Last updated Jul 15, 2024
Originator,having its registered office at 809 Laurel Street #12, San Carlos, CA, 94070, USA (“Originator Inc.”, “We”, “Our” or “Us”) is committed to protecting your privacy as a data subject (“You” or “Your”) and the secure processing of Your personal data and We strive to limit the processing of personal data as far as possible and do not collect personal data beyond what is necessary.
Needless to say, all processing of personal data, including the collection, registration, storing and general handling is governed by applicable privacy legislation, including the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“UK GDPR”). Originator, strives to make sure that the processing of personal data done by Originator,, is done in accordance with applicable legislation.
We apply the GDPR to everyone but if You reside outside the European Union and use Our services, We may apply additional standards to You as required by local law. To the extent that the California Consumer Privacy Act (“CCPA”) applies to You, the definitions in this privacy policy are to be read as follows: “personal data” includes “personal information”; “data subject” includes “consumer”; “controller” includes “business”; “processor” includes “service provider”, all as defined under the CCPA. For more information about the CCPA, please see Section 10.
As a service directed towards children, We also adhere to the Children’s Online Privacy Protection Rule (“COPPA”). To the extent that the COPPA applies to You, the definitions in this privacy policy are to be read as follows: “personal data” includes “personally identifiable information”; “processor” includes “service provider”, all as defined under the COPPA. For more information about the COPPA, please see Section 12.
Originator Inc. (“Originator”) develops and publishes entertaining and educational mobile apps for kids and families. As we create truly meaningful digital experiences beloved and respected by kids, parents, and educators we are also committed to protecting your privacy. We take privacy seriously at Originator and this policy is designed to share the information we collect and how we use it. This notice describes Originator’s privacy policy for the Cubric app (“Cubric”) which is developed and distributed by Originator. We may revise this privacy policy at any time, and the date of last revision will be available at the top of this page. By using Cubric, you understand and accept this Privacy Policy. Your continued use of Cubric after changes have been posted to the Privacy Policy will constitute your acceptance of such changes.
Originator, is a subsidiary of Spin Master Ltd and a part of Spin Master Digital. We cooperate with Spin Master Ltd, and the other gaming studios of the Spin Master Digital group (each a “Group Company”) to learn from one another, help each other and improve how We all make apps.
Our contact details are:
Originator Inc.
809 Laurel Street #12
San Carlos, CA
94070, USA
The contact details to Our Data Protection Officer are:
Spin Master Ltd
Attn: Data Protection Officer
225 King Street West
Toronto, ON M5V 3M2, Canada
Should You have any questions related to privacy and/or Your rights, You can also contact Us at info@originatorkids.com or Our Data Protection Officer at DPO@spinmaster.com. Alternatively by phone to our Customer Care line at +1 800-622-8339. Below You will also find detailed information on how We process Your personal data, on Your rights and how You can exercise them.
Our website www.cubric.com is just for grownups, while Our apps are designed for everyone, including children under the age of 13. We encourage parents and guardians to take active part in your children's gaming experiences.
Our social media accounts are intended and made for everyone over the age of 13 (or any other age applicable in your country).
We take privacy seriously at Originator, and this policy is designed to share what information We collect and how We use it. When You visit Our website, install the Cubric app or interact with Our social media channels, Originator, processes Your personal data in accordance with this privacy policy and acts as the controller of Your personal data as defined by the GDPR.
This privacy policy describes how We collect and use Your personal data when You are using Our services, playing Our apps or interacting with Us. It applies to all visitors of this website, end users (including paying and non-paying users, grownups and children) and Our social media channels.
Under the GDPR and UK GDPR You have certain rights concerning Our processing of Your personal data. If You would like to access, correct, erase or limit the use or disclosure of any of Your personal data that has been collected and stored by Originator, or exercise any other right under applicable data protection legislation, please notify Us at info@originatorkids.com so that We may consider and respond to Your request in accordance with applicable law.
Right of information: You have the right to be provided information concerning Our processing of Your personal data. This includes understanding the purposes of processing, the categories of personal data concerned, and who else might receive Your personal data.
Right of access: You have the right to obtain confirmation as to whether or not We are processing Your personal data and, if this should be the case, have access to Your personal data.
Right to rectification: You have the right to obtain rectification of inaccurate or incomplete personal data concerning You.
Right to erasure (“right to be forgotten”): Under certain circumstances, such as if the personal data is no longer necessary for the original purpose, if You withdraw Your consent, or if the personal data has been unlawfully processed, You have the right to obtain the erasure of Your personal data. However, this does not apply if Our interest in continuing to process Your personal data outweighs Your interest in having it deleted or if We are subject to a legal requirement to retain Your personal data.
Right to restriction: Under certain circumstances, such as if You contest the accuracy of Your personal data or if the processing is unlawful but You oppose erasure and request restriction instead, You have the right to obtain the restriction of processing.
Right to data portability: Under certain circumstances, such as when the processing is based on Your consent or a contract with You and the processing is carried out by automated means, You have the right to receive Your personal data in a structured, commonly used and machine-readable format and the right to transmit this information to another controller.
Right to object: Under certain circumstances You have the right to object to the processing of Your personal data. This includes but is not limited to the right to object in cases in which We process Your personal data based on legitimate interest (Article 6(1)(f) GDPR).
Right to lodge a complaint: If you are an EU resident You have the right to lodge a complaint with a supervisory authority, Autoriteit Persoonsgegevens, if You consider that Originator,’s processing of Your personal data infringes the GDPR. You can also lodge a complaint with Your own national data protection authority, please see list here.
Right to withdraw consent: If a processing of Your personal data is based on Your consent as set out in this privacy policy, You have the right to withdraw Your consent at any time.
Right to not be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You.
In this Section, We describe the types of personal data that We collect or create. In Section 4 We describe for what purposes and which legal ground that We rely upon when We process Your personal data. For the purposes of this privacy policy, the term personal data shall have the same definition as it has under the GDPR.
User Information: Information about Your use of Originator,’s apps - such as in-app generated events based on Your interaction with the app, error and crash reports.
Device Information: Information from Your device - such as device IDs, Android ID, Apple’s Identity for Vendor (IDFV) and Identity for Advertiser (IDFA), other advertising identifiers such as Android Advertiser identifier ID (AAID), operating system, platform, screen resolution and similar information about Your device and device settings/usage, IP address (including Your approximate location).
Unique Identifiers: Information from Your account - such as user name, Cubric Account ID, email address and password (where email login is applicable) and age.
Purchasing Data: Information relating to Your purchase history - such as in-app properties/playset and purchasing tendencies.
Social Media: Information about You and Your interactions with Originator, fan pages on social media - such as name and/or user name, posts You like and comment.
Customer Information: Information from You provided to Us via Our customer support and/or service functions - such as first name, last name, email, age, Your issues and/or ideas.
In the table below We indicate:
Here is a general explanation of each legal basis to help You understand the table:
What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data and where they come from |
To provide You with the Cubric app and to give You access to play and to be able to save Your progress without setting up an account. | Contract with You. |
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To create an account for the Cubric App and to be able to save Your progress to your account. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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To send out emails for parental consent and account creation. We will also send out emails with important updates for Terms of Service and Privacy policy. | Depending on the purpose of Your question We rely on either one of the legal grounds below: Legal obligation or It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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In Cubric We sell in-game items such as packs and houses in the in-app store. We are doing this to provide You as a player a more fun and unique experience in Our app. | Contract with You. |
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To be able to provide You with Our virtual currency. | Contract with You. |
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To be able to understand how many active players, how the player experience currently is and the engagement of the app. This information will help Us to understand how the app will perform from a business perspective. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in being able to understand how many active users, user experience and user engagement that we have and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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To be able to provide functionality and improvements of Our app, We need to collect, store and analyze crash related information from Your device. This will help Us to understand what could be wrong in the app. | Contract with You. |
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We use user attribution and marketing analytics to measure the effectiveness of Our advertising. For the purpose of marketing campaigns to measure ad performance by driven installs and click through rates on various media platforms. This will help Us to bring new players, create a better experience for You as a player of Our apps and provide relevant offers that You may like. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in knowing our players to be able to create better experiences for You. We have also determined that this processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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Through Cubric, we may allow third-party advertising partners to use technologies and other tracking tools to collect information regarding Your use and Your device. We also may share information relating to your device and Your use with Our third-party advertising partners so they may deliver targeted advertisements to You when You visit third-party services and websites within their networks. This only applies if you have passed our age gate with an age that is above the age of digital consent in your jurisdiction. | Consent |
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Whenever an action is performed in-app that requires a server side response, We will be processing and storing pieces of personal data as part of log files. We do this to ensure technical functionality. | Contract with You. |
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To allow You to invite and play with friends in a multiplayer friendly environment. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in knowing our players to be able to create better experiences for You. We have also determined that this processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. For the purposes of analyzing marketing campaigns, no personal data is shared with any third party networks. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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Account Linking - You are able to log on to Your account across different devices so that any purchase and in-game progress will be transferable cross devices. | Contract with You. |
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In order to provide You with support/assistance/help in Our app, We need to ask You certain questions in order to help You. We do this to provide You with a better gaming experience if something unexpected happens in Our app. | Contract with You. |
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To be able to provide a self-service for You to delete Your account and provide You with other ways to exercise your privacy rights. . | Legal Obligation |
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If You download or make in app purchases in Cubric on Your mobile device or tablet, We receive information about You from the app stores and other mobile platform providers. This information may include Your username or device ID and the fact that You made a purchase, as applicable, but does not include any financial information. | Contract with You. |
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If You are using Our customer support services powered by Zendesk so that We can provide service in accordance with Our contract with You. For example, give You access to Our app or answer any questions that You may have. | Depending on the purpose of Your question We rely on either one of the legal grounds below: Contract with You. or It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in being able to understand how You feel about Our products, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data used for the purpose |
We reply to comments left by fans on Our own posts, We define this as reactive engagement. We also engage (by liking, leaving emojis or commenting) with fan channels on an as needed basis, We define this as proactive engagement. These are posts that have either gained high traction among the Originator, community or have created content that We like to support. We also share social media posts internally, but these are also publicly accessible on all social media platforms. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in being able to connect with You on social media, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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What We use Your personal data for and why | Legal basis allowing the purpose | Categories of personal data used for the purpose |
To ensure network and information security of Our website. | It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in being able to offer you a secure website experience, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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If You are using Our customer support services powered by Zendesk so that We can provide service in accordance with Our contract with You. For example, give You access to Our app or answer any questions that You may have. | Depending on the purpose of Your question We rely on either one of the legal grounds below: Contract with You. or It is necessary for the purposes of Our legitimate interests. When balancing interests, Originator, has determined that We have a legitimate interest in being able to understand how You feel about Our products, that the processing is necessary to achieve that purpose, and that Our interest outweighs Your right not to have Your personal data processed for this purpose. You may contact Us for more information about how the determination was made. Please see Our contact details in Section 1. |
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We use cookies and other tracking technologies on our website. You can read more about the cookies and other tracking technologies in our cookie policy.
We will retain Your personal data for as long as necessary to provide Our services to You or as required by law.
We will keep Your personal data that is tied to Your account and Your usage of Our apps as long as You use the services and for a period of two years after You last used the service unless You contact Us asking for a removal.
For analytics, instead of deleting Your personal data We may anonymise the personal data so that no direct or indirect identifiers remain and after such anonymisation We will store the information for an indefinite period.
For marketing attribution purposes, We keep Your personal data for three months after that We delete it.
For the purpose of customer support and services We will keep Your personal data for one year before We delete it.
Our website and services may include community or social media features, such as forums and chat rooms. Please note that any information You post in these features may be publicly available. We encourage You to use caution when sharing personal data in these features. We take reasonable measures to keep these features secure and protect Your personal data.
Originator, may share Your information, including Your personal data which includes but is not limited to billing information or user names, with Our agents, contractors, or service providers who are hired to perform services on Our behalf. We may also share Your information with Our affiliates. We disclose necessary information to authorities such as any relevant Data Protection Authority and other authorities if We are required to do so by law, or under some circumstances if You have requested Us to do so.
Description of the recipient: Suppliers and subcontractors are companies that only have the right to process the personal data they receive from Us on behalf of Originator,, i.e. data processors. Examples of such suppliers and subcontractors are software and data storage providers, and business consultants.
Service Providers - Processors
We use the following service providers that acts as processors in relation to children in all Our apps:
Description of the recipient: Group Companies. These Group Companies only have the right to process the personal data they receive from Us on behalf of Originator,, i.e. data processors.
List of companies that We share personal data with:
Spin Master Ltd.
225 King Street West
Toronto, ON M5V 3M2, Canada
Please see the privacy policy here.
Spin Master Toys UK Limited
Winter Hill House Marlow Reach,
Station Approach, Marlow, England, SL7 1NT
Please see the privacy policy here.
Sago Sago Toys Inc
John St., 5th Floor,
Toronto, ON M5T 1X3, Canada
Please see the privacy policy here.
Toca Boca AB
Lumaparksvägen 13A
120 31, Stockholm, Sweden
Please see the privacy policy here.
Purpose and legal basis: This is required for Originator, to be able to provide You with its services and functionalities. We have a legitimate interest in being able to access and provide these services and functionalities (Article 6(1)(f) GDPR). We ensure that the processing this entails is necessary to pursue that interest, and that Our interest outweighs Your right not to have Your information processed for this purpose. You are entitled to object to this processing, for reasons connected to the circumstances in Your particular case. Please see Section 2 for more information about Your rights.
Through Cubric and our website, We may allow third-party advertising partners to use technologies and other tracking tools to collect information regarding Your use and Your devices if You agree to this. We also may share information relating to Your device and Your use with our third-party advertising partners so they may deliver targeted advertisements to you when You visit third-party services and websites within their networks.
If You have provided Us with your consent for the above mentioned actions We may use any or all of the following ad network partners. We may also, at any time and at Our discretion, add and make changes as to what partners We work with. Please note that this only applies to the users that pass our age gate and provides us with their consent to be tracked.
In some cases Originator, might transfer personal data outside the EU and EEA, so-called third countries. For Our transfers to the US, Canada and UK following conditions apply:
We also identify and use additional protections as needed for each data transfer. For example, We use technical protection measures, such as encryption and pseudonymization.
We are committed to protecting Our users’ personal data and are among other things using pseudonymization, encryption and user based access levels to protect Your personal data. We strive to take appropriate technical and organizational measures to ensure the protection of Your personal data.
Under California Civil Code sections 1798.83, “Shine the Light Act”, California residents are entitled to ask Us for a notice describing what categories of personal data We share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. Please note that We do not share Your personal data with any third parties or affiliates for their direct marketing purposes.
CCPA provides consumers who are California residents with specific rights regarding their personal data.
Right to Access: If You are a California resident, You have the right to request, up to two times each year, access to categories and specific pieces of Your personal data that We collect, use and/or disclose.
Right to Delete: If You are a California resident, You have the right to request that We delete Your personal data that We collect, subject to applicable legal exceptions.
Right to Opt Out of Sale of Personal Information: As the term is defined by the CCPA, Originator, does not sell any personal data.
To make a request regarding Your rights under CCPA as described above, please send an email to info@originatorkids.com or DPO@spinmaster.com or write to us, using the addresses above.
This privacy notice may be changed from time to time to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to You if these changes are material and, where required by applicable law, We will obtain Your consent. The notice may be sent to You by email to the last email address You provided Us with, by posting notice of such changes on Our sites and applications, or by other means, consistent with applicable law. The date of the last modification is stated at the top of this document.
Click here to view the Children's Privacy Policy