Privacy Policy

Last modified July 8, 2021

S&P Holbrook LLC dba MagicPin (“MagicPin,” “we,” or “ us”) respects your privacy and is committed to communicating transparently regarding our privacy practices. This Privacy Policy describes the types of information we may collect from you when you visit our website at or any subdomain thereof, or visit or use our mobile software application known as “ MagicPin” (the “App”) or any related mobile or desktop applications, including any content or functionality offered on or through any of the foregoing (collectively with the App, the “Site”), or when you access or use the online services we make available on the Site (collectively, the “ Service”). This Privacy Policy also describes our practices for collecting, using, maintaining, protecting, and disclosing such information.

This Privacy Policy applies to information we collect on the Site, in email, text, or other electronic messages between you and the Site, and through your access to or use of the Service through the Site. It does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party, nor to information collected by any other third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site or Service.

Please read this Privacy Policy carefully before you start to use the Site or Service to understand our policies and practices regarding how we treat your information. By accessing or using the Site or Service in any manner, you accept and agree to be bound by this Privacy Policy. If you do not agree with any terms of this Privacy Policy, you may not access or use the Site or Service for any purpose.

This Privacy Policy may change from time to time (see Updates to Our Privacy Policy, below). Your continued use of the Site or Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Privacy of Children

The Site and Service are not intended for or directed to children. No one under age 16 may provide any information to or on the Site or Service. We do not knowingly collect or solicit personal information from children under age 16. If you are younger than 16 years of age, do not use or provide any information on the Site or through the Service or any of its features, register on, make any purchases or trades through, or use any of the interactive, messaging, or public comment features of the Site or Service, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under age 16, we will delete that information. If you believe we might have any information from a child younger than 16 years of age, please contact us at

Information We Collect

When you access the Site or use the Service, we collect certain information about you. This may include information by which you may be personally identified, such as name, postal address, geographic location, e-mail address, or telephone number, as well as information that is about you but may not specifically identify you, such as information about your internet connection, the equipment you use to access the Site or Service, and usage details, IP addresses, and certain other information collected through cookies and other tracking technologies (collectively "personal information"). 

Information You Provide Us

We collect personal information from various sources, such as directly from you when you access or use the Site or Service. This may include: 

You also may provide information, images, and other content to be published or displayed (hereinafter, " posted") on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although you may have the option to set certain permission settings through your account, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect by Automatic Means

When you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing, actions, and patterns, including:

In addition, we use third-party web analytics services to help us understand your use of the Site and the popularity of certain content so we can improve your experience. For more information on our use of third-party analytics services, see Third Party Providers below. 

Information we collect automatically may be statistical data that does not include personal information. We may maintain or associate any such statistical data with personal information we collect in other ways or receive from third parties. It helps us to estimate our audience size and usage patterns, speed up user experience, and to improve and personalize the Service, including enabling us to identify and authenticate users. To the extent that we associate any of this non-personal information with your personal information, we will treat it as personal information under the terms of this Privacy Policy.

Technologies we use for automatic data collection may include cookies. A cookie is a small file placed on the hard drive of your computer. Pages of our Site and our emails may also contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Geographic Location Data

In addition to the other geolocational information we collect automatically, we collect certain information about the geographic location of your mobile device when the App is open or running. In order to facilitate in-person trading of Disney Pins, and where expressly consented to by you through your enabling of the functionality, this geographic location information may include your location if you are within the geofence of a supported Walt Disney theme park, resort, or other Walt Disney destination (a “Disney Destination”), which information may be displayed to other users of the Site that have agreed to be geolocated and whose mobile device is likewise located within the geofence of the same Disney Destination.

You may withdraw your consent to this function of the Service (i.e., the tracking of geographic location information within Disney Destinations and its disclosure to other Site users) by disabling the geolocation function on your mobile device. If you do not enable this Service function, if you later disable it, or if your mobile device is located outside of a Disney Destination, the App will automatically display to other users only your state, province, or similar sub-national territory.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Site are served by third-parties, including content and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about any targeted content, you should contact the responsible provider directly.

How We Use the Information We Collect

We may use information we obtain about you, or that you provide to us:

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please email For more information, see Your Choices.

How We Share Your Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual user, without restriction. 

We may disclose personal information that we collect or you provide (as described in this Privacy Policy):

We may also disclose personal information to third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Your Choices, below.

We also reserve the right to transfer your personal and other information to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets. Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use your information in a manner that is consistent with our Privacy Policy.

Third Party Providers

Without limiting the foregoing, we may also employ third party companies and individuals to facilitate our Site and to process data, perform Site-related services, or to assist us in analyzing how the Service is used (collectively, “Third Party Providers”). These Third Party Providers may have access to your personal information for purposes of performing these tasks on our behalf, and may have the right to retain and use personal information or other information through performance of these tasks on an aggregated and de-identified basis in accordance with the terms of the applicable Third Party Provider’s privacy policy. We advise you to review the privacy policies of the Third Party Providers, but note that we have no control over and assume no responsibility for the content, privacy policies or practices of any Third Party Providers, their sites or services.

Third Party Providers may include, but are not limited to, the following:

Payment Processors. We use Third Party Providers (currently PayPal) to process certain payment transactions initiated via the Service. You may be required to create an account with our current third party payment processor, and to provide MagicPin (directly or through the third party payment processor) certain information with respect to your account (such as the email address or telephone number associated with your account), in order to engage in certain transactions through the Service. Please note, however, that your payment card details are not stored by the Site or the Service. If you purchase, sell, or trade a Disney Pin through the Service, your payment card details are encrypted and securely stored by our third party payment processors. You can learn more about PayPal’s privacy practices at

Additionally, when you made certain in-app purchases through the App, those purchases will be processed through Apple’s App Store or through Google’s Play Store, depending on which mobile platform you use to access the Service. You can learn more about Apple’s privacy practices at You can learn more about Google’s privacy practices at

Analytics. We may use Third Party Providers to monitor and analyze the use of our Site.

You may opt out of the aggregation and analysis of data collected about you on our Site by Google Analytics by downloading the Google Analytics opt-out browser add-on, available at Please note that if you opt out, analytics companies other than Google Analytics may continue to aggregate and analyze data collected about you on the Site.

Other Service Providers. We also use Third Party Providers for marketing, technical, operational, and other services, including as follows:


MagicPin takes protecting your information seriously, and implements reasonable measures to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to the Service or certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

We urge you to be careful about giving out information in public areas of the Site like message or comment boards and when using the User Messaging functions. The information you share in public areas may be viewed by any user of the Site (or, in the case of User Messages, by the user that you are messaging). Please use caution in determining what personal information to disclose.

Please note that the electronic transmission of information is not completely secure. We cannot guarantee that the security measures we have in place to safeguard information will never be defeated or fail, or that such measures will always be sufficient or effective. Any transmission of information is at your own risk.

Information and Data Transfers

The Service is administered by MagicPin in the United States. When we obtain information about you through your access to or use of the Site or Service or when you input or import information to the Service from somewhere other than the United States, we may transfer, process, and store such information in the United States. If you access the Site and/or Service from outside the United States, you do so on your own initiative, at your sole risk, and you are responsible for compliance with all applicable laws. If you are a non-United States resident and provide us with your personal information, or if you use the Service, you consent to the transfer to and processing of such information in the United States, which may have data protection laws less stringent than those in the country in which you reside.

Your Choices

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site and the Service may then be inaccessible or not function properly.

Notifications. The Service may deliver notifications to your mobile device from time to time. You can disable these notifications by changing notification settings on your mobile device.

Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending an email to us with your request at

Emails. MagicPin may send Service updates, Service notifications, promotional information and other communications to you via email. Promotional email communications will contain instructions describing how you can opt out of receiving future promotional emails from us. If you opt out of promotional emails, you may continue to receive non-promotional, transactional emails from us.

Limiting Provided Information. You can choose not to provide us with certain information. If you decline to provide certain information, however, please note that some features of the Site and/or Service may then be inaccessible.

“Do Not Track” Request

We adhere to the standards set out in this Privacy Policy and do not monitor or respond to Do Not Track browser requests.

Third Party Applications and Websites

The Site and/or Service may contain links enabling the electronic transfer of data from third-party applications to the Site or Service, as well as links to third-party websites. MagicPin is not responsible for the privacy practices or content of these applications or websites, and linking to an application or website does not constitute endorsement by us of that application or website. You should review the privacy policy and terms and conditions of any such third-party application or website prior to using or providing information to the same.

Accessing and Correcting Your Information

Your personal information is accessible through, and may be reviewed and changed by logging in to, your user account. You may also send us an email at to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions, including any User Messages sent via the Service, copies of your User Contributions or correspondence may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access and use of information provided on the Site and Service, including User Contributions and correspondence, is governed by our Terms of Use.

Your California Privacy Rights

California law grants additional privacy rights to California residents. In particular, the California Consumer Privacy Act (CCPA) requires businesses to disclose, for the past 12 months, (i) the categories of personal information collected, (ii) the sources of the collected personal information, (iii) the purposes for which the collected personal information is used, (iv) the categories of personal information disclosed for a business purpose, and (v) the categories of any personal information sold. MagicPin provides these disclosures in the following table. (Note that MagicPin does not sell any personal information, even under the broad CCPA definition of a “sale.”)


Sources of Collection

Purposes of Collection

Disclosures for a Business Purpose


Site visits, creation of accounts and registration for MagicPin products and services, importation or upload by users of the Service

For user registration, to enable MagicPin to provide its products and services and to allow MagicPin to communicate with you

To Third Party Providers to assist in providing MagicPin products and services and processing associated payments; to other third parties to allow them to market their products or services to you

Personal information categories listed in the California Customer Records statute

Creation of accounts and registration to receive MagicPin products and services, submission of payment information, importation or upload by users of the Service

For user registration, to enable MagicPin to provide its products and services and to allow MagicPin to communicate with you

To Third Party Providers to assist in providing MagicPin products and services and processing payments

Commercial information

Registration for MagicPin products and services, importation or upload by users of the Service

To provide MagicPin products and services to users and maintain purchase history

To Third Party Providers to facilitate delivery of products and services

Internet or other electronic network activity

Your browsing and search history on our Site and Service and other interactions with our Site or Service

To improve the user experience on the Site, diagnose server problems and administer the Site, and to improve Service function

To Third Party Providers for the purpose of enhancing the Site and improving the effectiveness of our advertising; to other third parties to allow them to market their products or services to you

Geolocation data

IP address

To provide MagicPin products and services and to improve the visitor experience on our Site

To Third Party Providers for the purpose of enhancing our Site and improving the effectiveness of our advertising, and to other users of the Site for purposes of making certain Service functions available to you

Inferences drawn from other personal information

Your browsing and search history on our Site and other interactions with our Site and Service

To improve the visitor experience on our Site

To Third Party Providers for the purpose of enhancing our Site and improving the effectiveness of our advertising; to other third parties to allow them to market their products or services to you

California residents also have the rights described below. We will not discriminate against any California resident who exercises these rights. 

Right to access/know your information. You may request from us a list of (i) the personal information that we have collected about you, and (ii) the categories of third parties to whom we have disclosed your personal information. You have the right to up to two (2) access requests each twelve (12) months.

Right to delete your information. You may request, at any time, that we delete your information and direct our service providers to delete your information from their records.

You may contact us to exercise these rights at To ensure the privacy and protection of individuals, we are required to verify your identity (or that of your authorized agent) or otherwise authenticate your request(s), which we will do in accordance with the CCPA regulations. Please note that, under the CCPA, we are not required to grant a request to access/know or a request to delete with respect to personal information obtained from you in your role as an employee, owner, director, officer or contractor of a company and within the context of MagicPin providing its services to such company.

Your European and UK Privacy Rights

If you are a resident of the European Union or the UK, you are entitled to certain information and have certain rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “ GDPR”) or the UK GDPR adopted post Brexit (also referred to herein for convenience as simply the “GDPR”). Those rights include:

If you are located in the European Union or the UK and you are or have been a user of our services (including the Service), we may send you marketing communications based on our legitimate interests, subject always to your right to opt out of such communications. Further, if you are located in the European Union, we will never share your information with a third party for such third party’s marketing purposes, unless you have specifically consented to us doing so.

You may contact us at magicpinapphelp@gmail.comto exercise any of the above rights. We may request specific information from you to confirm your identity, and in some circumstances, we may charge a reasonable fee for access to your information.

Furthermore, if you believe that our processing of your information is inconsistent with your data protection rights under the GDPR and we have not adequately addressed your concerns, you have the right to lodge a complaint with the data protection supervisory authority of your country.

For purposes of the GDPR, we are a “controller” and you are a “data subject.”

Updates to Our Privacy Policy

MagicPin reserves the right to change this Privacy Policy at any time. If we make a material change to this Privacy Policy, we will make an effort to communicate these changes to you via email or by posting a notification on the Site. The date this Privacy Policy was last revised is at the top of this page. We encourage you to review this Privacy Policy periodically to check for any updates or changes.

Contact Us

If you have any questions about this Privacy Policy or our information practices, please email us at or write to us at:

P.O. Box 1174
West Jordan, UT 84084