previous calendar year, and the categories of personal information shared. To make such a request, submit a written request to the address listed in the Contact section below, or send an e-mail to [email protected], specifying that you seek your "California Customer Privacy Notice." Please allow thirty days for a response.

USE OF COOKIES AND OTHER TECHNOLOGIES

Topps and its service providers, including advertising and analytics partners, use small text files called “cookies” and similar technology that are saved on your computer or mobile device to automatically collect information about use of the Services. Different types of cookies, such as session or persistent cookies, may be used for different functions. Persistent cookies remain on a user’s device for a set period of time, and are activated each time a user visits the Services where cookies were set. Session cookies are temporary and allow us to link a user’s actions during a browser session. The information collected includes device information, information about the network you are using to access the Services, sites or services that you previously visited, and content you see or click on.

The Services use the following types of cookies and other technologies for the following purposes:

  • Essential. These are essential to navigate the Services and use the features, and they enable us to provide services such as registration and shopping carts.
  • Functional. These are used to recognize you when you use the Services. They enable us to personalize content for you and remember your preferences.
  • Analytics. These are used to understand and improve the Services and understand how you use the Services.
  • Advertising. These are used to deliver relevant ads and track ad campaign performance and efficiency.
  • Social. These allow you to share content and experiences and to sign in with your social network ID and stay logged in across the Internet.

Although many browsers are initially set to accept cookies, you may be able to adjust your settings to reject cookies. Choices are browser and device specific, and if you clear

cookies from the browser on any of your devices, your opt-out choices will need to be reset. Consult the "Help" section of your browser or built-in mobile device settings for more information. In addition, please note that certain areas of the Services only can be accessed when cookies are enabled. Thus, disabling cookies may prevent you from accessing some of our content.

Other third party partners, like social media sites, may also use cookies and similar technology to collect information automatically about your use of the Services through social media plug-ins. You may be able to provide social sign-on information to access the Services, in which case the social network may be able to link your activities in the Services to your social media registration information. The social media networks’ privacy policy and terms apply to your use of their platforms. Your browser or device may allow you to block these technologies, but you should visit the third-party website and review their privacy policy and your registration profile or account to find out your options.

INTEREST-BASED ADVERTISING

As described above, third party advertising partners may use cookies and similar technology to collect certain information regarding use of the Services and other websites and apps automatically and may use the information to serve targeted ads for products and services that may be of interest based on your activity. To learn more about interest-based advertising and how you can opt-out of having your web browsing information used for interest based advertising by companies that participate in the Network Advertising (“NAI”) or Digital Advertising Alliance (“DAA”), visit the NAI website (US) and the DAA Ad Choices websites (US, EU, Canada, and AU/NZ). Note, however, that not all service providers participate in the NAI and DAA. In addition, if you opt-out, you may still see online advertising from Topps and third parties, but the ads may be less relevant to you. If you delete or block cookies, buy or use a different device, access the Services from a different device, login under a different name, or change web browsers, you will need to opt-out again. Some web browsers may transmit “do not track” signals. At this time, Topps does not take steps to respond to such signals.

CUSTOMIZED AD CAMPAIGNS

For some of the Services, we work with Facebook to display interest-based advertisements on Facebook through a tool known as the “Custom Audiences”. We share hashed/encrypted email addresses collected from users of the Services with Facebook, which permits Facebook to target advertisements on our behalf through its platform

• Service Providers:We may share information we collect with third parties that process information on our behalf. We may use such service providers to

• host the Services and provide database and server maintenance and security,

• help us conduct contests, sweepstakes or other promotions,

• send e-mails on our behalf,

• help us analyze our offerings, and

• process and fulfill online transactions.

• Business Partners: With your consent, we may share information with non-affiliated third parties to enable them to provide you with information about their products or services that may be of interest. Please see the section below titled, "Your Choices Regarding Direct Marketing" for more information on how to changes your preferences or opt out of such information sharing.

• Legal Compliance & Protecting Security and Safety: Topps may access, preserve and disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (i) comply with legal process or respond to a legal request or subpoena; (ii) enforce the Topps Terms & Conditions; (iii) respond to claims that your conduct has violated the rights of third parties; (iv) respond to your requests for customer service; (v) protect the rights, property or personal safety of Topps, its users and the public; (vi) or as otherwise required to comply with, or permitted by, applicable laws and regulations.

• Business Transactions: We may transfer information collected if we or one of our affiliates are acquired by, sold to, or merged with another entity.

• Legal Compliance & Protecting Security and Safety: Topps may access, preserve and disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (i) comply with legal process or respond to a legal request or subpoena; (ii) enforce the Topps Terms & Conditions; (iii) respond to claims that your conduct has violated the rights of third parties; (iv) respond to your requests for customer service; (v) protect the rights, property or personal safety of Topps, its users and the public; (vi) or as otherwise required to comply with, or permitted by, applicable laws and regulations.

• Business Transactions: We may transfer information collected if we or one of our affiliates are acquired by, sold to, or merged with another entity.

YOUR CHOICES REGARDING DIRECT MARKETING

With your consent, Topps may use personal information collected pursuant to this policy to market our own sports entertainment, collectible, and candy products and services and on behalf of other companies within the Topps family, and to market products and services offered by select non-affiliated sports, collectible, games, and candy companies.

Receiving marketing communications from Topps is voluntary. If at any time you wish to change your marketing preferences or opt out entirely from receiving further marketing information from us, you can log into your account if you have registered through the Services, follow the unsubscribe instructions in an e-mail communication, or contact us at the address in the How to Contact Us section below.

SECURITY

Topps strives to use commercially reasonable physical and electronic security measures to protect against the loss, unauthorized access, misuse, or alteration of your personal information. We use encryption or other security measures to protect payment information during transmission and adopt internal procedures to safeguard such information in our systems. We limit access to personal information to those employees, agents, contractors, and other third parties who have a business need to know. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee the security measures of third parties.

LINKS AND THIRD PARTIES

We may provide links to other sites owned by third parties. When you place an order or register on the Services where transactions are handled by a third party vendor, those transactions are conducted through the vendor’s website and are subject to the vendor’s privacy policy and terms of use. We are not responsible for those other sites, their privacy policies, or how they treat the information of their users. We advise you to review their privacy policies for information on how those sites collect, use, and protect your information.

You may be required to register with and log onto a third party mobile app store before you can download or purchase a Topps app or make in-app purchases using a Topps app. When downloading a Topps app or using a Topps app with online features through your mobile platform, the app provider will typically collect certain device and app-related information. Topps does not control the requirements or processes of the 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. On occasion, we may offer content, promotions or other activities that are sponsored or co-sponsored by or presented with identified third parties. By using this content or participating in such promotions or activities, the personal information that you voluntarily submit may be provided to both Topps and the third parties. Topps has no control over such third parties’ use of this information.

INTERNATIONAL DATA TRANSFERS

As the Topps family of companies operates globally, we may transfer to and process personal information about you on our servers in the United States and/or countries other than your home country, and we may use cloud services whose servers may be anywhere in the world. Please note that the data protection laws of some countries, such as the United States, may not offer a level of privacy protection equivalent to that within the European Economic Area (EEA) or your home country. If your use of the Services results in the transfer of personal information from the EEA to non-EEA countries that have not been deemed to offer an adequate level of privacy protection, we may rely on (i) standard contractual clauses approved by the European Commission in our contracts with parties that receive information in such countries, and /or (ii) third party service providers in the United States that are certified to receive such information under the Privacy Shield program. By using the Services, you expressly consent to such transfers.

STORAGE/RETENTION

Personal information we collect will not be stored for longer than is necessary for the purposes described in this Privacy Policy, or to otherwise meet legal, regulatory, tax, accounting, or reporting requirements. In some cases we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use the information indefinitely without further notice to you.