ToysRus BabiesRus

Release date: April 25, 2023

Effective date: April 25, 2023

Personal Information Protection Policy

Toys”R”Us Retailing (China) Limited (“we” or “Toys”R”Us”) respects users’ privacy and personal information. When you register Toys”R”Us accounts, purchase our products online, leave product reviews, become Star Card member, join “Geoffrey Club”, use functions such as “Haowan Community” and receive our customer services, this Personal Information Protection Policy (“Policy”) tells you how we collect, use, store, share and transfer your personal information, and your rights to your personal information.

Before starting to use our products and services, please read carefully to ensure you thoroughly understand this Policy, especially those areas marked in bold. Please proceed to access out products or services after confirming your full understanding and giving your consent.

If you have any questions, comments or suggestions about the content of this Policy, please feel free to contact us via the contact information provided in Section IX.

This Policy aims to help you understand:

  1. Definition and scope of application
  2. How we collect and use your personal information
  3. How we share, transfer and disclose your personal information
  4. How we retain and secure your personal information
  5. Your rights
  6. How we process children’s personal information
  7. International transfers of personal information
  8. How this Policy is updated
  9. How to contact us
  1. Definition and scope of application

  1. Definition
  • Personal information: various types of information that is recorded by electronic or other means and related to any identified or identifiable natural person; anonymized information is excluded.
  • Sensitive personal information: the personal information that is likely to result in damage to one’s dignity or personal or property safety once disclosed or illegally used, including such information as biometric identification, religious beliefs, specific identity, medical health, financial account and whereabouts and tracked locations, as well as the personal information of minors under the age of 14.
  • Anonymization: the processing of personal information in a way that makes it impossible to identify natural persons and cannot be reversed.
  • De-identification: the processing of personal information in a way that makes it impossible to identify certain natural persons without the use of additional information.

  1. This Policy applies to all products and services provided by Toys“R”Us through the websites “Toys”R”Us China official website” (www.toysruschina.com),“Babies”R”Us official website” (www.babiesruschina.com) (“Websites”), the WeChat official account “Toys”R”Us China (“Official Account“), the WeChat mini program “Toys”R”Us China Official Store” (to be closed on 30 May 2023 ), the WeChat mini program Youzan store "Toys“R”Us Preferred", Tmall store “Toys”R”Us Flagship Store”, JD store “Toys”R”Us Flagship Store”, TikTok store “Toys”R”Us Flagship Store” and Meituan store “Toys”R”Us [XX store]”(Collectively, “Malls”).

  1. How we collect and use your personal information

When you use our products and services, we may need to collect and use your personal information in the following two ways:

  • In order to provide the basic functions of our products and/or services, we need to collect and use information necessary for such basic functions. If you refuse to provide your information, you may not be able to use our products and/or services. For example, WeChat Open ID and Uni ID of WeChat are necessary for browsing and searching for the content of Official Account, the name, address and mobile phone number of the receiver are necessary for placing an order;
  • In order to provide ancillary functions of our products and/or services, we need to collect and use other additional information. If you refuse to provide this information, you cannot use relevant ancillary functions or the functions cannot achieve the intended effects. For example, location information is required for “finding a nearby offline store”, personal information is required for registering Star Card member and joining “Geoffrey Club“.

We will specifically explain the types and purposes of personal information collected and used based on each type of user and each business function as below.

[If you are a user of Websites, you can browse the information of our products as a visitor. During this process, some of your personal information will be processed by cookies set on Websites, please see the " Cookies" section below for details. If you are interested in becoming a member or purchasing products, etc., you will automatically jump to the page of our Official Account or Malls to complete the corresponding steps.]

[if you are a user of Official Account, your personal information will be used in the following scenarios.]

Information Service

When you browse, search for our products and services, or receive updates and promotions from us, your WeChat nickname, profile photo, Open ID and Uni ID will be collected through the WeChat authorization interface. We use the above information to check your unique WeChat user identity and to ensure the safety and stability of Official Account.

Customer Service

When you contact us about our products or services, we may obtain and use the personal information you voluntarily provide so that we can answer or process your questions, comments or suggestions, and track customer feedback.

[If you are a user of Malls, your personal information will be used in the following scenarios.]

Account registration

  • Malls offer visitor mode, where you may browse product information and place an order without an account. However, if you would like to view and manage your orders, or use other functions of Malls, you must register an account.
  • To register an account on Malls, we have to collect your personal information on the corresponding third-party platform, including your unique ID, nickname, profile photo and other information authorized by you, subject to instructions on the registration page. For example, your WeChat nickname, profile photo, Open ID and Uni ID will be collected through the WeChat authorization interface for registration of an account of WeChat mini program; your WeChat nickname, profile photo, Open ID and Uni ID, mobile phone number, points, level and orders will be collected through the Youzan authorization interface for registration of an account of WeChat mini program Youzan store; your mobile phone number, points, level and orders will be collected through the Tmall authorization interface for registration of an account of Tmall store; your mobile phone number will be collected through the JD authorization interface for registration of an account of JD store; your mobile phone number, points, level and orders will be collected through the TikTok authorization interface for registration of an account of TikTok store; your mobile phone number, points, level and orders will be collected through the Meituan authorization interface for registration of an account of Meituan store.
  • The above information is collectively referred to in this Policy as “Account Information”.

Order placement and management

  • When you order the products and/or services on Malls, our system will generate an order. In the process of placing an order, you must fill in at least the receiver's name, address and mobile phone number. In addition, the order will contain the information about such products and/or services, the order number, the time when the order was generated, the price and the method of payment. The collection of the above information is to help the transaction proceed smoothly, ensure the transaction security, facilitate your inquiry of order information, provide customer services, and for other purposes previously outlined.
  • You may order products and/or services for others through Malls. If you provide aforementioned personal information of the actual receiver, you must ensure that you have obtained his/her consent.
  • You may provide additional information including email address and remarks to us to ensure the accurate delivery of products or services. Please note that orders can be generated and processed without such additional information.
  • The above information is collectively referred to as Order Information. We (including relevant third-party service providers) will use Order Information to verify your identity, confirm transactions, process payment, distribute and deliver, inquire about orders, and provide customer services and after-sales services.

Payment

  • To complete the order payment, you may choose payment methods provided by third-party payment companies ("Payment Companies", including Alipay, WeChat Pay, UnionPay, MasterCard and Visa). The payment function itself does not collect personal information, but we need to share your order number and transaction information including your bank account number, validity period, repayment amount and necessary bank card (both debit card and credit card) related information with these Payment Companies to respond to your payment instructions and process the payment.

Delivery

  • To ensure that the products and/or services you purchased can be delivered smoothly, safely, and accurately, we will share Order Information with local courier partners.

Customer services and dispute resolution

  • Account Information and Order Information is a necessary component of our customer services.
  • To ensure the security of your account, our customer service department will use Account Information to verify your identity. When you seek customer services and after-sales services related to orders, we will access Order Information. You may provide additional information when communicating with our customer service staff in scenarios such as modifying the delivery address and the receiver's mobile phone number.

Customer comments

  • You may post reviews through the comments function we provide for you. Please note that the reviews you leave may involve personal information or even sensitive personal information of you or others. For example, you may upload pictures and videos containing personal information in your reviews. Please consider carefully whether to share or even publicly disclose relevant information when using our services.
  • If your reviews involve others' personal information, you must obtain his/her consent before disclosure.

[The following scenarios and rules of personal information processing apply to the users of Websites, Official Account and Malls.]

        1. Star Card member
  • Exclusive offers are available under the Star Card Membership system. When completing and submitting your mobile phone number, name, gender, birthday and registered store online, the system will automatically generate your Star Card member number. If you refuse to provide the above personal information, you will not be able to register as a Star Card member and enjoy exclusive offers, including promotional products, points redemption, free trials, lucky draws, etc.
  • Please note that if you choose to be a Star Card member, in order to provide a consistent membership experience in terms of membership levels, points and benefits, we will link and summarize your account and purchase orders information from multiple channels (including Websites, Official Account, Malls and offline stores) to achieve cross-channel membership binding, points accumulation, member interaction, benefits redemption and other functions.

        1. Marketing activities

  • We will also obtain your behaviors (such as how you browse our services) and purchases from Websites, Official Account, Malls and offline stores, and distribute coupons and personalize promotions based on your purchase preferences.
  • In addition, we will send store and discount information which may be more in line with your needs based on your location, age and gender of your children. If you do not wish to receive such information, you can follow the steps indicated in the information to unsubscribe.

  1. Other additional services

In order to provide more convenient, higher-quality, and personalized products and/or services, and improve your experience, we may collect and use your personal information in the course of providing the following additional services. If you refuse to provide this information, it will not affect your use of the basic services provided by the WeChat official account, but you may not be able to obtain the user experience brought by those additional services. These additional services include:

  • Additional services of photo/video access and upload based on photo albums: when the permission of the photo album is given, you can upload photos from your photo album to communicate with online customer service.
  • Recommendation service based on location information: when the location permission is given, we can obtain your location information and provide you with relevant store information based on your location.

You can decide whether to enable or disable these permissions. Please note that if you enable any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you disable the permission, you cancel the authorization of personal information collection and use, and we will cease to collect and use your information based on the corresponding permissions, as well as providing corresponding services. However, your disabling of the permission will not affect the previous collection and use of information based on your authorization.

  1. Cookies
  • Please see our separate cookie policy www.toysruschina.com/en-cn/cookie-policy.html for our use of cookies on Websites.
  • Our Malls are built on the platforms operated and maintained by the third parties and therefore any use of cookies on Malls will be governed by the terms of the third party's privacy policy/personal information protection policy/cookie policy, which you can refer to by reading the third party's policy for specific information. Cookies on WeChat mini program is subject to Tencent’s cookie policy, please refer to https://privacy.qq.com/policy/cookie-privacypolicy for more details; cookies on WeChat mini program Youzan store is subject to Youzan’s privacy policy, please refer to Section "2. How we use cookies and similar technologies"; cookies on Tmall store is subject to Tmall’s privacy policy, please refer to Section "2.10.2 cookies and similar technologies”; cookies on TikTok store is subject to TikTok’s privacy policy, please refer to Section "1.9 cookies and similar technologies”; cookies on JD store is subject to JD’s privacy policy, please refer to Section "2. How we use cookies and similar technologies"; cookies on Meituan store is subject to Meituan’s privacy policy, please refer to Section "2. How we use cookies and similar technologies".

  1. You fully acknowledge and agree that we may collect and use your personal information without your consent, under any of the following circumstances:

  • where the collection or use is necessary for execution and performance of a contract requested by you;
  • where the collection or use is necessitated by the performance of our legal obligations;
  • where the collection or use is in response to public health emergencies, or for the purpose of protecting your or others’ health and safety or property in emergencies;
  • where the personal information is used in news reporting or public sentiment monitoring in the public interest within a reasonable scope;
  • where the personal information is collected from publicly-available information within a reasonable scope;
  • other circumstances specified in laws and administrative regulations.

  1. We may collect your personal information through a third party to enhance our understanding of you and improve the products and services we provide accordingly. We will confirm the legality of the source of such personal information and the scope of consent. If we intend to use your personal information beyond your consent, we will request your consent again.

  1. Please note that, in accordance with applicable laws, if we take technical measures to process personal information, making it impossible to be used to re-identify specific individuals and such a process is irreversible, we may use such information for statistics and analysis to improve our products and services, and support our business decisions, which does not require separate notice and your consent.

  1. How we share, transfer and disclose your personal information

  1. Sub-contracting

We may outsource related services and certain suppliers will perform part of the work on our behalf. These suppliers include (some suppliers are also involved in personal information cross-border transmission, please see Section VII for details):

Deppon Logistics Co.,Ltd.

Deliver our products and services based on orders.

Shanghai Intone Network Technology Co., Ltd.

Operate WeChat mini program “Haowan Community” and Official Account.

ChinaPay e-payment Service Co.,Ltd.

Assist in capturing and processing payments for all transactions.

Alibaba Cloud Computing Co.,Ltd.

Provide fast delivery of Internet content by using its content delivery network service.

AddThis (by Oracle Corporation)

Provide a web widget for sharing an item using a variety of integrated social services/platforms.

Shanghai Hairui Automation Engineering Technology Co., Ltd.

Manage and distribute physical awards to the winners of activities launched by "Haowan Community", H5 interactive, product trial and other channels.

Hangzhou Youzan Technology Co., Ltd.

Develop WeChat mini program store and provide purchasing tools in WeCom.

Hangzhou Shuyun Information Technology Co., Ltd.

Manage memberships for all channels.

Shanghai NetSDL E-Commerce Co., Ltd.

Manage omni-channel orders and distribute online orders in close proximity.

LF Logistics (China) Co., Ltd.

Storage, packaging and delivery of products.

Shanghai KaiJie Ecommerce Co., Ltd.

Digital host for Tmall store and JD store.

Hangzhou Juyun Technology Co., Ltd.

Book offline parent-child activities in Youzan mini-program

Oracle (by Oracle Corporation)

Data analysis

Microsoft (China) Co., Ltd.

Data analysis

According to our contracts, the suppliers shall use the information to the extent necessary for performing their contractual obligations, to ensure that we can smoothly provide products or services to you, and they have no right to use it for other purposes. Under this circumstance, our suppliers process your personal information in accordance with our instructions, and they do not constitute personal information processors.

  1. Sharing

Sharing means we provide your personal information processed by us to other processors. We will keep your personal information strictly confidential. Unless otherwise required by law, we will not share your personal information with any company, organization or individual.

  1. Transfer

We will not transfer your personal information to any other company, organization or individual, except under the following circumstances:

  • Transfer your personal information according to your prior explicit consent;
  • If your personal information is transferred as a result of a merger, acquisition or bankruptcy liquidation, we will inform you and ensure that the surviving company or organization that will possess your personal information to be continuously bound by this Policy. If the purpose and method for personal information use changes, we will require the surviving company or organization to seek your consent again.

  1. Public disclosure

In principle, we will not publicly disclose your personal information. If your personal information must be publicly disclosed, we will inform you of the purpose for disclosure, the type of personal information to be disclosed, and whether any sensitive personal information is involved, and seek your separate consent.

  1. Under any of the following circumstances, our sharing, transfer or disclosure of your personal information is not subject to your consent:

  • where the collection or use is necessary for execution and performance of a contract requested by you;
  • where the collection or use is necessitated by the performance of our legal obligations;
  • where the collection or use is in response to public health emergencies, or for the purpose of protecting your or others’ health and safety or property in emergencies;
  • where the personal information is used in news reporting or public sentiment monitoring in the public interest within a reasonable scope;
  • where the personal information is collected from publicly available information within a reasonable scope.
  • Other circumstances specified in laws and administrative regulations.

  1. How we retain and secure your personal information

  1. We will only retain your personal information for a limited period necessary for achieving the purposes specified in this Policy or as required by law. We will promptly delete or anonymize your personal information after such retention period expires.

  1. We have technical and administrative measures that meet industry standards to protect your personal information, to prevent unauthorized data access, public disclosure, use, tampering, damage or loss. For example, we use trusted protection mechanisms to prevent malicious attacks on data, and deploy access control mechanisms to ensure that only authorized personnel can access personal information.

  1. The Internet environment is not one hundred percent secure, and we will endeavor to ensure or guarantee the security of any information you provide. Please properly protect your personal information, and do not share your membership account and other information with others.

  1. In case of any personal information security incident, we will, in accordance with requirements set out in laws and regulations, inform you promptly of the following matters, including basic information about the security incident and the potential impact, the measures we have taken or will take to deal with such incident, suggestions on what measures you may take to prevent or mitigate risks, and your remedies. We will inform you of the status of the incident by email, letter, phone or push notifications. In the event that it is difficult for our notification to reach every individual affected, we will make public announcements in a reasonable and effective manner. Meanwhile, we will report the status of the handling of the security incident as required by the regulator.

  1. Your Rights

We respect and honor your rights to your personal information under relevant laws and regulations, and common practices in other countries and regions, which include the following:

  1. Access to your personal information

  • Star Card Member Information: you can access your Star Card membership code on the “Star Card-My Star Card” page of Official Account or on the “Personal Center” page of WeChat mini program Youzan store. You can also check your points on the pages.
  • Account Information: you can access your account information in the “Personal Information-Address Book” section on the “Personal Center” page of WeChat mini program Youzan store.
  • Children’s Information: you can access your children’s information in the “Member Center” page of WeChat mini program Youzan store.
  • Order Information: for users of Malls, you can access order information in the “My Orders” section on “Personal Center” page.

  1. Correct/update your personal information

  • Star Card Member Information: if you find that account information is incorrect or account information has changed, you can request a correction by calling our customer service hotline at 400-886-8828, sending an email to help.cn@toysrusasia.com, leaving a message on Official Account or interacting with online customer service.
  • Order Information: for users of Malls, if you find that order information is incorrect, you can edit or modify it through the “My Orders” page of Malls, call customer service hotline at 400-886-8828 or interact with online customer service.

  1. Deregister your account

You may deregister your account by calling the customer service hotline at 400-886-8828 or by connecting with online customer service. Once your account is deregistered, our services will cease, and your personal information will be deleted upon your request, unless otherwise required by law.

  1. Delete your personal information

Under any of the following circumstances, you may delete your personal information via calling our customer service hotline at 400-886-8828 or emailing to help.cn@toysrusasia.com:

  • When our processing of personal information violates law;
  • When we collect or use your personal information without your consent;
  • When our processing of personal information violates our agreement with you;
  • When the purpose of processing your personal information has been achieved, cannot be achieved, or the processing is no longer necessary (e.g., when you no longer use our products or services, or you have deregistered your account);
  • When we no longer provide you with any products or services; or
  • When you have withdrawn your authorization and consent to our processing of your personal information.

Once your information has been removed from our services, such deletion may not be immediately synchronized in our systems, and we will delete the information once our systems are updated.

  1. Change the scope of your consent

  • Each business function requires certain basic personal information. You may withdraw your consent regarding the collection and use of any supplemental personal information at any time by means of calling our customer service hotline at 400-886-8828 or emailing to help.cn@toysrusasia.com.
  • Once you withdraw your consent, we will not process the corresponding personal information. However, your withdrawal of consent does not affect our previous processing of your personal information based on your consent.
  • If you do not wish to receive our advertisements or notifications, you may contact us through our customer service hotline at 400-886-8828 or our email address at help.cn@toysrusasia.com.

  1. Obtain a copy of your personal information

  • You have the right to obtain a copy of your personal information that we have processed. Please contact us if you need this.
  • If conditions prescribed by law are met, we can also directly transfer your personal information to a third party designated by you at your request.

  1. Responding to your requests

You can reach us via the contact information provided in Section IX. We will promptly respond to your rights requests within 15 working days, unless otherwise specified by applicable laws or regulations. You may contact us to make a complaint if you are dissatisfied with our response.

We will not respond to your requests under any of the following circumstances:

  • where the processing is necessitated by the performance of our legal obligations;
  • where the processing is necessary for reasons of state security or national defense security;
  • where the processing is necessary for reasons of public security, public health, or material public interests;
  • where the processing is necessitated by the investigation, prosecution, adjudication, or law enforcement of criminal cases etc.;
  • where we have proof that your request is frivolous or vexatious;
  • where the processing is necessary for safeguarding your or others’ material legal rights and interests, such as the right to life and property, and it is difficult to obtain your consent;
  • where responding to your requests will give rise to serious damages to the rights and interests of you or other individuals or organizations;
  • where your requests involve our trade secrets.

  1. How we process children’s personal information

  1. We regard any minor under the age of fourteen as a child. We attach great importance to the protection of children’s personal information.
  2. If it is proved that children have registered and used our products and/or services without the consent of their guardian, we will contact the guardian and work to delete relevant personal information promptly.
  3. Part of our functions and services involve the collection and use of children's personal information, for example, to help you participate in the activities of “Geoffrey Club”, to get exclusive offers for children, or to provide you with information that may be of interest to you. Please understand that it is your choice whether to complete or provide children’s personal information, but your failure to do so may prevent you and children in your custody from participating in the activities of “Geoffrey Club”. We only collect the personal information of children in your custody with your express consent. If you are not a parent or a guardian, please do not provide us with children's personal information. In addition, please be aware that in the function of product reviews, the product information actively provided by you may contain children’s personal information. As a guardian, you should judiciously perform your guardianship duties to protect the security of children’s personal information. Please guide and supervise children carefully if children wish to register or use our products and/or services by themselves.
  4. Children or their guardians have the right to access and correct children’s personal information at any time, and can also request that personal information be deleted. Please contact us via the ways mentioned in Section IX, if you have any comments, suggestions, complaints or reports regarding children’s personal information, and we will provide assistance at any time.
  5. Our Star Card membership is aimed at the general public, not children.. Please pay close attention to the notice on the Star Card registration page. Please do not register or use relevant functions of the Star Card membership if you are under the age of fourteen.
  6. We will strictly comply with laws, regulations and the agreement with you to use the children’s personal information you provide in accordance with the aforementioned purposes. We are committed to protecting the security of children's personal information.

  1. International transfers of personal information

Your personal information will not be transferred to, or be accessed from, any jurisdictions outside of the People’s Republic of China (“China”). If we need to transfer outside of China in the future, we will separately seek your consent, comply with relevant laws and regulations, and ensure that your information will be protected at the same level as in China.

  1. How this Policy is updated

  1. Toys”R”Us reserves the right to modify this Policy at any time.
  2. Without your explicit consent, we will not diminish your rights under this Policy. If this Policy is updated, we will release the updated version through Toys”R”Us Websites and WeChat Mini Program as well as sending notifications (e.g., sending a text message or displaying a pop-up window). Please review the updated version to ensure that you are fully aware of the updated content of the Policy.
  3. If you do not agree to our revision of the Policy, please stop using related products and services immediately. If you continue to use such products or services after this Policy is updated, you are deemed to have fully read and agreed to be bound by the updated Policy.

  1. How to contact us

  1. If you have any questions, suggestions or comments about our Policy or about the use of your personal information, you can call the customer service hotline at 400-886-8828 (Monday to Friday: AM 9:00 – PM 5:30; Saturday, Sundays and holidays: AM 10:00 – PM 6:30), send an email to help.cn@toysrusasia.com, or contact our online customer service.
  2. In order to verify your identity, you may be required to provide additional materials or written requests for processing your request and/or complaint. We will respond within 15 working days.
  3. If you are dissatisfied with our response, especially when our personal information processing impairs your legal rights, you can also file a lawsuit with a court with jurisdiction in the defendant’s domicile.

Toys”R”Us Retailing (China) Limited

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