
Effective Date: September 1, 2026
This Privacy Policy applies only to your interactions with us through the Gund Forever Friends Promise™ Program (the “Program”) owned or controlled by Spin Master Australia Pty Ltd and their related entities ("we", "our", "us" and “Spin Master”). Your interactions with our websites and mobile apps outside of the Program are otherwise subject to our main privacy policy, located at https://privacy.spinmaster.com/. The Program does not target and is not intended for users younger than 18 and we do not knowingly collect personal data directly from any person younger than the age of 18.
Please also review the Terms of Service which govern your use of the Program. By accessing or using this Program, or by otherwise providing us with personal data, you consent and agree to the Terms of Service and this Privacy Policy.
If you do not agree with this Privacy Policy and the Terms of Service, do not access or use the Program or provide personal data to us.
Personal Data You Provide to Us Directly
We collect personal data from you directly when you interact with the Program platform, accessible through the QR code located on the tag of the plush friend (“Plush Friend”) either when you are registering the Plush Friend as a user or you are returning the Plush Friend as a finder. We use the term “personal data” to mean any data that could be used to identify you or make you reasonably identifiable, including your identifying information (name, address, email address, phone number), messages you send to our customer care team, and specifically for users registering a Plush Friend, the name you have given to the Plush Friend and date of purchase. We will also treat other information, including IP addresses and cookie identifiers, as “personal data” where required by applicable law. Note that we may de-identify personal data so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified data as non-personal to the fullest extent allowed by applicable law. If we combine non-personal data with personal data, then we will treat the combined data as personal data under this Privacy Policy and as required by applicable law.
Data We Collect Automatically
We and our third-party business partners (including any third party service providers and analytics providers) may use a variety of technologies, including cookies, that automatically or passively collect certain information about you, your device, or household, whenever you access, use, or otherwise interact with the Program platform. Such cookies are used to allow the Program platform to function properly which are set in response to actions made by you when accessing the Program platform such as loading the Program platform, logging in, and filling out form fields.
“Cookies” and local storage are pieces of information (data files) transferred to a browser when the user visits the Program platform. Cookies and similar technologies may be used for many purposes by us and our third party providers, such as automatically collecting device information, keeping your use of the Program platform more secure, maintaining the integrity of the Program platform, and enabling essential functionality. These technologies may also include analytics or performance cookies, which help us understand how visitors interact with the Program platform by collecting information such as page views, traffic sources, user journeys, and site performance metrics. In addition, we and our third-party partners may use targeting or advertising cookies (typically third-party marketing cookies, such as the Facebook/Meta pixel) to deliver relevant advertising and measure the effectiveness of advertising campaigns. Certain browsers or browser add-ons may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Program platform may make use of this local storage. Most browsers provide you with the ability to disable, decline, or clear cookies and local storage; please check your browser’s settings for further information. You can find more information about cookies and how they work at https://www.allaboutcookies.org/.
We may use this personal data to provide the Program to you, including the platform, and to fulfill, track, ship, and otherwise facilitate the reunification of a Plush Friend with a user. This includes ongoing customer support, internal record keeping, and meeting our legal and tax obligations, such as responding to subpoenas, court orders, or legal processes. We may also use your personal data to prevent fraud or other illegal activity, protect our or third-party rights, in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, including during due diligence, and for other purposes disclosed at the time of collection or with your consent.
We may disclose the personal data we collect with third parties that provide services on our behalf, including to assist us in performing certain services and functions on our behalf, such as facilitating the shipping of a found Plush Friend, providing the Program platform, verifying users through multi-factor authentication, customer support services, and internal analytics and reporting. When you (as a user) register a Plush Friend or claim (as a finder) that you have found a Plush Friend, we will share such information as necessary to reunite the Plush Friend with the applicable user.
We and our service providers may also share your personal data to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, such as a warrant, subpoena, or other court order, or to protect against fraud, illegal activity, or as otherwise required or permitted by applicable domestic or international laws or legal processes.
We may share certain personal data with our affiliates, meaning an entity that controls, is controlled by, or is under common control. Our affiliates may use the personal data we share in a manner consistent with this Privacy Policy, including for business and operational purposes.
Your personal data may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Notwithstanding anything else in this Privacy Policy, we do not share personal data we collect specific to our SMS/MMS/RCS text message programs (such as mobile number and record of consent) with third parties for their own direct marketing purposes without your specific consent.
Except as expressly prohibited by law, we may share non-personal data, including, without limitation, de-identified information, usage information, aggregated user statistics, and hashed or otherwise de-identified information (including email addresses), and/or analyses derived from such information with third parties at our discretion, including for marketing and targeted advertising purposes.
We store your personal data in a range of electronic systems managed by us, or by third parties acting on our behalf. We use commercially reasonable security measures to protect against loss, misuse, and alteration of your personal data under our control. We keep personal data as long as it is necessary or relevant for the practices described in this Privacy Policy, after which we will take reasonable steps to destroy or deidentify your personal data. However, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf. Before submitting any personal data, please be aware of these inherent risks and understand that you do so at your own risk.
Subject to some exceptions and pursuant to applicable law, you are provided the following rights: (1) Access Your Information – to request to access your personal data. There is no charge for requesting access to your personal data but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material); (2) Correct Your Information – to request we correct the personal data we hold about you if it is inaccurate, out-of-date, incomplete, irrelevant or misleading. You can exercise these rights by using the contact information provided below. We will respond to your requests to access or correct your personal data in a reasonable time.
If you have a complaint about the way we have handled any privacy issue, including your request to access or correct your personal data, you should contact us. Please include your full name, the basis for your complaint, and any additional information to consider. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation. You may also approach an independent advisor or contact the Office of the Australian Information Commissioner ("OAIC") for guidance on alternative courses of action which may be available. The OAIC's contact details are as follows:
Note that we may retain personal data that you have requested to be updated in backup systems or for internal, legal, or administrative purposes and for other reasons to the extent allowed by applicable law, such as to resolve disputes and troubleshoot problems.
Information we maintain may be stored both within and outside of Australia. As part of the services offered, the information you provide to us may be transferred to recipients outside of Australia, such as the United States and Canada. By interacting with the Program platform or providing us with any information, you fully understand and unambiguously consent to the transfer to, and processing, usage, sharing, and storage of your information in other jurisdictions which may not afford the same level of protections as those in Australia.
To the extent allowed by applicable law, we reserve the right to alter, modify, update, add to, subtract from, or otherwise change this Privacy Policy at our discretion at any time. When we make material changes to this Privacy Policy, we will notify you by posting the updated Privacy Policy, and we will update the effective date at the end of this Privacy Policy. We may also provide notice to you in other ways at our discretion, such as through contact data you have provided.
As this Privacy Policy may be modified from time to time, we encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and share personal data. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified, and your continued use after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will constitute your consent to those changes to the fullest extent allowed by applicable law.
If you have any questions about this Privacy Policy or our processing of data about you, please contact us at dpo@spinmaster.com. Alternatively, you can reach our Customer Care line is +1 800 943 503 or via our online form: https://contact-form.spinmaster.com/email-support.