IMPORTANT ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

IMPORTANT ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

Last Updated: [December 5, 2025]

In conjunction with the information provided under our Privacy Policy, this section provides additional information for California residents. This section will describe our information practices, including how we collect, use, disclose, sell, share and retain personal information. This will provide a comprehensive description of our online and offline practices. Additionally, this section will provide your personal information rights as a California resident.

Categories of Personal Information that We Collect, Disclose and Sell

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, CCPA), personal information is defined as any information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household.

The statutes further define categories of personal information. Below, please find the categories of personal information about California residents that we have collected, sold and/or disclosed to third parties or service providers for a business purpose in the preceding 12 months.

NAME, CONTACT INFORMATION AND IDENTIFIERS:

Identifiers such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address and email address.

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell or share? YES

CUSTOMER RECORDS:

Paper and electronic customer records containing personal information, such as name, address, telephone number, credit card number and debit card number.

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell or share? NO

PROTECTED CLASSIFICATIONS:

Characteristics of protected classifications under California or federal law such as gender and age. We sell this information solely to enable account registration and to comply with laws preventing children from accessing certain websites, apps and services without parental consent.

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell or share? NO

PURCHASE HISTORY AND TENDENCIES:

Commercial information, including products or services purchased, obtained, or other purchasing or consuming histories or tendencies.

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell or share? YES

USAGE DATA:

Internet or other electronic network activity information, including, but not limited to, browsing history, search history and information regarding a resident’s interaction with a website, application or advertisement.

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell or share? YES

AUDIO/VISUAL:

Audio, electronic, thermal, visual information, such as photos, videos, and call recordings/transcripts.

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell or share? NO

PROFILES AND INFERENCES:

Inferences drawn from any of the information identified above to create a profile about a California resident reflecting the resident’s preferences, characteristics or behavior.

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell? YES

SENSITIVE PERSONAL INFORMATION:

We also collect certain sensitive personal information as defined under CCPA, including financial information (e.g., credit card numbers).

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell? NO

We may collect precise geolocation data as defined under CCPA if you provide your consent.

  • Do we collect? YES
  • Do we disclose to a third party for business purposes? YES
  • Do we sell? NO

Sources of Personal Information
We generally collect personal information from the following categories of sources: directly or indirectly from you; your device(s), our subsidiaries/affiliates, data analytics providers, advertising networks and social media platforms, business partners, service providers, regulators and data brokers.
Purposes of Collection, Use, and Disclosure
As described in Section 2, “How does the LEGO Group use your personal data?” of our Global Privacy Policy, in general, we collect and otherwise process personal information for the following business or commercial purposes, or as otherwise directed or consented to by you:

  • LEGO apps, app-connected toys and online channels;
  • Order fulfilment;
  • Customer support;
  • Digital Marketing communications (e.g., email, SMS, push messages in app messages or similar direct electronic marketing);
  • Printed marketing including catalogs and newsletters and other print marketing;
  • LEGO Insiders account/LEGO account/administration and statistics & insights;
  • LEGO Insiders account/LEGO account personalized experience and marketing;
  • Contests, sweepstakes, marketing and other promotions;
  • The LEGO Group’s own social networks;
  • Third-party social networks;
  • Live streaming events (in-store and online);
  • Video monitoring and collection of images (in stores and other relevant LEGO Group locations);
  • Business partners and commercial relations;
  • Research; and
  • General business and operational support.

Sales and Sharing of Personal Information
The CCPA defines "sale" as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-contextual behavioral advertising.
While we do not disclose personal information to third parties in exchange for monetary compensation, we may be considered as “selling” or “sharing” personal information under the CCPA because of our use of third-party ad or analytics cookies and other tools. We “sell” or “share” the following categories of personal information: Name, Contact Information and Identifiers, Purchase history and tendences and Usage Data, identifiers, commercial information, and internet or other electronic network activity. We disclose these categories to subsidiaries/affiliates, data analytics providers, advertising networks, data brokers and social media platforms for advertising and marketing purposes/ FOR SALE/SHARING.

California Residents’ Rights

California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

Right to Opt-Out

California residents have the right to opt out of our sale of their personal information or sharing personal information for cross-context behavioral advertising purposes. Additionally, under the CCPA, residents have the right to limit the use of sensitive personal information. Online opt-out rights can be exercised by visiting our Cookie Policy for global privacy control options or by going directly to our Cookie Settings page and deleting or preventing cookies from being used. You can also click on the ‘Do Not Sell My Personal Information’ link at the bottom of every webpage.

Right to Opt-In

We do not sell or share personal information about residents who we know are younger than 16 years old without verifiable parental consent.

Notice at Collection

We are required to notify California residents, at or before the point of collection of their personal information, of the categories of personal information collected, the retention periods for such information and the purposes for which such information is used.

Verifiable Requests to Delete, Requests to Know, and Requests to Correct

Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months:

  • Right to Correct: Under the CPRA (California Privacy Rights Act), California residents now have the right to request corrections to inaccurate personal information that we maintained.
  • Right of Deletion: California residents have the right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted.
  • Right to Know – Right to a Copy: California residents have the right to request a copy of the specific pieces of personal
    information that we have collected about them in the prior 12 months,
    and to have this delivered, free of charge, either (a) by mail or (b)
    electronically in a portable and, to the extent technically feasible,
    readily usable format that allows the individual to transmit this
    information to another entity without hindrance.
  • Right to Know – Information: California residents have the right to request that we provide them certain information about how we have
    handled their personal information in the prior 12 months, including:

o categories of personal information collected;

o categories of sources of personal information;

o business and/or commercial purposes for collecting, selling or sharing their personal information;

o categories of third parties with whom we have disclosed or shared their personal information;

o categories of personal information that we have disclosed or shared with a third party for a business purpose;

o categories of personal information sold or shared to third parties, and the specific categories of personal information sold or shared to each category of third party.

Right to Non-Discrimination

We will not discriminate against residents who exercise their rights under CCPA/CPRA. However, we may offer different pricing or service levels if such differences are reasonably related to the value provided by the data.

Rights to Disclosure of Financial Incentives

You have the right to opt in to any financial incentives offers and be notified of their material terms, and the right to be able to opt out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives.

Notice of Financial Incentive

The LEGO Insiders program includes a voluntary LEGO Insiders loyalty program, which may be considered a financial incentive program under California law. The value of the personal information that we collect is reasonably related to the expenses related to offering you the LEGO Insiders loyalty program. The LEGO Insiders terms and conditions are available at https://www.LEGO.com/en-us/insiders/terms.

LEGO Insiders loyalty program (‘Loyalty Program’): If you’re at least 18 years old, you can join the Loyalty Program. Members of the Loyalty Program can accumulate and collect loyalty points (‘Points’) by making a qualifying purchase of a LEGO product in: A LEGO Store, on www.LEGO.com, or in Participating Third-Party LEGO Stores, as well as in other participating third-party retailers as designated by the LEGO Group from time to time. Members of the Loyalty Program may also earn Points in other ways, as specifically communicated by the LEGO Group in emails or online postings from time to time. The LEGO Group may decide to introduce additional ways of earning Points from time to time. Points can be redeemed for discounts on future purchases, exclusive rewards, promotions and events. Members of the Loyalty Program also get special early access to select new items. When you register your LEGO Insiders account, you’ll receive a digital card that you can download to your smartphone.

Opting-In to the LEGO Insiders Program:

a) Signing up in a physical LEGO Store or Participating Third-Party LEGO Stores (find a local, participating store https://www.LEGO.com/en-us/stores)

b) Contacting LEGO Customer Service through the contact info found here and subsequently, through use of a confirmation code or link in an email received upon in-store sign-up, confirming the LEGO account and LEGO Loyalty Program membership. The sign-up process will not be completed until a LEGO account has been created and the Loyalty Program Card has been connected to the LEGO account profile.

c) Signing up on LEGO.com/insiders and creating a profile. After you sign up, you’ll receive a welcome email and your digital card.

Withdrawing From the Financial Incentive Program: You may terminate your LEGO Insiders account or cancel your LEGO Insiders membership at any time by contacting the LEGO Group through our Customer Service, either by phone, email or through the Customer Service at https://www.LEGO.com/en-us/service. When contacting Customer Service, you will be asked security questions relating to your LEGO account profile to verify that it is your LEGO Insiders membership profile.

Categories of Personal Information We Collect for the Loyalty Program

In order to provide you with the incentives described in the Terms & Conditions, the LEGO Group uses personal information about you including your Name, Contact Information and Identifiers (specifically, full name, postal address, valid email address and phone number, country and region of residence, date of birth and LEGO account details, etc.); Customer Records (specifically, points earn activities, points redemption activities, coupon/code redemption, download activities, etc.); Purchase History and Tendencies (specifically, purchase history, participation in promotional events such as sale, gift with purchase, bonus points periods, early access, etc.); and Profiles and Inferences (specifically, survey and polling responses; participation in activities, games, apps and events; theme, product and category preferences; product registration, etc.).

We may disclose your personal information and/or make it available to other members of the LEGO Group, store operators, our suppliers and/or service providers in connection with the general operation of the Loyalty Program, e.g., maintenance of the Loyalty Program, analysis and marketing tasks, general operational requirements, etc. We may process your personal information in a de-identified, aggregated or pseudonymized form for the purposes of management, further development, marketing of the Loyalty Program and general reporting and analysis.

Summary of Terms and Estimate of Value and Methods

As more fully described in the Terms & Conditions at https://www.LEGO.com/en-us/insiders/terms, Points may be earned for a qualifying purchase of a LEGO product in a LEGO Store, on LEGO.com and in participating stores at LEGOLAND Parks and LEGOLAND Discovery Centers.

Qualifying purchases are defined as any service or merchandise available for purchase, excluding gift cards. Members of the Loyalty Program may also earn Points in other ways as specifically communicated by the LEGO Group in emails or online postings from time to time.

The LEGO Group may also, at its sole and absolute discretion, award ‘bonus’ Points for certain actions (such as early enrollment or frequent activity). Additional rules and restrictions may apply to such bonus Point promotions, which are explained more specifically at the time of the promotion.

Points can be used only for the purposes expressly specified in the Terms & Conditions or as set out more specifically in the terms for rewards, promotional offers or activities that are offered from time to time.

While Points have no cash value, we have estimated in good faith in the United States that 6.5 points is equivalent to $0.05. The basis of calculation for the Loyalty Program is Points that are credited to a member’s LEGO Insiders account. The method for calculating the Points is the same globally, but the number of Points a Member of the Loyalty Program may earn on the purchase of a particular product will differ from country to country, as the price will be different. The Points and awards allotment principles can be found at https://www.LEGO.com/en-us/Insiders and will be updated from time to time.

The expenses associated with the program incentives will vary as it is dependent on your engagement with the Loyalty Program, including the amount of products you purchase, your interactions with or answers to certain Loyalty Program questions and the frequency and type of discounts you choose to use.

We reserve the right to make special rewards or promotional offers or activities available to groups of Members of the Loyalty Program based on their program activity, including, but not limited to, points status and history, country of residence, shopper history/product preferences and rewards history. The terms and conditions for such special rewards or promotional offers/activities, and the nature, scope, duration and availability of such special rewards or promotional offer/activities will be presented with the offer/activity and may differ from time to time.

Third-Party Rewards: Please note that some rewards or promotions or offers are delivered and operated by independent third parties to the LEGO Group and may be subject to separate privacy conditions and may require separate consent of use of your personal information. The LEGO Group will inform you that you are leaving the LEGO platform/website. Please make sure that you read those terms and conditions carefully before agreeing.

Retention Period

We retain the categories of personal information outlined above for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law.

Service Providers and Contractors

We share personal information with service providers and contractors as necessary for business purposes. Contractors are subject to the same CCPA regulations as service providers.

*Requests may be denied in whole or in part due to various factors, including because a request was not verifiable, was not made by a consumer, was made multiple times, or called for information exempt from disclosure.

CALIFORNIA PRIVACY RIGHTS METRICS

Request to Know
Requests Received: 6
Requests Completed in Whole or in Part: 6
Requests Denied: 0
Average Days to Complete: 15

Request to Delete
Requests Received: 36
Requests Completed in Whole or in Part: 2
Requests Denied: 0
Average Days to Complete: 37

Request to Correct
Requests Received: 44
Requests Completed in Whole or in Part: 44
Requests Denied: 0
Average Days to Complete: 0

Do Not Sell My Personal Information
Requests Received: 9
Requests Completed in Whole or in Part: 9
Requests Denied: 0
Average Days to Complete: 5

This data reflects all requests received from individuals in the US as well as certain requests from individuals outside of the US between August 1, 2024 and July 31, 2025.